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Chukchi Sea Oil & Gas Lease Sale 126 Final Environmental Impact Statement Vol. II 1991
This Environmenta planning doc production, a assumptions t environmenta details of deve not represent development ownership, a With reference the United S the figures a reflect the po boundaries, con coastal states con used, as a local t d evelopment and it best-estimate d any resulting jut potential local assumptions do facility, site, or ing, zoning, land offshore regions, with neighboring -aout the extent of ry lines shown in zy do not necessarily of international ed States and the A OCS EIS/EA. Alaska Outer Continental Shelf aes SS Chukchi Sea Oil & Gas Lease Sale 126 Final Environmental Impact Statement Volume Il U.S. Department of the Interior MS *. Management Service Alaska OCS Region January 1991 V REVIEW AND ANALYSIS OF COMMENTS RECEIVED V. REVIEW AND ANALYSIS OF COMMENTS RECEIVED A. Introduction During the DEIS comment period, written comments and oral testimony were provided by various governmental agencies, petroleum companies, Alaska Native organizations, environmental organizations, other groups, and individuals. A total of 23 letters were received--7 from Federal agencies, 1 from the State of Alaska, 1 from the North Slope Borough, 4 from petroleum companies, 2 from Alaska Native organizations, 3 from environmental organizations, 2 from other groups, and 3 from individuals. Public hearings were held in the NSB communities of Barrow, Wainwright, and Point Lay and in Anchorage. A total of 22 individuals presented testimony at these hearings--16 in Barrow, none in Wainwright, 3 in Point Lay, and 3 in Anchorage. An Inupiaq language translator was available at each of the hearings in the NSB communities. Most of the comments on the DEIS addressed concerns regarding (1) oil spills and oil-spill-cleanup technology; (2) effects of oil spills and industrial activities on the environment, biological resources, and subsistence harvesting; (3) adequacy of environmental information; (4) mitigating measures; (5) alternatives and areas to be deferred; and (6) adequacy of petroleum industry technology to operate in the arctic marine environment. All written and oral comments on the Sale 126 DEIS were reviewed, and responses were prepared for 228 comments. Where comments warranted changes or presented new, substantive information, the text of the EIS was revised accordingly; a reference to the revised section(s) is made in the responses to the specific comments. B. Letters, Comments, and Responses The following section presents a reproduction of all letters received during the DEIS comment period. Specific comments in each letter are bracketed and numbered. The MMS responses to the specific comments follow each letter. Commenter and Letter Designation Federal Agencies Executive Branch--Departments Commerce National Oceanic and Atmospheric Administration - NOAA Interior Bureau of Indian Affairs - BIA Bureau of Mines - BOM Fish and Wildlife Service - FWS National Park Service - NPS Independent Establishments Environmental Protection Agency - EPA Boards, Committees, and Commissions Marine Mammal Commission - MMC State and Local Governments State of Alaska - AK North Slope Borough - NSB Petroleum Companies ARCO Alaska, Inc. - ARCO V-1 BP Exploration (Alaska), Inc. (No response required) Texaco, Inc. (No response required) Unocal Corporation - UNO Alaska Native Organizations Alaska Eskimo Whaling Commission - AEWC NANA Regional Corporation, Inc. - NANA Environmental Organizations Greenpeace USA - GP Northern Alaska Environmental Center - NAEC Trustees for Alaska - TFA Other Groups Bering Sea Fishermen’s Association - BSFA SEACO - SEA Individuals Joash Tukle - JT John Luther Mohr - JLUM Scott Sunan (?) - SS v-2 UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration Office of the Chief Scientist Wasnington, OC. 20230 September 14, 1990 Mr. Alan D. Powers Regional Director Minerals Management Service Alaska Region 949 East 36th Avenue Anchorage, Alaska 99508-4302 Dear Mr. Powers: Enclosed are comments to your Draft Environmental Impact Statements for the proposed 1991 Outer Continental Shelf Oil and Gas Lease Sale 126 in the Chukchi Sea. We hope our comments will assist you. Thank you for giving us an opportunity to review the document. Sincerely, Tyran llitting 47 David Cottingham Director Ecology and Environmental Conservation Office Enclosure cc: Director, MMS Richard Miller, MMS 1 NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION PROPOSED 1991 OUTER CONTINENTAL SHELF (0C8) OIL AND GAS LEASE SALE 126 IN THE CHUKCHI SEA The Alaska Region of the National Marine Fisheries Service (NMFS), the Alaska Office of the National Ocean Service (NOS) and the Office of Charting and Geodetic Services (C&GS) have reviewed the subject document and offer the following comments. Please direct nautical charting questions to Mr. Charles Harrington at 301-443-8360, and biological questions to Dr. Jawed Hameedi at 907-271-3033 or Ron Morris at 907-271-5006. General Comments This sale is essentially a re-offering of tracts within this planning area, having been preceded by Sale 85 and Sale 109 (May 1988). Much of the information in the Draft Environmental Impact Statement (DEIS) is dated. The document does not include a very substantial amount of available scientific data, either in describing the affected environment or in the analysis of potential effects of Outer Continental Shelf (OCS) development. The DEIS ignores studies and facts that have taken place since il the last DEIS was prepared for this region (OCS Sale 109): for NOAA example, study of the Chukchi Sea sediment and benthos (in Section III and elsewhere), and the fact that since early 1989 BP 1 Exploration, and not Standard Alaska Production Company, has operated a portion of the Prudhoe Bay oil field (in Appendix E). Given that the Minerals Management Service (MMS) -sponsored studies were conducted to establish information needed for the assessment and management of environmental impacts which may result from offshore oil and gas development (43 USC 1346), the non- inclusion of results from those studies in the DEIS is disappointing. Some of the omitted information may be critical in presenting a succinct description of the environment and offering a basis to judge environmental impacts of the proposed action. Available information does indicate the marine fishery is characteristically composed of relatively few species, some of which may be seasonally abundant in certain areas such as coastal lagoons or river estuaries. We continue to find that the extant data do not support the impact assessments presented in the DEIS, and recommend additional research on the coastal, anadromous, and marine fishery resources within the planning area. The DEIS describes exploration activities which would exclude il drilling or seismic operations during the springtime, assuming NOAA i" 2 that ice-strengthened drillships and support vessels would NOAA operate for approximately a 90 day period in August through October. However, technology exists which would permit drilling 2 operations throughout the year for some waters, and new technologies may allow year round operations throughout the sale area. Drilling activities in the spring lead tem (SLS) could jeopardize the continued existence of the endangered bowhead whale. The proximity of the sale area to the SLS, and the possibility of springtime or year round activity are therefore of special concern. Echolocation and the importance of certain frequencies of sound may be critical concerns under ice-cover NOAA conditions, as migrating whales maintain communication between individuals or groups and as they navigate and locate thin ice or 3 leads for breathing. The DEIS largely fails to discuss this issue or analyze the potential impact that drilling activity could present. We believe that Alternative IV, the Point Lay deferral, would be an effective mitigative measure in minimizing adverse impact to endangered whales and coastal resources. Adoption of this alternative would be consistent with the Arctic Region Biological Opinion and the regulations governing incidental taking. Adequacy of Information The DEIS states (p. I-14) that "it is the judgement of the MMS that the information currently available is adequate for environmental assessment and .... to make decisions concerning this lease sale." In essence, this statement preempts all questions concerning the adequacy of the environmental data for the proposed lease sale. Yet the lease sale area is virtually unstudied in terms of its biological productivity, fisheries resources, habitat use by birds and mammals, geotechnical framework, and ocean circulation. The inadequacy of information is reflected in a number of statements scattered throughout the DEIS. For example, on p. Iv-c-25, it is stated that "... paucity of information regarding stock sizes, fidelity of streams, and movements of anadromous fish in the Sale 126 region means that analysis is based primarily on generalizations from Beaufort Sea populations." But on p. III-21, the DEIS states "However NOAA Craig and Skvorac (1982) caution that extrapolation of fisheries data from the Beaufort Sea or Norton Sound may not 4 be valid because of differences in oceanography, fish populations, and presumed use of coastal habitats." Further, on p. III-23 dealing with marine fishes, the DEIS 3 NOAA states that information concerning the life history, 4 population dynamics, distribution and ecological relationships .... is lacking. tric pagi The DEIS repeatedly refers to numerous environmental studies conducted as part of the OCS leasing program. The bibliography is 33 pages long including nearly 500 references of published and unpublished reports. There is little evidence that results from these studies were indeed incorporated in the description of the affected environment or in the determination of potential effects. There are numerous statements of inclusion of scientific data by reference alone. The burden to review and judge the suitability of the studies data to statements on the DEIS is left to the reader. Such a task would be burdensome and virtually impossible for an ordinary citizen or organization. Magnitude of Effects There is very little in terms of logic or formalized analysis by which effects on various biota and other environmental entities have been categorized. Considering a dearth of data on biological populations on most species of interest in the Sale 124 area, assessment of relative NOAA effects of different scenarios remains unfounded. Relative effects on the biological resources indicate an assessment 4A of lethal or sub-lethal damage to populations; yet population dynamics or other pertinent data are lacking from the DEIS. The assessment of cumulative impacts is even harder to accept. It is not clear as to why the effect of the proposed sale on subsistence harvest in the village of Nuiqsut will be high, and not so for Point Hope. Qcean Circulation Ocean circulation data from much of the proposed lease area are inadequate, as only a few, sporadic source of data exist. The area has not been studied with sufficient spatial and temporal resolution to determine ocean NOAA circulation patterns and their effect on spilled oil trajectories and mixing. 5 Ocean circulation as illustrated in the DEIS is derived from a review of physical sciences data done by the U.S. Geological Survey in anticipation of OCS Sale 85 (Grantz, et al. 1982 b). The ocean circulation figures in Grantz et. al (1982 b) were redrawn from similar figures in Coachman, Aagaard and Tripp (1976); which, in turn, was a review of historic data incorporating information obtained up to 1974. A small amount of new information on the subject, which can 4 NOAA be derived from the results of the NSF-funded ISHTAR study 5 and the MMS-funded Research Unit 687, is not given in the DEIS. A large portion of a rather short text on ocean circulation is concerned with water properties and transport into the southern Chukchi Sea via Bering Strait. There is some discussion of waters originating in the Yukon River delta NOAA and the Gulf of Anadyr -- much farther south -- but none 6 of water originating in Kotzebue Sound, which can and probably does influence water properties east of the proposed lease area. shown in the southwestern part of the proposed lease area There is no basis for opposing currents of similar magnitude (Figure III-A-7). Recent data have indicated that the Anadyr/Bering Strait NOAA water, which occupies most of the proposed lease area in a mixed state, probably follows the Hope Sea Valley northward Zz and may enter the Arctic Ocean east of Wrangel Island. Such a flow will not be consistent with the circulation pattern shown in the DEIS. Polynyi Except for a brief mention in the context of the lead system between Pt. Hope and Barrow (p. III-7), the DEIS does not consider the existence, dynamics or importance of polynyi either to transport of spilled oil or to biological use. NOAA Several polynyi -- most of which are recurring type -- have been identified in the Chukchi Sea. Their formation, size 8 at maximum ice cover, and disappearance have significant influence on the biological productivity as well as on regional circulation and heat transfer. sedi ical Very little data exist on the strength and engineering properties of sediment on the bottom on the Chukchi Sea, such as those caused by gas-charging of sediment. Studies to obtain such data have not been performed as part of the MMS environmental studi program. On p. IV-A-19 the DEIS states that sedimen geotechnical properties must be determined to understand how the sediment will react under NOAA static or cyclic vertical and lateral loads. Yet such 9 information is not provided. A regional description of gectechnical properties of sediment -- rather than site- specific data that are required of the petroleum industry for specific actions -- is necessary to assure that potential hazards or constraints to OCS development have heen identified. 5 Causeways 7 The DEIS dismisses the environmental effects of construction and existence of causeways because “causeways NOAA are not part of the development and production scenario for 10 Sale 126." (p. I-14). Yet the DEIS does not offer the means or alternatives by which equipment, goods and shipments will be brought in or transferred to, for example, Pt. Belcher. Point Belcher We do not believe there is an adequate basis to assume that produced oil will be transferred to Pt. Belcher, and from there to the Trans-Alaska Pipeline. In view of the vast acreage of the proposed lease sale area and the cost and environmental considerations of a buried pipeline on the seabed, one has to assume that the pipeline landfall would NOAA be the shortest and most economical direct route from a 11 producing (or gathering) area offshore. We believe an examination and analysis of alternate terminal site(s) should be included in the DEIS. This would permit an evaluation of relative merits and environmental factors for each site. Pt. Lay Deferral (Alternative IV) Statements referring to this alternative are not clear (Appendix B and elsewhere in the DEIS). Apparently deletion of 501 block (nearly 1.15 million hectares) does not markedly affect the base case resource estimate. Does it affect the high case resource estimate? Does deferral of NOAA this coastal region indicate a lack of commercially 12 recoverable amounts of oil? If so, why lease it? But on page B-2 under the "Deferral Alternative" the DEIS states that MMS would “expect some block in the deferral to be leased and possibly drilled .... " When? As part of Sale 126 or some future sale?? These discussions should point out the specific difference between Alternative IV and the various full development scenarios. As presented, the DEIS basically finds no advantages to the Point Lay deferral. We believe this is an artifact of the assumptions used in the DEIS and the resolution of impact projections. By presenting figures and statistics for the entire sale area with the deferral, this analysis minimizes any advantages of Alternative IV. For instance, while the DEIS points out that leasing of the deferred blocks could produce greater adverse effects since the area incorporates an important pupping area for seals as well as a lead system important to many species as a spring migration corridor and is important foraging NOAA 13 s NOAA habitat used by seabirds during the open water season, both the nS Base Case and Alternative IV have the same projected impact to marine resources. The DEIS further adds to this jumbled assessment by incorporating in Section IV G. an additional, separate analysis which "examines the effects of a minimum level of exploration, development, and NOAA production activities in the area to be deferred (not offered) by 4 this alternative." If the DEIS is presenting this as an |! additional alternative, it should be specifically discussed in a separate section. We question why the deferral is only compared ~] to the base case and not the high case as well. It is also NOAA unclear whether certain features such as pipeline routing and . seismic work would occur within the deferral. As pipeline 15 rupture or leakage is a primary source of potential oil spill, no pipeline or other activity should occur in the deferral area (with the exception of vessel and air crossings). On page II-41 paragraph 5 the DEIS states that no oil spills are projected for NOAA the Point Lay Alternative, while Section IV G. projects a probability of two spills greater than 1,000 bbl as a result of 16 this alternative. The Point Lay Deferral presents a meaningful mitigative measure which would minimize potential impact to endangered species, other marine mammals, and important coastal resources. We recommend the FEIS revise these discussions to present a meaningful analysis of this alternative. Pt. Lay Subsistence The DEIS states that an oil spill in the Pt. Lay subsistence use area during the normal period of harvest would have moderate effects on the Pt. Lay belukha whale harvest (p. Iv-C-72 et seq.). One could easily argue that it would have high effect. An oil spill that occurred during the harvest period, which is only 2-3 weeks long, could quite conceivably affect or cancel the entire harvest. Even if NOAA the animals did not come in contact with oil, the villagers 17 could perceive the animals as inedible and not proceed with the harvest. Oil spill response activities could also cause the animals to avoid the area, thereby eliminating the harvest for that year. If such an event succeeded or preceded a low harvest year (for example the year 1989), the availability of this food resource to the village could be substantially reduced for more than one year and could be very damaging. nl Pt. Lay Harvest Data There is very little quantitative data on the relative use of subsistence resources at Pt. Lay. This is unfortunate since Wainwright and Pt. Lay are the two principal NOAA 18 fast | Betinieietaatieeetmernes 7 communities in the vicinity of the proposed lease sale area. It is understood that Stoker (1983) and ACI/Braund (1984) NOAA did not include either Atqasuk or Pt. Lay in their surveys. 18 It is important that some effort be made to obtain information from this region, especially since it is not clear as to how much of the information obtained from Point Hope, Barrow and Nuiqsut was (or can be) used to describe the situation at Pt.Lay. Belukha Whale Harvest The major marine mammal subsistence resource of Pt. Lay is the belukha whale. The North Slope Borough has maintained harvest data for the past three years. It would be NOAA appropriate to include that data in the DEIS. The harvest of this animal at Pt. Lay is probably important to other 19 communities as well, such as Barrow, as much of the belukha magtak is distributed to other communities. Pelagic Bird Data The DEIS provides good information on coastal birds, but 1 ; data on pelagic birds is scanty. A large number of seabird transects were sampled as part of OCSEAP (see Research Unit NOAA 196 Final Report, 1987). At the least, data from those surveys 20 should be included in the DEIS. Specific Comments Page I-17, Figure 1-3. The boundary limit between United States and the U.S.S.R. is not plotted correctly. As the result of the recent U.S.-U.S.S.R. boundary agreement, the northeast corner should be at 72°46'29" N, 168°58'37" W (North American Datum of NOAA 1983) and the entire western limit should stop at 168°58'37" W 21 for the proposed area. This correction should be made to Figure 1-3 and any other figures or diagrams which depict the boundary. Page II-21. (a) Bowhead and Gray Whales We disagree with the assessment that most bowhead whales are ‘71 unlikely to encounter noise associated with production operations during the spring migration. Without the Point Lay deferral, NOAA leasing activity would be situated in or adjacent to the SLS. 22) Additionally, whales may travel through the ice covered margins seaward of the lead system and become exposed to drilling noise. Page II-36 Alternative IV - Point Lay Deferral Alternative Because of our concern expressed above for the spring migration of bowhead whales, we believe that alternative IV is an NOAA appropriate mitigation option for avoiding major long-term impacts to this endangered species. Although exploration could 25) be conducted in the coastal area and be timed to avoid the spring migration, we cannot foresee how potential year-round development 8 NOAA and production activities can be so timed to avoid the spring 23 migration. This alternative would effectively reduce the ° potential for disturbance to bowhead whales and may have beneficial impact on other coastal resources, as described on page II-39. <= Page II-44 The idea that removing an area of heavy subsistence NOAA use from the sale will not modify effects on subsistence harvest patterns lacks logic. 24 Page II-51 Stipulation No, 5 - Industry Site-Specific Bowhead Whale Monitoring Program We assume the blocks identified in this Stipulation are NOAA considered to be outside the SLS. Observations from such locations may provide valuable information on the extent of the 25 bowhead spring migratory corridor and account for possible movement outside of the actual lead system. Page II-57 ITL No, 1 - Information on Bird and Marine Mammal Protection paragraph 3, and Page II-62 ITL No. 6 - Information on Endangered Whales and MMS Monitoring Program paragraph 4 NMFS published final regulations on July 18, 1990 under Section 101 (a) (5) of the Marine Mammal Protection Act and Section 7(b) (4) of the Endangered Species Act authorizing non-lethal NOAA incidental taking of bowhead, gray, and belukha whales and 26 bearded, ringed, and spotted seals by U. S. citizens engaged in oil and gas exploration in the Chukchi and Beaufort Seas. These regulations provide measures necessary to minimize impacts and require applicants to monitor and report on the effects of exploration activities on these marine mammals. Taking of bowhead whales during the spring migration is not authorized by these regulations. Page II-63 ITL No. 7 - Information on Development and Production Ww} Under the "Purpose" discussion, the DEIS should also state that consultation will be required prior to any development and NOAA production activity. Consultation must also be initiated for i exploration within the SLS, whenever new information reveals 27 previously unconsidered adverse effects, whenever a new species may be listed, and for any modifications which may adversely effect these species. Page II-64 Effectiveness of ITL No. 7 The second sentence in this paragraph suggests that a jeopardy i situation regarding development and production operations would NOAA be avoided through the results of additional information and new technologies. While the NMFS will consider such information, 28 there is no assurance that a jeopardy situation can be avoided with respect to drilling activities in the SLs. Page III-20 Ecological relationships and trophic linkage diagrams, e.g., Figure III-B-3, are based on speculative data. More appropriate NOAA information is available from the Peard Bay region and some from ! the Kasegaluk Lagoon region. Information contained in Figure 293 III-B-3 is much too simplistic to be of any analytical use in the environmental assessment process. Page III-26 (first paragraph) int Statements regarding euphausiids are unclear at best, and they are not consistent with what is shown in Figure III-B-2. The NOAA reference citation for that figure (DOC NOAA 1988) is not 30 included in the bibliography. Page IV-A-4 (b) The assumption that produced oil would flow through an offshore gathering system and land-based pipeline to the Alyeska pipeline is fundamental in projecting the spill risk scenarios in the DEIS and in the type and magnitude of anticipated impact. With this scenario, a very large spill could occur within the nearshore portion of the pipeline, jeopardizing the bowhead migratory corridor and important coastal fishery resources. The DEIS NOAA projects a one in five probability of a large oil pipeline spill 1 entering a major river system. The impact to freshwater fish is projected to be VERY HIGH. Considering these projected consequences, the DEIS should discuss alternative delivery systems which may mitigate these impacts. This might include a marine transportation system or buried pipeline. Page IV-A-8 (paragraph 4) al Are there not more current statistics on spills from TAPS than NOAA the pre-1981 data cribed here? A larger data set would be SZ more representative. Page IV-A-14 (6) Effectiveness of Oil-Spil] Cleanup in Ice | This discussion should be expanded to provide a narrative on what procedures would be employed to contain and recover oil in an ice NOAA environment. Please provide a reference for the statement that 33 experiments have shown burning to be a more effective cleanup technique than mechanical methods. Page IV-B-10 paragraph 2 Ile While the 50% criteria for definition of the response zone has practical and statistical significance, it has no basis in law. NOAA The DEIS should note that any such disturbance, unless previously 34 authorized, may violate Federal law. Also, a significant number (i.e. up to 49%) of whales in an area outside of the response 10 NOAA zone could react to industrial noise. Thus the statement that 34 only a small number of whales outside this zone would respond is misleading. Page IV-B-20 Summary 7 We believe this summary should reflect that all observations of the interactions of bowheads and OCS noises have been made on NOAA animals in open water or in ice leads. Presently no data exists on the potential effects of drilling noise on animals moving 55 through ice, nor the impacts of infrasonic noise on communication or echolocation. Page IV-C-22 71 It is stated that fish in the nearshore areas will be most vulnerable to petroleum-related effects because this zone NOAA contains the highest densities of fish. No reference is provided 36 for this statement. We do not believe there are supporting scientific data from Sale 126 for this statement. Page Iv-C-25 (2) Marine Fish The arctic cod may be considered a keystone species in the marine environment of the central and northern Chukchi Sea, as it is typically the dominant species of marine fish occurring in these waters, is found throughout the year in the Chukchi Sea, is associated with the undersurface of sea ice, forms dense aggregations at or near the ocean surface (juveniles) which provide the major food source for offshore-feeding marine birds, and is the most important winter food source of the ringed seal and the principle prey item for a variety of other marine NOAA mammals. The DEIS should reflect this ecological significance, and discuss the potential impacts of exploration and development oT in greater depth. The current state of knowledge is not sufficient to fully assess the impact of development on this species. Basic information on summer and winter distribution, age class structure of the population, and spawning locations is necessary to support the conclusions in the DEIS. What is the toxicity of petroleum hydrocarbons to the various life history stages of arctic cod? Would wintering populations of cod associated with crevices, holes, and cracks on the underside of sea ice be more affec by spilled oil than in open water seasons? How might the release of formation waters impact the survival and distribution of juvenile cod? While suspended sediments per se have very low direct toxicity values, the composition of sediments should be tested prior to assessing the potential impacts from dredging. In Norton Sound, for example, nearshore sediments contain high background levels NOAA of mercury and other metals. Dredging activities may resuspend such materials and make them available to aquatic organisms, with 38 Page IV-C-30 paragraph 2 | 11 | NOAA resultant adverse effects. The EIS should provide data on the 38 chemical composition of nearshore sediments for the Beaufort and Chukchi Seas. Page IV-C-32 =| This section should include an overview of the probabilities of NOAA oil spill occurring in the pelagic portions of the proposed sale area during at least the open water season. _|39 Page Iv-C-47 (b) Development and Production While most of this sale area is outside of the SLS, we do not agree that most bowhead whales would therefore not encounter noise from production operations in the spring. Unlike the fall migration, the spring corridor is relatively narrow, with a NOAA higher probability that a significant portion of the population would be present and may encounter noise. Also, some migration 40 may occur outside of the lead system, through ice covered waters and in closer proximity to drilling operations. This section should present a statistical analysis of noise encounters for the spring migration, as it has for the fall period. Page IV-C-55 paragraph 4 This discussion suggests that migrating whales would be only briefly exposed to oil spilled in the SLS unless stopping to feed or trapped in the lead where oil was present. Discussion is warranted regarding the potential impacts of an intensive and NOAA large scale cleanup operation within the lead system, as would likely occur following a large spill. The resultant high levels 41 of sea and air traffic and cleanup activities would, of themselves, create a potential source of disturbance which could delay or interfere with the migration. Page IV-C-56 Development/Product ion NOAA See comment, Page IV-c-47. 4g Page IV-C-57 See comment, Page IV-C-55. NOAA 43 Page IV-G-11 paragraph 3 This paragraph suggests that adoption of Alternative IV - Point Lay Deferral could adversely effect bowhead whales in that potential oil spill sites would become concentrated nearer to the fall migration corridor with the deletion of southerly, nearshore tracts. The predictions regarding how and where oil exploration, development, and production would occur are not sufficiently NOAA accurate to infer that Alternative IV would increase activity in 44 the remainder of the sale area. While spill sites in the deferral area would be farther from the fall migration corridor than the remainder of the sale area, with the deferral these sites would not exist at all (excluding pipeline spills). Therefore, the validity of this argument is questionable, and we 12 NOAA recommend it be deleted from the final statement. The adoption 44 of Alternative IV would reduce potential impacts to endangered whales and should be adopted as the preferred plan. The omission of finback and humpback whales from the cumulative case discussion seems unwarranted given the fact that recent aerial and shipboard surveys have demonstrated that large NOAA fractions of their Pacific populations are seasonally present in 45 the Gulf of Alaska. Those summering stocks could be affected by oil spills originating from tankers carrying TAPS crude oil because the animals are concentrated in coastal areas, e.g., Prince William Sound. Conclusion The DEIS for OCS Sale 126 is a voluminous document but it lacks substantive scientific basis for the description of the affected environment. Most of the inferences or conclusions regarding effects of oil and gas development on the environment can be questioned as having no validity or being based on arbitrary presumptions. A substantive revision of the DEIS will improve the quality and contents of the document. Page IV-H-65 1 National Oceanic and Atmospheric Administration Response NOAA-1 The text in Section III.A has been amended to address this concern. The citation appears in the FEIS bibliography. Response NOAA-2 Technology may exist or may be developed to allow year-round drilling in the Chukchi Sea, but the EIS analysis and underlying assumptions are consistent with Exploration Plans that have been approved by MMS for the Chukchi Sea to date. If a proposal is made (by means of an Exploration Plan) to conduct year- round exploration operations, such operations would be reviewed by MMS as to potential environmental effects and appropriate mitigating measures to protect the resources of the area. Response NOAA-3 The EIS assesses the likely effects of the proposal based on the best available information to date. Information of this type (e.g., Richardson et al., 1985, 1990; Malme et al., 1983; 1984,1985, 1986; Ljungblad et al., 1985; Wartzok et al., 1989) consistently shows that whales encountering industrial noise are likely to experience the same local, short-term effects in the spring-lead system that they have exhibited everywhere else. Hence, the suggestion that industrial noise could "jeopardize the continued existence" of the bowhead whale appears conservative. Also, it has not been established that bowheads use echolocation as a means of navigation and communication, nor has it been established that whales are unable to compensate for noise of any type (including industrial noise). If bowhead whales use echolocation and other sounds to navigate and communicate through ice-impacted areas, industrial noise is not likely to adversely affect this anymore than naturally occurring noise would. If compensation is necessary, it is reasonable to assume that nonthreatening, passive noises, such as industrial noise, would be compensated for in the same manner as is done for naturally occurring nonthreatening noise. Response NOAA-4 The key word in the sentence cited is "may." There is no data to the contrary that Chukchi Sea marine and anadromous fish populations are uniquely different from those found in the Beaufort Sea and Norton Sound or that the respective habitats differ markedly to an extent that the fish populations would also show variance to the effects of oil and gas exploration/development. Whether additional studies/surveys would show significant discrimination from other areas is conjectural--at least as regards oil and gas exploration/development. Response NOAA-4A Although the comment does not elaborate on what specific aspects of formalized effects analysis would be desirable to include in the EIS, MMS assures the commenter that standard analytical procedures were employed and rational biological logic was applied to the analysis of available information for each "environmental entity." The MMS recognizes that the quantity and quality of data available for such entities is variable, but feels that it is adequate for sufficient numbers of species/environmental situations to permit accurate overall conclusions to be drawn. Likewise, available population data, although not incorporated other than by citing the appropriate references where the data may be found, have been considered in the course of each analysis. Response NOAA-5 The amount of data available is sufficient to run general ocean-circulation models for oil-spill-trajectory NOAA-1 modeling on the mesoscale level. The data presented at an OCSEAP/MMS Chukchi Sea Information- Update Meeting held in Anchorage, Alaska, on March 27, 1986, and the published proceedings (1987) show the same figure from Coachman, Aagaard, and Trip (1975). This same data is shown in Figures III-A-6 and III-A-7; thus, it is presumed that the general information shown in Figures III-A-6 and III-A-7 is still pertinent, even though it is based on historic data. Currently there is a cooperative effort with NOAA and the U.S.S.R. Far Eastern Hydrometeorological Research Institute and the Arctic and Antarctic Research Institute to collect oceanographic data in the Chukchi Sea. This oceanographic-research cruise, the first since 1976, will collect data across political boundaries and will be valuable for verifying the data from Coachman, Aagaard, and Trip (1975). Response NOAA-6 The text has been amended to include this information and the citation appears in the FEIS bibliography. Although this information provides a few more details, it does not change the overall description of the physical environment. Response NOAA-7 The commenter is interpreting the figure incorrectly, because it shows only the Sale 126 area. The original figure is from Coachman, Aagaard, and Trip (1975). As suggested by the commenter, the flow moves northwest and enters the Arctic Ocean east of Wrangel Island. This flow is discussed in Section IILA. Response NOAA-8 Appendix L addresses spilled oil in the polynya system. Discussions of the polynyi, as they relate to each environmental resource, are located throughout the FEIS. Response NOAA-9 The regional distribution of shallow gas is shown in Figure III-A-5. The MMS regulations require preliminary activities such as geological, geophysical, and other surveys necessary to develop a comprehensive Exploration Plan or Development and Production Plan. Response NOAA-10 The construction of a pipeline landfall at Point Belcher would be a relatively short-term phenomenon and should not require the expense to construct a causeway to accomplish this. Some temporary means for offloading may be called for rather than a causeway, which is a fairly permanent structure. The forward construction base for activities in the Chukchi Sea is specified in the scenario as being near Wainwright, where materials and equipment offloading would not be inconsistent with similar operations that now occur near the community. Barging could originate from Wainwright, or materials and equipment could be barged from some other community (such as Barrow or Kotzebue) for offloading at Point Belcher without the need for a causeway or other similar permanent structure. Response NOAA-11 Point Belcher represents a reasonable location for a pipeline landfall to be used for prelease environmental assessment purposes. The MMS is not required to assess the environmental effects of pipeline landfalls at all possible locations. Should a different landfall be proposed at a later time for developmental purposes, an environmental assessment of the location would be performed as part of a NEPA document. . NOAA-2 Response NOAA-12 Deletion of the Point Lay deferral area will not markedly affect the base- or high-case estimates. This is due to the estimates being directed to only those prospects that are most likely to have a major discovery capable of creating infrastructure and being developed and produced for Sale 126. Since none of these higher potential prospects appear to lie within the Point Lay deferral area, the base- and high-case estimates remain unchanged. However, Appendix B does indicate that the blocks within the deferred area are important for the upcoming sale and that the blocks within the deferred area have prospects that may contain developable volumes of hydrocarbons. The current MMS data do not provide evidence to support a major discovery in the deferred area, but we still expect some blocks to be leased for Sale 126. The MMS data suggest that any prospects drilled within the deferred area would significantly contribute to area delineation of geology and that discovery of subeconomic volumes of hydrocarbons are possible from Sale 126. These subeconomic volumes would not be large enough to create infrastructure and thus were not included in the base- and high- case estimates; but these volumes may become economic if infrastructure is created by any of the higher potential prospects comprising the base and high cases. It is very important to emphasize that the current interpretation of MMS data is only an indicator of what to expect from drilling activity in the deferred area; but it does not preclude a major discovery in the deferred area. Therefore, Appendix B correctly states that the blocks within the deferred area are important for Sale 126. Response NOAA-13 The differences in effect between alternatives that the commenter points out are recognized in the EIS. The general level of effect, however, remains about the same within the effect level definitions used by MMS because each defined effect level represents a range of potential effects that adverse factors, in various combinations and degree of severity, may satisfy. Thus, although Alternative I (base case) is likely to result in greater effects thanAlternative IV (Point Lay Deferral),, the effects would not be sufficiently different to warrant different class levels. Response NOAA-14 Analysis of the area not to be offered for lease in the Point Lay Deferral Alternative is not intended to represent analysis of an additional alternative but, rather, to show the potential environmental benefits that might accrue should the area not be leased. Response NOAA-15 Effects of the Point Lay Deferral Alternative are compared with effects of the base case of the proposed action rather than with both the base and high cases to avoid the possible confusion caused by excessive analytical comparisons. The area not to be offered (the area to be deferred) for leasing in the Point Lay Deferral Alternative should be able to accommodate a pipeline route to shore but would not accommodate any drilling or production activities. Seismic work necessary to locate an appropriate pipeline route would also have to be accommodated within the area to be deferred. Oil spills from a potential pipeline rupture have been factored into the OSRA. The commenter is correct that not offering the area to be deferred would not preclude the occurrence of environmental disturbances within the area to be deferred, should a pipeline that traversed the deferred area be used to transport oil to a landfall. Response NOAA-16 The commenter is correct in pointing out the contradiction. The sentence referred to in Section II.E.3.d has NOAA-3 been deleted. Response NOAA-17 See Table S-2 for the definition of the effects term "moderate" and effects levels associated with that term. "Moderate" means that one or more important subsistence resources would become unavailable, undesirable, or available only in greatly reduced numbers for a period not exceeding 1 year. Under this rubric, much of the consequences and potential effects discussed in the comment still fall into a "moderate"-effects category. In the last sentence of the comment, the commenter states that should an oil spill occur after a low-harvest year, Point Lay could be denied a harvest for 2 consecutive years. While this statement may be true, the commenter’s scenario of an oil spill coupled with a low harvest year represents a “worst-case scenario." The base-case effects of the proposed action are examined "standing alone," apart from other effects that may be due to other projects, weather, or the natural cycle of the subject species. Those issues are discussed in Section IV.H (cumulative effects). Response NOAA-1; The commenter’s observation is correct; additional subsistence-harvest data do need to be collected for Point Lay. The North Slope Borough has collected some data regarding the belukha harvest that has been added to Section III.C.2. This subject has also been discussed with the Environmental Studies Section (ESS) of the Alaska OCS Region. In the future, Point Lay needs to be added to the subsistence-harvest-data-gathering studies ESS is now conducting in Wainwright and Barrow. Response NOAA-19 The text of Section III.C.2 has been revised to address this concern. Response NOAA-20 Although an EIS seldom presents data as detailed and extensive as that typically found in the OCSEAP reports (e.g., Divoky, 1987), these reports were used extensively in compiling the generalized bird distribution map and in description and analysis sections. Response NOAA-21 Since the precise western boundary value correctly given by NOAA cannot be distinguished from the approximate 169° line shown, Figure I-3 and others are correct as they appear in the EIS. The northern limit of the planning area is correct as shown at 73°. The recent U.S./U.S.S.R. boundary agreement does not place a northern limit on territorial claims, and we are not constrained by the 200-mile Exclusive Economic Zone line on the continental shelf. Response NOAA-22 In order for bowhead whales to encounter industrial noise they must (by definition) enter an industrial- response zone. This zone is typically about 1 to 4 km in radius from sources of industrial noise. Since the distance from potential sites of exploration in the Sale 126 area is considerably beyond 4 km from the spring- migratory corridor, whales in the spring-migratory corridor are not likely to encounter industrial noise associated with Sale 126, as stated in the EIS. This is not to say that whales would not hear industrial noise. Response NOAA-23 As indicated in the analysis, production activities and associated noise are not likely to affect the bowhead whale population although industrial activities in the spring lead system could disrupt normal bowhead NOAA-4 activities. It is agreed that Alternative IV would remove any possibility of interference but it is assumed, because of ice conditions, that no exploration activities would occur until after the spring migration has occurred. Response NOAA-24 Please compare OSRA Tables C-13 and C-16 (Appendix C, base case) with Tables C-17 and C-20 (Point Lay Deferral). There are virtually no differences in degree of risk between the Point Lay Deferral Alternative and the proposed action. Since much of the effects-level analysis is driven by the OSRA, it is difficult to justify a sharp reduction in effects when the main effects- causing agent remains at the same level of effect. Response NOAA-25 The blocks identified in Stipulation No. 5 were intended to be outside of the spring-lead system. However, the spring-lead system moves about from year to year and may overlap the Sale 126 area in some years. Response NOAA-26 No response is necessary. Response NOAA-27 The purpose statement of ITL No. 7 (Information on Development and Production Phase Consultation with NMFS to Avoid Jeopardy to Bowhead Whales) adequately covers the intent of the commenter without further revision. Response NOAA-28 For the purpose of clarification, the referenced paragraph has been revised. Response NOAA-29 Peard Bay and Kasegaluk Lagoon are embayments some distance from the proposed lease-sale area. The MMS believes that the ecological relationships and trophic linkage diagrams would differ from those in the larger Chukchi Sea. Figure III-B-3 has been simplified for clarity in the FEIS. We agree that the food web of the Chukchi Sea coastal ecosystem is more diverse and complex; however, this complexity is beyond the scope of this EIS. Response NOAA-30 In the FEIS, the sentence dealing with euphausiids has been expanded to more thoroughly describe this group of crustaceans. The citation on corrected Figure III-B-1b appears in the FEIS bibliography. Response NOAA-31 The overland pipeline transportation assumption represents a reasonable assumption to be used in a pre- lease environmental assessment for initiating the transportation of oil to market. The MMS is not required to assess the environmental effects of a variety of transportation scenarios. Should a different transportation method or route be proposed for developmental purposes at a later time, an environmental assessment of the transportation mode and its characteristics would be performed as part of a developmental EIS. NOAA-5 Response NOAA-32 The BLM has current spill data on the TAP. No analysis of this data has been completed at this time. Response NOAA-33 Figure IV-A-12 show the applicability of oil-spill response in the proposed sale area in decaying ice; broken ice; widely scattered ice; and new, thin, broken slush ice. The text has been amended to address this concern and the citation appears in the FEIS bibliography. Response NOAA- The referenced analysis discusses the likely effect of the proposal on endangered whales as required by “FNEPA. The legal status of future actions will be analyzed on a-case-by-case basis if and when such action occurs. Also, it has yet to be established why most whales avoid close encounters (1-4km) with sources of industrial noise. Hence, it is premature to suggest that whales swim around industrial operations because they were disturbed by them. It is equally possible that avoidance occurs in order to prevent disturbance. Further, mammals subject to nonthreatening activities (natural or manmade) typically habituate to them. Since industrial noise is passive and nonthreatening, it is likely that whales would show less avoidance after habituation occurred. Regarding the idea of whales reacting beyond the response zone, this is also speculative since at these distances, behavioral responses to acoustic stimuli cannot be attributed to their source. Hence, there is no data that support the idea that whales beyond the response zone would react to industrial noise (the data support the opposite). Since the analysis is based on substantiated information, speculation along these lines would not have enhanced it. Response NOAA-35 Data concerning the effect of industrial noise on bowhead and belukha whales in the spring-lead system is available in Richardson et al. (1990), a 2-year study involving the response of whales to industrial noise in the spring-lead system (1991 report in process). These studies indicate that bowheads respond to industrial noise in the spring-lead system in the same way they do in open water (minor, short-term responses). This is not too surprising, since all whales, regardless of geographic area, have been observed to respond to industrial noise in essentially the same fashion. In general, it appears that passive stimuli (such as industrial noise) do not cause any perception of threat or long-term annoyance, as is common when marine mammals are subject to active stimuli (such as subsistence hunting). Regarding effects due to echolocation, see Response NOAA-3. Response NOAA-36 The statement in the EIS is supported by discussion in the Chukchi Sea Sale 109 FEIS (USDOI, MMS, 1987b), herein incorporated by reference. Anadromous fishes were found in coastal waters, in brackish estuaries, and river mouths (Morrow, 1980; Maynard and Partch/Woodward-Clyde Consultants, 1984). Craig (1984) and Wolotira, Sample, and Mann (1977) characterize the anadromous fishes of the southeastern Chukchi Sea as using only estuarine and other nearshore environments. Morris (1981a) indicates that arctic flounder, starry flounder, and fourhorn sculpin frequent low-salinity waters near estuaries or river mouths. Other marine fish species, such as arctic cod, apparently prefer higher-salinity, offshore waters; but population-size estimates and densities are lacking for most species. Quast (1974) estimated that more than 20.9 million kg of arctic cod were present between Cape Lisburne and Icy Cape in 1970, with implication given in the geographic reference that these juveniles were nearshore. NOAA-6 Response NOAA-37 The importance of arctic cod as a keystone species is indicated in Section III.B.2.b. Additional information as to the importance of this species is contained in the Chukchi Sea Sale 109 FEIS (USDOI, MMS, 1987b), herein incorporated by reference. Arctic cod are most important as food for higher-trophic- level organisms, although size is smaller in the northern part of the Sale 126 area (Fechhelm et al., 1984). Young-of-the-year are normally found in the upper 50 m of water, while juveniles and adults are found more toward the benthos. Additional information on life history, distribution, and significance of this species is contained in the Sale 109 FEIS. Response NOAA-38 Concentrations of trace metals within the Chukchi Sea sediments are similar to those for other coastal seas (USDOI, MMS, 1987b: Sale 109 FEIS, Table III-4). Unlike Norton Sound, mineralized deposits are not in evidence inshore or offshore; and locally, anomalously high trace-metal values are not found. Generally, trace-metal analyses of sediments are not required by permitting agencies prior to dredging unless sediment contamination is suspected. Response NOAA-39 The probabilities of an oil spill occurring and contacting offshore resources in the sale area and vicinity are discussed in Section IV.C.5. Response NOAA-40 See Response NOAA-22. Wherever studied, all species of whales have been observed to respond to industrial noise in a similar fashion (local, short-term effects). Hence, the important issue is really the effect of industrial noise on whales, not the location of the whales when they encounter industrial noise. Further, a statistical analysis of whales encountering noise in the spring-lead system is unnecessary, since the spring- lead system is mostly outside of the sale area. Response NOAA-41 It is unlikely that there would be a "large scale cleanup operation within the spring lead system" when bowheads are present, since bowheads have passed through the spring lead system (mid-June) before industrial equipment could enter it (mid-July). Ii is possible that there could be long-term adverse effects from a production operation in the spring lead system. Hence, further consultation with NNMFS will be accomplished when production and development is contemplated. Response NOAA-42 See Response NOAA-40. Response NOAA-43 See Response NOAA-41. Response NOAA-44 The rationale expressed in the EIS is correct as stated. It is based on the premise that the areas leased are leased with the intention of conducting exploratory drilling. If the deferred area is not leased, some of the industrial noise and potential spill sites that would have occurred in the deferred area (inshore) would occur farther offshore. If the deferred area is leased, then some of the industrial noise and potential spill sites that NOAA-7 would have occurred in the remainder of the sale area (offshore) would occur farther inshore in the deferred area. The EIS does not state that oil-spill sites would become concentrated; rather, it states that potential sites of industrial noise and crude oil would be moved closer inshore or offshore, depending on whether the deferred area is leased. Response NOAA-45 The Gulf of Alaska (GOA) is outside of the sale area, as are the many destinations of crude oil and its products. Oil originating from the sale area would be piped to a GOA port before leaving the GOA by tanker. However, this oil would be mixed with a much larger share of oil that comes from other sources before it leaves the GOA. Hence, it is difficult to know the origin of crude oil being transported at any given time, and even more difficult to know the origin of crude oil arriving at processing and distribution sources. For this reason, the GOA was not assessed in detail; and the many other destinations of Sale 126 crude oil were not addressed at all. NOAA-8 are: REPLY TO ‘ATTN OF susuect To: velie UNITED STATES GOVERNMENT memorandum BUREAU OF INDIAN AFFAIRS September 6, 1990 Acting Area Director, Juneau Area Comments on Draft Environmental Impact Statement for JUNEAU AREA OFFICE Chukchi Sea Le: Sale, No. 126, Outer Continental Shelf Regional Director, Minerals Management Service The subject proposed Oil and Gas Lease Sale should have negligible effects on the surfaces of allotted Alaska Native properties in the general geographic area known as the North Slope Borough Alaska. The overall effects of che base case drilling activity of the Oil and Gas Lease Sale, if approved, are expected to be high on subsistence harvests in the Wainwright area and low to moderate in the remainder of the proposed lease area. The Bowhead Whale harvest, specifically, would be adversely impacted, with anticipated adverse effects expected to accrue on the subsistence walrus harvest. Very high effects are also anticipated on the freshwater habitats of the anadromous fishery at the base level drilling intensity level. Stipulation No. 6 of the possible mitigating measures of subsistence whaling and other subsistence activities, appears to imply the intent is to minimize the net effects which any drilling or exploratory activity would have on whaling or other subsistence activities. Although as Stipulation No. 6 seems to address the issues surrounding subsistence whaling and other related subsistence activities, more precise language should be incorporated into the lease sale to provide for specific measures to protect the subsistence harvest and socioeconomic lifestyle of the Alaska Natives. Utilizing the best current information available on Bowhead Whale migrations, BIA seismic and other drilling related activities will be prohibited in the vicinity of migrating whales when it is likely that such activity would interfere with subsistence activities or jeopardize the availability of whales or other marine mammals for subsistence purposes. In further regards to Stipulation No. 6, activity above the depth at which oil and gas bearing strata is likely to occur may be conducted on a year-round basis, but would be postponed or halted if such activity was likely to interfere with subsistence activities or affect the availability of whales or other marine mammals for such purposes. All nonessential sea and airborne traffic associated with drilling and/or completion activity under this lease sale is to be conducted prior to or following the normal whale migration time frames and is to be halted if found to interfere significantly with other subsistence activities. It is further noted that Seasonal Drilling Restriction (SDR) was listed as a mitigating measure not recommended for further study (page I-16). We believe pacman that this mitigating measure has very substantive value to the subsistence BJA issue. Not as the Arctic Regional Biological Opinion relates it to a possible aCavED (nev 7-76) soro-112 OPTIONAL FORM NO. 10 GSAFPMR (41 CFR) 101-11 6 Regional Director, Minerals Management Service September 6, 1990 Page Two oil spill, but rather, as a mitigating measure directed at assuring that migrating Bowhead Whales and other marine mammals have sufficient time and space free of industrial noise and activity to complete their normal migrating patterns. The SDR would be involved when available current specific data indicated Bowhead and/or Gray Whales were in the process of migrating to or through the area of oil and gas exploration activity. In reviewing the various alternatives to Sale 126, the Point Lay Deferral Alternative (No. IV), appears to offer the greatest opportunity for the discovery and development of hydrocarbons with the smallest amount of possibility of adverse effects on the overall environment and the Alaska Natives’ subsistence and cultural-traditional way of life. This alternative provides virtual exclusion of the Bowhead Whale and other marine mammals' migration routes. It also removes most of the traditional subsistence harvest areas from Sale 126, which effectively eliminates our greatest concerns in these are: The remaining effects would be principally in the area of oil spills and their effects on anadromous fishes both in fresh and in salt water. These concerns appear to be adequately addressed in the Point Lay Deferral Alternative. Although fish would be severely impacted by the event of an ofl spill, the possibility of such an expected occurrence appears to be quite low and the overall effects minor, compared to Alternative No. 1., as proposed. In conclusion, the Bureau of Indian Affairs recommends the adoption of the Point Lay Deferral Alternative (IV). It is believed this alternative would present the least impact on the requirements and needs of the Alaska Natives, including their subsistence rights and their cultural-traditional way of life. oren arogr BIA 2, Bureau of Indian Affairs Response BIA-1 Stipulation No. 6, Subsistence Whaling and Other Subsistence Activities, has been changed to incorporate more specific language regarding subsistence activities other than bowhead whale hunting. The specific language recommended by the commenter has not been incorporated into Stipulation No. 6 because the commenter’s concerns are addressed by other mitigating measures, such as Stipulations No. 2 (Protection of Biological Resources), No. 3 (Orientation Program), and No. 5 (Industry Site-Specific Bowhead Whale- Monitoring Program). The commenter’s concerns are "to provide for specific measures to protect the subsistence harvest and socioeconomic lifestyle of the Alaska Natives," with the notion that offshore oil and gas activities must halt when potential conflict might ensue with subsistence activities. Stipulation No. 5, Industry Site-Specific Bowhead Whale-Monitoring Program is designed with specific reference to the migration of the bowhead whale. This Stipulation provides the authority for halting offshore activities should conflict exist with the migration of the bowhead whale. Stipulation No. 2, Protection of Biological Resources, addresses a means for protecting marine subsistence resources, whereas Stipulation No. 3, Orientation Program, emphasizes the special relationship that exists between man and nature in the Arctic. Response BIA-2 The purpose of the seasonal drilling restriction (SDR) was to protect whales from what were then the unknown effects of an oil spill. Since that time studies have consistently shown that both crude oil and industrial noise are likely to have only minor, short-term effects on some cetaceans. In addition, because of prevailing ice conditions, no exploratory activities are assumed to occur in the spring lead system. Consequently, the SDR was dropped. However, in its place a measure was developed to ensure that the effects of industrial activities on bowhead whales would continue to be monitored. An additional measure was also developed to prevent potential conflicts between the oil industry and whalers. In addition further consultation with NMFS will be persued if and when production and development activities are contemplated. BIA-1 Aste United States Department of the Interior BUREAU OF MINES Alaska Field Operations Center 201 East 9th Avenue Suite 101 Anchorage, Alaska 99501 Sir ena August 20, 1990 R Ssisisuv 3\]) AUG 22 132) Regional Director Minerals Management Service REGIONS. : 2 aL Lexa oes Alaska Region Min: a 949 East 36th Avenue Anchorage, Alaska 99508-4302 Re: Draft Environmental Impact Statement (DEIS) for the Proposed OCS Chukchi Sea Oil and Gas Lease Sale 126 Staff from the Bureau of Mines, Alaska Field Operations Center have examined selected portions of the DEIS which could pertain to or describe possible impacts from the proposed Sale 126 on development of mineral resources. The DEIS is well written and relatively comprehensive. A few general suggestions for your consideration are outlined below. t. Estimates of the quantity and identification of possible source areas for gravel needed for construction purposes associated with exploration, development and transportation of oil should be included in the DEIS. On page II-13 an estimate is quoted that 500,000 m’ of gravel would be needed to construct land-fall facilities associated with offshore development at BOM Point Belcher. However, it is unclear whether this estimate includes 1 gravel needed for roads to connect Point Belcher with other communities in the region. Also, gravel would likely be required for construction of the pipeline from Point Belcher to the TAPS. Quantities would be very large if an all-weather road paralleling the pipeline was also built. 2. A related consideration involves the application of the evolving wetlands al policy and regulations by the Corps of Engineers and Environmental BOM Protection Agency. Development of new on-shore infrastructure eae | 2 become more expensive and/or difficult. 3. On page I1-23,24 there appears to be a contradiction between section 10 (Effects on the Economy of the North Slope Borough) and section 11 (Effects on Subsistence-Harvest Patterns) relative to the overall effect of the base case on subsistence harvest. BOM The overall effect of the base case on subsistence harvest patterns is 3 rated as high (Wainwright), moderate (Barrow), and low (Point Hope) in section 11. However, the overall effect is rated as very high on the economy of the North Slope Borough (section 10) because of impacts on subsistence harvest. Other economic impacts are rated as moderate. This same comment applies to comparable sections for other alternatives | 3 (pp. 11-34,35; I1-43,44). Thank you for the opportunity to review the above well-written document. Pl: contact me at the above address or by calling FTS 868-2455 if you need clarification of these comments. Coheot & Ueki awe Robert B. Hoekzema Chief, Anchorage Branch cc: Director, Minerals Management Service Paul Gates Millie Gloster RBH: mm:8/20/90:Sale126. ltr Bureau of Mines Response BOM-1 Information concerning the amount of gravel that might be needed to construct a typical facility is presented to provide the reader some indication of the quantities that may be required. While estimates of the amount of gravel that might be needed to construct the facilities noted in the hypothetical scenarios would be useful, the purpose of the EIS is to analyze the potential environmental effects of activities that might result from the lease sale. The effects of habitat alteration and destruction caused by gravel mining and construction activities can be analyzed without knowing the exact volume of gravel that might be used or the extent of potentially affected areas. If development occurs as a result of this lease sale, plans showing the locations of facilities, the amount of gravel required, and the gravel-mining sites will have to be submitted to the appropriate regulatory agencies for review and approval. Response BOM-2 No response is necessary. Response BOM-3 Based on a review of Section IV analyses and related sections, the very high effect on the economy for the base case has been changed to a high effect in the FEIS. However, the analyses for subsistence-harvest patterns and the economy of the NSB in Section IV of the DEIS--using the definitions in Table S-2--lead to the conclusion of different levels of effects and were consistent. It is possible to have a high effect on subsistence-harvest patterns and an even greater effect, very high, on the economy and still be consistent. These two environmental resource categories are related. However, in this case, the effects were increased when the high effect on subsistence-harvest patterns was translated to the effect on the economy. Subsistence-harvest patterns and the economy of the NSB are interrelated but separate environmental resource categories with their own analyses, definitions of effects, and, in this case, conclusions. Conceptually, the conclusion of high effects on subsistence-harvest patterns could have translated to a very high effect on the economy, as reflected in the DEIS. BOM-1 fet United States Department of the Interior = FISH AND WILDLIFE SERVICE IN REPLY REFER TO 11. FUDOR RD. NAES/MMM/DOS ANCHORAGE, ALASKA 99503 Memorandum SEP iL 1990 To: Regional Director, Minerals Management Service Se toed Alaska ALASKA ¢ From: Regional Director air erhes Region 7 LASKA Subject: Comments on Draft Environmental Impact Statement, Lease Sale 126 [Chukchi Sea] (EC 90/86) The U.S. Fish and Wildlife Service (Service) has reviewed the Draft Environmental Impact Statement (DEIS) for Outer Continental Shelf Oil and Gas Lease Sale 126 in the Chukchi Sea Planning Area. The proposed lease sale encompasses 23.7 million acres between three and 240 miles offshore from Point Belcher to Ledyard Bay. We provided comments on Lease Sale 109, also located in the Chukchi Sea, in letters dated May 7, and May 27, 1987, as well as on the Notice of Intent to Prepare an Environmental Impact Statement for this sale in a letter dated March 2, 1989. Copies of our earlier comments are attached. General Comments The northwest coast of Alaska adjacent to the proposed Lease Sale 126 area includes critical fish and wildlife habitats. Habitats in the vicinity of Cape Thompson, Cape Lisburne, Kasegaluk Lagoon, Icy Cape, Peard Bay, and Point Franklin are of national interest as portions of the Alaska Maritime National Wildlife Refuge system. Mudflats and salt marshes at Icy Cape, in Kasegaluk Lagoon, provide feeding, molting, and staging habitat for large concentrations of brant, eiders, oldsquaw, and shorebirds using the Chukchi coast. Common eiders and Arctic terns nest on the barrier islands. Beluga whales feed and molt in Kasegaluk Lagoon and spotted als use the islands as haulout areas. Kasegaluk Lagoon is also thought to be an important feeding area for anadromous fish. The Kuk River (Wainwright Inlet) supports anadromous fish, 71 including Arctic char, rainbow smelt, least, Arctic, and Bering FWS ciscoes, and pink and chum salmon. Very little is known about their distribution, movements, overwintering areas or dependence 1 upon protected coastal areas where the water is warmer and more FWS brackish (Craig and Skvorc 1982). Much additional information is 1 needed to adequately assess the potential impacts of offshore oil and gas development on anadromous fish and their nearshore habitats. The Chukchi Polynya forms south of Point Hope when the prevailing easterly winds that usually occur in March and April separate the pack ice from the fast ice along the flaw zone (LaBelle et al. 1983). This polynya often provides the only open water habitat available in early spring before any major deterioration of the pack ice occurs. Migrating marine mammals and birds concentrate along this lead system in the spring and follow it as it progresses northward. Virtually the entire Alaskan and northwestern Canadian population of king eiders (more than one million birds), as well as thousands of common eiders and oldsquaws, migrate along these spring leads (Woodby and Divoky 1982). mammals for which the Service is responsible. The document provides an incomplete seasonal description of sources of potential impact to marine mammals and underestimates the degree of impact to polar bear within the lease sale area. The document also, to a lesser degree, downplays the impacts to walrus, FWS provides an incomplete description of potential impacts, and | > < We have a major concern for the document's treatment of marine fails to incorporate findings of a recent study describing effects of drilling and support activities upon the distribution of walruses. The document's description of oil spill scenarios for the spring and fall periods and associated impacts to pinnipeds and polar bears is incomplete. Mitigative measures to clean and rehabilitate polar bears and possibly walruses contaminated in a spill are stated to be the FWS responsibility of individual operators. A more complete assessment of remedial actions to a spill is necessary to evaluate impacts to marine mammals. in quality and productivity of marine mammals is not adequately addressed. Given the nature of polar bears and other bear species it would appear that this family is intolerant to minor habitat changes. Polar bears, for example, may be attracted in concentrated numbers in certain areas at specific times not only FWS by large marine mammal carcasses, but by the mere dynamics of | 4 Habitat alteration and the cumulative effect of long-term =| their movements associated with polar ice. Such aggregations may likely occur in the lease area because it would logically serve as a staging area along the ice edge in the fall during rapid ice formation and advancement to the south. Walruses make two large scale movements through the lease area and are present, albeit not as visible and possibly not as numerous as other times, during the open water phase. More F importantly, the component of the population present is | predominantly the nursery herds and younger males and females, which is the nucleus of the future population. The DEIS appears FWS to place a great emphasis upon the adaptability and resilience of these populations to perturbation. Studies substantiating the S) conclusion of population recovery from disturbance, stress, oiling and other impacts are unavailable for walrus and polar bear. Most arctic species depend upon a migratory lifestyle. Bowhead, gray, and beluga whales, walruses, spotted and bearded seals, and marine birds pass through the Bering Strait and through the Chukchi Sea twice annually during spring and fall migrations. The critical nature of the Chukchi migratory corridor for many marine species warrants a conservative approach, at least until we know more about the vulnerability of fish and wildlife species during migration. The marine environment of Ledyard Bay is highly productive and used extensively in spring, summer, and fall by seabirds. All of the gulls and common and thick-billed murres nesting in colonies at Cape Lisburne feed there. Ledyard Bay is especially important to tens of thousands (possibly hundreds of thousands) of king and common eiders, which molt there in July and August (Roseneau and Herter 1984). During this time, eiders are flightless, which renders them particularly vulnerable to oil spills and noise disturbance. The Service believes that the Point Lay Deferral Alternative is the best compromise for allowing exploration while protecting the biologically sensitive coastal areas. The Chukchi coastal ecosystem has been little studied and many questions and information gaps remain on the importance of the lease area to fish and wildlife. This Deferral Alternative would afford some protection to the coastal ecosystem during the exploration phase. However, long-term research and adequate biological resource data is needed to provide for environmentally responsible decisions on how to produce and transport commercially recoverable oil that may be discovered. The production phase calls for a network of subsea pipelines from remote leases to a landfall, possibly in the vicinity of Point FWS Belcher. The biological importance of any landfall site should be determined and possible alternative sites will need to be 6 considered. Detailed discussion of transportation scenarios and potential impacts on fish and wildlife will occur when a specific plan is Proposed. We will be pleased to assist you with an impact analysis of the likely scenarios. From a Service perspective, the following resources should be addressed: (1) Western Arctic caribou; (2) nesting Arctic peregrine falcon; (3) migrating, nesting and staging shorebirds and waterfowl; (4) anadromous fish important to local commercial and subsistence users; and, (5) high-value wetlands and uplands that support these resourees. Specific Comments Page I-7, paragraph 2: The specific incidental take provisions of the Marine Mammal Protection Act contained in Section FWS 101(a)(5) should be discussed in general in this section, as well as on page II-57. 4 7 Page I-14, paragraph 2: Missing from the DEIS is the issue of availability of adequate studies information. While the Minerals Management Service should be commended for the quantity of studies conducted in offshore areas, it remains that little site specific evaluation and information on the lease area's value to FWS polar bear and walrus are included. Population dynamics information including size and trend are unavailable for polar 8 bear in this area. Contemporary studies describing the long term and seasonal relationship of polar bear and walrus populations to the area should be conducted. Page I-15, paragraph 3: The orientation program should include a 7 mandatory polar bear orientation training for all field employees and an approved Polar Bear Interaction Plan. The orientation program should include a summary of polar bear biology and life history information, relevance of the Marine Mammal Protection Act to the exploratory and production activities and the conduct of employees (e.g., feeding wildlife, waste disposal, deterrence FWS activities, employee safety, Native use of polar bears, the Polar Bear Management Agreement between the North Slope Borough and the 9 Inuvialuit Game Council of Canada, the International Agreement on the Conservation of Polar Bear). The interaction plan includes site design, site operations, offsite procedures and monitoring and reporting of polar bear interactions and sightings. The orientation program and interaction plan should address offshore activities, support activities, and shore based activities. Page I-15, paragraph 8-9: Areas of Special Biological Sensitivity. Notice to Lessees (NTL'S) and operators of Federal Oil and Gas Leases in the Outer Continental Shelf (OCS), Alaska OCS Region dated December 1, 1989, provides conditions helpful in minimizing the potential for incidental taking of polar bear and = walrus. Recommendations for conducting preliminary and other ocs FWS lease activities, including associated aircraft, support vessel 10 and ice-breaking activity contained within the NTL are not mandatory. Therefore NTL's do not eliminate the potential for taking and that the liability of such taking continues to be borne by operators pending the development of incidental take regulations and accompanying Letters of Authorization. es Page I-16, paragraphs 5-6: The dismissal of seasonal drilling restrictions as mitigative measures for further study is premature and inappropriate. Although inclusion of the Point Lay deferral alternative (I-17) addresses, to an extent, the concerns FWS for the nearshore habitats associated with the Chukchi Polynya, ad and its importance to marine mammals, the resultant leasing of 22 ee |e blocks within the subarea continues to warrant the evaluation of FWS seasonal restrictions, particularly during any production phase which may develop. Adoption of the Point Lay Deferral 11 Alternative and withdrawal of the 22 leased tracts would greatly mitigate against concerns for the integrity of the spring lead system of the Chukchi Polynya. Page II-2, paragraph 3: Statements found in this paragraph 7 provide few clues as to the actual scope and magnitude of effect FWS of the planned activities. Given current technology and the ambiguity of development scenarios can accurate impact i assessments be developed? Page II-3, paragraph 4: Exploratory drilling is ongoing (II-2, “Ews paragraph 1). 4 { 3 Page II-5, paragraph 5: Effects on Pinnipeds and Polar Bear [Low Case) The document presents effects for the exploratory phase only, yet seeks National Environmental Policy Act approval for the production phase as well. It is recommended that the document be modified to reflect technological advances which will allow for the production of hydrocarbon and portray expected effects to marine mammals. The expected effects of exploration on walrus underestimate the effect of frequent aircraft flights and disturbance and displacement of walrus herds and do not accurately portray the impact of underwater acoustical disturbance transmitted by drilling, accompanying vessel traffic or ice-breaking activities. Preclusion of marine mammal use of areas is of concern. Citation of the Ebasco Report, "1989 Walrus Monitoring Program: The Klondike, Burger, and Popcorn Prospects in the Chukchi Sea," (1990) is appropriate, particularly in FWS relationship to ice-breaking activities and the potential for attraction of walrus to the drill ship and potential for 14 mortality which is not indicated to occur in the DEIS. The document further indicates that, "Vessel traffic coinciding with animal movements may interfere temporarily with local movement or migrations within a lead system, but there is no evidence that vessels would block or significantly delay migration." The document earlier states that exploratory activities will occur only during the open-water phase (II-4). It is true that lead systems are comprised of open water and ice; however, they are generally considered to be in an ice-covered phase due to the predominance of the surrounding ice habitat. If vessel traffic does occur within the spring lead system, the associated impact ef introducing additional stress would be greater than projected. Blockage of migrations may not necessarily have to occur in order for significant impacts to take place. In addition, polar bear may be present within the area even during the open water phase, either on solitary or scattered ice which frequently moves through the area or swimming to find ice platforms. Amstrup (1990) documented interactions of ice-breakers with polar bears in the Beaufort Sea under similar exploratory conditions. Page II-20, paragraph 3: Effects on Pinnipeds and Polar Bear (Base Case) Comments from the Low Case apply. A further discussion of the effects of oiling on polar bears and seals during the fall spring period is necessary. Discussion is not included on the impacts of oiling to marine mammals during the fall period. Marine mammals in the region make two major migrations per year associated with the spring retreat of the pack ice and again in the fall with the advance of the polar ice pack. Region specific information on the distribution, composition and abundance of polar bears near the spring lead system should be presented. If the information is unavailable, additional studies should be conducted to provide data necessary to projecting valid impacts. Gardner (1989) points out that polar bear densities may become more concentrated during certain seasons and in specific areas. For example, polar bears appear to pulse across the North Slope in a westerly direction during the autumn and early winter as ice conditions move animals from the northern pack ice into proximity with the coast. Large numbers (40+) have been reported in the Point Franklin, Point Belcher and Atanik areas during the fall. Icy Cape has long been considered a favored gathering or migratory path of polar bears during this period. Similarly, residents of Point Lay report seeing numerous polar bears along coastal areas in the vicinity FWS of the village and along the barrier islands adjacent to the 15 Kasegaluk Lagoon. The location and amount of beach carrion and normal distribution and availability of ringed seals are believed to contribute to the attraction and local persistence of bears. The annual variability in deposition of carcasses and the severity of the fall weather combined with the accessibility of natural live prey may interact to determine polar bear distribution along coastal areas. It is believed that family groups of females and cubs having a greater nutritional demand may be represented in a greater proportion than other sex or age classes. Subadult animals just becoming proficient at securing prey may also be heavily represented in these areas. Polar bear have a low productive capability given a late age of first reproduction, small litter sizes and lengthy interval between litters. In short, the critical female component of the population may be at greater risk during this period in coastal areas. Even if the polar bear population were evenly distributed during this period, it is incorrect to assume that low densities equate to low level impacts. An understanding of the relative number of animals within the population (valid current estimates are unavailable and a predictive methodology to this estimate population size in this region has not been developed), population trend, and effects of annual non-natural mortality are required before impacts (mortalities) from oiling can be described. Any spill and the attendant clean up effort may attract polar bears. Polar bears are curious and seek out novel visual stimuli or may be attracted by unusual smells associated with a clean up effort. A comprehensive discussion is not provided on oil spill contingency plans, securing the spill areas against further oiling or rehabilitation efforts for oiled animals. Further, a narrative on the persistence of oil within the environment should be included so the reader can assess the potential for residual oiling in other seasons or locations. Polar bears spend a great amount of time travelling across sea ice and traversing open water leads in search of food, primarily seal. They then become particularly susceptible to under-ice spills and the effects of "herding" of oil by wind and ice action, as well as to oil spreading on top of the ice. The possibility of ingesting oil fractions is real because ringed seals, their main food source, may accumulate petroleum hydrocarbons. As a major predator of seals, the polar bear may ingest bioaccumulated petroleum hydrocarbons in the event of an arctic oil spill. Because polar bears will eat ringed seals contaminated by oil, the impact of oiling may spread through the movement of oiled seals. Engelhardt (1981) found that bears showed no aversion to oil, and once oiled, would actively groom to eliminate oil in coated fur. They also would lick oil from cage walls. Amstrup et al. (1989) document a polar bear death after it ingested toxic antifreeze. During the spring, bears are frequently distributed adjacent to the lead systems which support a higher density of ringed seals. Additionally, shore-fast habitats which afford more secure seal pupping habitat are intensively hunted by bears in search of food and during breeding season in May and June. The DEIS does little to evaluate the impact of an oil spill to polar bear in this zone during the spring period. Further, 200 miles of offshore trunk and lateral gathering pipelines and the effectiveness of leak or rupture proof operation is open to question. The proposed location of the main arterial trunk pipeline approximates the spring lead system. Are alternate locations possible which would allow a single subsea crossing of the lead or flaw zone? Information contained in II-15 indicates that installation would involve barges and that the normal operating period of 70 days could be extended through the use of ice-breakers. The effect of creating an artificial open water lead system in a portion of the migration pathway for marine mammal species is uncertain. Further, the effects to polar bears, seals and possibly walruses of an alternate approach of laying pipe from the shorefast ice during the winter is not known. Additional concerns for the integrity of the pipeline within this zone come from the following DEIS statement: "To protect the pipe from collisions with drifting ice masses, the pipeline is assumed to be laid ina trench cut into the sea floor. Pipeline placement below the level of ice gouging would be required in the areas where ice gouging could occur. If the trench were laid in unconsolidated sediments of the seafloor where ice scouring is evident, the pipeline might have to be covered with fill material. In areas where the sediment layer is thin or absent, the trench might have FWS 15 to be cut into the bedrock; a pipeline laid in a bedrock trench might not have to be covered." The Service believes it may be prudent to move the pipeline from areas of active ice scouring and to consider an alternate offshore route for the trunk line. Denning of polar bears has been verified in the vicinity of Wainwright, Icy Cape and Point Lay. Because of an inadequate understanding of polar bear denning in northwestern Alaska, further evaluation is necessary to determine the magnitude and extent of denning in this area. Although scenarios of activities associated with development and production (II-12) are “highly speculative," they warrant response. Support and logistic activities raise numerous concerns for the welfare of polar bear in the Peard Bay, Point Franklin, Icy Cape and areas between Wainwright and Point Belcher. On shore developments including roads from Wainwright to Point Belcher, potential dredging of Peard Bay and alternate airfield development at Icy Cape or Cape Beaufort pose a high probability of impacting polar bear to various degrees depending upon which development or combination of developments are actually pursued. The document's projected impact of aircraft disturbance to walruses and polar bears presumes a greater understanding of the situation than is practical given the amount of published information on the topic. The number of helicopter flights alone is cause for concern. Between the year 2000 and 2004 a total of 9,630 helicopter flights to 214 production and service wells, .5 trip per well per day, are anticipated. Flights for the year 2002 to 2020 are estimated to average about 2 per week per platform and total 11,856 flights. A greater discussion of the persistence of crude oil products in the arctic environment and latent effects on polar bear and their prey species is warranted. Also a discussion of the effects to lower level food chain organisms should be expanded II-17. A detailed description of the rationale for the following statement should be included. "Those organisms that inhabit nearshore, shallow environments are more at hazard from oil spills; however the oil-spill-risk analysis does not show appreciable inshore areas as being contacted by oil spills." Near shore areas parallel the main subsea trunk pipeline. Therefore, any spill or leak from this pipeline structure would appear to place near shore areas at risk to oiling. Likewise, a spill during the spring would occur in the spring lead system. Walrus are dependent upon bivalve clams for food. Even though clams are distributed over the Chukchi Sea their population status is not certain. Some evidence indicates that walrus populations may be experiencing shortages in food prey and are undergoing stress as a result. If information is available on the status and trend of bivalve populations in the Chukchi Sea, it would be helpful to incorporate reference materials. FWS 15 Walrus are gregarious and may be found in a clumped distribution seasonally. Since populations occurring within the area may be FWS clumped, any local impact to prey species could have a 15 substantial impact upon animals. Of particular concern are the reproductive females. The ingestion of oil contaminated clams by walrus should be discussed and any studies of the effects of oil ingestion incorporated by reference. The projected level of impact to pinnipeds and polar bears should be reconsidered. Page II-31, paragraph 5 (High Case] comments from low and base 1 cases apply WS Correspondingly higher levels of activities associated with F exploration, development and transportation are cause to 16 reconsider the projected level of impact. Page II-57: ITL No. 1--Information on Bird and Marine Mammal 71 Protection: Differences in the conditions contained within NTL No. 89-1 and this section should be explained. More protective FWS conditions of NTL No. 89-1 should be incorporated within ITL [ie No. l. Page III-21, paragraph 2: This discussion of existing fisheries information available for the Chukchi Sea points out that the very limited fisheries data are based only on a few brief reconnaissance surveys. Similar points could be made related to the limited number of migratory bird and marine mammal studies of the Chukchi Sea area. The Service is concerned that inadequate baseline biological resource information for the Chukchi area will continue to hamper resource agency assessments of potential impacts resulting from offshore exploratory drilling and production. In the absence of resource data specific to the Chukchi area, the document extrapolates resource information from areas in the Beaufort Sea and the Bering Sea areas. The Service believes that long-term studies of fish, birds, and marine mammals are needed in the Chukchi Sea, particularly in light of the fact that exploratory drilling is currently underway in these areas. We appreciate the opportunity to comment on this draft document. wet. stegphe Attachments REFERENCES Craig, P.C., and P. Skvorc. 1982. Fish resources of the Chukchi Sea: status of existing information and field program design. U.S. Dep. Commer., NOAA, OCSEAP Final Rep. 63:1-62. Craig, P.C. 1984. Fish resources. Pages 117-131 in J.C. Truett (ed.). The Barrow Arch environment and possible consequence of planned offshore oil and gas development. Proceedings of a synthesis meeting, 30 October-1 November 1983, Girdwood, AK. LaBelle, J.c., J.L. Wise, R.P. Voelker, R.H. Schulze, and G.M. Wohl. 1983. Alaska Marine Ice Atlas. AEIDC, Univ. of Alaska. Anchorage, AK. 302 pp. Roseneau, D.G., and D.R. Herter. 1984. Marine and coastal birds. Pages 81-115 in J.C. Truett (ed.). The Barrow Arch environment and possible consequences of planned offshore oil and gas development. Proceedings of a synthesis meeting, 30 October-1 November 1983, Girdwood AK. Woodby, D.A., and G.J. Divoky. 1982. Spring migration of eiders and other waterbirds at Point Barrow, Alaska. Arctic 35:403-410. PAIRSANKS PISH AND WILDI.IFE RYHANCEMENT OFFICE FCOLOGICAL SERVICES/ENDANGERED SPECIES RANCH Room 222, Pederal Building, Box 2C 101 12th Avenue Pairbanke, Alaska 99701-6267 May 7, 1987 Rogional Dtrector Minerals Management Service, Alaska Region 949 East 36th Avenue Anchorage, Alaska 99508-4302 Attention: Laura Yoesting Re: Chukchi Sem Lease Sale 10° Dear Ma. Yoesting; We appreciate the opportunity to review the Draft Pnvironnental Impact Statement (DFIS) for the propeaed 1988 Outer Continental Shelf O11 and Gas Lease Sale 109, Chukchi Sea. Unfortunately, due to fim4ing and personnel limttations, we can only offer a cursory teview of this document at this tine. We would like to call vour attention to some inaccuracies and omissions, oarticularly in the cumulative effects ansessment. The proposed State of Alasha Lease Sales, as depicted in Graphic 3, are {naccurate according to the St current 5-vear lease sale plan. We have previously called your attention to these inaccuracies in our comments on the DPIS for Reanfort Sea Saie 97, Also, since Bea:fort Sea Sale 97 in being conefdered almoet concurrently with Chukchi Sea Sale 109, the proposed pipeline routes and transportation corridors for Beaufort Sea Sale 97 should te included in the cumulative impacts asseanment for the Chukchi Sea Sale, and their locations should be depicted on Graphic 3. The potential combined cumulative effects of both lease salen should be considered since they will be offere? in the sane vear and {n the sane region, Ia addition, we note that the “eaufort Sea Sale 97 DFIS discussed a proposed pipeJine from Pt. Belcher acrosa the sonthern portion of National Petroleum Reserve - Alanka (NPR-A) to the Trans-Alaska Pipeline (TAPS) Pump Station 3, while the Chukchi Sea Sale 109 N&IS proposes a pipeline from Pt. Belcher to the TAPS Puop Stetion 2. It aoens unlikely that two different pipeline router would be seeded from Pt. Belcher to the TAPS, However, if separate pipelines are proponed, the two route locations should be depicted on Graphic 3 and the cumulative effects of the two pipelines should be dincuased. In any case, the “hukchi Sea DEIS is deficient in ite discussion of the environmental effects renulting from the construction of the 440 km pipeline and asncciated roads, support camps, and gravel sources. As stated in our comments on the Beaufort Sea Sale 97 DEIS, it ‘s prohably unrealistic to ssaume that thie road would remain perranently closed to the public. Significant secondary impacts to fish and wildlife resources are likely to occur from opening the road to the oublic. The overall impact aesensment approach used in this DEIS, as well as in previous DEIS'’s for OCS o11 and gas lease sales, can be misleading in that potential “MAJOR” fmpacts are apparently diluted by being average? over a large area, or with other lesser effects. For example, the DEIS mentions several “MAJOR” potential effects on the regional populations of vartous bird species (murres, aukleta, snow geese, brant) in the cumulative effects analysia (pp. IV-B-46 to 49), yet the conclusion sta’ that the cromlative effects will be “MODFRATE”. We appreciate the opportunity to review this DFIS, and regret that we are unable to give thie document the full review it deeerves at this time, We look forward to future opportunities to provide suggestions and input on this proposed leane sale. If you bave any questions regarding our comments, please contact Kate Moitoret at 456-0709, Sincerely, Tony Booth Acting Pield Supervisor ect Director, MMS, Weshington, D.C. Ron Lamhertaon, Assistant Director, FYS-PWE, Washington, D.C. Peter Escherich, Branch of Env. Coord., PWS, Washington, D.C. Paul Getes, DOI Reg. Environmenta] Officer, Anchorage Ron Morrie, NMFS, Anchorage Rich Suemer, EPA, Anchorage John Warrer, P&G, Anchorage Warren Matumeak, NSB, Barrow Patty Wipghtean, DGC, Fairbanks Al Ott, ADP&G, Fairbanks Larry Dietrick, ADEC, Pairbanke Bob Cannon, ADLWM, Fairbanks FAIRBANKS FISH AND WILDLIFE ENHANCEMENT OFFICE ECOLOGICAL SERVICES/ENDANGERED SPECIES BRANCH Room 222, Pederal Building, Bor 20 101 12th Avenue Fairbsoks, Alaska 99701-6267 May 27, 1987 Regional Director Minerale Management Service, Alaska Region 949 Fant 36th Avenue Anchorage, Alaska 99508-4302 Attention: Laura Yoesting Re: Chukchi See Lease Sale 109 Dear Me. Yoesting: In a letter dated May 7, 1987, we submitted comments on the Draft Environmental Impact Statement (DEIS) for the proposed 1988 Outer Continental Shelf O11 end Cas Lease Sale 109, Chukchi Sea. Since then, we have been epprised of additional inforsation that aay warrant inclusion in the DEI8 and consideration in proposed leasing activities. The proposed Chukchi Sea Lease Sale 109 is adjacent to several unite of the Alaska Maritime National Wildlife Refuge, which contain {eportant nesting and staging areas for several species of sigratory birds. The attached map shows the locations of these units at Cape Thompson and Cape Lisburne, and on the barrier islands et Kanegatuk Lagoon, Icy Cape, and Peard Bey. Although the DEIS 1 tifies aator seabird colonien, waterfowl and shorebird feeding, staging, and molting areas at these locations, it joes not mention that these arean are portions of the Alaska “aritime MWR. Inclusion of « pap with thie information in the EIS would be appropriate, since thine are areas of national interest which could potentially be affected by the Lease Sale. The EIS should discuss the potential effects of the proposed dredging, road, and berge facilities at Peard Bay (p. II-7, last peragraph) on the adjecent National Wildlife Refuge wnit at Point Franklin, More detailed mapn of the Alaska Maritime Mattonal Wildlife Refuge are in preperation, and may be obtainet from the Refuge Manager, 202 Went Pioneer Avenue, Homer, Alanka 99603; teJephone: 235-6546, Thank vou for considering the addttionel coments in vour EIS preparation, Sincerely, Paul E. Gertler Pield Supervisor cet Director, MMS, Weshington, D.C. Ron Lanmbertaon, Assistant Director, PWS-FWF, Washington, D.C. Peter Eecherich, Branch of Env. Coord., FWS, Washington, N.C. Paul Ga DOI Reg. Env. Officer, Anchorage Ron Morris, NMFS, Anchorage Rich Sumner, EPA, Anchorage John Warren, DO&G, Anchorage Warren Matumeak, NSB, Barrow Patti Wightman, DGC, Patrbanks Al Ott, ADP&C, Fairhanks Larry Dietrick, ADEC, Peirhanks Bob Cannon, ADLWH, Pairbanks IN REPLY REFER TO: Copy For Your Information ei A BR United States Department of the Interior ——— —s FISH AND WILDLIFE SERVICE 1011 E. TUDOR RD. ANCHORAGE, ALASKA 99503 Dos MAR 2 [989 = Memorandum ne To: Regional Director, Minerals Management Service = j Alaska OCS Region Noe : From: ho 6s ona1 Director Nat Tie” Region 7 SLO 2 ae Subject: Call for Information and Notice of Intent to Prepare an Environmental Impact Statement, Outer Continental Shelf Sale 126, Chukchi Sea The Fish and Wildlife Service (Service) has reviewed the referenced Call and Notice for the Outer Continental Shelf Oil and Gas Lease Sale 126 - Chukchi Sea, which is expected to be held in May of 1991. The proposed lease e covers 29.5 million acres between 3-240 miles offshore from Peard Bay southwest to Cape Thompson. We have previously commented on environmental documents prepared for proposed Lease S. 85 and 109, also in areas of the Chukchi Sea. Many of the topics addressed in those comments represent concerns on which the Service will focus during review of the Draft Environmental Impact Statement for Lease Sale 126. These concerns include: o The environmental effects of Outer Continental Shelf development and production scenarios that include the following features: - anticipated pipeline landfills (e.g., causeways or other structures at tidewater) and utility corridors within units of the Alaska Maritime National Wildlife Refuge at Cape Thompson, Cape Lisburne, and the barrier islands at Kasegaluk Lagoon, Icy Cape, and Peard Bay, as well as elsewhere along the Chukchi Sea coast; - expected port and ofl transshipment facility requirements, with emphasis on the possible use of lagoons; and - potential combined effects of Outer Continental Shelf activities and other existing and future onshore and offshore oil and gas developments. © The analysis of potential nearshore and onshore effects of Outer Continental Shelf development, with special attention to: - migratory birds (waterfowl, sea birds, and shorebirds) and their use of river deltas, coastal barrier islands, and other coastal habitats such as salt marshes; ~ anadromous fish stocks, particularly around principal river deltas and lagoons; ~- cumulative impacts of multiple facilities on fisheries, birds, marine mammals, caribou, ausk ox, and subsistence use of these species; and = cumulative effects on fresh and marine water quality and aquatic food webs from various industrial activities, including chronic discharges of petroleum products, drilling effluents, and water treatment chemicals. © The effects of increased air traffic over coastal areas during the exploration phase and the selection of staging sites for activities in the planning area. © The consideration of tract deletion immediately seaward of environmentally sensitive areas, including: - Icy Cape to eastern limit of the planning area; and - Point Hope to Cape Beaufort. In general, our greatest concern lies with the long-term cumulative effects of offshore development and production on the water, fish, and wildlife resources of the Chukchi S region, and how Outer Continental Shelf activit re likely to promote or intensify similar development affecting the biologically productive coastal zone. i We appreciate the opportunity to respond to the subject Call for Information, and will provide more detailed comments on the forthcoming Draft Environmental Impact Statement. cc: Chief, Offshore Leasing Minerals Management Service Washington, D.C. ~ er ey Fish and Wildlife Servi Ri nse FWS- As analyzed, oil spills would be the major agent with potential to affect anadromous fish species in the nearshore zone and then only during the short, ice-free season. Oil-spill-risk probabilities, however, estimate oil spills to be most limited in number and volume and not to contact large, nearshore areas in any significant number over time. It is not anticipated that an oil spill during winter, some distance offshore, might reach overwintering or nearshore areas. An offshore-pipeline break could not affect any large area of fish habitat or its fish populations during winter or summer since; such spills are also of very small volume and very limited in number. Response FWS-2 To the extent possible, potential sources of effects on marine mammals have been discussed with regard to season of most likely occurrence. The analysis of potential effects on the polar bear was made with regard to probable densities expected in the sale area, in turn based upon available data and conversations with FWS personnel. The analysis of potential effects of activities associated with this sale on walrus is valid within the framework of information available concerning their temporal and spatial distribution and abundance. For most Alaskan species, detailed information for much of the annual cycle period is fragmentary and specific knowledge of their vulnerability to oiling or activities associated with development is lacking; thus, conclusions regarding potential effects are to some extent likely to be speculative. The text of Section IV.C.6 has been revised to incorporate the findings of Brueggeman et al. (1990). Oil-spill scenarios for spring and fall periods are not subject to greater resolution than presented in the document because the oil-spill model used in this analysis does not separate contact-probability values for these periods from those for winter and summer, respectively. Response FWS-3 A statement concerning mitigation of potential effects on polar bears and walrus by cleaning and rehabilitation does not appear in the document. Such actions, if pursued, while initially the responsibility of individual operators, would be carried out under the guidance of the appropriate regulatory agencies (e.g., FWS in this case) and under the overall authority of the U.S. Coast Guard. Unless proposed as a potential mitigating measure, this topic would be most appropriately covered in plans developed by the Natural Resource Trustees or Regional Response Team under the Oil Pollution Act of 1990. Since activities associated with oil-spill containment and cleanup could disturb portions of pinniped and polar bear populations in this area, the text of Section IV.C.6 has been revised to include this point. Response FWS-4 The text of Sections IV.C.6 and IV.H.2.b(3) has been revised to address the concern for vulnerability of polar bear aggregations. Response FWS-5 No attempt was made to de-emphasize potential effects of disturbance on walrus, but effects are likely to be rather localized and therefore not to affect a significant proportion of the population. The observations of Brueggeman et al. (1990) have been incorporated into Section IV.C.6. Response FWS- Possible alternative sites for a landfall for the subsea-pipeline system most likely will be considered when a developmental EIS is prepared. Under these conditions, the locations of offshore production sites will be FWS-1 known, and specific alternative configurations for bringing product to shore (or to an offshore loading facility) will be investigated. For this prelease EIS, the Point Belcher site was chosen because it represented a reasonable location, for analysis purposes, where such a landfall might occur. The Point Belcher landfall site was also used in the Chukchi Sea Sale 109 EIS. Response FWS-7 The incidental-take provisions of the MMPA are discussed in the EIS, and additional or lengthy discussions are not necessary for the purposes of NEPA compliance. The technical publication, "Legal Mandates, Authorities, and Federal Regulatory Responsibilities," (Rathbun, 1986) referenced in Section I.C generally discusses the provisions of the MMPA. Readers of the technical publication are directed to the MMPA for specific provisions. Also, the text of ITL No. 1 on Bird and Marine Mammal Protection discusses the specific provisions of the MMPA concerning incidental taking of marine mammals and references FWS’ and NMFS’ implementing regulations. Response FWS-8 The MMS has funded research concerned with "Delineation, Faunal Composition, and Repeated Use of Benthic Feeding Areas by Walrus and Endangered Gray Whales in the Northeastern Chukchi Sea." In Fiscal Year 1991, the MMS will fund the first year of a study concerning "Development of Guidelines for OCS Operations in Polar Bear Habitats." In addition, the MMS currently is conducting a study on the "Use of Kasegaluk Lagoon by Marine Mammals and Birds" that, while not specifically targeting polar bears or walrus, will record seasonal distribution and abundance of these species as they occur. It is anticipated that this study will document critical marine mammal and bird use areas in this important lagoon system. Shell Western E & P Inc. recently contracted a walrus-monitoring program during its exploration activity on three Chukchi Sea prospects (Brueggeman et al., 1990). Response FWS-9 A new stipulation or revision of an existing potential stipulation with regard to any unavoidable killing of polar bears is not necessary to protect polar bears, which already are protected from excessive takes or human-induced mortality under the MMPA. Concerns about harassment and taking also are covered under Stipulation No. 3, the Orientation Program, and under ITL No. 3, Information on Bird and Marine Mammal Protection. All of the measures under the Polar Bear Interaction Plan are covered under existing OCS regulations or would be covered under FWS review of OCS exploration and development plans. For example, existing regulations prohibit the dumping of garbage that would attract bears; and the organization and layout of buildings and work areas are confined to the offshore drill platform or gravel island, thus minimizing the chance of bear/human interactions. The MMS agrees it is important that lessee activities not affect polar bears. It is MMS’ understanding that Letters of Authorization (LOA’s) are required for unintentional take of polar bear and that the LOA can or would further identify lessees’ obligations or requirements to prevent disturbance to polar bears. Avoidance plans would not alleviate lessees from the responsibility of obtaining LOA’s. The MMS will provide Exploration Plans to the FWS and will coordinate with FWS on LOA’s and their requirements, eliminating the need for MMS to require separate plans. Response FWS-10 No response is necessary. Response FWS-11 The purpose of the seasonal drilling restriction (SDR) was to protect whales from what were at that time the FWS-2 —— ell ae en SoS Oe ™ unknown effects of an oil spill associated with activities (fall and spring) permitted by the MMS. Since that time, studies to date have shown that both crude oil and industrial noise are likely to have only local, short- term effects on some cetaceans (Richardson et al., 1985, 1990; Malme et al., 1983, 1984, 1985, 1986; Ljungblad et al., 1985; Wartzok et al., 1989). Due to heavy ice, exploratory operations are not likely to occur when cetaceans are present in the spring-lead system. Consultation with NMFS will be reinitiated if and when development and production is contemplated. Therefore, the continuation of the SDR is unnecessary. Nevertheless, in the interest of obtaining further effects-related information, a bowhead whale-monitoring stipulation was developed. The 22 blocks lying within Deferral Alternative IV that were leased as part of Sale 109 are not a part of Deferral Alternative IV and are not subject to lease under Sale 126. The mitigating measures designed to protect endangered whales will continue to apply to the 22 blocks leased under Sale 109. Response FWS-12 The paragraph cited contains a generalized introduction to the scenarios for the low, base, and high cases for Alternative I and the scenario for Alternative IV. The scenarios are described in detail in Section II.B.1.a for the low case, Section II.B.2.a for the base case, Section II.B.3.a for the high case, and Section II.E.1 for Alternative IV. Response FWS-13 Exploratory drilling is not ongoing, as suggested by the commenter. A basic assumption for effect- assessment purposes is that exploration will take place only during open-water periods, as indicated in Section II.B.1.a (the reference cited by the commenter). In 1990, exploratory drilling as a result of Sale 109 terminated in the Chukchi Sea in mid-October. Response FWS-14 It should be noted that the low case is discussed in Section IV.B; Section II, to which this comment refers, contains only summaries of the several cases and thus omits the more detailed discussion in Section IV. Because the resource estimate for the low case falls below that required for recovery with current technology and economics, potential effects of development and production are not considered. Should recoverable resources be discovered, potential effects of these phases are expected to be as discussed under the base case. Exploration activities are expected to take place primarily during the open-water season. However, some activities could take place when ice and ice habitats are present in early summer or fall; hence, the possibility of some vessel/marine mammal interaction is possible, although it is not anticipated that activities would occur sufficiently early to involve larger numbers of mammals migrating in the major eastern Chukchi spring- lead system. The proportion of the polar bear population that may occur either individually on pack ice or on isolated ice floes drifting into the vicinity of exploration activities and experience lethal effects is not likely to be significant. The reference in this comment (Brueggeman et al., 1990) has been added to Section IV.C.6. Response FWS-15 It should be noted that the base case is discussed in Section IV.C; Section II, to which this comment refers, contains only summaries of the several cases and thus omits the more detailed discussion in Section IV. Section IV.C.6 has been revised to address several of the site-specific concerns expressed in this comment. It is evident that much information concerning various aspects of the polar bear annual cycle remain to be collected; such studies would be most appropriately carried out by the FWS within its ongoing polar bear research program. Regarding the concern for pipeline locations (e.g., Fig. I[V-A-8), these locations are strictly hypothetical for purposes of discussing potential effects. If development occurs, a developmental EIS as well as a development plan will show planned pipeline locations; and the FWS will have ample opportunity FWS-3 to comment on both of these documents. Regarding potential indirect effects of locally decreased prey availability on walrus, or those effects that might occur as a result of ingestion of polluted prey, no substantiating evidence is cited to support the contention stated in the comment. Response FWS-16 It should be noted that the high case is discussed in Section IV.D; Section II, to which this comment refers, contains only summaries of the several cases and thus omits the more detailed discussion in Section IV. Response FWS-17 The differences in ITL No. 1 and NTL No. 89-1 are: (1) Information to Lessees (ITL’s) are designed to either (a) state MMS policy and practices that are carried out and enforced, (b) inform lessees about special concerns in or near the lease area, or (c) advise or inform lessees of the existing legal requirements of MMS and other Federal agencies; and (2) Notice to Lessees (NTL’s) are prepared for lessees and operators of Federal oil and gas leases in specific a OCS area. The NTL’s are prepared to advise lessees and operators of changes made to requirements because of changing conditions or changes brought about by judicial proceedings. The NTL’s are also used to provide clarification of the regulations. Therefore, the provisions of NTL 89-1 would apply to all lease activities resulting from this sale, and no additional protective language needs to be added to ITL No. 1. FWS-4 a) ~~ — > ~—— — —- — www : Ss United States Department of the Interior ; We have the following specific comments and concerns regarding the creatment of NATIONAL PARK SERVICE == cultural resources in the DEIS: P.O. BOX 37127 a | WASHINGTON, D.C. 20013-7127 1. MMS's responsibilities under the National Historic Preservation Act (NHPA), NPS Wm REPLY RAPER TO as amended, should be acknowledged and cited (Section 106 and 36 CFR 800). 4 L7617(774) DES 90/0019 2. In appendix G the potential for the occurrence of archaeological resources S$ in the sale 126 is cited as being low to moderate. Nevertheless, the EP 18 1990 Faperel ChAGl (wi pare Sf SELpULatLoA I (GagelII@6)abould bel prepared itor NCS Mr. George H. Allen tracts where archaeological and historic resources may exist. Jd 4 EIS Coordinator Minerals Management Service a Ipiutak Site National Historic Landmark at Point Hope and Birnick sice ] Alaska OCS Region National Historic Landmark at Barrow should be part of the discussion of NPS 949 East 36th onshore archaeological resources (III-66). National Historic Landmarks Anchorage, Alaska 99508-4302 should also be idencified in Figures III C-18 and III C-19. d Dear Mr. Allen: 4. Side scan sonar or other remote sensing data collected for the sale 126] area should be interpreted by a qualified archaeologist. The data could PS The National Park Service (NPS) reviewed the draft environmental impact statement show offshore locations of shipwrecks, aircraft or topographic features (DEIS) on proposed lease sale 126, Chukchi Sea. We fully appreciate with archaeological potential. | 6 acknowledgement of important archaeological resource concerns in Cape Krusenstern National Monument and Bering Land Bridge National Preserve. Neverthel, , as as: The potential for effects on archaeological resources (pages 1V-B-26, nT we expressed in our scoping letter of February 1989 (enclosed), our concerns also C-91, IV-D-42, and IV-H-17) assumes that submerged cultural resources have encompass the relatively pristine and extensive coastal resources of the areas. been destroyed by ice gouging and other marine processes. The maximum NPS Of additional note, Bering Land Bridge National Preserve is included in a current depth of ice gouging is two ers. Sites buried beneath that depth, such joint U.S.-U.S.S.R. effort to create an international park that would also as aircraft, shipwrecks, deeply stratified archaeological sites, caves, 7 include a portion of the Chokotskiy Peninsula. or similar features, should be intact. As currently presented in the DEIS, we are unable to find conditional or 6. On page IV-B-28 it is stated that "Personnel and equipment transported over cumulative probabilities for oil spill contact on the Land Segments of direct archaeological sites during clean-up treining runs could cause low effects interest to us, Land Segments 1-5 and 9-10. Ne ertheless, it is noted in on archaeological sites in land OSRA Land Segments 14-24...." This NPS appendix IV-J-14 and 15 that a large spill would be likely to move outside of determination needs to be fully discussed by indicating the number of the sale a to the beach area of Cape Krusenstern. The Becing Land Bridge personnel, types of equipment and thi ture of the training runs. The 8 National Preserve on the Seward Peninsula also has a high likelihood that oil locations of training runs should have the prior approval of the State would damage the beach. PS Historic Preservation Officer. 1 We think that the two national park a: should be described as environmentally affected environment of proposed leare sx well as the international project, msitive or special areas within the e 126. Moresver, we thick ic is We appreciate this opportunity to comment. Pl e contact Kheryn Klubnikin, Environmental Quality Division if you need more information or assistance regarding our comments and concerns. She can be reached at FTS 268-5126 or 907- to have further discussion and analysis of the oil spill contact 208-5126. potential as+aVluded to in Appendix IV. Response capabilities south of Point Hope in tha,event of the migration of a major spill into the area of the park Sincerely, units shouldyalso be discussed. The National Park Service is willing to work with the Minerals Management Servic: (MMS) to ensure that appropriate information regarding the park units is integrated into appropriate stipulations, such as stipulation 2 for the ———— —4 z identification of special areas or populations of biological concern, stipulation NPS "Denis P. Galvin 3 for orientation, stipulation 4 on the transport of hydrocarb: , and in the 2 jociate Director Information to Lessees (ITLs), such as numbers 1,2, and 8. Please contact NPS Planning and Development Alaska Regional Director Boyd Evison for further coordination of this effort at 907-257-2690. Enclosure Lacascnees eS ~~ National Park Service Response NPS-1 The conditional probabilities for oil spill contact and the combined probabilities for oil-spill occurrence and contact are <0.5 percent for Land Segments 1 through 5, 9, and 10. The OSRA numbers in Section IV.J.13 are incorrectly cited and the text has been modified to include the correct numbers. The note on Tables C- 4, C-5, C-6, C-10, C-11, C-12, C-14, C-15, C-18, C-19 has been modified to read: "All land/boundary segments having rows with all values <0.5 percent are not shown." Figures IV-A-4 and IV-A-5 have been modified to include the same note. Response capability south of Point Hope is discussed in Appendix L. Response NPS-2 The MMS contacted NPS to discuss any missing appropriate information. The discussion included potential MMS mitigating measures for Sale 126 and existing NPS concerns over the identification of special-interest areas and their locations in reference to the sale area. The MMS appreciates the concern and interest of NPS and will ensure that they are contacted at the Call for Information step in the OCS leasing process to identify all potential areas of special interest. Response NPS-3 The MMS Archaeological Resource Protection Program is conducted under the authority of several laws and regulatons, including the National Historic Preservation Act (NHPA), as amended (16 U.S.C. 470 et seq.). This authority is cited in Appendix G of this EIS. Response NPS-4 The text of Appendix G has been revised to include a list of those blocks on which the archaeological stipulation will be invoked for both prehistoric and historic resources. Response NPS-5 The text of Section III.C.4 has been revised to address this concern. Response NPS-6 Review of the sidescan-sonar data, acquired through the geohazards survey, will be required by a qualified marine archaeologist in conjunction with a geophysicist in the event that the archaeological resources stipulation is invoked; and an archaeological report is required. Response NPS-7 Most of the overlying sediments average 2 to 4 m in thickness. There are some areas north of Point Franklin and northwest of Icy Cape that are 10 to 12 m thick (thick enough to protect a shipwreck from 2-m-deep ice gouging). However, these areas are offshore beyond the 3-mile zone where, at most, two or three shipwrecks have been known to occur. Therefore, the possibility that shipwrecks are in that area of 10- to 12-m sediments is low. All of the other shipwrecks are within 3 miles of shore and onshore. The sediment level in nearshore areas is approximately 2 m. Here, the sediment thicknesses could not protect shipwrecks from ice gouging, and it is likely that shipwrecks or other cultural resources have been destroyed by ice gouging and other marine processes. In those areas of 10- to 12-m sediment thickness there could be prehistoric resources; the text in Sections IV.B.13, IV.C.13, and IV.D.13 has been revised to incorporate this possibility. Section IV.H.1.i of the cumulative case was not revised because activities other than OCS are summarized and refer generally to all cultural resources; thus, specific locations that do not contribute significantly to the NPS-1 overall cumulative effects, such as the two places of 10- to 12-m sediments, are not mentioned in detail. R Mn ~ There is no certainty that cleanup training will be undertaken. The MMS can only estimate the number of personnel and types of equipment involved based on cleanup of past spills and can only speculate on the nature of the training. Training locations will depend on decisions by multiple agencies (including the State Historic Preservation Officer) and involved oil industry. The assumption that OSRA Land Segments 14 through 24 would be affected means only that training could be done in the vicinity of lease-sale-area shores. Training could just as well be done elsewhere in a location similar to the Chukchi Sea shore. Such location would have to be selected by the above-mentioned parties. Therefore, it is not practical to discuss details in this EIS. NPS-2 ee a a a SS 3S eS Sa oe Se — a United States Re 10 Alaska, Environmental Protection 20S Avenue kao | fy q Washington SEPA nepLy TO SEP 04 1924 armor: WD-136 4 3CEIV. Barry Williamson, Director SEP 101%; Minerals Management Service a Department of Interior ML DIRECTOR, AL Washington, D.C. 20240 eaals Managemen’ ANCHORAGE, AL ...= Dear Mr. Williamson: The Environmental Protection Agency (EPA) has reviewed the draft environmental impact statement (EIS) for the Alaska Outer Continental Shelf (OCS) Chukchi Sea Oil and Gas Lease Sale 126. Our review was conducted in accordance with the National Environmental Policy Act (NEPA) and our responsibilities under Section 309 of the Clean Air Act. EPA requested to be a cooperating agency in the preparation of the EIS. EPA and the Minerals Management Service (MMS) have agreed that EPA's role as a cooperating agency would involve the preparation of an appendix for the EIS dealing with the fate and effects of deliberate exploratory phase oil and gas drilling discharges. In anticipation of the promulgation of new source performance standards (NSPS), EPA requested to be a cooperating agency because we will have a NEPA compliance responsibility for any new source National Pollutant Discharge Elimination System (NPDES) permits issued for oil and gas drilling discharges in accordance with Section 511(c)(1) of the Clean Water Act (CWA). This Section of the CWA indicates that EPA must comply with NEPA when issuing an NPDES permit for the discharge of any pollutant by a new source. Final promulgation of effluent guidelines and NSPS for the Offshore Subcategory of the Oil and Gas Extraction Point Source Category are expected by the 1991 lease sale date. The NPDES permit that EPA Region 10 will develop for this particular lease sale will regulate sources that are subject to the NSPS. As a cooperating agency, EPA plans to adopt the final EIS for this sale to meet our NEPA compliance responsibility for our NPDES permit. This should prevent a duplication of effort by EPA and MMS and prevent undue delays in the issuance of our NPDES permit relative to this lease sale. This draft EIS presents a comprehensive evaluation of the potential effects that could result from this lease sale. Overall, the draft EIS reflects the current state of knowledge about the physical, chemical, and biological characteristics of the Chukchi Sea planning basin. However, we have several concerns that are summarized in the paragraphs that follow. These concerns are fully described in the enclosed detailed review comments. We are providing these comments in an effort to improve the information presented in the draft EIS and to clarify issues that are important for making decisions on the leasing options for the proposed lease sale. 2 EPA continues to be concerned that the proposed action does not incorporate the protective stipulations described in the draft EIS. We object to the proposed leasing without inclusion of protective environmental stipulations until after the EIS process is complete. MMS concludes that the proposed stipulations do not represent meaningful mitigation. The majority of the stipulations provide no means of reducing the potential adverse effects. Many of the proposed stipulations and Information to Lessees (ITLs) presented in the draft EIS have been included in a number of past Alaska OCS lease sales. The discussions of the effectiveness of these stipulations in mitigating adverse effects could be improved if they provided a historical perspective on how well these mitigating measures have actually performed in the past. PA 1 Additional explanation of how MMS analyzes the effects from the various activities associated with this lease sale is needed. Some species found in the Chukchi Sea could encounter a combination of lease sale activities or repeatedly encounter the same activity, which represents a variation on cumulative effects. The definition for cumulative impacts indicates there is an additive component to the evaluation process. An explanation of how MMS incorporates this additive process for assessing effects would provide useful information. NU > {Led With regard to the selection of a preferred alternative, EPA strongly supports selection of Alternative IV - Point Lay Deferral Alternative. This alternative provides protection to marine mammal habitat (migratory pathways), “additional protection for important coastal habitats, and an additional protective buffer for offshore subsistence- harvest areas’. This deferral alternative provides localized protection to endangered whale migration paths and feeding areas. Among the leasing alternatives, Alternative IV is the environmentally preferable alternative since, on a relative basis, it minimizes the adverse effects from oil and gas activities. In our scoping comments for Lease Sale 109 in the Chukchi Sea, EPA requested that the sensitive habitats protected by this alternative should be considered for deferral. Deferral of the 501 blocks in this alternative does not reduce the probability of finding hydrocarbon resources in the remainder of the sale area and deferring the blocks does not reduce MMS estimates of hydrocarbon resources for the sale area. In conclusion, the draft EIS has identified environmental consequences associated with the proposed action. We believe that adverse effects could be reduced by implementation of the Point Lay deferral alternative in conjunction with implementation of appropriate mitigation. Due to uncertainty about whether stipulations will be included in the sale, uncertainty about the effectiveness of mitigating stipulations, and the potential long-term disturbance effects on endangered bowhead whales if leasing occurs anywhere in the spring migration area, we are rating the proposed action EO-2 (Environmental Objections-insutficient Information). The insufficient information rating is based on the need for additional information or clarification about; the effectiveness of stipulations to lessen impacts, oil transportation assumptions, wetland impacts, the analysis of effects to endangered bowhead whales, 3 and how the analysis adds the effects from exposure to several effect producing activities. Thank you for the opportunity to review this draft EIS. If you have any questions about these comments, you may contact Sally Brough, in the Environmental Review Section at FTS 399-4012. Sincerely, Chi Bvt Robert S. Burd Director, Water Division Enclosure cc: MMS Alaska OCS Region . i ll ll ella. acelin, lll, _ 2 lala Menta. _ WATER DIVISION @o02z/006 09/12/90 «12:28 FAI 206 442 0165 U.S. ENVIRONMENTAL PROTECTION AGENCY CHUKCHI SEA OIL AND GAS LEASE SALE 126 DRAFT ENVIRONMENTAL IMPACT STATEMENT DETAILED REVIEW COMMENTS Introduction As noted in our letter we have a number of concems about the proposed action. We offer the following comments in an effort to develop a project with a minimum of delay and environmental harm. Some of the issues that we are commenting on in these detailed review comments we also included in our comments on the draft ElSs for the Beaufort Sea Lease Sale 124 and the Navarin Basin Lease Sale 107. Since we have not had an opportunity to see the responses to our Sale 124 and Sale 107 comments, we are restating the issues that are common to this draft EIS and the Sale 124 and Sale 107 draft ElSs. Our objections with the action are focused on the selection of a preferred alternative, clarification on the effectiveness of many stipulations and Information to Lessees (ITLs), the lack of commitrient to Protective stipulations, effects on wetlands, the potential need for causeways, and the combined effects of activities associated with this lease sale. Our concems are outlined below. Stipulations The draft EIS presents and discusses several lease sale stipulations that are designed to mitigate potential adverse environmental The draft EIS states that the decision to include any or all of these mitigation measures will be made at the final Notice of Sale stage in the overall leasing process. The Notice of Sale occurs several steps after the final EIS has been reviewed. Thus, uncertainty exists about whether mitigation measures will be included in the proposed action. Our major concern regarding the stipulations is that unrestricted leasing could occur in sensitive offshore habitats. Many of these sensitive habitats Could be protected either through deletion (deferral) of those areas from the sale or through the Inclusion of protective stipulations in the terms of the leases. The deferral and mitigation decisions will not be made during this EIS process for this lease sale. EP, By bas covers ox kosnen [tte are concord ter otte cola moon hocions action less severe or intense. We are concerned that of the eight mitigating stipulations Proposed for Inclusion in the terms of the lease sale, the effectiveness of six of the Stipulations would: "not likely change the overall effect levels", ‘would be minimally effective’, “would not be expected to reduce the effects, ar “would reckice emects somnatier bot ris enough to change the levels of effects" without mitigation. We are concerned that the MMS decision process does not provide a commitment to until after the EIS process is completed. in Ga Gorn ct te tone con tet decides to include all of the stipulations in terms lease Stipulations do not represent true mitigation since according to the draft EIS they will not lessen the effects from the proposed action. EP Many of the proposed stipulations have been included in past Beaufort Sea and Chukchi Sea planning areas. However, the discussion of the effectiveness of many of the stipulations does not provide a historical perspective for how well they have lease sales in the fi 09/12/90 = 12:30 @Qo003/006 Par 206 442 0165 WATER DIVISION worked In the past. Does a “track record" exist for stipulations that have been included in past lease sales, to use as a basis for the analysis of the effectiveness of these mitigating measures? For example, how effective has the Orientation Program been in making the unique environmental, social, and cultural values since the last Chukchi lease sale? Has into this analysis of effects? How often is the mechanism Incorporated frovidod by stpaation Nove been used to identi important or unique biological populations? We suggest that Stipulation No. 5 should be extended to all blocks in the proposed sale area rather than only those in the spring lead migration pathway.. This would provide useful information in several ways. tt would increase the effectiveness of the stipulation. The ‘The draft EIS states that the effects of causeways are not analyzed In this EIS because causeways are not part of the development and production scenario. The draft EIS assumes that oll will be brought to shore by pipeline rather than moving hydrocarbons by tanker. The draft EIS indicates that bring oil to shore, must be specifically designed to withstand sea ice and cther hazards. The draft EIS states that subsea permafrost * presents @ set of engineering challenges to potential development” and that “the presence and distribution of subsea permafrost is largely unknown" in the area. Therefore, to suggest that causeways are not part of the development scenario, at least in shallow water where pipelines come ashore, may not be prudent. The final EIS should address the impacts of a Causeway used to bring ofl ashore. The draft EIS assumption that subsea pipelines will be used to bring oil ashore is contrary to industry's assertion that the success of a subsea pipeline, especially in areas of unknown is uncertain from both an operational and engineering perspective. Industry maintains that the cost involved in the construction of a subsea pipeline vs a causeway, severely cuts into the profit margin of a developing field. In addition, industry state that detection of leaks under ice and in open water, the ability to respond and mitigate environmental damage, and the cost of excavation and repair render subsea pipelines economically infeasible. Pile supported are viewed as having increased capitol Costs for hardware and construction, and maintenance costs that would severely cut Into the profit margin, and increased environmental risks from spills. Based on EPA's ran lgarcia lethal art assumption be optimistic, The EIS should present new information regardin, engineoring fostbilty and the cost of subsea pipelines that can account for using thre e assumption as a basis for the analysis of environmental consequences. EPA EPA on EPA 00/12/90 12:31 Pal 206 442 0165 WATER DIVISION @oos/o0e Endangered Species We have several concems about the analysis of effects on endangered bowhead whales. Our primary concem is the potential for effects from noise and disturbance in the spring migration corridor. The Biological Opinion for Lease Sale 108 concluded that in available to avoid or minimize jeopardy to for ice caver. The EPA would likely be different than when no ice Is present. 9 their spring and fall migrations their behavior be different from open water conditions. Since bowheads travel in and under ice and sensitivities to noise and disturbance Wetlands The draft EIS does not evaluate the effects of the overland pipeline, associated access roads, and additional pumping facilities on wetlands. The draft EIS has no general discussion of the type of terrain that would be crossed by the pipeline before it connects with the Trans- Alaska Pipeline. If the ElS discusses the impacts of of ofl on caribou andland EPA use Classification, then it should also discuss the effects to special aquatic sites—wetiands. 10 The discussion should include information on where and how the fill would be obtained. In light of the recent interest generated by the Memorandum of Agreement between the Corps of Engineers and EPA, wetlands are an important consideration. Conditional Probabilities Past OCS lease sale ElSs have stated that conditional ies are “useful in Identifying those sites (launch points) that pose the highest risks to specific environmental resources if a spill ocours.". The conditional probabilities show that the launch points in the EPA 200 meter Isobath deferral area pose high risk to the biological resource areas along the shelforeak and the St, Matthew Polynya. Were these conditional probabilities used to help 11 09/12/90 123k PAK 206 442 0105 WATER DIVISION @oos/ooe 4 EB determine the tracts to be leased or deferred and the stipulations that could minimize Poe mane scene oes ? Cumulative Effects reasonably foreseeable future actions...“ This implies that there is an additive component in the effects evaluation process. It would seem reasonable to apply this additive concept to the cumulative effects assessment as well as the assessment of effects resulting from exposure to a combination of activities associated with this lease sale. We are concerned that the draft EIS evaluation of impacts multiple effect producing i iu activity. ” provide analytical approach used by MMS technical staff to determine the levels of impact and the “incremental 7) This definition |12 ‘States that the cumulative impact Is ‘the incremental impact of the action when added to other contribution". The analysis of the ‘incremental contribution" should apply to Tesource categories are low and very low? ror | | | | 09/12/00 = 12:32 Pak 206 442 0165 WATER DIVISION @oos/oos Selction of a Preferred Alternative EPA strongly supports the selction of Altemative IV - the Point Lay Deferral Alternative as the preferred alternative for several reasons. This alternative removes the remainder of the bowhead spring migration pathway from the lease sale area. Deferral of the 501 blocks in estimated to be found in the lease sale area. The biological opinion, for the last Chukchi Sea lease sale, concluded that a likelihood of exists if development/production occurs in the spring lead system. The proposed for this lease sale conciude that the Soines aor feccnaenane in lessening the potential adverse effects on whales or increasing our understanding of their behavioral response to industrial noise and disturbance. The Point Lay Alternative represents a meaningful mitigation measure that lessens the impacts to endangered bowhead and gray whales, other marine mammals, and important coastal resources. i — Environmental Protection Agency Response EPA-1 As indicated in Section ILF, all laws, regulations, and orders that provide mitigation are considered part of the proposal. The mitigating effect of these measures has been factored into the environmental-effects analysis. The potential stipulations and information to lessees (ITL’s) listed and discussed in the DEIS are evaluated in the discussions of the effectiveness of stipulations or ITL’s. It is MMS policy that decisions on whether or not to include a potential stipulation or ITL or to defer blocks from the proposed-lease-sale area are made after the FEIS has been published. The potential mitigating measures are not assumed to be in place for the purpose of analysis because this could distort and potentially would reduce the levels of effect that could result from the lease sale. Although there is no formal method for measuring the effectiveness of the potential mitigating measures outlined in the Sale 126 DEIS, support for including these measures in the lease sale has been received from some of those individuals, organizations, and governmental agencies--including EPA--that have commented on the Sale 126 DEIS as well as the DEIS’s for past lease sales. This support indicates that the measures are perceived as being effective. The Orientation Programs developed to date have been excellent, particularly those created more recently, and are rigorously presented to all workers. Response EPA-2 See Response EPA-12. Response EPA-3 As indicated in Section II.F, all laws, regulations, and orders that provide mitigation are considered part of the proposal. The mitigating effect of these measures has been factored into the environmental-effects analysis. The potential stipulations and information to lessees (ITL’s) listed and discussed in the DEIS are evaluated in the discussions of the effectiveness of stipulations or ITL’s. It is DOI policy that decisions on whether or not to include a potential stipulation or ITL or to defer blocks from the proposed-lease-sale area are made after the FEIS has been published. The potential mitigating measures are not assumed to be in place for the purpose of analysis because this could distort and potentially would reduce the levels of effect that could result from the lease sale. If such measures are adopted in whole or in part, their intention is to reduce environmental effects. Their effectiveness in achieving this may not be measurable, but their simple existence is a positive step in the right direction ia all cases. Response EPA-4 Although there is no formal method for measuring the effectiveness of the potential mitigating measures outlined in the Sale 126 DEIS, support for including these measures in the lease sale has been received from some of those individuals, organizations, and governmental agencies--including EPA--that have commented on the Sale 126 DEIS as well as the DEIS’s for past lease sales. This support indicates that the measures are perceived as being effective. There is no specific information available on how effective the Orientation Program has been in making petroleum industry personnel “aware of the unique environmental, social, and cultural values of local residents and their environment" or how successful this stipulation has been in protecting environmental resources and cultural values. However, the Orientation Programs developed to date have been excellent, particularly those created more recently, and are rigorously presented to all workers. EPA-1 Response EPA-5 The MMS believes it unnecessary to expand potential Stipulation No. 5 to include leases in the fall bowhead whale migration area of the Chukchi Sea. The Sale 109 Biological Opinion did not include conservation recommendations for monitoring the fall migration, nor did the Arctic Region Biological Opinion make a recommendation for monitoring the fall migration in the Chukchi Sea. The monitoring stipulation adopted for Sale 109 is limited to the spring migration only. Unlike the fall migration in the Beaufort Sea, the fall migration through the Chukchi Sea does not follow a defined corridor. Due to the dispersed nature of the migration and the limited scope of exploratory-drilling activity, we do not believe monitoring would be appropriate or necessary. Response EPA-6 Causeways are not part of the development and production scenario because all prospects included in the base case are more than 80 km from shore and in waters deeper than 30 m. Therefore, causeways are not a practical consideration for the development scenario. The EIS assumes that buried offshore pipelines will bring oil ashore. Engineering studies indicate that a key consideration in the design of buried offshore pipelines in an arctic environment is to determine the optimum burial depths that maximize the pipeline’s safety from rupture by ice gouging and minimize costs. The problem of ice scour has been investigated to considerable extent, and burial depths that will minimize the probability of scour are now specified and known. Continuous monitoring techniques will enable the operators of such pipelines to be forewarned of potential scour problems and to take corrective actions. Even if a discovery is made in the near future in the Chukchi Sea, production will not occur for 12 to 15 years. With such a lead period, production and transportation problems can be adequately resolved. Response EPA-7 As shown in the EIS analysis, industrial noise has only a local, short-term effect on whales that actually respond to it (Richardson et al., 1985, 1990; Malme et al., 1983; 1984, 1985, 1986; Ljungblad et al., 1985; Wartzok et al., 1989). This combined with the assumed "no industrial activity during the spring migration" is why we have projected as the most likely case that industrial activities are not likely to jeopardize the continued existence of the species. It is possible that there could be long-term adverse effects from a production operation in the spring lead system, so the conservative approach has been adopted. Response EPA-8 As indicated in the EIS analysis, crude oil and industrial noise associated with Sale 126 are likely to have no significant effects on whale populations. Hence, there is little need of mitigation. While it is true that the potential stipulation would not add to the body of information for spring-migrating whales, it is also true that there is already enough information to determine what the likely effect of spring operations would be, if they occurred in the lead system. In addition, the stipulation would provide information on the effects of operations on fall-migrating bowheads, if operations continued during that period. Response EPA-9 There are no known studies pertaining to baleen whales that show industrial noise to have had anything other than local, short-term effects on whales. Consequently, while long-term effects are possible, it is much more probable that they would not occur and that habituation would take place, as occurs in response to other nonthreatening stimuli. Ongoing studies in the spring-lead system indicate that the effects of industrial noise there are similar to, or even less than, those anywhere else. For example, Richardson et al. (1990) states "Our preliminary impression is that bowheads are no more sensitive to fixed wing aircraft like the Twin Otter during the spring migration through pack ice than they are in the late summer in largely open waters." EPA-2 — in a a Response EPA-10 Wetlands are an important consideration in evaluating the effects of the onshore-pipeline scenario. Wetlands has been included as a separate resource category in the Section IV analyses (Secs. IV.B.15, IV.C.15, IV.D.15, IV.G.15, and IV.H.1.k). The text of the base-case scenario (Sec. II.B.2.a) has also been amended to include information on where and how gravel-fill material would be obtained and a general discussion of the type of terrain crossed by the pipeline. Response EPA-11 Many factors go into the analysis to determine the tracts to be leased and the stipulations that could minimize potential adverse effects. Conditional probabilities can be one of these factors, inasmuch as they are calculated from the path and destinations of an oil-spill trajectory, assuming an oil spill occurs at a given point in space. Conditional probabilities, therefore, are conditioned on the presence and discharge of oil from specified "launch points." Volume of oil or number of spills are not factors generating the results of conditional probabilities. The path (trajectory) and destinations of an oil slick are determined more by oceanographic and seasonal factors such as currents, wind patterns, etc. Launch points are distributed as uniformly as possible within the planning area as a means of determining areas of relative vulnerability to oil- spill effects. By this means, the results of modeling spill trajectories and calculating conditional spill probabilities can provide useful data for delineating seaward and coastal areas most vulnerable to oil-spill effects. Response EPA-12 In the EIS, the approach is to use a systematic method of examining the individual potential effects on a species or species group from each effect-producing activity (oil spills, noise/disturbance, drilling discharges, etc.) and then to examine the potential effects from these activities in the aggregate. With this method, the conclusion for any species or species group can be no lower than the highest rating from any of the effects produced by any individual effect-producing activity. The variety of effect-producing activities is further considered in the oil-spill-risk and cumulative-case analyses for each resource. Most effect-producing activities are short-term, localized, and usually not additive; therefore, they are not working together. The probability of any two effects occurring at the same time, at the same place, and to the same individuals in the population are extremely remote. Also, not all the species or species groups are going to be affected by all the projects listed for the cumulative case. The approach, per se, that the analysts use in analyzing the data is of lesser importance than is their consideration of relevant scientific data and other information in their analyses. Therefore, MMS does not believe it necessary to describe the analytical approaches used by the analysts. The data and information used to analyze the potential environmental effects of petroleum activities in the Chukchi Sea Planning Area are discussed and cited in the EIS. The review process should scrutinize this data and information--and the conclusions--and not analytical approaches. As you suggest, the cumulative-effects analysis of marine and coastal birds and the analysis of marine mammals does factor in additively the combination of effects of oil spills; noise from aircraft, boats, and drilling activities; and habitat alteration from various potential development projects on the North Slope and in the Beaufort and Chukchi Seas. Response EPA-13 Based on a review of Section IV analyses and related sections, the very high effect on the economy for the base case has been changed to a high effect in the FEIS. However, the conclusion of effects on the economy, subsistence-harvest patterns, and selected species can be different and still consistent. The analysis and conclusions of effects on the economy of the NSB in Section IV draw, in part, from the analysis and EPA-3 conclusions of effects on subsistence-harvest patterns--but not from endangered and threatened species. For example, the conclusion for the potential effect of oil spills (and other factors) on bowhead whales is low. However, the potential effect of an oil spill on subsistence-harvest patterns is high for Wainwright, in part because pulling whales up through oiled waters would result in an unusable whale. The high effect on subsistence-harvest patterns translates to a high effect on the economy because of the potential unavailability of an important resource for a significant proportion of households. The bowhead whale is an important part of the economy for Wainwright households. By this process of working through different components of the environment, the conclusion of high effects on subsistence-harvest patterns translated to a very high effect on the economy, as reflected in the DEIS. EPA-4 See Ul MARINE MAMMAL COMMISSION 1825 CONNECTICUT AVENUE, N.W. #512 WASHINGTON, DC 20009 10 September 1990 Mr. Alan D. Powers Regional Director, Alaska Region Minerals Management Service 949 East 36th Avenue Anchorage, Alaska 99508-4302 Dear Mr. Powers: By letter of 6 July 1990, the Marine Mammal Commission received a request to send you comments on the Draft Environmental Impact Statement for the proposed August 1991 Chukchi Sea Outer Continental Shelf Oil and Gas Lease Sale (Sale 126). Ti Marine Mammal Commission, in consultation with its Committ. of Scientific Advisors on Marine Mammals, has reviewed the document and has the following comments and recommendations on the information and assessments in the document bearing on marine mammals. General Comments The Draft Environmental Impact Statement (DEIS) assesses possible effects of a proposed action to lease up to 4,319 blocks (approximately 23.68 million acres) of submerged lands in the Chukchi Sea for the purpose of oil and gas exploration and development. The 1 area is located 3.5 to 200 miles off northwest Alaska and is scheduled tentatively for August 1991. Possible effects of exploration and development activities associated with the proposed sale are assessed assuming a low, base (i.e., expected), and high level of petroleum resource discovery. Effects also are considered for a no sale alternative, ad Y e alternative, and a track deferral alternative. Among other things, possible effects on four species of endangered whales, polar bears, pinnipeds, walrus, and belukha whales are considered. With respect to endangered whales, the DEIS concludes that bowhead whales and gray whal. are the species most likely to be affected. Under all leasing alternatives and resource discovery scenarios, the DEIS concludes impacts on these species likely would be very low (i.e., no discernible population decline, sublethal effects to some individuals, and recovery to pre- activity conditions within one year). For reasons noted below, we believe that the DEIS underestimates possible effects on bowhead whales. 2 The DEIS indicates that fin whales and humpback whales also occur in the sale area. However, because they are present only rarely, no significant effects on these species are expected. pursuant to section 7 of the Endangered Species Act, the Service asked the National Marine Fisheries Service for confirmation that formal consultations on possible effects of the proposed sale on endangered species should focus on bowhead and gray whales. Based on copies of correspondence in Appendix D, the National Marine Fisheries Service replied affirmatively on 27 November 1989. Since that time, Steller sea lions have been listed as threatened on an emergency basis. Although the species may not occur in the sale area, transportation of oil from the sale area may affect this species or habitat critical to its survival. Therefore, if it has not already done so, the Minerals Management Service should contact the National Marine Fisheries Service to ask if consultations should be expanded to consider this species. In preparation for this sale, the DEIS indicates that, M MC 1 Regarding non-endangered marine mammals, the DEIS concludes that, for all leasing alternatives and resource development scenarios, impacts would be low (i.e., there would be no discern- ible population decline, no lethal effects, some individuals will experience sublethal effects, and recovery to pre-activity conditions within one to three years). The DEIS does not address the possibility of polar bears being attracted to offshore facilities and being killed or injured by operating equipment, by consuming toxic supplies, or by being shot to protect workers. MMC As discussed below, the DEIS appears to underestimate possible effects on polar bears and it should be revised to indicate that |2 effects could well range from very low to moderate levels. A number of potential stipulations and information to notices to reduce possible impacts on marine mammals and wildlife are described in the DEIS. These mitigation measures would be helpful and we recommend that they be modified as noted below and adopted as part of the proposed action. We also recommend that two additional mitigation measures be included. The first would require lessees to develop and implement polar bear interaction plans to: a) minimize the likelihood of interactions between bears and offshore workers, equipment, and supplies; and b) minimize adverse effects on bears and workers should any interactions occur. This recommended measure is discussed in greater detail in the enclosed letter and discussion paper sent to the Fish and Wildlife Service on 27 June 1990. MMC The second is a seasonal drilling restriction as was 7 recommended in the scoping process for this sale by the North Slope Borough and the State of Alaska. In this regard, we note MMC that related regulations recently were published by the National Marine Fisheries Service concerning exploration activities in the 3 Chukchi Sea and Beaufort Sea under section 101(a)(5) of the Marine Mammal Protection Act. The regulations prohibit explora- tion activities from incidentally taking any marine mammals in the bowhead whale migratory corridor during the species' spring migration. Because of uncertainties noted below, we believe such a measure is appropriate and should be included as a mitigation measure for any leasing action except the Point Lay Deferral Alternative, in which case the restriction would be moot. Specific Comments 3; This paragraph refers to Table S-1 for a summary of possible effects likely to occur as a result of the proposed lease sale and alternative actions. The Table should be expanded to include possible effects on walrus. Also, for reasons noted below, the estimate of possible effects on polar bears (projected to be low) seems to be unde: timated and should be revised. In addition, thi stimate app: inconsistent with previous Minerals Management rvice estimat That cumulativi fects on polar bears from this sale and other activiti are estimated to be low in thi: EIS, but they are projected to be moderate in the DEIS rele d earlier this year for the Beaufort Sea Sale (Sale 124) immediately east of the Chukchi Sea planning area. Page I-3, Fourth Complete Paragraph: This paragraph notes that studies and Information Transfer Meetings conducted by the Service's OCS Environmental Studi Program are an integral part of preparing Environmental Impact Statements. It ref to Appendix F for a more complete di ssion of the Studies Program. The Marine Mammal Commission agrees that the Studies Program is vitally important for preparing Environmental Impact Statements. It also is important for verifying predicted effects and providing lease managers with information and analyses for making informed management decisions after lease sales. This paragraph and Appendix F are appropriate and very helpful in describing the Program's role in the: matters. Because of its importance in assuring that necessary studies will be identified in a timely manner, an additional point which should be described eith: this section or in the Appendix is the pl. ing pro Program priorities are periodically re: ed and Page I-4, Endangered Species Consultation: This section notes that the Minerals Management Service initiated consultations with the National Marine Fisheries Service pursuant to section 7 of the Endangered Species Act to assess the possible effects of the proposed sale on endangered and threatened species. The section MC notes that the two services have confirmed the list of species to be addressed during the consultations, but that a Biological 1 Qpinion had not been completed in time for inclusion in the DEIS. atta, it ce el ee an cell ei. MMC 4 n= a Oz o N= QO ee ee Se en 4 Copies of the supporting correspondence in Appendix D indicate that only gray whales and bowhead whales are to be considered. Since the date of the correspondence in Appendix D, the National Marine Fisheri Service has listed Steller sea lions as threatened on an emergency basis. Although the Chukchi leasing area is north of the usual range of Steller sea lions, transportation of oil from the lease area may affect this species or habitat critical to its survival. Therefore, if the Minerals Management Service has not already done so, the Marine Mammal Commission recommends that it contact the National Marine Fisheries Service to determine whether Steller sea lions should be considered during the consultation process for Sale 126. = -= a Elsewhere in the DEIS, reference is made to information and analyses in an Arctic Regional Biological Opinion prepared by the National Marine Fisheries Service. That Opinion should be included in Appendix D. Page I-5, Lease Operations: This paragraph briefly describes responsibilities of the Servic Field Operatio: other agencies in managing le operations after a le Because of its importance in ensuring that the lease manager has accurate up-to-date information to meet his responsibilities, the paragraph should be expanded to note the role of the Service's Environmental Studies program in meeting the Service's legal mandate to monitor changes in human, marine, and coastal environments during and after oil exploration and development. In this regard, the section should refer readers to the discussion of the Program in Appendix F. This section notes that a recommendation by the North Slope Borough and the State of Alaska for a seasonal restriction on drilling, as well as seismic operations and tug and icebreaker operations, to protect migrating bowhead whales in the spring will not be considered a potential mitigating measure. The reasons cited for this decision are that "...the Arctic Region Biological Opinion does not find threat from oil spills to exist for bowhead whales during the exploration period"; " analyses of other stipulations...suggest...the bulk of the bowhead spring migration would not occur within the sale area"; ..."the migration likely would be finished in the Chukchi Sea by the time exploration activities started"; and ..."no bowhead whale subsistence hunting areas exist...within the proposed 126 sale area." a Ee The rationale for rejecting further consideration of the recommended seasonal drilling restriction measure is incomplete and somewhat misleading. For example, while it is true that the lease area constitutes only a small segment of the bowhead whale migratory corridor, the length of corridor affected is relatively unimportant. Of greater importance is the proportion of the bowhead whale population passing through or immediately adjacent to the area. As noted elsewhere in the DEIS, the majority of the bowhead whale population apparently does pass through or immediately adjacent to the proposed lease area. In addition, the fact that the migration may well be finished by the time exploration activities begin does not eliminate concern for those instances when exploration activities commence before migrating animal; passed the area. Rather, if this is the e, it would st that restricting drilling until after the whales have passed would provide a useful measure of protection which would pose little, if any, inconvenience to lessees. The analysis in this section also fails to consider possible effects other than those due to an oil spill. In the Beaufort Sea leasing area, seasonal drilling restrictions have been considered important for preventing noise and other t: disturbance that could alter the path of migrating bowhead whales, and, among other things, affect their availability to Eskimo subsistence whalers. Similar effects seem possible from activities in the Chukchi Sea leasing a .» That is, although traditional subsistence hunting grounds may not occur within the Chukchi leasing area, slight shifts in migratory routes due to disturbance as whales pass through the Chukchi Sea leasing area may alter the migration route and affect the availability of MMC whales for subsistence purposes east of the sale area. 4 The decision not to include a seasonal drilling restriction also appears to be inconsistent with analyses and actions taken by the National Marine Fisheries Service to protect whales from seasonal exploration activities in the spring lead system. That is, on 18 July 1990, the Service published a final rule pursuant to section 101(a)(5) of the Marine Mammal Protection Act regarding the allowable take of marine mammals in the spring migratory corridor incidental to exploration for oil and gas in the Chukchi Sea and the Beaufort Sea over the next five years. The regulation prohibits the incidental take of marine mammals by the oil and industry in the spring lead system used by bowhead whal intil such time that it is determined that the whales have passed through leads off Point Barrow and the spring subsistence hunt for bowhead whales has been completed in all villages. This section should be expanded to provide a more complete sonal drilling restriction would not provide a useful measure for avoiding possible adverse impacts. It should include an explanation of the basis for concluding that migrating bowhead whales whose course is deflected due to exploration activity in the leasing area would return to the same track line they otherwise would have taken by the time they reach subsistence whaling areas located east of the leasing area. It also should indicate how the validity of this conclusion was ascertained. Alternatively, 6 the recommended measure should be included as a mitigating measure. = = : This section notes that the effects of the base case scenario on polar bears and walrus are not likely to exceed low levels. Analyses in the DEIS do not consider a number of factors that may increase the likelihood of adverse effects on these species. For example, polar bears may be attracted to work areas by smells, noise, or lights and be killed or injured as a r lt of interactions with workers or equipment; wide-ranging movements by foraging bears and walrus may bring substantial numbers of both species into contact with spilled oil or offshore activities even though overall densities in the lease sale area may be low; and oil spill cleanup and monitoring, as well as spilled oil itself, may affect both species indirectly as well as directly. Such factor: in addition to those mentioned in the DEIS, suggest that e cts on these species could reach or exceed moderate levels (j.e., a portion of their respective populations would experience changes in abundance and/or distribution whose recovery would require one generation or more). Assessments upon which these conclusions are based should be reexamined in consultation with experts in the Fish and Wildlife Service and the Alaska Department of Fish and Game and the conclusions modified accordingly. This comment also applies to assessments for these species under the high case scenario. Page II-21, Second Complete Paragraph: The third sentence of this paragraph states that "since the sale area is believed to be outside the spring lead-system, most bowhead whales are not likely to encounter noise associated with production operations." The premise of this conclusion is not consistent with information presented elsewhere in the DEIS. Figure III-B-5 indicates that the southeast portion of the sale area includes most of the migratory corridor off Point Lay through which bowhead whales pass in the spring. Production facilities in this area therefore could expose most of the bowhead whale population to noise. Indeed, the rationale for the Point Lay Deferral Alternative is, in part, to exclude portions of the bowhead migratory corridor. The third sentence of the paragraph should be deleted. = ; This section concludes that the deferral of nearshore tracks from the proposed lease sale would be inconsequential in reducing risks to nearshore habitats of pinnipeds and polar bears or the probability of contact by an oil spill. Available information does not appear to be sufficient to justify this conclusion for polar bears. For example, some polar bear denning has been documented in nearshore areas along the Chukchi Sea, however, the extent to which polar bears den in this area is unknown. If the area is an important polar bear denning area, this deferral B= QO N= a oz Qa a | Meee eee MMC 10 7 alternative could reduce the risk of bears avoiding the area or causing females to abandon dens before their cubs are mature enough to survive. It also could prevent some bears from being killed or injured due to interactions with people, equipment, supplies, and/or oil spills. In addition, by excluding development in nearshore areas MMC adjacent to the State's three-mile jurisdictional boundary, it substantially reduces the risk that the expected oil spills will 10 originate in the deferred area. Therefore, it follows that spills expected to occur under the proposed action would be much less likely to contact the deferral area if petroleum development is excluded from the area. The referenced statement should be deleted and replaced with a statement indicating that the potential significance of the deferral alternative for protecting polar bears is uncertain because of incomplete understanding of the area's importance for denning, feeding, and other purposes. iS. 3 A critical factor in deciding whether to proceed with the proposed action is confidence that lease managers will have accurate, up-to-date environmental information with which to make informed lease management decisions. To better reflect this point, the beginning of the second sentence of this section should be expanded to read something like the MMC following: 11 “Examples include the OCS Lands Act, which grants broad authority to the Secretary of the Interior to control lease operations and mandates postlease environmental monitoring to help detect and determine how to respond to unforseen impacts on human, marine, and coastal environments;...". = = 3 This section includes a number of potential stipulations and Notices to Lessees that would improve protection of marine mammals and other wildlife. The Commission recommends that they be modified, as discussed below, and adopted as part of each leasing alternative. recommends that the Minerals Management Service include an additional mitigation measure requiring lessees to prepare and implement polar bear interaction plans. The purpose of these plans is to ensure that lease operators identify and take steps to avoid or minimize encounters with bears and, in the event that encounters do occur, to respond in ways which will minimize possible adverse impacts on both bears and people. The purpose and scope of these plans is discussed in greater detail in the attached letter and discussion paper sent by the Commission to As indicated earlier, the Marine Mammal Commission also ] M MC 3 8 the Director of the Fish and Wildlife Service on 27 June 1990. Implementation will require cooperative efforts by the Minerals MMC Management Service and the Fish and Wildlife Service, the State of Alaska, and the Alaska oil and gas industry. If consultations with appropriate officials of those organizations have not been initiated to discuss and agree on steps to develop and implement such plans, the Marine Mammal Commission recommends that the Minerals Management Service do so immediately. Pages II-47 to II-49, Stipulation No. 2 -- Protection of Biological Resources: This stipulation would authorize the Service's Regional Supervisor for Field Operations to require lessees to conduct biological surveys to determine the extent and composition of wildlife populations or habitats that may occur in lease areas. The Commission recommends that this stipulation or stipulation number 5 (Industry Site Specific Bowhead Whale Monitoring Program) be expanded to require that lessees conduct an on site observation program designed to detect, record, and report all sightings of, and interactions with, marine mammals and other protected wildlife that occur at or near the location MMC of drilling platforms, seismic vessels, pipeline laying vessels, causeways, etc. 12 Observations should be conducted during work periods to provide lease managers with an improved basis for identifying and assessing potential adverse impacts on protected species. Provisions for the wildlife observation and reporting program should be developed in consultation with representatives of the Fish and Wildlife Service, the National Marine Fisheries Service, and the Alaska Department of Fish and Game. If such an observation program is not incorporated into this stipulation or other mitigation measures, the FEIS should indicate how the Service expects to identify and assess unforeseen or inaccurately predicted interactions between field activities and marine mammals and other protected species. Pages II-49 to II-50, Stipulation No. 3 -- Orientation Program: This section discusses a potential mitigating measure requiring lessees to provide an orientation program at least once a year for all employees, contractors, and subcontractors involved in field exploration, development, or production activities. Its purpose, in part, is to ensure that workers are aware of MMC pertinent lease sale stipulations and provisions and the need to avoid harassing wildlife. In this regard, prohibitions on taking 13 and penalties under the Marine Mammal Protection Act and the Endangered Species Act will be in effect for all such personnel. To ensure that provisions of these and other wildlife protection laws are addressed in the orientation programs, the orientation programs should be required to cover such information. To reflect this point, something like the following should be added as the last sentence of the first paragraph of the stipulation: eer es ~~ ro _— — 9 MMC "The program also shall include information on 13 prohibitions and penalties under relevant laws and regulations to protect marine mammals and other wildlife." This potential stipulation would require lessees of certain blocks to conduct a site specific bowhead whale observation program during April and May of each year. The stated purpose of the program is to determine when bowhead whales are present in the vicinity of exploratory MMC activities carried out in the spring months and the effect of those activities on whale behavior. A map showing the blocks to |14 which this stipulation would apply should be provided. Also, this stipulation should be expanded as appropriate to cover the fall months and the lease areas where bowhead whales are likely to occur during the fall migratory period. As noted above, either this or another mitigation measure should require an observation and reporting system to detect and monitor interactions with important species of wildlife in addition to bowhead whales. = Oo me == £ for Protection of Bowhead Whales from Potential Effects of Noise This stipulation provides that the Service's Regional Supervisor for Field Operations may prohibit exploratory drilling between April 15 and May 15 if it is determined that the density of drilling activity could impede the bowhead whale migration. As noted above, this stipulation appears to be inconsistent with regulations recently adopted by the National Marine Fisheries Service (Federal Register Vol 55, No. 138, pp 29207-29218) MMC authorizing the incidental take of bowhead whales and other marine mammals during oil and gas exploration activities in the 15 Chukchi and Beaufort Seas. Those regulations prohibit the taking of any marine mammals in the spring lead system incidental to such exploration until it is determined that migrating bowhead whales have passed through the area. If it has not already done so, the Minerals Management Service should consult with the National Marine Fisheries Service to determine the appropriate time frame and terms for this stipulation. In addition, a map should be included showing the blocks to which this stipulation would apply. the Regional Supervisor for Field Operations will consider recommendations of the Chukchi Sea Biological Task Force (composed of representatives of the National Marine Fisheries MMC Service, Fish and Wildlife Service, Environmental Protection 16 Agency and Minerals Management Service) and consult with the Task Force on biological surveys conducted under Stipulation No. 2 and actions to be taken in light of survey results. The role of the Pages II-60 to II-61, ITL No. 4 -- Information on Chukchi Sea Biological Task Force: This proposed notice advises lessees that 10 Task Force is not very clear. For example, it is not clear whether the Task Force would be asked to review and comment on MMC planned orientation programs (Stipulation No. 3), bowhead whale 16 monitoring programs (Stipulation No.5), or the timing and restriction of drilling activity along the bowhead whale migratory route (Stipulation No. 8). Advice of the Task Force on these matters would be desirable and the Marine Mammal Commission recommends that this stipulation be expanded to note that the Regional Supervisor, Field Operations, also may consult the Task Force on steps to implement any stipulations bearing on the protection of biological resources. Page III-30, Pacific Walrus: The last paragraph of this section notes that, according to a 1980 source, U.S. and Soviet censuses of walrus over the preceding 20 years indicate that the size of the Pacific population has increased rapidly. More recent censuses discussed in Sease and Chapman, 1988 (reference cited in the DEIS) indicate that the population increase has slowed and that there is some evidence that the number of walrus may have MMC declined recently. The Minerals Management Service should consult with the Fish and Wildlife Service to obtain the most 17 recent population information and include that information in this section. In this regard, we note that the DEIS relies, in many cases, on information that was collected more than 10 years ago. For such cases, it should be recognized that substantial population changes may have occurred since the data were collected. Pages III-30 to III-3], Carryover Paragraph: The second sentence | of this paragraph notes that radiotelemetry studies of polar bears suggest that interchange of animals between populations in MMC northern and western Alaska occurs more often than previously 18 suspected. A reference for this information should be provided. =) : This paragraph, citing 1972 and 1974 sources, suggests that polar bear denning along the Chukchi Sea coast appears to be less concentrated than at other denning areas in the Arctic. Information on polar bear distribution and occurrence along the Chukchi Sea coast is very MMC incomplete. In the absence of more recent and detailed studies, this conclusion should be conditioned by noting that available 19 information is not sufficient to verify the extent to which polar bear denning occurs in this area, to what extent the number of denning females varies from year to year, or what factors are responsible for annual variation. i : Although the second | sentence of the paragraph states that no reliable data exist regarding bowhead whale population trends, the third sentence MMC has increased dramatically in recent years. References are not, states that some people believe that the bowhead whale population 20 but should be, provided or the statement should be deleted. il Page III-32, Third Complete Paragraph: This paragraph discusses the timing and route of the bowhead whale migration through the lease area. It should be expanded to indicate the distribution of whales across the spring lead system, the extent to which whales appear to prefer inshore verses offshore leads, and whether there is any information regarding age, x preferences for inshore or offshore leads. Page III-34, Third Complete Paragraphi This paragraph should be expanded to note that Seaman et al. 1985, as cited in the DEIS, suggest that the belukha whales in the Bering Sea may be composed of four stocks, one of which occurs in the eastern Chukchi Sea, including Kotzebue Sound and waters in and adjacent to Ka: uk Lagoon. This paragraph also should note that belukha wha. may move back and fourth during the summer between the pack i and coastal waters (see pages 204-205 in J. Lentfer, 1988. S Marine Mammals of Alaska: Species Accounts with Research and Management Recommendations. Marine Mammal Commission. Washington, D.C. 275p.). Effects of development on belukha whales therefore could be greater than is stated in subsequent sections of the DEIS. the data on subsistence harvests of marine mammals in this section are from periods prior to 1982. The section should be updated to identify and assess more recent harvest data. Most of Pages IV-B-] to IV-B-29, Alternative 1 -- Low Case: The comments noted below for specific parts of this section also apply to corresponding discussions under the base case and high case scenarios. this paragraph states that " The second sentence of the effect of industrial noise on bowhead whales in or near th ring lead system is likely to be simil to that anywhere else, since the stimuli are the same." While effects may be similar to those during the spring migration and in other portions of the spring migratory corridor, the effects may not be the same in feeding areas, over wintering areas, or other areas where whales are not engaged in migrating or are confined by ice. Thus, something like the words “at the same time of year in comparable ice-covered areas along the migratory corridor" should be inserted after the words "anywhere else" in the second sentence. These pages discuss the effect of noise from vessels, drilling, and other offshore oil and gas associated activities on bowhead and gray whales. Available MMC 21 MMC 22 5 MMC J23 MMC 24 5 information suggests that whale “response zones" around noise MMC sources (defined in the DEIS as the range of distances where a 25 behavioral response to industrial noise can be expected from Ml ct a 12 about one-half of the whales in the vicinity of the noise source) may range from less than a kilometer to over 20 kilometers depending on a number of factors and that responses may include changes in the direction of movement and other behavioral modifications that typically last a few minutes to an hour or more. The discussion should be expanded to assess the extent to which data are available on the effect of noise on whale distribution in the hours and days following the initial response. That is, if migrating whales change direction to avoid noise sources, to what extent, if at all, are data available to show that disturbed migrating whales will return to their previous course, tract, and behavior immediately after passing the no source. For example, if whales migrating east along shoref, ice change direction to avoid noise from a nearshore drill ship four or perhaps even 20 or more kilometers before reaching it, would they skirt the sound source and then return to their nearshore migratory tract once past the drill ship or, alternatively, would they resume a migratory course further offshore leaving nearshore areas further along the migratory corridor with comparatively fewer whales? In the latter case, the availability of whales at traditional subsistence hunting areas may be altered. Also, it seems possible that whales, whose normal movements might be briefly delayed due to industrial noise disturbance, may have a higher risk of being trapped in a rapidly closing ice lead causing the death or injury of some animals. The analysis also should be expanded to consider synergistic noise effects. For example, it should consider overlapping response zones around drill ships and associated ice breakers and supply vessels. Combined effects could create an area in which few or no whales occur that is larger than the size of the response zon alone That is, the cour: of wha deflected away from a pon: zone may result in an absen of whales down-stream of thi Spo! zone even though noi levels in that area would not be sufficient to disturb many whales. For example, whal moving west during the fall migration may be deflected away from drilling-ice breaking operations leaving an area immediately east of response zones around a drilling site in which few or no whales would occur. If the area avoided had high concentrations of zooplankton, bowhead whales could be deprived of access to an important feeding opportunity during their fall migration. The discussion in this section also should be expanded to consider possible effects that may not be readily observable by overt or conspicuous behavior changes. That is, some animals may experience physiological or psychological stress from exposure to noise that may not be readily detected by changes in respiration patterns, swimming direction, etc. Such stress could manifest itself through a general decline in health, lower reproductive MMC 25 ~ — ~ -~, —- _ — 13 rates, decreased survival, and/or other such changes. The MMC absence of observed response, therefore, does not conclusively rule out possible adverse effects. This section should be |25 expanded to identify and discuss such uncertainties. The possible existence and significance of effects other than those readily observable exemplifies the need for post lease monitoring programs. Page IV-B-]2, First Complete Paragraph: This paragraph states that "deflections in bowhead swimming paths, changes in surfacing/respiratory patterns, and temporary cessation or a change in activity are not expected to result in a significant effect on the bowhead population/migration."” The meaning and basis of this conclusion are unclear. For example, it is not MMC clear whether the term "deflections in bowhead swimming paths," 26 refers only to t! initial change in direction of a whale affected by nois in the routes followed after passing out of hearing range. Therefore, this conclusion should be deleted or the discussion should be expanded to indicate why concerns noted in the preceding comment can be discounted. that, because some observers have en bowhead whales less than one kilome’ from an icebreaker, the avoidance of icebreakers by belukha whales and narwhals reported by Finley and Davis (1984) and Finley et al. (1984) to have occurred at distances of 35-50 MMC kilometers "...apparently were the startle responses of 27 ‘industrially naive' animals." The conclusion is speculative and should be indicated as such. The proposed action should be expanded to include monitoring programs designed to verify the accuracy of such speculative conclusions. This paragraph concludes Page IV-B-18, Third Complete Paragraph: This paragraph not that a study of bowhead whale distribution off Alaska betwi 1982 and 1988 suggests that the distribution of animals app: 's to be related to variation in ice conditions "...rather than the presence of industrial activity." As evidence, the paragraph notes differences in the median depth of water through which MMC! whales migrated during light, moderate, and heavy ice years. While the information supports the conclusion that ice influences 28 whale distribution, it does not indicate that industrial activity has not influenced whale distribution. Therefore, the reference that industrial activity has not influenced whale distribution should be deleted or the supporting information should be described. This paragraph notes that exploratory operations generally do not begin until mid- MMC July and, hence, the spring bowhead whale migration would not encounter exploration-related noise. Unless there is assurance that exploration activities would not begin until mid-July, it 29 14 cannot be stated with certainty that the whales migrating in the spring would not encounter exploration-associated noise. No such assurance is provided in the description of the proposed action and, unless it is, the paragraph should be revised to note that exposure of whales to exploration noise is possible but not expected given the usual annual exploration start-up date of mid- July. This paragraph states that, under the low case scenario, bowhead whale response zones (defined in the DEIS as the distance where a behavioral response to noise can be expected from about one half of the whale could cover 25 percent of the width of the bowhead whale fall migratory corridor and, thus, 25 percent of the whale population (1950 animals) may co within this distance during the fall migration. Assuming on alf of the whales within that spond, the paragraph concludes that 975 animals would be ected. While half the whales would react at or before reaching the perimeter of the response zone, others could or would respond at closer distances. Therefore, substantially more than 975 whales could be affected. The analysis should be revised to reflect this fact. n= : This paragraph notes that “due to the conservative nature" of the estimate of 975 whales being affected by exploration noise, "the likely rate of bowhead...whal encountering exploratory noise in the low case is expected to be very low in 1992 and zero thereafter." For the reasons noted above, the Service's estimate of the expected number of whales affected may not be conservative. Also, 975 whales encountering noise does not constitute a "very low" rate. This paragraph notes that any substantial increase in polar bear mortality above natural and subsistence caus: could have severe consequences. Although contact between bears and spilled oil poses a risk of additional mortality, the paragraph concludes that substantial additional mortality is unlikely because the density of bears in the Chukchi Sea is low and therefore only a small number of bears would encounter spilled oil. This analysis does not consider the possibility that the movements of wide ranging bears over the course of a spill may result in more than small numbe: of bears encountering a spill even though overall density may be low. In addition, it does not consider that bears may be attracted to a spill sit Such factors could cause oil spill impacts to exceed low 1 for polar bears and this paragraph should be expanded to consider such possibilities. Pages IV-C-42 to Iv-C-44, Effects of Disturbance: This section discusses possible effects of disturbance on polar bears and pinnipeds. The section does not consider the possibility that MMC 30 MMC 31 MMC 32 15 polar bears could be attracted to offshore facilities and activities by smells, lights, noise, or other factors. In addition to posing a threat to offshore workers, such attractions could result in the death or injury of bears through interactions with operating equipment, ingestion of toxic supplies, or being shot to protect workers. It is our understanding that at least one animal has already been shot and killed because it approached and was perceived as a threat to offshore oil workers. The penultimate sentence of this paragraph states that frequent or sustained disturbance due to industrial activity may cause pinnipeds and polar bears to avoid or abandon an area, but that the presence of substantial numbers of pinnipeds in the vicinity of intensive fishing operations suggests that these species can habituate to fairly high le of human activity. We fail to see how the presence of pinnipeds in the vicinity of fishing operations provides any insights into how polar bears might be affected by human activiti Further, the conclusion derived from the presence of seals in the vicinity of fishing activities is misleading. Pinnipeds likely occur near fishing activities because of the presence of fish. Their behavior when exposed to noise in the absence of concentrations of fish may well be entirely different. Also, there is evidence suggesting that noise associated with bottom trawler operations near Round Island in the Bering Sea has caused the number of walrus hauling out at that site to decrease dramatically. Finally, pinnipeds in the lease area are not the same species as occur in intensively fished areas and their responses to activity of any kind may differ. Thus, the suggestion that pinnipeds in the vicinity of fishing operations support the view that industrial noise is not likely to affect polar bears and pinnipeds in the lease area should be deleted. This paragraph concludes that effects on pinnipeds and polar bears under the base case scenario are expected to be low. In view of the possibilities mentioned above that are not considered in the DEIS, we believe this conclusion imates possible effects on polar bears and should be The second sentence states that the distance from a noise source where a response occurs repr nts the outer limit of the response zone. The third te! states that the response zone is defined as the distance where a response is expected from about one-half of the whales. These statements appear inconsistent and should be clarified. This paragraph, which assesses base case exploration-related impacts on bowhead whales, MMC ic all, tll -_— — -_ ‘dia —_— MMC 32 IL 33 16 assumes that the level of exploration effort would be the same as the low case scenario (i.e., two operations per year). To drill the number of exploratory wells projected for the base case scenario (39) between 1992 and 1998, it would appear that the number of exploratory operations would have to exceed two operations per year. Therefore, the paragraph should be clarified or deleted. =C-47 W=C= : The analysis in this paragraph of possible effects of noise from production platforms on bowhead whales fails to consider possible effects due to response zones of associated icebreaker operations. It also does not describe the basis for concluding that noise effects from associated supply boats might increase the total number of whales encountering noise only "slightly". Also, if the short-term response of whales to noise involves a course change that carries whales away from the sound source and whales do not return to the same course and track once past the noise source, it would appear that the result would be to exclude or at lease limit access to whale habitat both within the response zone and within an additional area of uncertain size east or west of the response zone depending on the direction of the whale migration. Affected areas may include important feeding areas. The likelihood, extent, and effect of such a habitat loss is not considered here or elsewhere in the DEIS. As presently drafted, the analysis appears to underestimate the likelihood and the extent of possible noise effects. The analysis should be expanded to better address the range of possibilities. ata i; The last sentence of this paragraph concludes that available information is considered adequate to determine the likely effect of crude oil associated with the base case on bowhead and gray whales. We do not agree that available information is adequate to predict likely effects, at least with reasonable certainty. For example, we are aware of no information on long-term lethal or sublethal effects of oil on individual free ranging cetaceans or any baleen whale. Consequently, there is little basis for predicting with certainty the possible or likely long-term effects on whale physiology, disease, reproduction, etc. While studies to date and the discussion of their results in this section of the DEIS help ease concern regarding short-term catastrophic effects, subtle long- term effects remain unstudied, uncertain, and potentially significant. The last sentence implies a degree of understanding not presently at hand and should be deleted. The detection of possible long-term as well as short-term effects should be one of the objectives for post lease monitoring programs. =Gm 3; The last sentence of this paragraph states that cetaceans confined to an area of an oil spill and inhaling vapors produced by the spill would sustain some damage, "...but the effect would depend more on the MMC 36 MMC Si = 38 oe MMC 39 i al 17 susceptibility of the animal, since the theoretically attainable concentrations of vapor are not high enough to pose a threat." While we are aware of no information regarding the inhalation of MMC oil vapors by cetaceans during the Exxon Valdez oil spill, it is our understanding that there is evidence that a number of sea 39 otters and perhaps some pinnipeds were killed as a result of inhaling toxic vapors associated with that oil spill. This paragraph should be expanded to include information on toxic effects of inhaled oil vapors derived from studies conducted during the Exxon Valdez oil spill. It also would be useful to nete the effects of such vapors on humans. Page IV-C-56, Fourth Paragraph: The first sentence of this paragraph states that "(s)jince the sale area is offshore from the majority of the spring lead system,...spring-migrating bowheads are not likely to encounter noise associated with the production operations". This point is repeated in many parts of the DEIS yet all figures in the DEIS showing the spring migratory corridor MMC indicate that virtually its entire width is included within parts of the sale area. If the referenced quote is true, all figures 40 should be changed to more correctly indicate the boundary of the migratory corridor. Alternatively, if the figures are correct, the statement here and elsewhere in the DEIS suggesting that the migratory corridor does not pass through the sale area should be clarified or deleted. V-G- -G- The first two sentences of the paragraph state that since the same level of development is considered for the base case scenario of the Proposed Action and the Point Lay Deferral Alternative, the likelihood of whales encountering noise under the Deferral MMC Alternative is the same as the Proposed Action. As is noted Al later in the paragraph, this is not true because the deferral area would exclude the spring migratory corridor of bowhead whales. The second sentence of the paragraph is misleading and should be deleted. =—= 0) : This paragraph concludes that exploration and development of the area deferred under the Point Lay Deferral Alternative would likely have an insignificant effect on bowhead whales. For reasons noted above, we believe the effects of oil and gas exploration and development in this area, which includes the bowhead whale spring migratory corridor, are uncertain and that available information is not sufficient to conclude that effects likely would be insignificant. The conclusion should be changed to indicate that effects under this alternative are uncertain, but that the alternative could significantly reduce the probability of oil and noise effects on migrating bowhead whales as compared to the Proposed Action. This point also appears to be true for belukha whales. For this reason, the Marine Mammal Commission believes the Point Lay Alternative is preferable to the proposed action. 18 -H-' V=e= ars: This section concludes that the cumulative effects of the proposed action and other human activitii on polar bears are likely to be low. Elsewhere, the DEIS no’ that substantial mortality above current natural and subsistence hunting levels would be significant. Given activities and spills expected from oil development already planned or underway on and adjacent to Alaska's north coast, we believe that cumulative effects on polar bears are underestimated in this section and that they may well be high. In addition, we note that the Service's assessment of cumulative effects on polar bears in the DEIS issued earlier this year for Beaufort Sea Sale 124 concluded cumulative effects on polar bears would be moderate. Therefore, the conclusion in this section also appears inconsistent with previous Service conclusions regarding this species. I hope these comments and recommendations are helpful. If you or your staff have any questions concerning them, please call. Sincerely, Buf Robert J. Hofman, Ph.D. Scientific Program Director Enclosure cc with enclosure: Mr. Barry A. Williamson MMC Marine Mammal Commission Response MMC-1 The MMS corresponded with NMFS by letter dated July 26, 1990, regarding the potential effects of oil and gas leasing in Alaska on the Steller sea lion. By letter dated August 28, 1990, NMFS stated that there was no need to reinitiate consultation under Section 7 of the Endangered Species Act for Lease sale 126. A letter dated October 25, 1990, from the NMFS indicated agreement with the MMS determination that proposed Sale 126 is "not likely to affect the continued existence of the Steller sea lion.” As suggested, a copy of the Arctic Regional Biological Opinion prepared by the NMFS has been included as part of Appendix D. Response MMC-2 Several of the criteria defining a low-level effect cited by the Commission are incorrect, e.g., there may be a population decline and lethal effects (see Table S-2). A statement addressing the possibility of polar bear attraction to offshore facilities has been added to Section IV.C.6. The record of arctic operations does not suggest that substantial polar bear mortality is likely to occur under these circumstances. Revision of an effect level requires the presentation of specific new information suggesting a significant elevation of risk. The discussion of potential effects on the polar bear includes a range of effect levels that could result in various circumstances; however, the MMS prefers to present the expected effect as a single effect level. Response MMC-3 A new stipulation or revision of an existing potential stipulation with regard to any unavoidable killing of polar bears is not necessary to protect polar bears, which already are protected from excessive takes or human-induced mortality under the MMPA. Concerns about harassment and taking also are covered under Stipulation No. 3, the Orientation Program, and under ITL No. 3, Information on Bird and Marine Mammal Protection. All of the measures under the Polar Bear Interaction Plan are covered under existing OCS regulations or would be covered under FWS review of OCS exploration and development plans. For example, existing regulations prohibit the dumping of garbage that would attract bears; and the organization and layout of buildings and work areas are confined to the offshore drill platform or gravel island, thus minimizing the chance of bear/human interactions. The MMS agrees it is important that lessee activities not affect polar bears. It is MMS’ understanding that Letters of Authorization (LOA’s) are required by FWS for unintentional take of polar bear and that the LOA can or would further identify lessees’ obligations or requirements to prevent disturbance to polar bears. Avoidance plans would not alleviate lessees from the responsibility of obtaining LOA’s. The MMS will provide Exploration Plans to the FWS and will coordinate with FWS on LOA’s and their requirements, eliminating the need for MMS to require separate plans. Response MMC-4 The EIS does not attach importance to the length of the migratory corridor. As noted in the EIS, most bowhead whales are expected to pass through the sale area in the fall in a dispersed fashion. However, very few (if any) are expected to pass through the sale area in the spring, since the spring migratory corridor is believed to be largely inshore of the sale area. Also, exploratory operations are not likely to occur when cetaceans are present in the spring-lead system (due to heavy ice). The purpose of the seasonal drilling restriction (SDR) was to protect whales from what were then the unknown effects of an oil spill. No exploratory activities are assumed in the spring lead system due to ice conditions and incidental take regulations. Thus, the SDR is not necessary. MMC-1 The regulation prohibiting the incidental taking of whales within the spring-lead system by exploratory activities is moot for three reasons. First, due to heavy-ice conditions, exploratory activities are not likely to occur until after the bowhead population has already passed the sale area. Second, the spring-lead system is outside (inshore) of the sale area and, hence, the area of MMS-permitted activity. Third, and most importantly, all studies to date have consistently shown that even if exploratory activities did take place within the spring-lead system, such activities would be likely to have little or no effect on the bowhead population, although some whales could be affected. The decision not to evaluate an SDR was based on this information. Regarding the return of whales to their original swimming path following diversions around industrial operations, there is no data on this subject. However, there have been a few observations of bowheads that returned to their predisturbance location and behavior following an encounter with industrial noise (see Richardson et al., 1987; Ljungblad et al., 1985). Also, Malme et al. (1984) provides information (see Fig. 8.3. of that report) showing that while most gray whales avoid close approaches to seismic-airgun noise, they generally do not alter their course much to do so. Response MMC-5 As requested, walrus has been added to Table S-1 as a separate resource category. Response MMC-6 The expected effect level for the cumulative case has been changed to moderate for consistency with the 5- Year OCS Oil and Gas Leasing Program SEIS (USDOI, MMS, 1990b). Response MMC-7 Section I.5 and Appendix F have been amended to address this concern. Response MMC-8 The text of Section I.13 has been amended to address this concern. Response MMC-9 The referenced sentence refers to the spring-lead system, which is generally nearshore, as being outside the sale area. It does not refer to the entire spring-bowhead-migratory corridor (as portrayed in Fig. III-B-5) as being outside the sale area. Although the spring-lead system does move about, the available information indicates that it is inshore of the sale area. Response MMC-10 Satellite tracking data does not indicate that nearshore areas in the Chukchi Sea are important polar bear denning areas, nor does it support the contention that deferring selected nearshore blocks (Alternative IV) would reduce risk to polar bears significantly. The probability that an oil spill would contact the nearshore area, except in the vicinity of a pipeline to shore, is extremely low whether leasing in the indicated blocks were deferred or not. However, Section IV.G.6 has been revised to reflect the uncertainty of use of this area by polar bears. Response MMC-11 Section II.F.1, Mitigating Measures That Are Part of the Proposed Action and the Alternatives, has been changed to include wording similar to that suggested by the commenter. MMC-2 Response MMC-12 Stipulation No. 2 (Protection of Biological Resources) or No. 5 (Industry Site-Specific Bowhead Whale- Monitoring Program) have not been expanded "to require that lessees conduct an on site observation program designed to detect, record, and report all sightings of, and interactions with, marine mammals and other protected wildlife that occur at or near the location of drilling platforms, seismic vessels, pipeline laying vessels, causeways, etc." The MMS believes that such a monitoring program would provide no more than randomized, anecdotal information rather than scientifically based and systematically acquired data. The MMS funds an environmental studies program that would be much more useful in acquiring needed scientific information. Response MMC-13 The Orientation Program stipulation notes that the program shall be formulated to ensure that personnel understand the importance of avoidance and nonharassment of wildlife resources. To accomplish this, the program presently includes a summary of environmental and cultural resource-protection requirements for the Chukchi Sea. This summary notes that all activities in areas leased are subject to the provisions of the MMPA, which prohibits the harassment of marine mammals; the ESA, which makes it unlawful to take endangered species; and some international treaties, which prohibit the harassment of species of international importance, such as migratory waterfowl and marine mammals. The MMS believes the content of the present program is adequate in making the workers aware of the laws protecting wildlife and does not believe the statement suggested in the comment needs to be added to the stipulation. In addition, MMS prefers to have as much of the program as possible presented in a positive manner and therefore does not believe a discussion of penalties that might be imposed for failure to comply with the wildlife-protection laws would be appropriate. Response MMC-14 The MMS believes it unnecessary to expand potential Stipulation No. 5 to include leases in the fall bowhead whale-migration area of the Chukchi Sea. The Sale 109 Biological Opinion did not include conservation recommendations for monitoring the fall migration, nor did the Arctic Region Biological Opinion make a recommendation for monitoring the fall migration in the Chukchi Sea. The monitoring stipulation adopted for Sale 109 is limited to the spring migration only. Unlike the fall migration in the Beaufort Sea, the fall migration through the Chukchi Sea does not follow a defined corridor. Due to the dispersed nature of the migration and the limited scope of exploratory-drilling activity, we do not believe monitoring would be appropriate or necessary. The blocks listed for Stipulation No. 5, Industry Site-Specific Bowhead Whale Monitoring Program, coincide exactly with the blocks to be deferred in the Point Lay Deferral Alternative. See Figure I-3 for a map of the Point Lay Deferral Alternative. Response MMC-15 Stipulation No. 8, Density Restriction for Protection of Bowhead Whales from Potential Effects of Noise, has been deleted as a potential mitigating measure because it is inconsistent with recent NMFS regulations on incidental take of bowhead whale (as pointed out by the Commission) and not required by the Arctic Region Biological Opinion or the Sale 126 Biological Opinion. Response MMC-16 The functions and responsibilities of the Biological Task Force (BTF) have been oriented toward identification and protection of unique benthic communities, such as the Boulder Patch community in the Beaufort Sea or other site-specific biological resources that may not have been identified or considered in the MMC-3, EIS. Other biological resources, including whales and other mobile species that are known to exist in the area, are identified and potential effects addressed in the EIS. If oil and gas activities could have significant effects on these resources, stipulations, or ITL’s are adopted, as appropriate, to mitigate potential effects. If potential Stipulation No. 2 (Protection of Biological Resources) were adopted and implemented, the BTF would focus on benthic communities whose presence at a site-specific location of proposed operations-- although unknown at the EIS stage--could be directly affected by proposed operations and might require additional protection. The BTF makes recommendations to the Regional Supervisor, Field Operations, on the need for and scope of surveys to determine the presence of these unique biological communities and how to protect such communities, if found. In recent years, the BTF has used information from site-specific geohazard surveys, particularly sidescan- sonar records, to determine if there are any anomalies that might indicate the presence of unique biological communities. If anomalies are identified at the proposed site of operations, the site would be moved or additional studies conducted, including camera or diver surveys to determine if biological communities are present. The MMS would coordinate with the BTF for further recommendations. More elaborate surveys including trawls, grab samples, etc., were required in the Gulf of Alaska and Lower Cook Inlet and where deemed appropriate. These efforts were eventually discontinued because the findings were consistent with known information about the presence and distribution of biological resources and provided no information pertinent to the site-specific proposed activity. A BTF was established for the previous Chukchi Sea Sale 109 area. That BTF has been involved in implementing a Biological Resource Stipulation for SWEPI’s exploratory-drilling program following the principles described above. Bowhead whale-monitoring programs required under potential Stipulation No. 5 would not be a responsibility of the BTF since these programs receive extensive review and con:ment through interagency and public review and consultation with NMFS for this endangered species. All exploration plans, including associated monitoring programs, are distributed for public review, including those agencies and organizations represented on the BTF. The BTF was involved in developing early orientation programs for the Beaufort Sea and may become involved in a Sale 126 orientation program, should the potential stipulation be adopted. However, since biological issues comprise only a portion of the programs, the role of the BTF may be minimal. While MMS has no objection to a BTF review of the program, timing and logistics can make this difficult. The orientation program already developed for the Chukchi Sea Sale 109 area could most likely be used to satisfy the requirements for Sale 126. Historically, once a program has been approved for an area, the existing program is revised, if necessary, to include any new information related to the new sale area. Such an approach was used for Beaufort Sea lease sales subsequent to Sale 71. Response MMC-17 The text of Section III.B.4 (Pacific walrus) has been revised to address the concern for a possible declining walrus population trend. Response MMC-18 Some additional information concerning polar bear movements was obtained in a conversation with Gerald Garner, USFWS, Anchorage, in early 1990. This reference has been added to Section III.B.4. Response MMC-19 Section III.B.4 has been revised to address the concern for polar bear denning along the Chukchi Sea coast. MMC-4 ow Response MMC-20 The sentence provides a reference, as suggested. Response MMC-21 The referenced paragraph refers to the fall bowhead migration in the Beaufort Sea, rather than to the spring migration in the Chukchi Sea. Response MMC-22 Much effort has been expended to limit the amount of speculation in the NEPA analysis and to base the analysis on substantiated findings concerning what is known or is likely to occur. Consequently, adding speculation concerning the number of possible belukha stocks and possible ways in which belukhas might move between pack ice and coastal waters would not enhance the analysis. Response MMC-23 In addition to the 1962-1982 ACI/Braund subsistence data cited in the text, the subsistence discussion also uses 1988-89 subsistence-harvest data for Barrow and Wainwright. The MMS studies program currently is continuing to acquire long-term subsistence-harvest data. However, the ACI/Braund information is still the most creditable long-term information available on subsistence-harvest levels. Response MMC-24 The studies cited in the EIS involve observations of whales that were feeding, migrating, and socializing in many geographic areas. However, as indicated in the analysis, the responses of whales to industrial noise were found to be generally the same regardless of location. The factors that cause actual differences in response remain unclear. Differences in ice cover, the time of year, the quantity and quality of the noise environment, hunting pressure, and individual behavior (and any combination of the above) have all been suggested as possible causes. Nevertheless, whales generally respond in a predictable fashion to similar stimuli, as do other marine mammals. Further evidence that continues to support this finding was again noted in Richardson et al. (1990), where it states that "Our preliminary impression is that bowheads are no more sensitive to fixed wing aircraft like the Twin Otter during spring migration through pack ice than they are in late summer in largely open water". Response MMC-25 The EIS analysis addresses the likely effect of industrial noise on bowhead and gray whales. The reference to a response zone of over 20 km comes from a predictive-modeling study (Miles, Malme, and Richardson, 1987). However, neither bowhead nor gray whales have been observed to respond to industrial noise at more than 10 km from the noise source. Consequently, it is unlikely that bowhead or gray whales would respond perceptibly at 20 km, although it is (based on the mathematical model from Miles’ report) hypothetically possible. There is no whale information that shows that "disturbed migrating whales will return to their previous course, tract, and behavior." However, there have been a few observations of bowheads that returned to their predisturbance location and behavior following an encounter with industrial noise (see Richardson, Wursig, and Miller, 1987; Ljungblad et al., 1985). Also, Malme et al. (1984) provide information (see Fig. 8.3 of that report) showing that, while most gray whales avoid close approaches to seismic-airgun noise, they generally do not alter their course much to do so. Regarding the possibility of whales being less available to subsistence hunters, it is unclear as to how this would adversely affect the bowhead whale population, if such diversions were to occur. Regarding the possibility of higher entrapment and death resulting from possible MMC-5 delays when whales divert around a source of noise, it should be remembered that a whale’s migratory course is not pre-set from its initial to final destination. Deviations to avoid naturally occurring objects or phenomena (including noise) are necessary and routine, yet they do not create any significant adverse effect on whales. Diversions around industrial noise are likely to have the same result, and studies to date confirm this. The suggested idea of entrapment or death resulting from diversions around industrial operations is considered well beyond the realm of reasonable expectation. Synergistic noise effects were discussed in Section IV.B.7(1)(e) (Whale Distribution in Response to Industrial Noise). Regarding the suggested possibility of industrial noise creating areas where whales could be absent and thereby miss feeding opportunities, this again is considered highly unlikely. Wartzok et al. (1989) documented over 180 feeding bowhead whales that voluntarily approached an active research vessel at ranges of only 15 to 500 m, and some of these animals even bumped into the vessel before moving off. Possible adverse physiological or psychological effects such as stress and decreased health and possible beneficial physiological/psychological effects such as energy savings, increased access to feeding areas, and death prevention due to icebreaker action have not been studied to any extent. Hence, they are speculative and are considered inappropriate in a NEPA analysis. Most importantly, although discussion of such possibilities and uncertainties could occur, it would not alter conclusions regarding the likely effect of Sale 126 on whales. Response MMC-26 The referenced sentence means that the bowhead population is not likely to experience a deflection in their migratory path that would significantly affect them as a population. This statement was based on the findings of the short-term-effects studies cited in the analysis. Response MMC-27 The referenced paragraph does not have a conclusion concerning the observations of Finley and Davis (1984). Further, the statement made by Finley and Davis concerning industrially naive animals was not one of their conclusions. Response MMC-28 The referenced statement does not indicate that "industrial activity has not influenced whale distribution." It indicates that the distribution of the bowhead population appears to be related to the severity of ice conditions rather than to the presence of industrial operations (based on Treacy, 1989). Additional supporting information has been added to the FEIS, as suggested. Response MMC-29 The annual spring bowhead migration has passed Point Barrow around mid-June. Based on what has occurred to date, the earliest time during which exploratory operations can occur during light-ice years is the end of June. In heavy-ice years exploratory operations would commence much later, if at all, The EIS also indicates that the spring-lead system is essentially outside the sale area. Therefore, as indicated in the DEIS, the spring bowhead migration would not encounter noise associated with exploration. Additional wording was added to the FEIS to re-emphasize this point. Response MMC-30 The definition for the response zone (Sec. IV.B.7.a(1)(a)) is defined as the range of distances where a behavioral response (attributable to the industrial noise) can be expected from about one-half of the whales in the vicinity of a given source of industrial noise. Hence, about one-half of the whales within the outer MMC-6 oe lll, — perimeter of this zone (in this case 975 whales) would be expected to exhibit minor, short-term responses to the industrial noise. The definition says nothing about whales that may respond beyond the response zone, since at distances beyond the response zone it is often difficult, or even impossible, to determine what a given response was attributable to. While it is probable that some whales would respond to industrial noise at distances beyond the response zone, it is also probable that the actual number of encounters within the response zone would be significantly less than 975. For example, only zero to one exploratory operations per year are likely. This alone would decrease the number of estimated encounters from 975 to somewhere between zero and 487. It is also unlikely that all exploratory operations would be conducted during the time when whales are nearby (which was assumed in the encounter scenario). This too would result in a further reduction in the number of estimated encounters. Consequently, while it is possible that there could be more than 975 whales affected due to those responding beyond the response zone, it is also probable that significantly less than this number would actually be affected within the response zone. Response MMC-31 The text of Section IV.C.6 has been revised to address the potential for polar bears to become concentrated under certain circumstances. Likewise, the possibility of polar bears being attracted to the area of a spill is acknowledged. Response MMC-32 The text of Section IV.C.6 has been revised to address the concern for polar bears being attracted to sites of human activity. Response MMC-33 The statement noting the potential for habituation of pinnipeds to activity has been made specific to this group; it was not intended that this example be extrapolated to the polar bear. This information had no significant influence on determining the concluded effect level and has been qualified in revision of Section IV.C.6. Several examples of disturbance of pinnipeds by human activities, or apparent habituation, have been cited to show the range of potential response in this taxonomic group. We would prefer, of course, to cite studies on the particular species in question; however, in many cases such studies have not been performed. Under such circumstances we can only suggest that there may be some rationale for extrapolating between the various pinniped species. Response MMC-34 The major factors of oil spills and substantial disturbance effects have been considered in concluding an overall effect level for pinnipeds and polar bear. Potentially minor disturbance effects (e.g., attraction of polar bears to offshore sites, temporary displacement of pinnipeds by icebreaking activities) are not considered sufficiently severe to result in a significant elevation of the concluded effect level. Response MMC-35 For the purpose of clarification, the second sentence has been deleted. Response MMC-36 Section IV.C.7.a(2)(a) of the DEIS states that five (not 2) exploratory operations are assumed for the base- case. Further, this paragraph does not assess base case exploration-related effects; it discusses only the level of exploration that has taken place to date in this area. MMC-7 Response MMC-37 As indicated on Table II-A-1 of the DEIS, there are no icebreaker activities projected for the production phase (as would typically occur during exploration), only intermittent supply-vessel visits (about 1/month). While these visits would be performed by an icebreaker, most would occur during the time when whales were not present in the area. Hence, supply-vessel activities would increase the likelihood of bowhead encounters only slightly, as stated in the DEIS. Regarding the concern of possible adverse effects on whales due to their being deflected by production operations, this scenario is addressed in Response MMC-25. It is unclear what is meant by "range of possibilities," as suggested by the commenter. In the past, possibilities have been discussed at length; however, since they have no scientific basis, they do not alter conclusions. Response MMC-38 Gray whales have been swimming through and around oil slicks caused by man since the time when ocean- going vessels began to carry petroleum products for fuel and cargo. In the southern portion of their range, fuel and/or oil spills are common due to vast numbers of industrial, commercial, military, and pleasure vessels in that area. Further, gray whales have for centuries been exposed to naturally occurring oil spills in many locations along their migratory corridor. While it is true that there has been no formal study performed that spans a period of time sufficient to qualify as a long-term study, it does seem prudent to recognize the fact that no gray whale (or any other whale, for that matter) has ever been found to have died from petroleum exposure. This includes the period when the entire gray whale population swam through the Santa Barbara oil spill in 1969. Further, the MMS believes that the information concerning short-term effects is adequate, on its own merit, to determine the likely effect of crude oil on baleen whales. This information has consistently shown that crude oil results in from only minor effects to no effect on whales. Response MMC-39 As the commenter stated, there is no available information on the inhalation of petroleum vapors by marine mammals during the Exxon Valdez oil spill. Hence, that information cannot be added to the analysis. Response MMC-40 The spring-migratory corridor and the spring-lead system are not synonymous. The spring-lead system (not shown in the EIS) falls within the spring-migratory corridor, which is shown in Figure III-B-5. While most bowheads are believed to migrate in the spring-lead system, others are believed to migrate somewhat farther offshore. Both of these areas are collectively illustrated as the spring-migratory corridor in the DEIS. The analysis in the EIS refers only to the spring-lead system as being largely outside the sale area, not to the spring-migratory corridor. Hence, there is no conflict between the figures and the text. Response MMC-41 For the purpose of clarification, the referenced sentence has been changed to read "similar to" rather than "the same as." MMC-8 = ial all te neti tia nal An] SL Tel i Sasa STEVE COWPER, GOVERNOR CENTRAL OFFICE OFFICE OF THE GOVERNOR RO. BOX AW JUNEAU, ALASKA 99811-0165 PHONE: (907) 465-3562 OFFICE OF MANAGEMENT AND BUDGET DIVISION OF GOVERNMENTAL COORDINATION SOUTHEAST REGIONAL OFFICE SOUTHCENTRAL REGIONAL OFFICE NORTHERN REGIONAL OFFICE 431 NORTH FRANKLIN 3601 °C’ STREET 675 SEVENTH AVENUE PO. BOX AW, SUITE 101 SUITE 370 STATION H JUNEAU, ALASKA 99611-0165 ANCHORAGE, ALASKA 99503-5930 FAIRBANKS, ALASKA 99701-4596 PHONE: (907) 465-3562 PHONE: (907) 561-6131 PHONE. (907) 451-2818 Certified Mail September 11, 1990 Return Receipt Requested Alan Powers Alaska OCS Region Minerals Management Service 949 E. 36th Avenue, Room 110 Anchorage, AK 99510 Dear Mr. Powers: SUBJECT: CHUKCHI SEA LEASE SALE 126 DRAFT ENVIRONMENTAL IMPACT STATEMENT STATE I.D. NUMBER AK90072416/A The Division of Governmental Coordination (DGC) has completed coordinating the state's review of the Draft Environmental Impact Statement (DEIS) for proposed Outer Continental Shelf (OCS) Oil and Gas Lease Sale 126 (Chukchi Sea). Our review focused on the lease sale configuration, the pro ed mitigation measures, and the DEIS description of the affected environment and environ- mental consequences. Detailed comments on each of these items are found in Enclosure 1. If you have questions regarding these comments, please contact me at 561-6131. Sincerely, AARGirror Elizabeth A. Benson Project Review Coordinator Enclosures Mr. ccs Powers -2- Gayle Berger, ADNR, Fairbanks Al Ott, ADF&G, Fairbanks Mike Wheeler, ADEC, Anchorage Wade Srock, ADNR/DO&G, Anchorage Warren Matumeak, NSB, Barrow Randall Weiner, TFA, Anchorage Rex Blazer, NAEC, Fairbanks September 11, 1990 ENCLOSURE 1 STATE OF ALASKA COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT OCS LEASE SALE 126 AK90072416/A The state has consistently support environmentally sound explora- tion and development of the Alaska OCS. The first step in achieving a proper balance between OCS development and environ- mental protection is to appropriately schedule and configure lease sales. The state resource agencies have reviewed the DEIS for proposed OCS Lease Sale 126 and have developed the following comments and recommendations on the DEIS generally, and specif- ically on the proposed lease sale configuration and mitigating measure to assist MMS and the Department of the Interior in their planning efforts. DESCRIPTION OF THE AFFECTED ENVIRONMENT (Section III) Although most of the information describing marine mammal dis- tribution is accurate, the distribution shown in Graphic No. 2 should be modified as follows: 1) Add the summer habitat used by Pacific walrus nursery herds; 2) The summer habitat of spotted seal and belukha is much more extensive than shown, and includes the area at least 20 nautical miles seaward from the south end of Kasegaluk Lagoon, least the numbers given in the text should be qualified to denote that they are late 1970's estimates. Por walrus, cite the most recent reference on population abundance (Gilbert, 1989. Marine Mammal Science 5:17-28). Furthermore, there should be a clear statement that there are no current programs in place to monitor population abundance or trends for species discussed in the text, except ringed seals. And finally, Stellar sea lions should be included in the discussion of "threatened and endangered spe- cies," as this species has been listed as "threatened" since April 5, 1990. Likewise, the description of subsistence activities should be expanded. For example, maps depicting polar bear hunting areas are missing. Such information is available for Point Lay. Also, although Atqasuk is a community that will potentially be affected by oil development resulting from this sale, the DEIS does not include land use maps for that village. Some of the references for the subsistence discussion are missing (e.g., "North Slope Borough 1988") or are not available to the public (e.g., Steven A Braund and Associates 1989 a and b). Population numbers for marine mammals should be updated, or at AK AK ENVIRONMENTAL CONSEQUENCES The DEIS underestimates the environmental consequences of the proposed lease sale for three reasons: (1) the assessment of the effects of oil spills underemphasizes the effects of a winter spill; (2) there is inadequate consideration for the different life history characteristics among species that would be affected by the spill; and (3) the effects of noise and disturbances, Particularly in the spring lead system, are underestimated. The effects of a winter spill are apparently based on the assump- tion that oil entrained under the ice will essentially freeze in place and be released in less toxic form during spring and summer. To our knowledge, there are no data to support this assumption. In addition, the winter spill scenario does not account for a major spill in open water or broken ice -- for example, from the major pipeline that runs the length of the flaw zone (figures Iv-A-8 and 9) -- where oil can reach the surface. In the flaw zone, where marine mammals and birds are concentrated 5 during the spring, a spill would immediately reach the surface where it could effect these fish and wildlife resources. Our experiences with the Exxon Valdez oil spill gives us little reason to believe that the scenario described by MMS would be a realistic portrayal of the extent and severity of such a spill. This is especially the case because much of the Sale 126 dis- cussion is a repeat of the Sale 109 discussion, which was pre- pared prior to the Exxon Valdez spill. With regards to the effects of a spill on wildlife species, the DEIS should not mix such diverse groups as polar bears and pinnipeds. Polar bears may be affected more adversely than, for example, bearded seals because polar bears are (a) very suscepti- ble to mortality from contact with oil, (b) are relatively AK concentrated along the flaw zone especially during spring, (c) may be attracted to cleanup activities and thus encounter oil, 6 and (d) may indirectly contact oil by preying on oiled seals. Purthermore, as the DEIS points out, the number of adult female polar bears that are available to maintain the population is relatively much fewer than the number of females for most pinniped species in the area. The DEIS also implies that the effects of disturbance would be relatively minor because most species are distributed widely; therefore, few individuals would be affected at any time. This assumption could be incorrect in spring and early summer when AK marine mammal and bird species are concentrated in the flaw zone, and marine vessel traffic could also be concentrated there. In 7 addition, although the effects of disturbance may not be lethal, that does not mean they are unimportant. Therefore, we recommend that the assessment of impacts be mod- ified as follows: 1. Base Case polar bear - moderate pinnipeds - low whales - moderate 2. High Case polar bear - high AK pinnipeds - moderate whales - moderate 8 3. Point Lay Deferral polar bears (as above, depending on the assumed base or high case) spotted seals - low belukhas - low 4. Cumulative Case polar bear - high whales - high Stellar sea lion, ringed seal, northern fur seal, bearded seal, harbor seal, sea otter -- moderate LEASE SALE CONFIGURATION The state has consistently supported deferring the coastal blocks known as the Chukchi polynya. The Chukchi polynya is an impor- tant spring migration corridor for waterbirds and bowhead and belukha whales. It is an open-water ice “lead system" that occurs along the eastern shore of the Chukchi Sea. The lead system is extremely important to marine mammals and sea ducks, particularly bowhead whales and king eiders, as a spring mi- gration corridor. Oil spills in this lead system could directly and severely impact these species. Noise and other disturbance caused by industrial activities such as drilling, supply, and ice AK Management activities, in this area also have the potential to disrupt the spring migration of bowhead whales, because whales 9 are restricted to the lead system during spring migration. Although the risk of impacts caused by exploratory drilling would be minimized by the adoption of proposed Stipulation No. 8, this protection does not extend to production. While we understand that MMS may conduct additional comprehensive environmental qtudies prior to production we cannot rely on the actual implementation of a seasonal restriction by MMS. MMS has failed to adopt a seasonal restriction as mitigation for both Lease Sales 97 and 109 and has waived such a restriction in the past for other exploratory operations in the Beaufort Sea. We contin- ue to recommend a deferral of the Chukchi polynya (Alternative IV - Point Lay Deferral). If commercially producible quantities of oil are found in offshore leases, and if there emerge demon- strably practical technologies to explore and develop the Chukchi polynya area with negligible impact on fish and wildlife popu- lations and their habitat use, and on subsistence uses, then additional lease sales including the nearshore area could be offered in the future. In addition, while we are pleased that the DEIS includes a description of the coastal deferral (Alternative IV - Point Lay), we recommend that the deferral area be expanded in the Final EIS to include all the area devoted as the "flaw zone" in Graphic No. AK 2. 9 Furthermore, during review of the Call for Comments for Sale 126, the state recommended that the lease sale be limited to areas of hydrocarbon potential that receive industry nominations of medium to high priority. Generally, the proposed sale area appears to include most of the planning area with the exception of some coastal blocks (Figure I-2). If the conditional resource esti- mates are considered, the Alternative I Base Case and Alternative Iv have identical oil production figures (Table II-A-1). Alter- native IV defers leasing of 501 blocks located 25 to 75 miles offshore. These data indicate that the hydrocarbon estimate remains the same if this deferral is adopted and that the Point Lay deferral blocks have little oil resource potential. The Department of the Interior (DOI) has continued to publicly support a "focused" leasing policy, and that those areas where there is strong geological evidence or a potential oil strike would not be offered for lease. The state supports the DOI's continued commitment to reduce the size of lease offerings and focus on areas of high hydrocarbon potential while withdrawing those areas where there are serious environmental concerns, such as the Chukchi polynya. MITIGATING MEASURES As we have stated regarding past OCS lease sales, the state prefers the use of mitigating measures in lieu of deferrals whenever scientific information and technological capabilities enables leasing to proceed in an environmentally sound manner. Not only should stringent protective measures be in place prior to leasing in this area but development in the planning area should not occur until comprehensive environmental studies are conducted, The mitigation measures proposed for Sale 126 generally include those proposed for Sale 109, with the exception of a seasonal drilling restriction during the spring bowhead whale migration. New stipulations deal with coordination with subsistence whaling (Stipulation 6, which was previously an Information to Lessee (ITL) measure in Sale 109), oil spill response preparedness (Stipulation 7), and density restriction for protection of bowhead whales (Stipulation 8). In addition to these stipu- lations, eight ITL's are proposed for Sale 126. The state supports adoption of all of these proposed mitigation measyres with the following additional provisions: Stipulation 6: Stipulation 6 should be expanded to include all subsistence activities, not just bowhead whaling. A useful model AK for such a stipulation is MMS Information to Lessees (ITL) No. 3 10 in the DEIS for Norton Sound Offshore Mining Leasing. Stipulation 7: This proposed new stipulation on oil spill response preparedness does little more than restate oil spill response measures currently in existence. Oil Spill Contingency Plans (OSCPs) must already be submitted and drills are already required under MMS regulations. This stipulation was most likely proposed as a consequence of heightened public concern in re- sponse to some recent oil spills. However, the only new require- ment in this stipulation is that drills must be conducted under realistic conditions (including solid-ice, open-water, and broken-ice), and must include deployment of onsite response equipment and additional cooperative equipment identified in the OSCP. To strengthen this stipulation, the state suggests the following three modifications: 1) prior to drilling in oil and/or gas bearing strata, the lessee must adequately demonstrate response prepared- AK ness for those conditions that may occur during the proposed drilling schedule (e.g., if drilling will dat occur during broken-ice conditions then the lessee must adequately demonstrate response preparedness in brok- en-ice conditions, if drilling will occur during open-water and broken-ice conditions then the lessee must demonstrate response preparedness in both open-water and broken-ice conditions); 2) if a less fails to adequately demonstrate response preparedness for a given condition (solid-ice, open-water, or broken-ice), then the drilling operation must not continue during that given condition until such time as inadequacies in the response preparedness are addressed and the lessee successfully passes a new spill drill; and 3) the decision on whether or not a lessee successfully passes a spill drill shall be made by a committee composed of representatives from those federal and state agencies currently required to review the OSCP. We also request that the following language be added as a fourth AK modification to Stipulation 7: a 4) The lessee shall be required to demonstrate same-season relief well drilling capability. This addition, if adopted by MMS, will require operators to have a same-season relief well capability, and thus avoid a multi-year blow-out spill scenario. We also recommend that MMS expand the stipulation to include state approval of all types of fuel and oil spill prevention programs, to fund prevention research, and provide for informa- tion transfer on prevention technology. State of Alaska Response AK-1 The text and/or Graphic No. 2 have been revised to reflect additional information concerning distribution of spotted seal and walrus. Although there appears to be no doubt that some spotted seals forage offshore, particularly when the ice front is located in the vicinity of coastal concentration areas, we have been unable to verify the 20-nautical-mile distance cited in this comment. Response AK-2 Section III.B.4 has been updated with regard to the estimated size of the walrus population; population estimates for other species incorporate the best available information. Budgetary constraints preclude MMS from undertaking a comprehensive program of monitoring for all species.. The MMS currently is funding marine mammal and marine bird surveys in the Kasegaluk Lagoon area, and has funded ringed seal studies in recent years. Stipulation No. 2, Protection of Biological Resources, although concerned more with isolated animal concentrations than variations in distribution and abundance of populations determined over long periods, could provide information potentially useful in responding to, e.g., oil spills where population distribution and status information may be used to focus the response. Response AK-3 The Steller sea lion analysis (Sec. IV.H.12.b(3) of the DEIS) appears in Section IV.H.2.b(5) (Endangered and Threatened Species) of the FEIS. Response AK-4 The maps selected (Figs. III-C-6 - III-C-11 and IV-C-4) represent appropriate coverage of the harvest- concentration areas of the communities principally affected by Sale 126 activities. Although polar bear- harvest-concentration-area maps are not included in this EIS, a discussion of the locations in which they are hunted is included in the text (Sec. III.C.2). The polar bear take represents a small fraction of the total subsistence harvest of the communities studied. Point Hope harvests the highest percentage of polar bear (1.1%) as a portion of total subsistence harvest. The marine mammal-harvest area for Atqasuk is subsumed under the marine-harvest regime of Barrow. A discussion of the reasons upon which this assumption is based can be found in Section IV.C.11. The bibliographic citation "North Slope Borough, Planning Department. 1986" has been revised to "North Slope Borough, Planning Department. 1988." The two referenced Braund reports can be obtained from the MMS Alaska OCS Region Library as Technical Report No’s. 135 and 136. These reports are also available from the National Technical Information Service (NTIS). The MMS librarians can assist the general public in ordering any MMS publications. Response AK-5 The effects of a winter spill are not based on the assumption that all the oil will be released in a less toxic form. Oil pooled on the surface of the ice will be toxic to animals and birds as it weathers. Section IV.J has been modified to clarify the difference between first-year and multiyear ice and the interaction with petroleum. Multiyear ice will discharge unweathered oil directly into the water column as it melts. First- year ice allows for brine-channel migration and weathering of the oil before subsequent release into the water column. The data was taken from an article by Martin (1979) entitled "A Field Study of Brine AK-1 Drainage and Oil Entrainment in First-Year Sea Ice." From field observations this paper describes the growth and development of first-year sea ice and its interaction with petroleum. Section IV.J discusses the interaction of a spill in a flaw-lead zone with marine and coastal birds, pinnipeds, polar bears, and endangered species. The spill-scenario extent was calculated using an oil-in-ice-weathering model (Payne et al., 1987) and historical data. Most Exxon Valdez-spill data is not available for analysis at this time. Available, published reports from the Exxon Valdez spill are included where appropriate. Response AK-6 Although the noncetacean marine mammals are a diverse group, the MMS believes that the analysis of potential effects has been kept sufficiently distinct by treating species or species groups in separate paragraphs, thereby providing separation of attributes and effects peculiar to a given species. In this regard, the text of Section IV.C.6 has been revised to include additional information on the polar bear. Response AK-7 Nowhere in this analysis does it state that disturbance is unimportant; rather, it states that disturbance is not expected to be significant. Available evidence suggests that the likely level of disturbance and interaction with wildlife populations will not be sufficiently great in most instances to elevate the concluded effect to the next higher level. The text of Section IV.C.6 has been revised to include additional information on potential disturbance of polar bears in particular. The MMS would appreciate any further information that might be available. Response AK-8 The overall environmental consequences determined in this analysis for each species or species group have incorporated the best available information. Regarding the concern for pipeline locations (e.g., Fig. IV-A-8), these locations are strictly hypothetical for purposes of discussing potential effects. If development occurs, a developmental EIS as well as a development plan will show planned pipeline locations; and there will be ample opportunity to comment on both of these documents. As noted in Response AK-6, we feel that the analysis of potential effects on noncetacean marine mammals has been kept sufficiently distinct by treating species or species groups in separate paragraphs, thereby providing separation of attributes and effects peculiar to a given species. As noted in Response AK-7, available evidence suggests that the likely level of disturbance and interaction with wildlife populations will not be sufficiently great in most instances to elevate the concluded effect to the next higher level. Thus, MMS considers that the appropriate conclusion regarding the expected effect level has been determined. In the cumulative case, the effect on the polar bear has been elevated to the moderate level to reflect the potential for concentrations to occur. The MMS disagrees that the Steller sea lion qualifies only for the moderate effect level, as suggested by the State; instead, we concluded a very high effect level, reflecting this species’ recent precipitous population decline. Response AK-9 A considerable number of factors enter into the decision process by which the boundaries of deferral alternatives are drawn, including the critical habitats and flaw zone of the Chukchi Sea. The western boundary of the flaw zone shown on Graphic No. 2 in the Sale 126 DEIS, however, is only indicative of possible annual and seasonal boundary locations and cannot be used with precision to describe a lease-sale boundary. This is why a cautionary note to readers is provided on Graphic No. 2 to underscore the imprecision of the data described. Please note that Stipulation No. 8, Density Restriction for Protection of Bowhead Whales from Potential Effects of Noise, as described in the DEIS, has been deleted as a potential mitigating measure because it is AK-2 inconsistent with recent NMFS regulations on incidental take of bowhead whale and not required by the Arctic Region Biological Opinion or the Sale 126 Biological Opinion. Response AK-10 The wording of Stipulation No. 6 has been changed to include all subsistence activities. Response AK-11 The stipulation is a summary of the detailed requirements for oil-spill preparedness and drills and training contained in 30 CFR 250.42 and 250.43. These or similar requirements have applied to all previous Alaska OCS lease sales and activities. We would also like to stress that, to date, only exploratory drilling has occurred on the Alaskan OCS; therefore, current practices for OSRD’s are based on the type, location, season, and duration for each exploration activity. If development and production from the Alaska OCS Region were proposed, additional requirements and practices for conducting oil-spill-response drills (OSRD) would be developed commensurate with the type, location, and scope of proposed activities. Item (1) of this comment suggests that MMS set a threshold depth before which the OSRD must be held. Although this specific point is not addressed in the stipulation, the Alaska OCS Region requires that drills be held before drilling below surface casing, to ensure that OSRD’s are completed well above potential hydrocarbon accumulations. The following summarizes the requirements for timing and frequency of drills for exploration drilling: (1) when pollution-control equipment is initially put in place and, in the case of a new well, before drilling out of the surface casing; (2) at least every 12 months; (3) if environmental conditions change during exploratory operations (i.e., open water to solid ice); and (4) upon request of the RSFO. The MMS also requires a Table Top/Communications Exercise for testing the lessee’s communications, knowledge of the Oil-Spill-Contingency Plan (OCSP), and ability to initiate a response to a major oil spill. Item (2) of this comment suggests that MMS not allow drilling in a particular ice season until a satisfactory OSRD is conducted in that particular ice season. As indicated above, the Alaska OCS Region requires the lessee to demonstrate adequate response preparedness for each type of environmental condition that occurs during drilling operations. This also is reflected in potential Stipulation No. 7, which requires lessees "to conduct drills. . .for appropriate environmental conditions, e.g.: solid ice, open water, and broken ice conditions." If well-drilling activities should continue year-round in the Arctic, the operator would be required to conduct a drill in solid ice and in open water/broken ice. If, upon evaluation of the results of the OSRD, the RSFO finds the response inadequate, the RSFO may require the lessee to conduct additional drills to correct any deficiencies found. Item (3) of this comment requests that MMS create a committee composed of representatives from State and Federal agencies to provide an adequacy decision for the OSRD. The RSFO is responsible for evaluating OCS OCSP’s and related activities, and MMS cannot transfer this statutory responsibility. In the Alaska OCS Region, the principal State and Federal agencies involved in oil-spill response (U.S. Coast Guard and Alaska Department of Environmental Conservation) are involved through review and comment on OSCP’s and through attending and observing the OSRD. All advice and comments are incorporated into the RSFO’s decision to approve or disapprove the plan and drills. This method has proven satisfactory, and we see no need to modify this process. For the Alaska OCS Region, MMS requires lessees to submit, with an exploration plan, their contingency plans for drilling a relief well should a blowout occur. This includes information on the availability of backup equipment, including a relief-well rig and support craft (including icebreakers, when appropriate) and the timing to obtain, initiate, and complete a relief well. The lessee is required to provide the MMS with updated information on the location and availability of drilling rigs capable of operating in the environment AK-3 where operations are proposed prior to each drilling season and of any changes during the drilling program. The MMS requires mutual assistance/relief-well-drilling-rig agreements between the two operators conducting concurrent operations in the same area to facilitate and expedite relief-well drilling. The adequacy of the relief-well plan is determined based on individual circumstances including the type and location of proposed activities, the type of drilling unit, other operations in the area, and company plans for monitoring environmental conditions and well status and curtailing operations and securing the well prior to the end of the drilling season. In the Chukchi Sea, floating drilling units will be used for exploratory drilling. Floating drilling units are capable of moving offsite in the event of a blowout and starting a relief well almost immediately. There are currently four drilling units and associated icebreakers and ice-class support vessels that have been successfully used in the U.S. and Canadian Arctic, and that are available in the Arctic and can be mobilized to support a relief-well-drilling program in the Chukchi Sea. The likelihood of an oil blowout occurring during exploration drilling is extremely low. There has never been an oil spill resulting from an OCS exploratory-well blowout. Blowouts typically are a result of shallow gas without any oil that lasts for short periods of time. Bridging (including depletion) of blowouts (oil and gas) occurs greater than 70 percent of the time, with bridging occurring shortly after the blowout. Relief-well drilling has been attempted for approximately 4 percent of those blowouts that did not naturally bridge (Norwegian Oil Review, 1985). Prevention is the key to mitigating the risk of an oil spill resulting from a blowout. The MMS regulations establish strict requirements in the form of performance standards to ensure that operations will not result in an unsafe condition. Plans, equipment, equipment inspection and maintenance, testing, and training requirements all contribute to the low risk of a blowout on the OCS. Recent technological advances and continuing high levels of research are improving the safety of drilling in the Arctic, thus reducing the already negligible potential for a blowout. The MMS maintains a near-continuous inspection presence at each exploratory-drilling location and monitors the progress and status of the well and environmental conditions on a daily basis, including well depth, type of operation (drilling, coring, logging), next planned operation, the timing for completing current operations, the next planned operation, downhole conditions, and potential problems in maintaining well control. The MMS has the authority to require that operations be suspended in the event that ongoing operations could increase the risk of well-control problems or, continuing with the next operations following completion of ongoing operations such as drilling to the next casing point following setting and cementing casing, could not be completed before the end of the drilling season. The costs associated with drilling an exploratory well in the Chukchi Sea are high. Same-season relief-well capability significantly affects an already restrictive and short drilling season in the Sale 126 area, which could require a second season to complete the drilling of a single well or maintain a second drilling unit at the site. The costs associated with such a requirement would be substantial and would not significantly increase safety or reduce risk. The MMS recognizes the importance of relief-well panning for exploratory-drilling activities in frontier areas such as the Chukchi Sea. The MMS believes that regulatory requirements for documenting relief-well capabilities in conjunction with MMS? inspections and monitoring of well status and environmental conditions on a real-time continuous basis for each site-specific activity, and authority to require operations be suspended, provide an effective and prudent mechanism to ensure that drilling activities are not continued if there is a significant risk of lost well control and remedial action, including drilling a relief well, could not be conducted. In response to the State recommendation that "MMS expand the stipulation to include state approval of all types of fuel and oil-spill prevention programs, to fund prevention research, and provide for information AK-4 transfer on prevention technology," we must point out that MMS cannot transfer the statutory responsibility for approval of oil-spill-contingency plans and related activities. AK-5 NORTH SLOPE BOROUGH OFFICE OF THE MAYOR P.O. Box 69 Barrow, Alaska 99723 Letter to Alan Powers September 11, 1990 Phone: 907-852-2611 Page 2 George N. Ahmaogak, Sr., Mayor September 11, 1990 Mr. Alan D. Powers Regional Director Minerals Management Service Alaska OCS Region 949 East 36th Avenue, Room 110 Anchorage, AK 99508-4302 sep is RE: DRAFT EIS PROPOSED OCS LEASE SALE 126 Dear Mr. Powers: As was the case with proposed Beaufort Sea Lease Sale 124, “long and forceful testimony was heard at recent meetings in our North Slope villages in opposition to the leasing of Chukchi Sea blocks in proposed Lease Sale 126. The same strong concerns over the safety of drillship operations which were expressed at those hearings have been detailed in our May 8, 1990 comments to you on the Sale 124 Draft EIS. We attach and incorporate our Sale 124 comments here for reference, and have the following additional comments on the Sale 126 Draft EIS. ° ‘o IG SEASON RELIEF WELL The North Slope Borough does not believe that the oil industry has the capability to effectively respond to, contain, or clean up a major oil spill if one occurs in arctic waters. We have seen nothing in the Draft EIS or any exploration or oil spill contingency plan we have reviewed which changes this view. A major concern in this regard is industry's apparent inability to substantially guarantee the completion of a same- season relief well in the event of a late season blowout, or even to plan to cease drilling early enough to provide the appropriate drilling window to accomplish such a task. Accepting, as we do, that same-season completion is essential in all cases when a relief well is called for, we believe that exploratory driliing should be halted no later than a date which would provide the minimum TOR, ALACKA OCS 1 S2mvicg S8A NSB NSB operational window before ice and other environmental conditions can be expected to prevent safe drilling of a relief well. While this logic seems to us so elementary, it is not provided for in the Draft EIS or any contingency plan we have reviewed. This failure to appropriately restrict operations to minimize the likelihood of what could be a devastating multi-year blowout gives us great cause to question a succession of other claims that oil spill threats are minimal. The Draft EIS discusses oil spill risk factors, including potential dispersion patterns of spilled oil, shoreline impacts, recovery techniques, localized and long- term wildlife and subsistence impacts, and appropriate measures to protect environmentally sensitive areas and vulnerable resources. These risk assessments are suspect if impacts from a multi-year blowout are more likely than they have been considered to be. SECTION IT OCCURRIN! EATLUBE TO PLAN FOR SPILL RE RONSE Lit IVIRO} ‘AL COND NS OFTEN We also do not believe that MMS has adequately considered industry's inability to respond to a major spill in the combination of environmental conditions which can often occur in the proposed sale area. The Draft EIS and contingency plans we have reviewed contain extensive discussions of spill response techniques in varying ice conditions, but do not describe how these techniques would be affected by other conditions which our people know often occur in tandem with significant ice cover. This is particularly worrisome given that the same condition which would likely render on-site containment ineffective (e.g. high waves) would often bring with it other conditions which will impair secondary response. In other words, a raging October storm, with sea states of 4 or higher, with 20-30 knot winds, low visibility, and some broken ice for good measure would seem to us to hobble both primary and secondary response efforts. Also absent from the Draft EIS is any discussion of the possibility that fog, wind, precipitation, waves, or ice conditions can severely hamper spill response efforts not only at the spill site, but also for long periods at locations where secondary equipment and personnel are to be mobilized and transported to the site. We believe that MMS should require exploration and contingency plans to contain a clear discussion of the effectiveness of suggested mechanical containment and recovery equipment in the specific environmental conditions or combination of conditions which are likely to occur at proposed drillsites. NSB 2 Letter to Alan Powers September 11, 1990 Page 3 Even before that point, however, MMS should include in the EIS the same analysis for various locations within the proposed sale area. To us it is simple; you should not lease a specific area unless you are certain that the best available response technology, applied most effectively, can perform adequately in the full range of conditions which can be expected to occur at that site with some frequency. Any claim that this region-specific capability analysis would be too burdensome an undertaking for such a large sale area just points out the inappropriateness of offering for lease an area so huge that it contains markedly different environmental conditions. Despite what may be the best efforts of individual oil companies, we believe that if industry does not have the capability to prevent a major oil spill from having significant impacts on the arctic environment, wildlife resources, and our subsistence culture, then continued leasing should not occur. Simply requiring the use of state-of-the-art equipment and techniques is not good enough if those measures cannot achieve the goal of environmentally safe exploration. s ° 10 It is important to understand that questions of noise impacts and proper mitigation measures should not even be raised unless and until industry can meet its burden of establishing that it can operate without the threat of significant oil spill impacts. Only then must operations be further tailored to minimize disturbance of sensitive species and critical subsistence activities. A variety of marine mammal species disturbance utilize the proposed sale area. Bowhead and beluga whales migrate through the Chukchi Sea. Seals and walrus use the waters and ice for feeding, resting, and rearing their pups, and are in turn fed upon by polar bears, which are vulnerable to displacement from preferred denning areas with increased industrial activity. Likewise, critical waterfowl habitats could be impacted by the noise from support activities. sensitive to noise Recent observations of spotted seals in Kasegaluk Lagoon and the surrounding area by scientists from the North Slope Borough and the Alaska Department of Fish and Game reinforce concerns that these animals are particularly sensitive to aircraft noise. A large number of seals utilize the area during the open water season. Census attempts from heights of 1000 feet failed as the Letter to Alan Powers September 11, 1990 Page 4 animals quickly retreated to the water from haulout areas. From land, the observers witnessed approximately 450 seals flush back into the water in response to an overflight by an aircraft at about 500 feet. A very few seals (perhaps 30) did haul out again several hours after the overflight. Up to five hours after the disturbance, seals reacted twice to the sounds of planes flying well above 3000 feet by flushing into the water. These observations conflict with the conclusions found on pages IV-C-42 and 43 of the Draft EIS that seals may habituate to fairly high levels of human activity and that site-specific effects of aircraft disturbance on seals are likely to be low. An increase in aircraft traffic associated with increased industrial activity or a large spill response effort could significantly increase the physiological stress in spotted seals by shortening or eliminating the duration of haulout and feeding periods. The disturbance would of course be more pronounced if it occurred in preferred haulout or feeding areas. Seals, already sensitive to noise disturbance, may be more vulnerable to harm from an oil spill if it occurs at a time of stress (Geraci and St. Aubin. 1980. NMFS Mar. Fish. Rev. 42:1- 12). We would expect the same to hold true for all the pinniped species found in the proposed sale area. SECTION IV. ON OF SC RECORD When the primary purpose of the EIS process is to provide a basis for the assessment of the environmental risks posed by a particular action, it should go without saying that it is essential that all references to the scientific record must be accurate. Few, if any, reviewers of a document the size of the Sale 126 Draft EIS have available the time or resources to examine the full text of each and every source cited. We have found that this document does not accurately reflect the scientific record, and are particularly disturbed that certain inaccuracies concern one of the central issues surrounding the propriety of continuing to allow industrial activity in our waters. Only through careful examination of the referenced study report were the inaccuracies of Section 7a(3) (a) on pages IV-C-49 and IV- c-50 of the Draft EIS discovered. This section discusses the potential impacts of oil contact on endangered whales. Throughout the section's 7 paragraphs, the 1982 report by Geraci and St. Aubin is repeatedly cited as evidence of the lack of threat posed by exposure of bowhead whales to gasoline or crude oil. This "proof" of no impact oversimplifies the study and is misleading when Letter to Alan Powers September 11, 1990 Page 5 compared to the actual data in the report. noted below. Consider the points i. Paragraph 2 of the section indicates that even after 75 minutes of gasoline exposure dolphin skin was unharmed and “at no time was there any swelling, hemorrhage, or break in the continuity of the skin associated with exposure to gasoline". This is misleading because the report on page 90 states that 3 of the 4 tested dolphins developed blisters on the skin. Two developed skin blisters after 30 minutes exposure and the third developed skin blisters after 45 minutes exposure. 2. Paragraph 2 of the section also refers to a 17 hour exposure of the skin of a "living sperm whale" to crude oil. Paragraph 2 notes that "After 17 hours of exposure to crude oil, the contact sites were normal in appearance and the skin was only mildly affected". Paragraph 2 would not be so misleading if it also noted that it was not a 17 hour exposure study on a living whale, but rather was something much less. In this regard refer to pages 153-154 of the report. The whale was stranded and was dying. Although the oil was on the skin for 17 hours, the whale was dead for 5-10 of these hours. In reality the experiment was on a dying stranded whale and the period of "live" exposure was not 17 hours but rather was an unknown period of probably 7-12 hours. It would also have been helpful if the DEIS would have noted the effect of gasoline exposure after "17 hours". In that instance (page 157 of the report) there were "dramatic changes", and "the original skin surface could not be defined and the upper 1/2 to 1/3 of the epidermis was pale gray and had the consistency of thick paste". This misstatement of the record on an issue at the heart of the debate is grounds we believe for a rejection of the Draft EIS's entire risk analysis. Before the document can be accepted in final form, we expect to see evidence that MMS has reviewed for accuracy not only the particular section highlighted above, but also every other cited reference on which conclusions of insignificant impacts are based. CONCLUSION We often hear comments when we raise objections to offshore industrial operations about the national security interest in exploring for new sources of domestic fuel. Any national security z—l Letter to Alan Powers September 11, 1990 Page 6 interest must be weighed against the potential devastation of some of the country's very last unspoiled wildlife habitat, its many unique and vulnerable arctic species, and the traditional Native subsistence culture of the Inupiat people. Before anyone questions our commitment to domestic energy security, they should consider their own resolve to pursue long-term solutions of potentially far greater import than business-as-usual OCS development. No one can honestly dispute that a national energy policy, including relatively simple conservation measures, requiring fuel-efficient vehicles, and development of alternative energy sources, would go far beyond exploitation of the arctic OCS to reduce dependence on foreign oil. Thank you for considering these comments. Sincerely, Zh w. +7 Mayor fina fbi Per} Ahmaogak, Sr. cc: Steve Cowper, Governor Ron Morris, NMFS Mayor Don Long, Barrow Mayor David Bodfish, Sr., Wainwright Mayor David Stone, Sr., Point Hope Mayor Amos Agnasagga, Point Lay Dan Fauske, CAO Warren Matumeak, Director, Planning Ben Nageak, Director, Wildlife Management Burton Rexford, Chairman, AEWC Jessica LeFevre, AEWC Attorney Elizabeth Benson, Division of Governmental Coordination Eugene Brower, President, BWCA Tom Albert, NSB Wildlife Management Randall Weiner, Trustees for Alaska Tom Lohman, Assistant Borough Attorney Dennis Roper, Federal Affairs mayor\powers.gna NORTH SLOPE sb neapannn OFFICE OF THE MAYOR P.O. Box 69 Barrow, Alaska 99723 Letter to Alan Powers May 8, 1990 Page 2 Phone: 907-852-2611 George N. Alunaogak, Sr, Mayor step (leasing) should be undertaken unless and until firm assurances can be made, based on good scientific evidence, that the intermediate step (exploration) and final steps (development and transportation) can be undertaken safely and with minimal disturbance of wildlife and subsistence activities. Without that essential base scientific evidence, including a much broader Nay 8, 1990 understanding of arctic ecosystems, noise impacts, and the effectiveness of oil spill clean-up techniques in the region, the leasing and regulatory agencies are playing a high stakes guessing game with our shared biological heritage and the {fnupiat culture. Zren png wie Alan D. Powers Regional Director Minerals Management Service 949 East 36th Avenue, Room 110 Anchorage, AK 99508-4302 We are not alone in questioning the sufficiency and quality of the scientific information which has underlain federal and state decisions concerning offshore industrial activities. The Arctic Research Commission was created by the Arctic Research and Policy Act of 1984 (15 USCS § 4102) to "promote Arctic research and to RE: PROPOSED BEAUFORT SEA LEASE SALE 124 recommend Arctic research policy", and is composed of five members appointed by the President. In December 1989 the Commission published a fourth in its series of FINDINGS AND RECOMMENDATIONS Dear Mr. Powers: reports with the title IMPROV UTS TO THE SCIENTIFIC CONTENT OF As should have been very evident from the testimony of our THE ENVIRONMENTAL IMPACT STAT! f PROCESS. The report states that residents at the well-attended public hearings in Barrow, Kaktovik, the Commission undertook a review of the EIS process "(b]ecause and Nuigsut on April 17, 18, & 19 respectively, the North Slope accurate scientific and technical information and adequate data Borough remains strongly opposed to this proposed offshore lease bases are such a fundamental requirement, and because the Arctic sale. The reasons given for opposition to the sale by Borough and Presents very unique environmental problems".(p. vii) The local officials, our elders, whaling captains and crews, wives and Commission identified an imperative need to improve the EIS process mothers, social and health workers, tribal representatives, in several respects, but concluded that the “most critical biologists, and many others were varied, but together left little deficiency is the absence of impartial external quality-control doubt about the local sentiment against offshore activities in the mechanisms for the data and information used in the stages of Beaufort Sea. We continue to believe that oil and gas leasing, scoping, synthesis and EIS preparation, and the follow-up exploration, and development should be restricted to onshore or monitoring programs." (p. 1) While we urge you to carefully review shallow-water tracts, where proven techniques and technologies can and respond to the entire briet report before proceeding with this be employed to significantly limit impacts from both day to day lease sale or permitting any other industrial activity on the operations. and catastrophic events. No one can yet make the same Alaskan OCS, several of the document's findings and conclusions claim with’ respect to offshore operations requiring the use of merit spec{al mention here: drillships, These comments will be in two major parts; Section I . will discuss our general position that leases should not be sold p.5. The effects of man-made environmental insult are in the arctic OCS in waters which would require drilling from aggravated by the relatively small number of species in floating structures, and Section II will deal with specific arctic ecosystems and the slowness of environmental provisions of the Sale 124 Draft EIS. recovery (environmental fragility). The result is that there are few comparable precedents on which to base EIS O} LES It ‘1 Cl 10T_ SU “ predictions in Alaska, and that the environmental consequences of erroneous predictions can be far more We believe that the path from leasing to development is a serious and long-lasting than in temperate regions. downhill one; that a bias in the regulatory process increases the likelihood with each successive step that the following step will In the Arctic, including the Alaskan Arctic, there is a find approval. Recognizing this, we do not believe that the first serious lack of data and information concerning the Letter to Alan Powers May 8, 1990 . Page 3 physical and biological (ecological) environment covering long periods of time, on a decadal scale. p.6. The scoping process is sometimes perceived to be organized to support decisions already made. EIS's are often viewed as supporting agency opinions rather than being the basis for such opinions. Too many nonverifiable hypotheses and unstated assumptions are included in the EIS, and much of the documentation is based on the "gray literature." p-1l. To improve the EIS process, impartial external scientific and engineering review mechanisms should be established for each of the following three stages: The scoping plan; Synthesis and preparation of the EIS; and Environmental monitoring programs. Some decisions stipulate that an environmental monitoring program is to become part of the project. Peer review of the design of the monitoring procedures will help assure accurate and usable results. Also instructive is the February 1990 final report of the Alaska Oil Spill Commission, entitled "SPILL: The Wreck of the Exxon Valdez". While this report focuses primarily on the Prince William Sound tragedy, it also contains several important general observations, as well as specific recommendations concerning continued industrial activities in the arctic. We ask that you consider the entire report and respond to these points before you proceed with this lease sale: p.100.. The consequences of the Exxon Valdez oil spill have brought into question the usefulness of existing oil spill containment and pollution-abatement technologies, not only for a catastrophic spill the size of that from the Exxon Valdez (10.8 million gallons) but also for any major oil spill in an offshore, remote or sensitive area. In general, none of the currently available technologies are adequate for these incidents. In the United States, almost all existing technology has been developed for use in harbors and other protected waters, not in offshore, remote or environmentally sensitive waters. Letter to Alan Powers May 8, 1990 Page 4 p.125. Conclusions reached for Prudhoe Bay were that in summer the spill response would be effective for small spills, but that there was insufficient equipment to contain and recover a large spill. Contingency planning at Prudhoe Bay relies heavily on the ARCAT skimmer, but there have been no tests to see how well it recovers oil, specifically how well it would recover highly weathered Prudhoe Bay crude. During fall at Prudhoe Bay the spill response in a growing offshore ice field would be only marginally effective with present equipment. Spill response on shorefast ice would not be easy, but there would be more time to marshal heavy equipment and personnel out on the ice where scrapers and front-end loaders could recover the pooled oil. During breakup there could be a period of several weeks in which the only action response crews could undertake would be to watch the interaction of the ice and the spilled oil.... The picture is bleak for remote areas. An effective response effort for a large spill from a drill ship or a tanker accident very far from Prudhoe Bay or Barrow would be extremely difficult...(uJsing airborne applications of chemicals, either dispersants or gelling agents, has received no testing whatsoever in these conditions, and none is known to work on heavy crude oils at typical arctic temperatures. p.144. The long-term need to develop environmental safety regimes of great stringency cannot be ignored. Development of arctic oil discoveries dependent on maritime transportation should await the preparation of approved systems of oil transportation using experience gained from the trans-Alaska pipeline system. p.201. ° The commission does not think that oil should be developed to production in any arctic area without a substantial planning effort on the transportation leg. We have long argued that drilling from floating structures, and therefore lease sale terms which would permit such drilling, are insupportable in arctic waters. You simply do not have enough good baseline scientific data to appropriately assess the environmental risks posed. You do not know how bowhead (and belukha) whales are impacted by industrial noise; just how vital their ability to communicate is to navigation in heavy ice Letter to Alan Powers May 8, 1990 Page 5 conditions, whether heavy seismic activity has damayed the hearing of individual whales, whether whales have already been driven from traditional migratory and feeding areas, or if intense localized drilling, support, or seismic noise could act as a migratory barrier and subject a large aggregation of animals to increased risk from environmental hazards. You are not certain how whales and other organisms would be affected by exposure to spilled oil in the arctic environment; whether an entire migratory pulse of whales could be harmed by even a comparatively small spill which could not be avoided due to environmental conditions, how long oil and its toxic byproducts would persist and migrate in the cold and ice of the arctic, or how spilled oil would affect krill, mollusk, and fish populations, and the higher organisms which feed on them, including seals, walrus, whales, and man. You are unsure of industry spill response, clean-up, and containment technologies under ideal conditions and in accessible locations, much less in the harsh and remote environment of this proposed sale. All this and more is the information which must be known before the true risks of oil exploration, development, and transportation can be determined. Without really understanding these variables, rather than just paying lip service to them, you cannot know whether the risks outweigh, or are outweighed by, the supposed benefits which you also accept with little basis. We strongly recommend that the final EIS contain as a preferred alternative a sale which would only offer for lease those tracts in water depths which could be explored and drilled from islands or bottom-founded drilling structures. SECTION II. PREFERRED AI,TERUATIVE AND PROPOSED MITIGATING MEASURES OF DEIS DO NOT ADEQUATELY PROTECT SALE AREA ENVIRONMENT OR SUBSISTENCE ACTIVITIES As explained above, we do not believe any Beaufort Sea tracts should be leased which would require exploratory drilling to be conducted from floating structures. Drilling from floating structures, whether anticipated under the low, base, or high case scenarios offered in the DEIS, would not comply with the provisions of the North Slope Borough Coastal Management Program prohibiting (1) significant interference with subsistence whaling, (2) jeopardy to the continued availability of whales for subsistence, (3) depletion of subsistence resources below the needs of local residents, (4) preclusion of reasonable access to subsistence resources, and (5) noise disturbance in areas of concentrated wildlife, and those provisions requiring effective oil spill control and clean-up plans. Our belief that drilling cannot now be conducted from floating structures with the required assurances of, safety and non-interference with wildlife and subsistence Letter to Alan Powers May 8, 1990 Page 6 activities is reflected in the Offshore Urilling Policy contained in the revised Land Management Regulations recently adopted by the Borough Assembly. The debate over the need for, and scope of, any seasonal drilling restriction (SDR) to protect migrating bowhead whales has often dominated the discussions preceding previous Beaufort Sea lease sales, including Sale 97, held in March 1988. We have consistently argued that the burden falls on those desiring to lease and explore offshore tracts to prove that exploration, development, transportation and related activities will not have an adverse impact on these endangered animals or the subsistence harvest. To its credit, the State of Alaska has acknowledged the potential threats posed by industrial activities, and has recently adopted a revised Beaufort Sea SDR. This new policy, unfortunately, only addresses potential noise impacts, and has left to a later date further improvement of measures to minimize oil spill threats. The SDR embodied in our Offshore Drilling Policy, though applicable directly only in State waters, addresses both noise and oil spill threats, and will be our guide in any consistency review of proposals in federal waters as well. The policy is as follows: 19.70.040 Offshore Development Policies. The following policies are intended to guide the approval of development and uses in the portion of the Beaufort Sea within the Borough boundary. Case by case extensions to the time periods below may be granted during approval or as a use permit if the activity will not significantly impact subsistence activities, will have minimal environmental risk, and all review agency comments have been addressed. A. Drilling shall be conducted from bottom founded structures. B. ‘Drilling above threshold depth may occur year-round. Cc. Drilling below threshold depth shall be conducted during the winter (November 1 through April 15) and be completed as early in this period as practicable. D. Confirmation, extension or delineation driliing, well testing and other well completion activities shall be completed by June 15. Consistent with C above, any additional drilling or other activities shall not penetrate any new oil or gas bearing formations, or significantly increase the risk of an oil spill. Letter to Alan Powers May 8, 1990 . Page 7 E. All nonessential boat, barge and air traffic associated with drilling activity shall occur prior to or after the period of whale migration through the area. Essential traffic (traffic that could not reasonably occur prior to or after the period of whale migration through the area) shall avoid disrupting the whale migration, subsistence activities, and be coordinated with the Alaska Eskimo Whaling Commission. F. Year-round drilling can occur following the unitization and approval of the Plan of Operation and Borough approval of a Master Plan and rezoning to the Resource Development district for the proposed development. By comparison, the proposed Stipulation 8 of the DEIS falls short of providing adequate protection for whales, other wildlife resources, and the subsistence harvest. While if imposed, the stipulation is an incremental step in the right direction for MMS, its time frames are not restrictive enough, drilling from floating structures is permitted when adequate spill response capability does not exist, and it fails to address the potertial cumulative impacts of development. Alternative I is unacceptable in other respects as well. Both the Barrow and Kaktovik Deferral Areas should be removed from consideration for this proposed sale and future sales. You should refer to our October 27, 1988 comments during the scoping process for Sale 124, and again to our Sale 97 comments, for extended discussions of the need to defer these areas. The Spring lead system around Barrow remains a unique and sensitive area of concentrated biological diversity and subsistence activities. Though the DEIS states that the risk of oil contact with bowheads is low, we think it is clear that the consequences of an oil release into the Spring lead system could be catastrophic. The Bering Sea, stock of bowheads typically migrates though a very confined area (Pt. Franklin, Pt. Hope, Pt. Barrow) ina relatively short period of time. In some years (e.g. 1980 and 1988) more than 90% of the population may move past Point Barrow in less than two weeks. This behavior, and the nature of the confining lead system itself, could make a dangerously high percentage of the population vulnerable to harm should oil be released or persist in this migratory corridor. As we stated in our previous comments, you should accept as true the long-held Inupiat belief that the waters to the east of Barter Island are an important bowhead feeding area. So often in Letter to Alan Powers May 8, 1990 Page 8 the past, outsiders were slow to accept Inupiat claims about their environment which were later proven correct only after much time- consuming and expensive research. In addition, information available only since our last comments has indicated the importance of the ANWR coastal plain and adjacent waters to denning polar bears. With the continued closure of ANWR to industrial activity, far greater consideration must also be given to the difficulties of oil transportation over extended distances offshore before tracts in the eastern Beaufort are leased. In addition, the DEIS understates the potential negative cumulative impacts of oil exploration, development, and transportation. The document states that in the cumulative arctic case, there is a 99% chance of an oil spill in excess of 1000 barrels, with it most likely that there will be eight such spills. Looking at only the Beaufort Sea, the probability of one or more spills of at least 1000 barrels is stated to be 49% in the base case, and 91% in the high case. These are disturbing predictions to our coastal residents who subsist largely off the resources of the ocean. The DEIS also states that since 1964, there have been twenty ocs spills of greater than 1000 barrels. While this is touted as an impressive statistic, it means to us that the eight spills predicted for the arctic represent a number of incidents equal to a full 40% of those occurring on the entire OCS over a period of 26 years. Unless arctic activity is expected to be at a level approaching 40% of all OCS activity over the past 26 years, it appears that MMS is anticipating greater difficulty in operating safely in the arctic than has been experienced elsewhere. Coupled with the far greater difficulty in responding to such significant spills in the arctic, we have little confidence that we should not expect significant cumulative impacts over the life of arctic OCS development. There is also information available, but not discussed in the DEIS, which should raise serious concerns over the possibility that vastly increased vessel traffic associated with development could impact the bowhead population. The Borough has documented scarring on whales which is believed to be the result of collisions with ships. The incidence of bowhead/ship collisions appears to be low (ca. 2%), and is probably not a significant source of mortality for the Bering Sea stock. This low rate is most likely attributable to the low level of vessel traffic within their range. Socializing right whales, however, have been found particularly vulnerable to collisions when they become apparently oblivious to approaching Letter to Alan Powers May 8, 1990 Page 9 vessels (Goodyear 1989).' That the same may be true of bowheads is evident in film recently shot by scientists having just completed a tagging effort in the eastern Beaufort Sea. Individual animals repeatedly collided with their vessel while the boat moved among a large aggregation of apparently socializing and feeding bowheads. Ship collisions are not infrequent for the North Atlantic Right Whale (NARW), a species closely related to the bowhead. Kraus (1990) has found evidence that perhaps 33% of NARW mortality is human induced, and that ship collisions are a significant problem, He suggests that such human-induced mortality may be preventing recovery of the NARW stock despite a more than 70-year ban on commercial hunting. Our concern is that increased vessel traffic, including ice breakers operating in lead systems, will lead to a dangerous increase in the incidence of bowhead/ship collisions. SECTION IIT, CONCLUSION We have discussed the State of Alaska's position on the Sale 124 DEIS with agency officials, and agree with much of their analysis regarding the shortcomings of the document's proposed mitigating measures and the need for the Barrow and Kaktovik Deferrals. Because our position, however, is that lease tracts should not be sold in waters which cannot be explored and drilled from bottom-founded structures, we find it unnecessary to comment on much of the DEIS. We do ask that you carefully consider and where appropriate, specifically respond to, the comments of those who testified at the public hearings in our villages. The elders who spoke particularly deserve a response to their concerns that bowheads and other subsistence resources have already been significantly displaced by industrial activity, and that current technology can neither withstand worst-case ice and weather conditions, nor deal with significant oil spills in this environment. ;You should respect the fact that no one knows this environment ter than its Inupiat residents, and no one will i Goodyear, J. 1989. Feeding ecology, night behavior, and vessel collision risk of Bay of Fundy right whales. In: Abstracts of the Eight Biennial Conference on the Biology of Marine Mammals. Available from: The Marine Mammal Society. 2 Kraus, S. 1990. Rates and potential causes of mortality in North Atlantic right whales. Marine Mammal Science. (In press). Letter to Alan Powers May 8, 1990 Page 10 suffer more if your best guesses as to the potential impacts of offshore oil development prove wrong. Thank you for this opportunity to comment. Sincerely, Le = hay fel « ipsa N. Ahmaogak, Sr. jayor cc: Steve Cowper, Governor Ron Morris, NMFS Mayor Don Long, Barrow Mayor Thomas Napageak, Nuiqsut Mayor Herman Aishanna, Kaktovik Dan Fauske, Acting CAO Warren Matumeak, Director, Planning Ben Nageak, Director, Wildlife Management Edward Hopson, Chairman, AEWC Jessica LeFevre, AEWC Attorney Elizabeth Benson, Division of Governmental Coordination Dennis Roper, Federal Affairs Anthony Kesler, State Affairs Eugene Brower, President, BWCA Tom Albert, Borough Senior Scientist Tom Lohman, Assistant Borough Attorney mayor/powersS.gna/k North Slope Borough Response NSB-1 The responses prepared by MMS to the comments made by the North Slope Borough regarding Beaufort Sea OCS Lease Sale 124 are herein incorporated by reference. Response NSB-2 For the Alaska OCS Region, MMS requires lessees to submit, with an exploration plan, their contingency plans for drilling a relief well should a blowout occur. This includes information on the availability of backup equipment, including a relief-well rig and support craft (including icebreakers, when appropriate) and the timing to obtain, initiate, and complete a relief well. The lessee is required to provide the MMS with updated information on the location and availability of drilling rigs capable of operating in the environment where operations are proposed prior to each drilling season and of any changes during the drilling program. The MMS requires mutual assistance/relief-well-drilling-rig agreements between the two operators conducting concurrent operations in the same area to facilitate and expedite relief-well drilling. The adequacy of the relief-well plan is determined based on individual circumstances including the type and location of proposed activities, the type of drilling unit, other operations in the area, and company plans for monitoring environmental conditions and well status and curtailing operations and securing the well prior to the end of the drilling season. In the Chukchi Sea, floating drilling units will be used for exploratory drilling. Floating drilling units are capable of moving offsite in the event of a blowout and starting a relief well almost immediately. There are currently four drilling units and associated icebreakers and ice-class support vessels that have been successfully used in the U.S. and Canadian Arctic, and athat are available in the Arctic and can be mobilized to support a relief-well-drilling program in the Chukchi Sea. The likelihood of an oil blowout occurring during exploration drilling is extremely low. There has never been an oil spill resulting from an OCS exploratory-well blowout. Blowouts typically are a result of shallow gas without any oil that lasts for short periods of time. Bridging (including depletion) of blowouts (oil and gas) occurs greater than 70 percent of the time, with bridging occurring shortly after the blowout. Relief-well drilling has been attempted for approximately 4 percent of those blowouts that did not naturally bridge (Norwegian Oil Review, 1985). Prevention is the key to mitigating the risk of an oil spill resulting from a blowout. The MMS regulations establish strict requirements in the form of performance standards to ensure that operations will not result in an unsafe condition. Plans, equipment, equipment inspection and maintenance, testing, and training requirements all contribute to the low risk of a blowout on the OCS. Recent technological advances and continuing high levels of research are improving the safety of drilling in the Arctic, thus reducing the already negligible potential for a blowout. The MMS maintains a near-continuous inspection presence at each exploratory-drilling location and monitors the progress and status of the well and environmental conditions on a daily basis, including well depth, type of operation (drilling, coring, logging), next planned operation, the timing for completing current operations, the next planned operation, downhole conditions, and potential problems in maintaining well control. The MMS has the authority to require that operations be suspended in the event that ongoing operations could increase the risk of well-control problems or, continuing with the next operations following completion of ongoing operations such as drilling to the next casing point following setting and cementing casing, could not be completed before the end of the drilling season. The costs associated with drilling an exploratory well in the Chukchi Sea are high. Same-season relief-well capability significantly affects an already restrictive and short drilling season in the Sale 126 area, which could NSB-1 require a seconnéeason to complete the drilling of a single well or maintain a second drilling unit at the site. The costs associated with such a requirement would be substantial and would not significantly increase safety or reduce risk. The MMS recognizes the importance of relief-well planning for exploratory-drilling activities in frontier areas such as the Chukchi Sea. The MMS believes that regulatory requirements for documenting relief-well capabilities in conjunction with MMS’ inspections and monitoring of well status and environmental conditions on a real-time continuous basis for each site-specific activity, and authority to require operations be suspended, provide an effective and prudent mechanism to ensure that drilling activities are not continued if there is a significant risk of lost well control and remedial action, including drilling a relief well, could not be conducted. Response NSB-3 Appendix L, Section IV, addresses oil spills in Alaska in which no response effort was undertaken due to the environmental conditions. It is noted that sea states would exceed the capabilities of mechanical response equipment from 9 to 24 percent of the time in summer months, the range in occurrences of Sea States of 3 or greater in the Chukchi Sea. It is noted in Section IV.A.2(e)(5) that weather, sea conditions, and crew fatigue become critical factors in cleanup. Partially as a result of the increased concern regarding spill response since the Exxon Valdez spill, the oil industry has upgraded its spill cooperative, ACS (Sec. IV.A.2); and the USDOI, MMS, OCS Oil-Spill Task Force has made recommendations to the Secretary of the Interior on improving evaluation of industry oil- spill-contingency plans (Sec. III.D, Appendix L). First production from the Chukchi Sea Planning Area would be preceded by a developmental EIS in which future, site-specific response capabilities will be evaluated. Response NSB- The text of Section IV.C.6 has been revised to address the North Slope Borough’s concern for disturbance of marine mammals. We thank the Borough for providing detailed documentation supporting their concern. Stipulation No. 2, Protection of Biological Resources, provides several options for avoiding areas of marine mammal concentration and thus potential disturbance situations. Stipulation No. 3, Orientation Program, alerts operators to environmental concerns in the sale and adjacent areas. Operators should be aware of provisions of the Marine Mammal Protection Act and Endangered Species Act and that disturbance of marine mammals could constitute taking and thus be in violation of these acts. In addition, operators are made aware of three ITL’s relevant to animal disturbance: (1) Information on Bird and Marine Mammal Protection, (2) Information on Areas of Special Biological and Cultural Sensitivity, and (3) Information on Arctic Peregrine Falcon. If the provisions of these acts, stipulations, and ITL’s are followed, MMS expects that the effects of disturbance on local animal concentrations would not exceed a low level. Response NSB-5 The 1982 and 1985 Geraci and St. Aubin reports are repeatedly cited in the EIS analysis because they represent the best scientific information available from the leading authorities in this field . The information used in the analysis was based on conclusions taken directly from these reports. The first example concerns a chart showing (among other things) the effect of gasoline on four dolphins after 15, 30, 45, 60, and 75 minutes of exposure. The report indicates that the very same animals that had small blisters at 30 and 45 minutes showed no visible reaction later on at 75 minutes. That is why the report stated on Page 89, concerning the chart on Page 90, that "In some cases, the exposed skin had a faint hobnail texture that disappeared within 5 minutes. Normal color was always restored within 2 hours. At no time was there any swelling, hemorrhage, or break in the continuity of the skin associated with exposure." The report concluded that "We found that dolphin skin exposed to gasoline and crude oil turned pale gray, and otherwise showed NSB-2 no evidence of damage or loss of integrity." Since the EIS analysis quotes what the reports stated and concluded regarding cetacean-skin contact with gasoline, we feel we have accurately represented the reports. The second example concerns the fact that the sperm whale being experimented upon was stranded and had been dead for 5 to 10 hours before the experiment was concluded. However, neither the stranding nor the death of the whale influenced the experimental results. This reality is borne out on Page 160 of the report, where it states that "The whale died during the course of the contact study. Yet the histological changes noted in the epidermis exposed to gasoline are noteworthy in that they are indicative of damage to living cells, and not postmortem autolysis." This represents a demonstration of effects on living tissue. Consequently, according to the report, the death of the sperm whale had no bearing on the outcome of the experiments. Wording to this effect has been added to the text of the FEIS. Regarding the suggestion that the analysis should have described the "dramatic" effects of 17 hours of exposure to gasoline, the effects of gasoline were mentioned for comparative purposes only. Since it is unlikely that free-ranging cetaceans would be exposed to gasoline for 17 hours due to activities permitted by MMS, the effects of 75 minutes of exposure (a more realistic scenario) were discussed instead. Regarding the actual damage caused by 17 hours of exposure to gasoline, the report also indicated that damage occurred only to the medial and superficial layers of the epidermis and stated that "even this degree of damage seems to be reversible." Response NSB-6 See Response NSB-5. The MMS has taken every effort, through re-examination of source materials and addition of new references, to ensure that the conclusions reached in this EIS are substantiated to the extent made possible by existing literature. NSB-3 ARCO Alaska, inc. Post Ottice dox 100360 Ancnorage. Alaska 39510-0360 Telephone 907 265 6101 Jerry L. Dees Vice President Raz ae Ww September 11, 1990 S RECEIY Mr. Alan Powers Regional Director Minerals Management Service Alaska Region 949 East 36th Avenue Anchorage, Alaska Re: P Chukchi Sea Lease Sale 126 - Draft Envi Suatement Minerals 99508-4302 Dear Mr. Powers, ARCO Alaska, Inc. has reviewed the Chukchi Sea Planning Area Oil and Gas Lease Sale 126 - Draft Environmental Impact Statement (DEIS). We have the following commentary that we urge the Minerals Management Service (MMS) to carefully consider. In addition to our comments, ARCO supports the comments that have been submitted by the Alaska Oil and Gas Association (AOGA) on the Chukchi Sea Lease Sale 126 - DEIS. In general the DEIS reflects a very reasoned approach to the various aspects of the lease sale. The MMS should be commended for this approach as it reflects the use of recent information, recognition of advancing technology, and the balance required for prudent, environmentally sound oil and gas development. As stated many times in the past the need for continued oil and gas exploration is crucial, if the United States is to maintain an acceptable import / export balance. Without this exploration effort the probability of further dependance on foreign sources, 10 meet our energy needs, will be of greater significance than it is in 1990. We therefore urge and support the MMS to continue the process for this OCS Lease Sale 126 in a timely and deliberate manner for the Alternative 1 - Proposed Action. There is some discussion in the DEIS which we believe inaccurately portrays the economic effects of the lease sale on the North Slope Borough (NSB). For each of the three cases (low, base, high), there is a discussion, under item 10, of the “effects on the economy of the North Slope Borough” of conducting the proposed lease sale. The conclusion drawn for the base case (page Il-23) and the high case (page II-34) is that the effect on the economy of the NSB is expected to be not only detrimental, but "VERY HIGH" (emphasis in original). ‘This very negative conclusion is not only unsupported by, but is in fact contradictory to the underlying facts and conclusions found elsewhere in the document. Page I-23 states, in part, that the “(e)ffects on the subsistence harvest are expected to have significant adverse effects on the economy of the NSB." This is apparently based on the allegation later in the same paragraph that “oil spills and industrial activities are expected to cause disruptions of the bowhead and belukha whale, walrus, fish and caribou harvests in the communities.” (Barrow, Wainwright, Atqasuk, Point Lay, Point Hope and Nuiqsut.) SEP 11 1999 REGIONAL DIRECTOR, ALASKA OCS inagoment Service ANCHORAGE, ALASKA ARCO Page 2 September 11, 1990 Mr. Alan Powers Re: Proposed Beaufort Lease Sale 124 -DEIS This is not supported, and is in fact contradicted, by the discussion in the DEIS about the impact of leasing on these species. Pages [I-21 and II-22 discuss bowhead and belukha whales. The conclusion drawn for each of these two species is that the effect of leasing is expected to be very low. Similarly, the slight possibility of an oil spill is expected to have a low level of effect on walruses (page 11-20). The impacts on caribou (page II-22) and marine habitat fishes (page II-17- 19) are expected to be low and very low, respectively. Only freshwater fishes are expected to suffer a very high effect (page II-17-19). Nevertheless, the DEIS concludes that the subsistence harvest of these species will be disrupted to a very high degree (page 11-23). This conclusion is simply not supported. The section of the DEIS discussing the effects of the leasing alternative on the economy of the NSB (page Il-23, II-34) is comprised of two parts. The first paragraph addresses the employment and revenue effects on the NSB economy. The conclusion drawn is that the effects are expected to be moderate for the base case (page II-23) and very high for the high case (this would be a positive impact). The second paragraph addresses the subsistence harvest effects on the NSB economy, and concludes (inappropriately for the reasons discussed above) that the effects are expected to be very high for both the base and high cases (this would be a negative impact). The concluding paragraph summarizes the first two paragraphs by concluding that the overall effect of the base and high case on the economy of the NSB is expected to be "VERY HIGH" (emphasis in original). This is an incorrect conclusion, if it is based on the previously discussed DEIS rationale. In summary, the conclusions that the proposed lease sale would have a very high detrimental effect on the economy of the NSB, are not supported by the facts presented, and contradict other portions of the DEIS. For example, when compared with the above referenced sections of the DEIS, section III.C.1, the “Economy of the North Slope Borough” paints a far more positive picture of the economic impact of oil and gas development on the NSB. Based on our review and the above discussions, we would urge the MMS to consider changing some of their conclusions to more accurately reflect the information that is presented throughout the DEIS document. If you have any questions with regard to the above comments, please feel free to call me at 265-6101. Yours truly, ARCO ARCO Alaska, Inc. Response ARCO-1 Based on a review of Section IV analyses and related sections, the very high effect on the economy for the base case has been changed to a high effect in the FEIS. However, the conclusions for endangered and threatened species, subsistence-harvest patterns, and the economy of the NSB should be viewed in light of the analysis in Section IV and the definitions in Table S-2--not just the Section II summaries of effects. The conclusion of effects on these three resource categories can be different and still consistent. The analysis and conclusions of effects on the economy of the NSB in Section IV draw, in part, from the analysis and conclusions of effects on subsistence-harvest patterns--but not from endangered and threatened species. For example, the conclusion for the potential effect of oil spills (and other factors) on bowhead whales is low. However, the potential effect of an oil spill on subsistence-harvest patterns is high for Wainwright, in part because pulling whales up through oiled waters would result in an unusable whale. The high effect on subsistence-harvest patterns translates to a high effect on the economy because of the potential unavailability of an important resource for a significant proportion of households. The bowhead whale is an important part of the economy for the households of Wainwright. Conceptually, the conclusion of high effects on subsistence-harvest patterns could have translated to a very high effect on the economy, as reflected in the DEIS. The analysis of effects on the economy relates to both positive aspects of employment and revenue to the NSB and to the potentially negative economic effects of diminished subsistence foods for Wainwright, Barrow, and Atqasuk. The Council on Environmental Quality (CEQ) regulations require that, where a particular type of environmental resource (in this case economic resources) incurs both positive and negative effects, the greatest negative effect--rather than an average of positive and negative effects--must be disclosed. In the second paragraph of the ARCO-1 comment (para. 4 of the entire letter), five places are listed after a quote that inaccurately reflects the original text. The entire two sentences in the DEIS read: "Oil spills and industrial activities are expected to cause disruptions of bowhead and belukha whale, walrus, fish, and caribou harvests in the communities of Barrow, Wainwright, and Atqasuk. To a lesser extent, harvests in Point Lay, Point Hope, and Nuiqsut would be affected." ARCO-1 September 10, 1990 Mr. Alan Powers Regional Director Minerals Management Service Alaska OCS Region 949 East 36th Avenue, Room 110 Anchorage, AK 99508-4302 BP Exploration (Alaska) Inc. 900 East Benson Boulevard PO Box 196612 Anchorage, Alaska 99519-6612 (907) S6r-si11 PECEN SEP 12 1999 REGIONAL DIRE Minera's Mana: it ANCHORAGE, ALASKA Draft Environmental Impact Statement Dear Mr. Powers: BP Exploration (Alaska) Inc. (BP) appreciates the opportunity to comment on the Draft Environmental Impact Statement (DEIS), for Oil and Gas Lease Sale 126. As an important component of the lease sale planning process, it affords all concerned parties the occasion to express their views and concerns. To that end, we note herein our general positions regarding the DEIS. BP strongly supports Alternative 1 of the DEIS which provides for an offering of the entire proposed sale area on schedule. The stated goals of the leasing program include (1) the orderly development of OCS oil and gas resources in an environmentally acceptable manner, (2) the maintenance of an adequate supply of OCS production to help meet the Nation's energy needs, and (3) the reduction of dependency on foreign oil. Additionally, as noted on page I-1 of the DEIS, Congress mandated the U.S. Department of the Interior to engage in “expedited exploration and development of" the OCS in order to “assure national security, reduce dependence on foreign sources, and maintain a favorable balance of payments in world trade.” BP, therefore, believes it is in the best interests of industry, the public, the State of Alaska and the nation to proceed with the evaluation of hydrocarbon potential of the Chukchi Sea in a prompt manner. Further delay of the sale would contribute to the steadily growing dependence on foreign sources for energy and would serve to frustrate the stated goals and the Congressional mandate to the Department of Interior. Mr. Alan Powers September 10, 1990 Page 2 We request that these comments receive full and careful consideration. Sincerely, Steven D. Taylor, Manager Environmental & Regulatory Affairs, Alaska SDT:EPZ:jns rAN vy Texaco inc Telex 227025 TEX UR Fax 713 661 7463 Contum 713 432 2004 4800 Fournace Place Bellawe Texas USA 77401 2324 7123 432 3003 CP Cazalot Jr General Marager September 6, 1990 COMMENTS ON DEIS OCS SALE 126 Regional Director, Alaska OCS Region Minerals Management Service 949 East 36th Ave., Room 110 Anchorage, Alaska 99508-4302 Attention: Mr. John Schindler Gentlemen: Texaco is pleased to have this opportunity to submit comments on the DEIS for Chukchi Sea OCS Sale 126. Texaco supports Alterna- tive I which proposes that the sale be held as scheduled in August 1991 without deletions to the sale area. This alternative best represents the OCS sale program which is designed to make prospective offshore acreage available for exploration and production to help meet the energy needs of the nation. Alternatives II (No Sale), and III (3-Year Delay) are not accep- table to Texaco. In order to provide additional reserves to our domestic supply of oil, the industry must be provided with timely access to prospective areas. Therefore, it is essential that the sale not be cancelled or delayed. Alternative IV (Point Lay Deferral) is inappropriate in our opinion since offshore petroleum exploration and marine har- vesting operations have proven to be compatible in the past. Also, the DEIS concludes that the potential adverse impacts do not decrease under any of the deferral alternatives. In conclusion, I would like to emphasize that industry has a proven track record of operating safely in the Chukchi Sea as well as in the Beaufort and Bering Seas and there is no reason to believe that operations in the Chukchi Sea would pose an environ- mental hazard. We appreciate this opportunity to present Texaco’s comments on this document. Please contact this office should you require any further information. Very truly yours, CP. Copgaards : em nc.ni Robert T. Anderson Manager Lands. Alaska Region Unocal North American Oil & Gas Division Unocal Corporation PO. Box 190247 Anchorage. Alaska 99519-0247 Telephone (907) 276-7600 UNOCAL® August 31,1990 Mr. Alan Powers Minerals Management Service Alaska OCS Region 949 E. 36th Ave., Rm. 110 Anchorage, AK 99508 CHUKCHI SEA AREA State of Alaska DEIS Sale 126 Dear Mr. Powers: Union Oil Company of California has reviewed the (Draft) Environmental Impact Statement for proposed Chukchi Sea OCS Lease Sale 126 and has the following comments: deferral of an area consisting of 501 blocks from the sale area as proposed in Alternative IV would be inconsistent with the goals established for the five-year oil and gas leasing program, UNO particularly since there are existing leases in the area representing exploratory interest for the | 1 We support Alternative | for holding the sale as scheduled in August, 1991. It is felt that a | sale area. Certain blocks in this area offered in Sale 109 already carry protective stipulations requiring site-specific whale monitoring programs. Although it may be perceived that only limited exploratory drilling has been conducted in the area since the last sale, with oil prices on the rise and the escalating tension in the Mideast our dependency on foreign oil has increased. We must maintain an adequate supply of readily available production to meet our ever increasing energy needs. Shortsightedness could be our Achilles heel. In conclusion, the investment to date by industry in preparing for the challenges of the Arctic in an environmentally safe manner have been demonstrated and recognized by the Secretary of the Interior as adequate for environmental assessment. We at Union can see no evidence presented which lends credence to any other alternative than to hold the entire sale area in OCS Sale 126 as scheduled in August of 1991. Nery truly yours, Awad Aho IN TZ Kevin A. Tabler Supervisor of Leases ECEIVE SEP 5 1999 0 REGIONAL DIRECTOR, ALASKA OCS Minerals i. Service ANCHORAGE, ALASKA KAT/clh Unocal Corporation Response to UNO-1 Alternative IV, the Point Lay Deferral Alternative, is consistent with the goals established for the 5-Year OCS Oil and Gas Leasing Program. The deferral alternative offers one additional option for the Secretary to consider in evaluating an environmentally sound lease sale. Deferral of the area would in no way jeopardize the existing leases in the area as a result of OCS Lease Sale 109. UNO-1 TESTIMONY OF ELIJAH ROCK BARROW, ALASKA August 27, 1990 at 7:00 Meeting Captain and Commissioner of Alaska Eskimo Whaling Commission of Pt. Hope. ("AEWC") Today I would like to share my knowledge of the Arctic coastal community's subsistence hunting of marine mammals and the effects that offshore oil and gas exploration are having on our use of these resources. I also would like to share our views on how the issues arising from these effects can be addressed. Our whaling community consists of nine coastal villages along the Beaufort and Chukchi Seas. In 1977, the International Whaling Commission ("IWC") imposed a quota on our hunt of the bowhead whale. Since that time, our villages have become a community under the umbrella of the AEWC, working together to manage our hunt of the bowhead whale, and to protect our rights to continue that hunt. in this way we are carrying on the traditions of the conservation and management of renewable resources Our people do not only hunt the bowhead whale. Our subsistence also depends on the beluga whale, walrus, several species of seals, polar bear, gray whale, sea birds, migratory birds of many species, fish of many species and delicate creatures at the bottom of the sea. These are some of the primary means of survival to the coastal natives of pf the primary means of survival to the coastal natives of the Beaufort Sea, Chukchi Sea and Bering Sea. However, the bowhead whale is the resource most important to our nine whaling villages, not only for our subsistence, but for our culture. It is my personal observation that bowheads are extremely sensitive to noise. In recent years oil industry seismic and exploratory drilling activity came into Barrow's hunting grounds. A vast amount of Beaufort Sea seismic work area is being done approximately 20-30 miles NNE off Cape Simpson and approximately 20-30 miles North off Pt. Barrow “Nuvuk, Alaska through the Beaufort Sea bowhead migration routes and the bowhead natural habitat area. Since this AEWC activity began, whaling crews have been reporting fewer 1 bowhead whales or no bowhead whales in areas where Barrow always hunted. The eastern Beaufort Whaling villages, Nuiqsut and Kaktovik, have had the same experience. In spite of great danger to human life, the Barrow whalers have begun to hunt farther from shore, to look for whales beyond the near shore noise. But even when they can locate and take whales at these distance, they often lose the whale meat because of the time required for towing. This is very serious problem. It is very difficult and very risky to hunt bowhead whales. We also have a limit on how many whales we can take because of the IWC quota. If we take a whale bu lose the meat because of too much time towing, this still counts against our IWC quota. Last year :Barrow lost the meat from four whales because of this. This was almost one-third of Barrow's quota of 15 bowheads for the year. AEWC Our whaling communities are very concerned that with i more offshore exploration in the near shore waters, the whales will move too far out for us to hunt them. Therefore, we believe that plans for this activity must AEWC include safeguards to protect our subsistence resources and 2 hunting. We also believe that more scientific research is | needed on the impacts of this offshore activity on marine AEWC mammal resources. Our whaling communities are also very 45 concerned about the possibility of oil spill in our Beaufort and Chukchi Sea hunting grounds. We believe that a spill in the Arctic could be very difficult, if not impossible to clean up. Such a spill could have a devastating impact on ae our marine mammal subsistence resources. Therefor, we believe that careful attention must be given to the development of effective containment and cleanup equipment for the Arctic. Despite the hardship cause by noise impacts and our concerns about oil spill, the whaling communities has not tried to stop the offshore development. It is part of our culture to share resources. However, it also is part of our culture to protect our subsistence resources for future generations. AEWC takes this responsibility seriously. As whaling captains, we are responsible for the cultural and subsistence livelihood of our people. It is part of our honor and dignity as whaling Captains. Without honor and dignity, a whaling captain loses face with the whaling community and loses the respect and prestige one attains through many years of involvement as a member of the whaling community. At this time, the AEWC is negotiating with the oil and gas operators working in the Arctic to try to reach agreement on mutually acceptable regulations to place reasonable restrictions on offshore exploration during the next five years. These regulations will also provide specific protections for our bowhead whale subsistence hunt. In addition, the AEWC is planning to join together with the Bering Sea Fishermen's Association and with other local communities and organizations from coastal Alaska to form the Alaska Arctic oil Spill Prevention Commission. Through this Commission, we will be able to coordinate information and representation on OCS oil and gas issues for affected coastal communities. Through this Commission, we also will be able to hire scientific experts in marine biology and acoustics , and in offshore drilling and oil spill containment and cleanup technology. These experts will be responsible for advising our people on the impacts of this offshore activity to our subsistence resources and on the international state of the art in offshore drilling and oil spill containment and cleanup technology. This Commission will provide our people with a better understanding of what is going on in our offshore hunting grounds. It will also provide us the opportunity to relay our informed opinions to the oil and gas companies and the Federal Government on how the impacts of oil and gas activity to our subsistence resources can b e minimized. It is our experience, as rural Alaskans, that given the great distances between our communities and the difficulty of transportation, organizations such as this are very useful. They help us to deal in a coordinated and efficient way with specific issues that affect a number of communities. They also allow us to avoid or resolve conflicts before they become disruptive to the activities in question. The AEWC is a highly successful example of this type of organization. CONCLUSION In conclusion, I would like to stress that our people do not oppose the development of energy resources. As long standing resources manager, however, we strongly urge that this development be done on the basis of sound principles of resource management. In our view, sound resource management in the Arctic requires the following: 1. On shore oil and ge resources should be developed and produced before offshore resources; 2. Of££ shore exploration and development should be accompanied by proven oil spill containment and cleanup technology; 3. Development in the vicinity of local communities should be undertaken so as to mitigate adverse impacts to local resources and cultural activities; 4. The protection of subsistence activities must be given top priority, and for our neighbors in southern Alaska, the protection of local commercial fisheries; and finally; 5. The Federal Government should encourage and support us in our creation of the Alaska Arctic Oil Spill Prevention Commission. This will help us to ensure an efficient information flow between our communities and the oil and gas companies and Federal Government. It also will provide us a means of avoiding disputes over the impacts of OS activities, and of resolving any disputes that do arise before they disrupt our activities or the important work of developing our nation's energy resources. Alaska Eskimo Whaling Commission Response AEWC-1 The MMS shares the commenter’s concern for not disrupting subsistence-hunting activities through the industry activities it permits on the OCS. Information on noise effects from seismic or drilling activities on whales and on local subsistence-hunting patterns (traditional hunting areas) does not indicate that seismic or exploratory activities cause whales to move farther offshore or to become less available for subsistence- hunting activities. Based on analyses of subsistence-hunting activities and environmental conditions, ice conditions appear to have the greatest effect on the whale migration and the ability of whalers to get offshore. The MMS has monitored the pathway of the fall bowhead migration every year since 1979, primarily to detect any long-term changes. No migrations have been found to be significantly different from each other except during 1983, when there was very little seismic-survey or drilling activity during the open- water season. The following stipulations and ITL’s are listed in this EIS: Stipulation No. 5 requires industry to monitor bowhead whale movements around its drilling sites (this is in addition to continued MMS monitoring under ITL No. 6), and Stipulation No. 6 specifies local input into industry exploration plans. Although there has been some seismic-survey work in the past 3 years north of Point Barrow and Point Simpson, it has not been a vast amount; actually only 2.5 percent of the Beaufort Sea monitoring program from 1987 to 1989 was conducted within 64 km of these points. Response AEWC-2 The MMS understands the importance of subsistence activities to local communities and the need to protect subsistence resources and hunting from potential effects from oil and gas activities. The EIS analyses concluded that, except for potential high effects on Wainwright subsistence hunting resulting from activity in the spring-lead system, the potential effects would range from moderate to very low. The EIS identifies several potential mitigating measures to reduce these effects even further and a deferral alternative to remove blocks from the lease sale that have the highest potential for affecting subsistence use near Wainwright and Barrow. These measures include: 1. Stipulation No. 6 (Subsistence Whaling and Other Subsistence Activities) requires the lessee to conduct all activities in a manner that minimizes any potential for conflict between oil and gas activities and the bowhead whale hunt. Lessees would be required to contact potentially affected subsistence-whaling communities to discuss potential conflicts with siting, timing, and methods of proposed operations, and to document conflicts and resolutions and unresolved conflicts in the Exploration Plan (EP) or Development and Production Plans (DPP’s) that must be filed with MMS. The EP is then subject to review by MMS and other Federal and State agencies and the public, including local communities, to ensure that lease activities will avoid unnecessary conflicts with subsistence-hunting activities. 2. Stipulation No. 3 (Orientation Program) requires all personnel involved in exploration or development and production activities (including personnel of the lessee’s agents, contractors, and subcontractors) to participate in an MMS-approved orientation program designed to inform personnel about biological resources and habitats and to increase the sensitivity and understanding of personnel to community values, customs, and lifestyles, including subsistence activities. 3. Stipulation No. 5 (Site-Specific Bowhead Whale Monitoring Program), designed to provide protection to the bowhead whale, requires the lessee to conduct a monitoring program to determine when whales are in the vicinity of lease operations and the extent of behavioral effects on bowhead whales due to these activities. If monitoring indicates that drilling activity could cause serious, irreparable, or immediate harm to the species, MMS has the authority and intends to require that operations be suspended. Several ITL’s are proposed to provide further information to lessees concerning protection of birds and marine mammals, including applicable laws, regulations, guidelines for vessel and aircraft traffic, and areas of AEWC-1 special biological and cultural sensitivity. The MMS has also issued Notices to Lessees regarding vessel- and aircraft-traffic guidelines to protect polar bears, walrus, and endangered whales in the area. In addition to the stipulations and ITL’s, the nearshore area, which includes the spring-lead system, is a proposed deferral option for the sale that, if adopted, would provide further protection to subsistence resources and subsistence-hunting activities in the spring-lead system. Recent Lease Sales 97 and 109 and proposed Lease Sale 124 have adopted measures similar to potential lease Stipulations No’s. 5 and 6. Cooperative programs between industry and local subsistence communities, such as the 1986 Oil/Whalers Group, provide for communication and coordination between oil and gas activities and subsistence activities and have been successful in minimizing and avoiding potential conflicts. Lessees’ EP/DPP’s will also be subject to coastal zone consistency review, including applicable policies related to subsistence activities under approved coastal zone management programs. No drilling or other activity can be conducted until an EP/DPP has been approved and the State has concurred with the consistency certification. Lease activities will also be subject to the provisions of the Marine Mammals Protection Act and the Endangered Species Act for incidental take. The NMFS and FWS are responsible for implementing these laws that allow for incidental take under certain conditions and, subject to a Letter of Authorization, can also identify or establish restrictions, limitations, or other permit conditions to protect both subsistence resources and subsistence activities. Response AEWC-3 See Appendix F for a discussion of the MMS Alaska OCS Region Studies Programs. Response AEWC-4 The commenter’s interpretation is in agreement with the analysis in Appendix L. Since the Exxon Valdez spill, oil-spill research and development has been in the spotlight. The Oil Pollution Act of 1990, Public Law 101-380, establishes an interagency coordinating committee on oil-pollution research. Membership of the Committee includes representatives of NOAA, DOE, DOI (includes MMS and FWS), DOT, DOD, EPA, National Aeronautics and Space Administration, and the United States Fire Administration in the Federal Emergency Management Agency, and other Federal Agencies that may be designated by the President. In addition to Federal research, Marine Spill Response Corporation (MSRC)--a consortium of oil companies and shippers, will administer a comprehensive research and development program to improve the knowledge and technology used to respond to and clean up spills. This program will complement programs in government, academia, and industry. AEWC-2 NANA (EGIONAL CORPORATION, INC. 4706 HARDING DRIVE, ANCHORAGE, ALASKA 99517 TELEPHONE (907) 248-3030 FAX (907) 248-3779 September 11, 1990 Mr. Alan D. Powers Regional Director Minerals Management Service Alaska OCS Region D eC elVfE 949 East 36th Avenue, Room 110 Anchorage, AK 99508-4302 SEP 11 1999 REGIONAL DIRECTOR, ALASKA ocs Minerals mont Sarvicg ANCHORAGE, ALASKA Attn: Paul Dubsky Dear Sir: NANA Regional Corporation, Inc. has reviewed the draft Environmen- tal Impact Statement for the proposed Chukchi Sea OCS Lease Sale #126. As a regional Native corporation whose shareholders and land base are located in Northwest Alaska south of the proposed lease area, we are greatly interested in this sale and the potential development that might subsequently occur. Our interest centers on the impacts that OCS and related onshore development might pose to our shareholders and to the animal and natural resources vital to the livelihood of our people. We share an equal degree of interest in the economic opportunities that OCS development might offer the people of the NANA region. Based on the DEIS, we prefer that better technologies and response scenarios be presented before Chukchi Sea exploration proceeds. In any case, development and production should not proceed until the technology for safe operation is in place. We acknowledge the need to know what the economic potential of an area is before massive amounts of money are spent developing specific technologies. While not opposed to exploration, we do think that the DEIS is lacking in number of areas that should be improved before activity proceeds. NANA's experience with the mining operation at Red Dog has afforded us an opportunity to actively participate in a world class mineral development while balancing the cultural and economic needs of our shareholders. Any OCS development that occurs in Alaska must consider the economics of the development, the people involved and the environment. The peoples most affected by the potential development must be afforded the opportunity to participate in all Member Villages: Ambler, Buckland, Candle, Deering, Kiana, Kivalina, Kobuk, Kotzebue, Noatak, Noorvik, Selawik, Shungnak stages of planning. This is particularly important with respect to the monitoring of environmental impacts and to the planning required to properly mitigate negative impacts and hazardous conditions. NANA requests that the NANA region be involved in any offshore planning efforts. The region encourages the use of local people to monitor the environmental impacts of OCS development and the effects on migratory marine and terrestrial wildlife. We further- more encourage the use of local people to work with the oil industry and federal government to ensure that adequate training and employment opportunities are offered to the residents of the areas most affected by OCS development. All committees should be composed of residents of the communities and regions that will be impacted by OCS and related onshore development. This would include the NANA region as our people rely on marine mammals that migrate through the lease area and on the caribou that likewise migrate through the areas that may be developed for support facilities or pipelines. The issue of OCS revenue sharing to offset the impacts of OCS development should be addressed in the sociocultural section. This is particularly critical to the Northwest Arctic Borough since a potentially significant proportion of the impacts may occur there. Workers may locate in and/or mobilize out of Kotzebue, rather than the North Slope Borough as the DEIS postulates. In fact, the DEIS makes little if any mention of the potential impacts to the Northwest Arctic Borough. This is a serious oversight because Kotzebue has climate and ice-free season advantages when compared to places north of Point Hope. Beyond the more general comments offered above, NANA Regional Corporation has several specific concerns about this proposed lease sale. Our major concern centers on the unproven ability of the oil industry to safely drill in Arctic waters, to prevent significant accidents or oil spills, and lastly to clean up a spill of any magnitude effectively and quickly. There is little information presented in the DEIS to dispel our concerns. In fact, the DEIS is quite pessimistic about the ability of the oil industry to clean up an oil spill in Arctic waters, particularly in the presence of ice. As noted in Appendix L, MMS' own evaluation of the response and cleanup capabilities of the industry found that the majority of the equipment tested performed below ratings. In the case of application in the Chukchi Sea, summer sea conditions would preclude effective use of response equipment for 9% to 24% of the time. Ice cover, which typically occurs 9 months of the year, eliminates standard application of most mechanical response equipment. The scenarios for mobilizing spill response teams and equipment center on transporting said teams from Barrow, Deadhorse or the Canadian Arctic. However, the minimum response times often exceed the critical initial response time required to contain and clean NANA NANA : up the oil. In other words, the response teams will arrive too late. And once they get to the scene of the spill, they will be using equipment and techniques that, by MMS' own admission, are likely to be ineffective and made even more so by the extreme weather and sea conditions that are common to this part of the Chukchi Sea. One technique discussed for dealing with oil spills in pack ice is to burn the oil when it reaches the top of the ice. However, as the DEIS notes, the requirements for dealing with a multitude of melted pools of ice and oil would be a "logistical nightmare". Moreover, oil spilled in the early winter is likely to remain underneath the ice for the entire winter before the ice starts melting. There was little discussion addressing the effects of significant quantities of oil trapped underneath pack ice for extended periods of time. It was noted, however, that oil trapped in pack ice may move considerable distances before the ice melts, further complicating the oil spill cleanup. To quote the findings of the DEIS, “industry could effectively clean up an oil spill in moving ice only if the spill is a platform blowout that could be set on fire without endangering platform integrity." The implications of this statement are that the industry is severely limited in its ability to respond to oil spills of any other source or cause. In light of the severe weather conditions commonly experienced in the Chukchi Sea, this admission is quite unsettling. As noted in the DEIS (page II-55), even recovery of most of the oil spilled from a platform is unlikely. We recognize that the oil industry has a good record in offshore United States. We are still wary of the technical problems associated with ice. Rather than relying on a good track record in non-iced areas, we think Chukchi exploration should proceed when the means for spill response has been developed. More specifical- ly, we are not convinced that platform-type drilling islands can be safely utilized in the Arctic. We think bottom-founded structures should be used since these have been tested in the Arctic. The DEIS says that an undersea pipeline from the drilling platforms to landfall is the most likely scenario for transporting oil. The DEIS goes on to describe the uncertainties regarding the safety of undersea pipelines in light of the potential for bottom scouring by ice. The DEIS notes that “experience with arctic-petroleum- transportation systems is limited; new problems must be solved". Other than to mention that more research must be done in this area, the DEIS offers little guidance as to the best means by which to deal with the potential problems associated with undersea pipe- lines. The most likely failure of the undersea pipeline system would be a result of ice scouring and rupturing the pipeline. This would occur in winter, the precise time of year when the oil industry's response capabilities are the most limited and ineffec- tive. The DEIS treatment of this dilemma and the resultant effects is inadequate. NANA NANA NANA The DEIS mentions the large amounts of drilling muds and drill cuttings that will be produced and disposed during exploration, development and production phases. The maximum amount of drilling muds and cuttings that may be produced is in excess of 320,000 short tons in the base case. Since these products contain some toxic trace elements, careful disposal is essential. A number of key points are not clearly discussed in the DEIS; for example, whether the disposal of these muds and cuttings occurs all year or only in the summer months. If this is a year-round operation, then disposing of these waste materials by transporting them to land, as suggested in the DEIS ostensibly to comply with NPDES permit requirements, would be difficult if not impractical. In conclusion, we believe the DEIS practically ignores the potential social and physical impact of offshore Chukchi activity on the NANA region. This needs to be considered. The DEIS also should present better scenarios for spill control. Also, more consideration should be given to the type of rigs used and to transportation pipeline problems. If petroleum resources are discovered, the industry should have to demonstrate an even higher level of technology and knowhow before proceeding to production. We appreciate the opportunity to comment and trust that our comments will be useful. Sincerely, Ze. A Mhnse John A. L. Rense Vice President, Minerals EB/45 Christina Westlake Chairman ces Roswell L. Schaeffer President Walter Sampson Vice President, Lands Chuck Greene Mayor, NWAB NA A 6 | | I |’ A A NANA Regional Corporation, Inc, Response NANA-1 OCS impact assistance could offset the effects of OCS development. Congress has considered this often in the past and may consider it in the future. At this writing, a system for OCS revenue sharing has not been established. Establishment of OCS revenue sharing is, in any case, a Congressional decision. The OCS Lands Act was amended in 1986 to provide for revenue sharing to coastal states. Coastal states receive 27 percent of all monies from OCS oil and gas leases that are between 3 and 6 miles from the coast. OCS revenue sharing could offset the effects of OCS development. The State of Alaska has received $389 million from the OCS for oil and gas leases that are between 3 and 6 miles from the coast. Effects could occur in the Northwest Arctic Borough if were workers located in and/or mobilized out of Kotzebue. The EIS anaylsis assumes that economic effects would occur in the North Slope Borough. When and if plans are submitted by lessees, potential effects on the Northwest Arctic Borough would be considered in the NEPA review. Response NANA-2 Historically, mechanical recovery of spilled oil is low (U.S. Congress, OTA, 1990). The interpretation of the commenter is in agreement with this analysis in Appendix L. Most spill responses in Alaska are logistically difficult, as in the case of the Exxon Valdez. However, logistical difficulty does not preclude response. Unlike transportation-related spills, such as the Exxon Valdez, or highly-publicized spills, such as Ixtoc I, OCS exploration and development and production activities require approved Oil-Spill- Contingency Plans that establish and commit equipment, manpower, logistical support, and communications resources for each specific activity. The MMS believes that response capability for specific OCS activities with a known and stationary location (well site or platform) and with a pre-established response plan (equipment, trained personnel, and logistical support) will ensure greater response than has been experienced in previous transportation or non-OCS spills. Oil-spill-contingency plans are approved by the MMS when industry has submitted evidence of the resources to respond to an oil spill under the conditions of the region. A very- large-winter-spill scenario and its effects are discussed in Section IV.J. Burning is a response method to a spill in moving pack ice or floes. Exploration drilling in the Chukchi Sea is currently accompanied by response barges and work vessels that provide additional platforms for working upon during an oil-spill response. Response NANA-3 We agree that exploration should proceed when the means for spill response have been developed. Experts from outside the oil industry, as well as within, have found that the oil industry in Alaska is capable of effective response during any season of the year in the Arctic. This includes decaying-ice, broken-ice, open- water, freeze-up, and winter conditions. Since exploration in the Chukchi Sea is planned to occur only during open-water or possibly broken-ice conditions, the current drilling technique seems appropriate. Regarding any potential production, ice researchers have stated that a Chukchi Sea structure would be similar to that designed for the Beaufort Sea. Industry’s preference is an inverted cone-shaped, gravity-based production system; but other economic alternatives are available. Any discovery would take 12 to 15 years to bring into production. Such a lead period will allow considerable time to evaluate production alternatives. Response NANA-4 Engineering studies indicate that a key consideration in the design of buried offshore pipelines in an arctic NANA-1 environment is to determine the optimum burial depths that maximize the pipeline’s safety from rupture by ice gouging and minimize costs. Prior to construction of subsea pipelines, operators would be required to conduct geological and geophysical surveys to determine potential hazards to the pipeline, including ice scouring. The density, age, depth, and reoccurrence rate of ice gouging must be fully evaluated and considered in the design, construction, and placement of a pipeline. Any pipeline design must include devices to monitor damage or leaks, and redundant automatic- and manual-shutdown valves to shut off the pipeline and stop a continuous leak if a break in the pipeline occurred. Continuous monitoring techniques will enable the operators of such pipelines to be forewarned of potential scour problems and to take corrective actions. Response NANA-; The EIS states that the muds and cuttings from the drill holes will be disposed of at the drill site under conditions in compliance with EPA’s NPDES. In Appendix J, prepared by the EPA, they state that land disposal of drilling muds and cuttings is generally undesirable. They also state that if the drilling-mud composition is such that ocean disposal would violate the conditions of the NPDES permit, on-land disposal would be the only option. It is expected that the drill muds used will meet the NPDES requirements, and on-land disposal will not be necessary. Response NANA-6 The proposed Sale 126 area is located north of Point Hope and is considerably removed from the coast, except in the Point Lay area. Based on published data, the MMS believes that the residents of NANA Region communities do not harvest resources within the lease-sale area but may harvest resources, such as caribou, walrus, seals, and birds that migrate through the lease-sale area or may be affected by an onshore oil pipeline. The effects levels on these migratory subsistence resources from Sale 126 activities are relatively low for populations as a whole. There could be effects to subsistence harvests by NANA Region residents of these migratory species, but the level of such effects cannot be determined with any degree of precision under these conditions of relatively low overall biological effects and vast distances over which considerable natural variability exists that could effect local hunting conditions. Response NANA-7 See Responses NANA-3 and NANA-4. NANA-2 ADELAIDE « AMSTERDAM + ANCHORAGE « AUCKLAND « BOSTON « BRUSSELS + BUENOS AIRES « CHICAGO » COPENHAGEN » DUBLIN ADELAIDE « AMSTERDAM + ANCHORAGE + AUCKLAND « BOSTON « BRUSSELS « BUENOS AIRES + CHICAGO * COPENHAGEN « DUBLIN, FORT LAUDERDALE « GOTHENBERG + HAMBURG « LEWES — U.K. « LONDON » LUXEMBOURG » MADRID « MONTREAL + OSLO + PALMA DE MALLORCA, FORT LAUDERDALE « GOTHENBERG » HAMBURG « LEWES — UK. + LONDON + LUXEMBOURG + MADRID « MONTREAL « OSLO « PALMA DE MALLORCA PARIS « ROME + SAN FRANCISCO « SAN JOSE — COSTA RICA « SEATTLE » STOCKHOLM + SYDNEY + TORONTO + VANCOUVER + VIENNA PARIS + ROME « SAN FRANCISCO « SAN JOSE — COSTA RICA « SEATTLE « STOCKHOLM « SYDNEY » TORONTO + VANCOUVER » VIENNA ‘WASHINGTON + WORLD PARK BASE — ANTARCTICA » ZURICH WASHINGTON + WORLD PARK BASE — ANTARCTICA « ZURICH GREENPEACE GREENPEACE Greenpeace USA + 1436 U Street NW * Washington DC 20009 « Tel (202) 462-1177 Greenpeace USA + 1436 U Street NW « Washington DC 20009 « Tel (202) 462-1177 Tix 89-2359 « Fax (202) 462-4507 Tix 89-2359 « Fax (202), 462-4507 BY FAX September 18, 1990 John Schindler Minerals Management Service Alaska Region Office of Leasing and Environment COMMENTS ON THE DRAFT EIS Dearie. iSenthales, FOR PROPOSED CHUKCHI SEA LEASE SALE 126 This is to confirm that MMS will accept the enclosed comments on Lease Sale 126. I had requested and received a one week extension SEPTEMBER 17, 1990 on the comment deadline until September 17; however, as I explained on the telephone this morning, I was unable to meet Prepared by Pamela Miller this extension because of a computer failure. In the interest of clarity, would you please let me know that MMS has accepted these comments and will treat them equally with any submitted within _the deadline- A hard copy of these comments will be sent to your office by mail. Thank you fer your cooperation. ‘Daatle, pee lt OcS Campaign Coordinator Introduction Greenpeace USA respectfully submits the following comments on the proposed Chukchi Sea Lease Sale 126 Draft Environmental Impact Statement (DEIS) on behalf of over 2 million supporters nationwide, 3000 of whom reside in the state of Alaska. Greenpeace strongly recommends that the Minerals Management Service (MMS) take the NO ACTION Alternative II for proposed Lease Sale 126 to prevent serious long-term inevitable and unmitigable impacts on the fragile Arctic environment. The proposed deferral alternative is too meager to provide adequate protection, although we note advocacy by other federal agencies should have resulted in immediate deletion of this area rather than mere "deferral". The Lease Sale 126 DEIS and MMS' zeal for drilling in this and other Arctic areas demonstrates its arrogant indifference toward environmental protection -- despite valid public concerns and skepticism on the part of other agencies and Congress. The DEIS reflects poor understanding of the Arctic marine, freshwater and terrestrial ecosystems under threat from proposed oil and gas development. It is our position that further proposed leasing in Arctic planning areas is being carried out hastily and without deserved consideration of the effect accelerated exploration and development will have on wildlife, habitat and Native cultural values, and without a critical eye toward the energy future of the United States. It has been our experience that MMS has only one goal -- to provide as much offshore land to the oil industry as possible. MMS is single-minded in promoting offshore drilling in even the areas most widely regarded as “sensitive.” The south Florida leases, for example, are located in close proximity to living coral reefs and the Everglades both of which are known to be highly vulnerable to spilled oil and pollution from the toxic constituents of drilling wastes. Yet MMS continues to advocate GP exploration on those leases and is resisting cancellation of the Al sale. As another example, the Bristol Bay lease sale was held in 1988 in spite of the region's unsurpassed marine biological diversity and the risk to world class fisheries. This persistence by MMS leads to the conclusion that the agency is not basing decisions on science, public concerns, or prudence. The proposed Lease Sale 126 threatens the Arctic environment with massive industrial development. The combination of large scale offshore operations and traffic from shorebased facilities potential oil spills, and the onshore pipeline system proposed across the North Slope to the Trans-Alaska pipeline will unleash unmitigable damage to this fragile region of the world. 1. MMS has inadequate information on which to base sound environmental decisions. We refute MMS‘ judgement that “the information base currently available is adequate for environmental assessment and for the Secretary of the Interior to make a decision concerning this lease sale." The National Academy of Sciences states “information on oil impact on polar environments is still fragmentary, with large knowledge gaps making the spill impact assessment more guesswork than sound appraisal. Underlying much of the uncertainty is the absence of data about the basic biology of many important polar marine species. Thus, studies are needed, GP not only on the effects of oil, but perhaps more so on ecological A2 relationships and on the precise ecological significance of such aspects as the several unique polar habitats -- leads, polynyas, ice edge and the under ice (1)." The National Academy of Sciences report to the President's task force on offshore drilling in California and Florida stated that MMS has inadequate information on which to make sound environmental decisions regarding proposed offshore drilling in those areas. The report also stated that less information is available for other OCS planning areas where public opposition has been less vocal (2). We question the validity of many of the conclusions in the DEIS since a large percentage of references cited are unavailable for review, were completed for government agencies or the oil industry and have not been published in peer-reviewed literature. Statements in the FEIS should be supported by data and analyses of references cited in the document, rather than by other documents “incorporated by reference". In addition, MMS' failure to include federal agency biological opinions further frustrates careful consideration of the proposed action. In its 1987 report to Congress, the U.S. Fish and Wildlife Service concluded: "fish and wildlife habitat losses resulting from the Pipeline System and Prudhoe Bay oilfields were greatly underestimated in the EIS. The qualitative nature of the EIS predictions made comparison of actual with predicted impacts difficult, and assessment of actual impacts was further confounded by the lack of baseline information and studies designed to specifically address EIS predictions. Monitoring efforts during construction focused on crisis-level responses to the most visible and immediate impacts, and did not address. the more subtle or latent effects on biological systems. Long-term and cumulative impacts have yet to be assessed, while additional impacts will continue to occur... The chain of events initiated by these developments continues, and it is difficult to separate their effects from those caused by the many other developments they have set in motion (3)." The Lease Sale 126 DEIS makes the same dangerous errors in trivializing potential impacts from the GP 1) GP 2 GP 3 proposed pipeline system and lacks the information necessary to assess cumulative, long-term and synergistic effects. 2. Technologies for safe operations in Arctic ice conditions are seriously lacking. In 1985, Lease Sale 85 was deleted from the 5-year schedule "to provide for further assessment of operations in heavy ice conditions." Lease Sale 109 was held in 1988 and Lease Sale 126 is scheduled for 1991, yet the DEIS does not explain what new information is available now regarding operations in heavy ice conditions. Indeed, the lack of referenced material post-1985 regarding this issue rai our concerns as to why Lease Sale 109 went forward and the current lease sale scheduled. GP 3 IGP 4 Uncertainties of offshore production technologies are illustrated in the DEIS -- "if ice island impact probability is very low and IGP 5 GP 6 an oil spill could be contained, a production platform could be designed and installed in the pack ice zone." The technologies for production operations in the pack ice are not developed, so it is impossible to assess whether these operations can be done safely. The DEIS notes the following with regard to exploratory rigs: “with icebreaker assistance, the floating units are capable of operating in the limited sea-ice conditions." Seasonal operations of exploratory rigs are a far cry from safe operation of production platforms in areas of multiyear ice. Production and transporation spill probabilities are not drawn from realistic conditions for this lease sale area, and are vastly underestimated. The elaborate scenario u: for pipeline transporation of oil ashore to Point Belcher is technologically unfeasible and unsafe. The DEIS admits that experience with arctic petroleum transportation is limited -- a gross understatement. Ice floe movements of 8 km/hour over a S-hour period associated with winds of 90 km/hr have been recorded at Barrow. Ice gouges in the sea floor of 3-8 meters depth are made by deep keels of drifting pack ice pre ridges (4). The environmental consequences of burying subsea pipelines in Arctic waters to avoid ice gouging are unknown and largely unpredictable. Poor understanding of distribution and behavior of subsea permafrost and potential long-term disturbance of benthic communities make subsea pipelines a questionable proposition. Stipulation no. 4 in the DEIS states that “pipelines will be required: (a) if pipeline rights-of-way can be determined and obtained; (b) if laying such pipelines is technologically feasible and environmentally preferable...." Proceeding with Lease Sale 126 under blind faith that these massive technological and safety questions will be overcome is unacceptable and further reveals how the leasing process is predisposed to development and production. MMS is not likely to allow environmental imperatives to stand in the way of exploration or production after industry 6 has made a substantial financial investment in the lease. MMS has failed miserably in enforcing environmental and safety rules for offshore drilling as evidenced by a Congressional report of the Subcommittee on Water, Power, and Offshore Energy Resources (5). The report documentnts that MMS found over 16,000 violations of environmental and safety rules in the years 1985- 1989, yet has not assessed a single civil penalty. "The nature of these violations range from extremely serious matters such as failure to test critical safety valves to lesser violations such GP as unsafe working conditions." The report further stated that “the administration has acknowledged the lack of enforcement and Zz has done nothing to correct it, clearly demonstrating they are not serious about enforcing it." These violations were found offshore California and in the Gulf of Mexico. Given this record in geographically accessable regions, we cannot assume that MMS will effectively monitor and enforce environmental and safety regulations in remote, harsh arctic conditions? This is further evidence to us that the lease sale process is driven by oil industry interest in league with MMS promotion and acquiescence without due regard for environmental protection. Also, under the Technology Assessment and Research Program discussed in Apendix P of the DEIS, MMS supports many joint federal-industry studies GP which focus on arctic engineering technologies. The proprietary nature of these studies belies an unholy union between the oil 8 industry and the government agency assigned to regulate that industry. 3. The Chukchi Sea marine ecosystem and adjacent tundra are highly sensitive and vulnerable to long-term damage from the proposed action. The DEIS demonstrates a serious lack of understanding of these ecosystems and draws unfounded qualitative conclusions that minimize potential impacts on Many species. The DEIS reveals a serious paucity of data necessary to assess impacts on biological featur unique to arctic marine environ- ments. "The Arctic presents special problems because of nearly year-round ice cover and inaccessibility. These are compounded by the large gaps in the data base on arctic biology, there existing only slim understanding of biological events during the brief open-water season and virtually no understanding of winter is unique features such as marine GP rustacean communities and seabird +.. The threat of ice and ice scouring, the appar- 9 ently slower degradation of stranded oil by arctic hydrocarbon- utilizing microbes and inaccessibility place this region near the to; of environmental concerns (1)." Sublethal effects "have more serious ecological consequences for polar species, many of which experience extreme oscillations in food supply. Any interference with the very abbreviated period of summer production may be critical for overwintering and reproductive success (1)." These biological realities are given inadequate consideration in the DEIS. In addition, the DIES fails to adequately consider the conse- quences of damage to the highly productive under-ice community which is critical in supplementing the brief season of water- column productivity when many species are releasing young. Stud- ies have shown ice algae communities to be highly sensitive to Prudhoe Bay and Cook Inlet crude (1). To date, there has been little research done on the biology of the ocean in shore leads and polynyas, largely due to inaccessi- bility (6). The authors of the DEIS take excessive liberties in the making arbitrary and qualitative assessments of VERY LOW to LOW impacts to most wildlife species given the lack of data on abundance and distribution of wildlife in the shore leads and polynyas of the Chukchi’Sea. The average lead-system width is less than 1 km between February and April, limiting the area into which and through which migratory species can move and making them extremely vulnerable to disturbance and/or spills. Persist- ence and subsequent release of spills through winter and several seasons is possible, placing large concentrations of arriving migratory species at considerable risk. GP 9 Even given the information we do know, many of the species popu- lations and habitats discussed are vulnerable to much greater risk than the DEIS would lead us to believe. Conclusions on population recovery rates for seabirds and marine mammals used to justify LOW impacts are largely unsupported. Reduced fecundity, dispersal and growth rates limits recovery rates in arctic envi- ronments (1). These population effects are not adequately considered in recov- ery predictions. In addition, probabilities of contamination of productive coastal lagoons, and kelp beds heavily used by birds and fish are grossly underestimated given the proximity of pro- posed developments (even with the meager Point Lay deferral alternative) and support activities. Specifically, we take issue with the following: a.) Air Quality The assertion in the DEIS that only "short-term, local effects on vegetation from a coating of soot" (base and high cases) dismisses potential for severe impacts to delicate tundra lichens from sulfurous air pollutants and toxic particulates in soot. The very rich, but understudied lichen flora of the North Slope is of considerable ecological importance as winter forage for caribou and in nitrogen-fixation (7). Similar low predicted levels of impact for the cumulative case are not believable. Though air GP 10 quality standards for NOx and other pollutants will be exceeded, only MODERATE overall impacts are predicted. The cumulative case fails to consider pollutant levels caused by transport from industrialized Europe and Asia and potential impacts from oil and gas development of the Soviet Arctic continental shelf. b.) Effects on Lower Trophic Levels The authors of the DEIS have the audacity to proclaim that "substrate changes may enhance habitats for some species" with no documentation or explanation. Habitat changes are only liklely to promote colonization by opportunistic and undesirable species. Given the volume and extent of drilling muds and other dis- charges, as well as lack of information on the behavior of these wastes in arctic marine systems, the potential impacts on water quality and benthic communities are considerably understated. The DEIS acknowledges the vulnerability of kelp beds and associ- ated communities, but underestimates probabilities of oil con- tact. Kelp bed distributions should be included on resource maps in the FEIS. c.) Effects on Marine Fishes The DEIS predicts low impacts even though it cites references stating that comprehensive information concerning the life histo- ry, population dynamics, distributions and ecological relation- ships of most of thesé species in lacking. This is not logical. da.) Effects from Pipeline The DEIS acknowledges VERY HIGH potential to fishes of the ten major rivers traversed by the proposed onshore pipeline, but ignores potential habitat destruction and direct impacts on nesting birds and other wildlife inhabiting the river cortidors and associated wetlands. The DEIS notes 40% of the pipeline length would traverse wetlands, the vulnerabilities of which are poorly considered. Please note also the assesment of USFWS qouted in section 1 of these comments regarding pipeline impacts The DEIS also notes that development at Point Belcher for the pipeline landfall is “highly incompatable" with current uses (subsistence hunting base). This incompatibility betrays the intention of the federal Coastal Zone Management Act. The USFWS also expressed concern in the scoping process for “environmental effects caused by pipeline landfalls; utility corridors within units of Alaska Maritime National Wildlife Refuge; the barrier islands; and the combined effects of OCS activities and other onshore and offshore oil and gas developments -- existing and potential." These concerns are not adequately addressed in the DEIS. e.) Birds As stated above, recovery rates for birds affected by oil spills are grossly underestimated given the major population concentra- GP 10 GP 11 ———————— IGP 2 GP 13 LU LN GP 14 Cal GP 15 GP 16 GP 17 | tions in lead-systems and coastal lagoons, vulnerabilities and low reproductive rates. Probabilities of contact are also under- estimated. Because activities from supply and support ve: ls are underrepresented, effects of disturbances are underestimated. Dr. George Hunt, eminent seabird biologist, has stated that a major spill could damage a world population of seabird species (8). Given the concentrations of eider, brant, lesser snow geese, murres, and other species of seabirds in coastal lagoons and leads, this is entirely possible. Many erroneous and contradictory statements are made including: 1)"Spills that occurred during winter would have no immediate effect on birds (IV C-32)." This ignores overwintering species occupying polynyas -- a poorly studied phenomenon. It should also be noted that spilled oil locked in ice can be released in the spring presenting new dangers to wildlife long after the initial spill event. 2)"The presence of surplus (sic) murres could speed replacement (Iv C-34)." Where will these "surplus" murres come from? An MMS surplus murre farm? The U.S. Army Surplus Murre Department? Wildlife does not occur in surplus and the fact that MMS would describe populations in this way indicates not only a lack of understanding of wildlife ecology but a lack of sensitivity for the value of the individuals which make up a population. GP 3) The DEIS states Ross' gull is at considerable risk, then 17 contradicts this by predicting LOW impacts. 4) The DEIS concludes that there is an abundance of uncontaminat- ed habitats, so that local feeding and nesting habitat destruc- tion represents no measurable effect (IV C-35). This is totally unfounded. 5) Cleanup activities in the event of a spill were presented as mitigation measures to drive birds away from contaminated areas. This is also unfounded. In fact, disturbances from cleanup activities after the Exxon Valdez spill caused significant nest abandonment and reproductive failures. 6) The DEIS states that bird densities in offshore migration corridors during open water are “relatively low", but gives no data to support that conclusion (IV C-32). 7) Regarding murre impacts from the Exxon Valdez, the DEIS as- serts that an “even higher level of murre mortality would not represent a threat to the species on a regional basis." This is totally unfounded. Murres accounted for 74% of the 100,000 to 300,000 birds killed by the Exxon Valdez, and are suffering a population decline on the west coast. Population impacts on purres should not be so easily dismissed. f.) Endangered Species and Other Cetaceans The bowhead whale population remains dangerously low despite the decades of protection from commercial exploitation. NMFS acknowl- edges that "present and proposed OCS exploratory and development activities in the Arctic region may eventually adversely affect the successful life cycle of bowhead whales (8)." Long-term displacement of bowheads from industrial areas has been document- ed. From 1984-86, significantly fewer animals were found in the industrial zone near the Mackenzie Delta -- an area of artificial island construction, drilling, overflights -- than in 1979-83 (9). The DEIS fails to address possible long-term behavioral changes that may result from planned OCS activities -- the ab- sence of short-term effects is extrapolated to mean the absence of effects. Almost all studies have used the following endpoints to measure bowhead response: 1)change in heading, 2)change in respiration rate, 3) change in dive profile (9). Short-term observations of these parameters from areal surveys, the results of which were not published in peer-reviewed literature, does not constitute adequate consideration of potential long-term disturb- ance effects which could occur by displacement form primary migration and feeding areas. The DEIS fails to discuss key behavioral and distributional information critical to impact assessment. Bowheads are calving on the northbound migration through the Chukchi Sea. Little is GP known of the southbound route after they pass Barrow, though they 18 have been seen at Wrangel Island. the DEIS makes the false as- sumption that “the effect of industrial noise in or near to the spring lead is likely to be similar to that anywhere else, since the stimuli are the same (IV B-9)." In the final rule for an incidental take permit under the Marine Mammal Protection Act, even Shell Western has agreed to not operate in the spring lead. It would seem that MMS could at the very least acknowledge the sensitivity of whales during this extremely vulnerable season. Another false assumption in the DEIS is that bowhead and gray whales can "be discussed together due to their simularities in their response to similar stimuli (IV B-8)." The two whales differ considerably in feeding behavior and migration patterns, to say the least. Vulnerability of gray whales in areas of concentration near Point Belcher and other significant feeding areas in not considered. The bowhead whale, which by virtue of its low population numbers and annual migration through the lead systems of the Bering, Chukchi, and Beaufort Seas, is at considerable risk from existing and proposed OCS activities (1). It is entirely irresponsible for the DEIS to conclude VERY LOW risks in the base and high cases and MODERATE in the cumulative case, since "the entire population of bowhead whales is susceptible to impacts in this area during their spring migration through nearshore leads (1)." The DEIS fails to consider extenuating circumstances presented by arctic conditions in assessing potential impacts on marine mam- mals, such as beluga whales and other cetaceans. For example, GP oil could be very difficult for marine mammals to detect and avoid in arctic waters because of widespread ice cover and 18 darkness (10). Movements of belugas and other marine mammals are directed and concentrated by location of leads and polynyas, thus inhibiting their ability to avoid contaminated areas. g.) Polar Bears and Pinnipeds As with wildlife discussed above, probabilities of oil contact and habitat destruction from oil spills for polar bears and pinnipeds is grossly underestimated. Lead systems (over water depths 20-50 meters) are the main seasonal migration route for polar bears moving back and forth between their summering areas and winter hunting habitat. Consequently, a significant proportion of the population is susceptible to impacts in these prime feeding areas (6). Significant habitat alterations from the creation of artificial leads by offshore rigs in winter would serve to concentrate polar bears and pinnipeds, and greatly increase potential impacts in the event of a spill. There is no reliable polulation estimate for the Chukchi Sea (6). Significant numbers of polar bears attracted to exploratory rigs have had to be shot because of preceived threats to humans (11). The DEIS fails to adequately consider these serious threats to the polar bear. Since the population of polar bears in the Chucki Sea migrates back and forth between the U.S. and U.S.S.R., and is protected by GP the International Agreement on the Conservation of Polar Bears and Their Habitats, international consequences of damage to polar 19 bears may result. Wrangel Island, and important denning area for polar bear, has a high percentage chance of oil contact (18%), as well as other productive areas or marine mammals and seabirds along the Siberian coast (Chukchi Peninsula, Herald Island). The DEIS concedes that a few thousand walrus, mainly cows and calves, could be “contacted” with oil in the event of a spill and more if the walrus are concentrated by food supply. Given the fact that nearly all pregnant females and those with calves migrate into the Chukchi Sea in large nursery herds in summer and the Chukchi Sea is their primary summer feeding ground, potential for devastation of the population exists. The DEIS fails to consider the loss of reproductive potential that would result if large numbers of breeding females were lost from the population. It is entirely incomprehensible that the DEIS concludes that impacts on Pacific walrus will be LOW. Significant impacts on polar bears and pinnipeds are inevitable from exploration and development of offshore oil and gas in this and other areas of the Arctic. h.) Sociocultural Local communities and subsistence lifestyles will suffer 10 extremely negative consequences from oil and gas development in the Chukchi and Beaufort Seas. The DEIS predicts curtailment and multiyear suspensions of subsistence activities in some areas, as well as other VERY HIGH negative impacts that boom and bust industrial development inevitably brings. A growing number of villages and Native subsistence and fishing groups have expressed serious concerns, and indeed, opposition to further leasing in the Chukchi Sea. 4. Qil spill probabilities underestimated, contingency plans and capabilities are inadequate and ineffective. The DEIS states (p. xix) that "effects from oil spills would be mitigated by the extent to which weathering occurred at sea and by effectiveness of any oil spill cleanup measures." The idea of mitigation is a dangerous myth. As discussed above, weathering of oil in Arctic waters is extremely slow, especially if entrained in ice. The oil spill response described in the DEIS is grossly inadequate. MMS requires that industry respond within 6-12 hours, geography permitting. This qualifier is an admission that response is not expected to be possible under common GP conditions in the Arctic. 20 In the article "Offshore Oil in the Alaskan Arctic," the authors “doubt that there will ever be completely satisfactory response to cleanup of an arctic oil spill other than preventing it from occurring (4)." The report by the Alaska Oil Spill Commission described cleanup capability in the Arctic as "bleak (12)." Prevention of oil spill under severe arctic conditions is also impossible. We question the efficacy of the spill rate data used. The DEIS states, "due to data limitations, tanker spill data rates were derived from worldwide spill data from 1974-1985." This produces underestimates of the risks of transporting oil in the Arctic and north Pacific. High risks of spills from offshore oil production in the Arctic are not reflected from generic OCS production data, and results in conservative estimates of potential spills. The worst case scenario, an uncontrolled blowout, is not presented. The impact of a catastrophic event should not be disregarded because of the statistical manipulation GP that "predicts" it should not happen. 21 For tanker spills only, the cumulative case predicts 15 spill of greater than 1000 bbls. The consistent use of greater than 1000 barrels is misleading for transportation and production scenarios, since in the case of tanker spills, the 15 spills consist of 7 spills of 5000 bbls, 1 of 15,000 bbls, 3 of 110,000 bbl spills, 3 of 260,000 bbls, and 1 of 520,000 bbls! That scenario predicts 3 spills of comparable size to the Exxon Valdez spill and 1 spill twice the size of the Exxon Valdez. To take 11 GP those kinds of risks in developing the Alaskan Arctic OCS is 21 wholly unacceptable. 5. Developing Chukchi Sea and other Arctic OCS energy resources will not contribute to U.S. energy security. The DEIS reiterates that one of the goals of the leasing program is to reduce dependency on foreign oil. This is short-sighted in light of the fact that we have the capability to implement conservation programs and alternative technologies that would preclude our crippling and environmentally devastating dependence on fossil fuels. The DEIS admits that “major dependence on a non-renewable resource-based economy could cause long-term social costs at the time of resource depletion." According to the DEIS, the base case resource estimate for Lease Sale 126 is 1,160 million bbl. This translates into about 95 days worth of oil at the current rate of consumption in the U.S. Even the high case estimate is the equivelent of only 208 days, or about six months, of oil. It is understood that this oil would be produced over a longer periods of time, but it is essential for GP the federal government to recognize that the OCS resources means far more in terms of industry profits than it does for energy for |22 the nation. The current Middle East situation is a signal for the U.S. to establish an aggressive energy conservation program which would replace foreign imports and OCS oil and gas many times over. Since the conservation programs created in response to the oil embargoes of the 1970's, the U.S. has saved $150 billion every year and 14 million bbl of oil every day. The U.S. is still twice as energy inefficient as many other industrialized countries. Further dependence on both foreign and domestic oil will only contribute more to the greehouse effect and acid rain. According to World Watch Institute, as much energy leaks through American windows every year as flows through the Alaska pipeline. It is unconscionable that the federal government, via MMS, would permit putting the entire Alaskan Arctic coast at risk through more development before exploiting the renewable energy resources available to us at a fraction of the cost to society and to the great benefit of the environment. 6. Potential cumulative. long-term. chronic and interregional impacts of oil and gas development in the Arctic and North Pacific have been vastly understated in this DEIs. As stated in Boesch and Rabalais' Long Term Effects of Offshore Qil and Gas Development, "the most significant unanswered questions for offshore oil and gas development are those 12 regarding the effects on ecosystems of long-term, chronic low- level exposures resulting from discharges, spills, leaks and disruptions caused by development activities...the cases of habitat disruptions or chronic petroleum contamination, either as a result of continuous or intermittent discharges or from repetitive accidental spills during the life of a field (13)." This is especially true of poorly understood Arctic ecosystems. Oil and gas development planned for other areas of the Arctic have the potential for devastating impacts on the entire arctic ecosystem and circumpolar populations such as the polar bear, in particular. Development of offshore oil and gas planned or being developed in the Soviet Arctic, Greenland, Svalbard, the Canadian High Arctic Islands and Hudson Bay, as well as the Canadian Beaufort and U.S. The polar bear is protected under the International Agreement on the Conservation of Polar Bears and Their Habitat, signed by Canada, Denmark, Norway, U.S.S.R., and the U.S. Potential global climate changes may be set in motion from a large spill in the Arctic as would result from a large uncontrolled blowout. Large quantities of oil could greatly accelerate melting of polar ice. Reduction of the reflective properties of oil-contaminated ice could accentuate melting and prevent refreezing. With exposure of the polar sea, meteorological conditions over the northern hemisphere would drastically change (14). Lease Sale 126 will place the Arctic marine, coastal and terrestrial ecosystem at great risk to long-term, chronic and acute damage from large scale oil development. It is incumbent upon the Department of the Interior to exercise reasonable caution by adopting the NO ACTION alternative. Thank you for your careful consideration of these comments. 13 REFERENCES 1) Oil in the Seas: Input, Fates and Effects. 1985. National Academy Press. 2) The Adequacy of Environmental Information for Outer - Continental Shelf Oil and Gas Decisions: Florida and California. 1989. National Academy Press. 3) USFWS Report to Congress on the Trans-Alaska Pipeline. 1987. 4) Weeks, W.F. and Weller, G. 1984. Offshore oil in the Alaskan Arctic. Science 255:371-378. 5) Committee Report of the House Interior Subcommittee on Water, Power and Offshore Energy, June 28, 1989. 6) Stirling, I. 1989. Polar Bears. Fitzhenry and Whiteside, Toronto. 7) Personal communication, Fred Rhoades, Botanist, Western Washington University, 8 September 1990. 8) Hunt, G. 1989. Pacific OCS Information Transfer Meeting presentation, Santa Barbara, May 1989. 9) Personal Communication, James Cubbage, Marine Mammal Biologist with Cascadia Research Collective, September 8, 1990. 10) National Marine Fisheries Service Proposed Rules for Incidental Take of Marine Mammals, Federal Register, October 3, 1989. 11) Stirling, I. 1988. Attraction of Polar Bears to Offshore Drilling Sites in the Eastern Beaufort Sea. Polar Record 24(148) :1-8. 12) Alaska Oil Spill Commission. 1990. Spill: The Wreck of the Exxon Valdez. 13) Boesch, D. and N. Rabalais. 1987. Long-term Environmental Effects of Offshore Oil and Gas Development. Elsevier Applied Science, London. 14) Personal Communication, Dr. Charles Jonkel, Polar Bear Biologist and Arctic Ecologist with the University of Montana, September 8, 1990. 14 Greenpeace USA Response GP-Al The DOI is charged by law (OCSLA) to develop the resources of the OCS. Highly vulnerable and critical resources and habitats are considered in this EIS, but the information contained in the EIS is only part of the information used by the Secretary to make an informed decision about whether or not to hold the sale and, if so, what conditions of block configuration and/or forms of mitigation will be imposed. The Secretary’s decision must also take into account other national-interest and economic information as well as the environmental information contained in the EIS. Response GP-A2 The MMS considers the information currently available to be adequate for a basic understanding of the potential environmental effects of Sale 126 in and adjacent to the sale area. In addition, MMS has successfully evaluated the potential environmental effects of two other lease sales in the Chukchi Sea Planning Area. The first sale, Sale 85, scheduled for February 1985, was not held. The second sale, Sale 109, was held in May 1988; but the task of analyzing the effects of the sale had to begin long before the sale date. Since work began on the first sale, the amount of information available to analyze the effects of petroleum exploitation in the Chukchi Sea has been increasing. The MMS Environmental Studies Program has helped to increase the information base. As a measure of this contribution, MMS has expended over $120 million on environmental studies in the Chukchi and Beaufort Seas during the period 1975 to March 1988. The studies conducted have investigated major disciplines including geology, oceanography, sea ice, pollutant transport, living resources, endangered species, ecosystems, oil-spill effects, noise effects, sociocultural systems, socioeconomic systems, and transportation; and a considerable effort has been made to integrate and synthesize available information. Monitoring programs have been developed to study specific effects on resources of concern. Response GP-1 The information used and cited in this EIS represents the best scientific data available for environmental description and analysis purposes. The MMS makes every effort to use reports and publications that are available for public review, including reports of the MMS Environmental Studies Program. The use of peer review is encouraged by MMS, but it is not always possible to accomplish this. The practice of incorporating material by reference is used as a means of reducing the bulk of the document, in accordance with CEQ regulations. Response GP-2 Federal-agency biological opinions were not reproduced in the DEIS because they were not available when the DEIS was published; they are now included in Appendix D of this FEIS. Response GP-3 The environmental-assessment process is an ongoing learning process that makes use of the best scientific data available at the time. This underscores the need to monitor environmental effects, as more becomes known over time, so as to better evaluate changing cumulative, long-term, and synergistic effects. With regard to the overland pipeline used in the developmental scenario for this EIS, no attempt was made to trivialize its potential effects, as was shown, for example, with the VERY-HIGH effects level assessed for fishes occupying freshwater habitats. This effects level was the direct result of potential spills (the number of which were predicted for the scenario) from the overland pipeline affecting freshwater streams and deltas. GP-1 Response GP-4 Lease Sale 85 was deleted from the 5-Year Oil and Gas Leasing Program to address the concerns of the State of Alaska and the Alaska Congressional delegation. The following sentences regarding those concerns are excerpted from a January 10, 1984, letter from the Honorable Bill Sheffield, Governor of Alaska, to William Clark, Secretary of the Interior: "The primary concern of the state was the pace of the Department of Interior’s current five-year oil and gas leasing program. Due to internal budget constraints, the MMS personnel assigned to Alaska’s OCS appear to be insufficient for their greatly expanded responsibilities under the accelerated program. A two year delay would enable valuable scientific data interpretation and synthesis effort of available information to continue." The assessment of working in heavy ice conditions was completed in the Sale 109 FEIS (USDOI, MMS, 1987b). Exploration is likely to continue in open-water conditions. It is estimated that development drilling will begin in 2000. This allows 9 years for the oil industry to study conditions. Drilling will be allowed when the oil industry demonstrates to MMS that they can operate safely in the ice conditions of the Chukchi Sea. Response GP-5 The ice-strengthened drillships and the CDU have shown that they can be used to safely and successfully drill exploration wells. Prior to operating in Alaskan waters, these units have been used since 1976 to drill exploration wells in the Canadian Beaufort Sea; also, they were inspected by MMS and the USCG to ensure compliance with applicable MMS and USCG regulations. Before an exploration well can be drilled on an OCS lease, the lessee must submit an exploration plan in accordance with 30 CFR 250.33 for approval by MMS. Information in the plan includes (1) a description of the type of drilling unit to be used and important safety and pollution-prevention features and (2) an oil- spill-contingency plan. After it has been deemed submitted, the exploration plan is transmitted to the governor and the CZM agency of each affected state. Comments from the governor are considered in the evaluation of environmental impacts of the activities described in the plan. The exploration plan may be (1) approved; (2) modified if it is inconsistent with the provisions of the lease, OCSLA, or regulations prescribed under the OCSLA including air quality, environmental safety, and health requirement; or (3) disapproved if it is determined that a proposed activity probably would cause serious harm or damage to life, property, offshore natural resources, the national security or defense, or the marine, coastal, or human environment, and that the proposed activity cannot be modified to avoid the condition(s). Prior to the initial drilling of a well under an approved exploration plan, the lessee shall submit to MMS an APD for approval (30 CFR 250.64). The APD’s for wells to be drilled from mobile drilling units shall include (1) an identification of the maximum environmental and operational conditions the rig is designed to withstand; (2) documentation of operational limitations imposed by the American Bureau of Shipping classification or other appropriate classification society, and either a USCG Certificate of Inspection or Letter of Compliance; and (3) for frontier areas, the design and operation limitations beyond which suspension, curtailment, or modification of drilling or rig operations are required (e.g., vessel motion, offset, riser angle, anchor tensions, wind speed, wave height, currents, icing or ice loading, settling, tilt, or later movement) and contingency plans that identify actions to be taken prior to exceeding the design or operating limitations of the rig. The MMS considers that the operating experiences, inspections, and information submitted in the exploration plans and the APD’s ensure that exploration wells can be drilled safely from floating units and in a manner that minimizes potential environmental effects and pollution risks. GP-2 Response GP-6 The system used to transport any commercial oil discoveries will depend on where the oil is discovered and the environmental features at and near the discovery site: the amount and characteristics of the oil; the relative costs of constructing, operating, and maintaining various systems that might be used; regulatory requirements; and the possible use of existing transportation systems. The Sale 126 pipeline scenario is a hypothetical case to equally distribute hypothetical pipeline-spill points throughout the Sale 126 area. The commenter’s interpretation on the distribution of permafrost is in agreement with the analysis in Section III.A.1(c)(2). Permafrost-behavior references have been added to Section III.A.1(c)(2). Extensive work on ice gouging has occurred on the Canadian Beaufort Shelf. The technical considerations for Beaufort Sea pipelines are discussed in Weidler et al. (1985). Row et al. (1987) looked at the overall feasibility for design of offshore arctic pipelines and concluded that current technology and design procedures allow technically feasible designs of arctic offshore pipelines to be developed. Response GP-7 The MMS is familiar with the referenced report and its findings that over 16,000 violations have been found and that no civil penalties have been issued. The lack of civil penalties was a result of a U.S. District Court ruling that MMS had no authority to impose civil penalties for violations without first providing the company the opportunity to correct the violation. The MMS subsequently sought legislative changes to the OCSLA that would allow civil penalties to be imposed for violations, regardless of corrective action taken. Legislative amendments were passed in the Oil Pollution Act of 1990 (Title 8, Section 8201), and MMS is currently pursuing promulgation of regulations to implement the changes to the law. Even without legislative authority to impose civil penalties, MMS has effective enforcement authorities. The MMS has the authority, and has required companies, to shutin a platform or specific component if operations are not in compliance with regulatory requirements. Operations are required to remain shutin while the violation is corrected. Most violations are minor and corrected immediately. The Alaska OCS Region inspection strategy is to maintain at least a near-continuous presence at the location during exploratory-drilling activities to ensure compliance with all applicable regulations, lease terms, and specific conditions of approval. This strategy has been adopted, in part, due to the nature of drilling activities, the special operating stipulations, the public concerns for maintaining a safe and pollution-free environment, and the remoteness of the Alaskan OCS. Inspections consist of witnessing critical operations and tests, records checks for proper worker qualifications and training, and checks for proper maintenance, testing, and testing frequency of safety, pollution-prevention and pollution-cleanup equipment at the drilling location, and for safe and workman-like operations. We believe that MMS has a credible and effective inspection and enforcement program that is further strengthened by the new legislative authority to impose civil penalties. Response _GP-8 The joint cooperation and funding of oil and gas-related studies is common to several countries, e.g., Canada. The proprietary nature of the studies extends only to those studies funded jointly by MMS and industry; these studies are proprietary for a limited time and are then available to the public. Wholly MMS-funded Technology Assessment and Research Program (TA&RP) studies are not proprietary and are available to the public. The MMS participates in joint technical projects with other governments and industry due, in part, to the tremendous costs associated with technical research, particularly large-scale field studies. The results of this research are available to MMS and industry in evaluating the technical aspects of oil and gas operations. These research efforts are not related to specific industry activities under consideration for GP-3 approval by MMS. The MMS does not consider joint research an “unholy union" but rather appropriate and necessary for MMS to remain abreast of technological advances. Response GP-9 While there is the desire to have more information about any ecosystem, MMS considers that there is sufficient information concerning the distribution and abundance of organisms inhabiting the Chukchi region, when combined with the OSRA and other environmental information, to forecast significant effects of oil and gas development in the sale area. According to the results of the OSRA, MMS has not underestimated the probability of oil contact in coastal areas. Given the relatively small numbers of individual birds and mammals likely to be contacted by oil, or the relatively small areas occupied by prey organisms likely to be affected, MMS feels that the concluded effect levels are realistic. The MMS would be receptive to any additional specific information pertinent to a discussion of potential effects that could result from this sale. Essentially all of the potential adverse effects discussed in references cited by the commenter are discussed in the introductory sections of these analyses, in referenced EIS’s, or other documents. To clarify your concerns, an analysis or discussion based on the specific evidence contained in the cited publications would be most useful. Response GP-10 The Western Arctic caribou herd depends on lichens and mosses for winter forage. A number of factors should be considered in evaluating whether the Western Arctic caribou winter-forage area could be affected by soot from burning spilled oil. The forage area is more than 80 km (50 mi) from the nearest part of the sale area. Northwest winds that could carry soot in the direction of the wintering area occur only 1 to 2 percent of the time. Ocean currents would carry spilled oil away from the wintering area. Soot deposited from a burn during the open-water season would likely be dispersed over a large area but could be concentrated in a small area. Summer and fall rains would remove some soot from lichens and mosses. Any winter burns would be from many small sources as oil surfaced in leads and ignited. Oil burned in the winter would have traveled with winds and currents farther from the winter-forage area. Only a spill of > 10,000 bbl close to shore could noticeably contaminate land. Given the distance from shore, the low likelihood of a spill of sufficient size to generate sufficient soot to travel to the winter-foraging area, and the potential mitigating effect of summer and fall rains, it is not likely that soot would affect the Western Arctic caribou winter- foraging area. All cases consider transport of winter and spring pollutants from industrialized Europe and Asia. Modeled emissions and emissions from other known sources are considered in determining compliance with Prevention of Significant Deterioration and National standards. Offshore Soviet arctic oil and gas development is not considered a reasonably foreseeable event for the cumulative case. Response GP-11 Since substrate changes associated with offshore oil and gas drilling/development are accumulative rather than subtractive, it follows that the miniscule increased substrate and subsequent similar change in benthic topography would increase the area available for colonization. Whether the colonizing species would be alien to that ecosystem is doubtful. At any rate, whether the colonizers are opportunistic or undesirable is a matter of judgment. Results of numerous studies to date have shown only very localized, short-term adverse effects on the biota from the discharge of drilling muds and fluids. Section IV discusses these discharges and their effects in some detail. GP-4 Response GP-12 Based on the OSRA, there is a low probability that the two shallow-water kelp beds located to date would be contacted by an oil spill. The location of these kelp beds is described in Section III.B.1.c., where it is also stated that their area varies to the extent that this measurement is indeterminate. Based on surveys to date, kelp beds are uncommon in the Chukchi Sea. Response GP-13 The assessment of low effect is based on the low number of oil spills projected to occur, their low volume, their infrequency as compared with the length of the proposed project, and the wide distribution of marine fish populations in the Chukchi Sea in comparison to the limited distribution of the projected small number/volume of oil spills. There is, we believe, sufficient information on the effects of discharges on fisheries habitats to justify the low-effect conclusion. Seismic surveys have been found to have virtually no effect on fishes. Response GP-14 The potential effects of onshore spills are considered in Sections IV.C.5 and IV.C.9. The relatively small areas of tundra and wetland affected by small onshore oil spills are likely to result in minor effects on bird and mammal populations. A spill in a major river also is unlikely to result in high mortality, since a spill would be greatly diluted if allowed to run the full length of the river; and most tundra-breeding waterbirds spend most of the breeding period on or near tundra ponds or in coastal areas rather than on major rivers. Development of the magnitude of Prudhoe Bay (FWS assessment cited by commenter) is not likely to be associated with construction and operation of the onshore pipeline. Response GP-15 The Point Belcher landfall is included in the scenario for analysis purposes only. Effects on land use plans and coastal management programs are discussed in Section IV.C.14 for the base case (Alternative I) and in Section IV.D.14 for the Point Lay Deferral Alternative (Alternative IV). Response GP-16 Every effort is made in this EIS to address pertinent issues identified in the scoping process. Contrary to the suggestion of the commenter, this EIS has addressed the environmental effects caused by the pipeline landfall at Point Belcher and the potential effects on the barrier islands. The effects of utility corridors within units of the Alaska Maritime National Wildlife Refuge were not addressed because the proposed lease sale is well northward of the northernmost segment of this refuge. "The combined effects of OCS activities and other onshore and offshore oil and gas developments--existing and potential" are discussed in Section IV.H. Response GP-17 The MMS takes exception to the statement that recovery rates for birds affected by oil spills are underestimated; we can find no substantiation for this statement by the commenter. Recovery rates, which were determined from Ford et al. (1982) (added to the FEIS bibliography), depend on percent mortality of a given population; these determinations incorporate species’ sensitivity and reproductive rates. The probabilities of oil-spill occurrence and contact are taken directly from Tables C-13 through C-16 of Appendix C. We find no example to substantiate the claim that the values used are underestimated; perhaps the commenter is confusing conditional probabilities, which assume that oil has been spilled, with combined probabilities, which incorporate the probability of spill occurrence and thus are lower. Certainly a large spill entering a coastal lagoon or lead during a period of heavy use by waterbirds could result in substantial mortality; but in concluding a level of effect, the likelihood of this occurring and the likely proportion of the GP-S regional population involved also must be considered. A large proportion of relatively few species populations concentrates where there is a high probability of occurrence and contact by a spill associated with this sale. No examples offered by the commenter substantiate the claim that activities of supply and support vessels, and potential disturbance arising therefrom, are underestimated. In fact, rather low numbers of vessels are contemplated; and since there is no evidence of significant disturbance of marine birds by vessels, the expected level of potential disturbance from this source is likely to be low. Regarding the numbered statements in this comment: (1) Although admittedly not well studied, there is little evidence to suggest that large numbers of birds overwinter in the flaw-zone lead or polynya that may extend from Point Hope to Barrow in late winter and spring. During the winter, this lead could often be less than 1 km wide and open only 50 percent of the time--not favorable statistics for an overwintering population. Effects from oil spilled in winter and released at breakup probably are more correctly termed "delayed" rather than "new" effects, since oil poses little danger to birds while it is encapsulated in the ice. (2) At each colony there exists a reservoir of nonbreeding murres from which individuals occupying any newly vacated breeding sites will come. This subpopulation includes young birds that have not yet bred, birds that have bred in the past but do not presently occupy a site, and failed breeders from the current season. This group may comprise a substantial proportion (e.g., 50%) of the birds present at the colony. In the sense that they are contributing nothing to the current reproductive effort of the population, they are "surplus," although this should not be interpreted as meaning expendable since they represent the replacements for any birds lost during the year. It is reasonable to suppose that species with a large population (e.g., murres) are likely to recover rather quickly from even a substantial incidence of mortality. The MMS disagrees with the statement that "wildlife does not occur in surplus"; there are numerous studies showing that when breeding birds are removed from a population, their vacant breeding site is soon reoccupied by individuals from a nonbreeding, "floater" subpopulation. Also, it would be difficult to explain population cycles if there were not, at times, a surplus of individuals beyond what a given habitat could support. MMS personnel are as concerned over the presumably painful death of individual birds in an oil spill as the general public is; however, the more important aspect, and the one that necessarily commands our attention because of the particular phrasing of the effect definitions used in this EIS, is the potential effect on regional populations and species. That is, we are not insensitive to the plight of individuals or individual colonies; but mortality is appropriately considered at the population level and related to the survival of the species. (3) The EIS states that the Ross’ gull could be at considerable risk. Other factors, such as the amount of time they are likely to be in the area of higher risk and their foraging method, were considered in concluding an overall low effect. (4) The cited statement actually reads ". . .represents no measurable effect on the availability of wetland- and tundra-bird habitats due to the abundance of uncontaminated habitats." The implication here is that the area of these habitats likely to be contaminated represents a very small proportion of that available in northern Alaska. The text of Section IV.C.5 has been revised to clarify this interpretation. (5) The statement suggesting that cleanup activities could drive birds away from an onshore-spill site, thereby making it less likely that they would be affected by oil, is presented as a possibility--not a fact. It also is noted that the reproductive effort of these individuals probably would be lost. (6) The best available information concerning pelagic-bird densities is found in Fadely et al. (1989); this citation has been added to the FEIS text. (7) Murres accounted for 74 percent of approximately 30,000 birds examined following the Exxon Valdez oil spill; the proportion of this number that was already dead and then oiled is unknown, as is the accuracy of the estimated 100,000 to 300,000 total mortality based on the 30,000 figure, since it is founded on very little GP-6 rigorous experimentation and mathematical modeling. If the figures are correct, the loss of 30,000 murres from an estimated population of 10 million (Sowls, Hatch, and Lensink, 1978) is not likely to threaten the species. Res, P-1 Fewer whales were observed in the industrial zone near the Mackenzie River Delta during the 1980-1984 period. The statement by Richardson et al. (1985) says that bowhead distribution may or may not be influenced by industrial activities, that bowhead distribution probably depends strongly on prey distribution, and that until prey/bowhead dynamics were understood it would be difficult to attribute changes in bowhead distribution to industrial activities. Since prey/bowhead dynamics are not yet understood, it remains unknown whether industrial activities have or have not affected bowhead distribution in the Mackenzie Delta area. The findings from a later distributional study (Harwood and Davis, 1985) add support to the hypothesis that prey distribution is responsible for bowhead distribution. Industrial noise has only a local, short-term effect on those whales that respond to it. It is not known if there are significant effects in the long term. Since potential long-term effects are unknown, they were not factored into the analysis. When and if production and development activities are contemplated, consultation will be renitiated with NMFS. Regarding the EIS assumptions that industrial noise in or near the spring lead is likely to be similar to that anywhere else, and that bowheads and gray whales can be discussed together, these assumptions are well- supported (e.g., Richardson et al., 1984, 1985; Malme et al., 1983; 1984, 1985, 1986; Ljungblad et al., 1985; Wartzok et al., 1989). In every geographic area examined, and for every whale species observed, whales have been observed to respond to similar industrial stimuli in a similar fashion. This includes bowhead whales that were responding to industrial noise in the spring lead system (see Richardson et al., 1990). Industrial operations are not likely to affect gray whales on their summer feeding grounds, since these grounds are located largely outside of the sale area. Further, all authoritative studies to date (e.g., Richardson et al., 1984, 1985, 1990; Malme et al., 1983, 1984, 1985, 1986; Ljungblad et al., 1985; Wartzok et al., 1989; Geraci and St. Aubin, 1980, 1982, 1985; Fishman et al., 1985) have shown that industrial noise and crude oil are likely to have only local, short-term effects on some whales. Consequently, industrial operations associated with Sale 126 are likely to have a very low effect on bowhead and gray whale populations, although some whales could be affected. Lastly, the EIS concludes nothing concerning "risk," but discusses what could occur. Respon: P-1 The text of Section IV.C.6 has been revised to address the concern for potential effects on polar bears. Response GP-20 The MMS planning guidelines provide that, if local conditions or geography permit, the target for initiating recovery operations with pre-staged equipment (i.e., the response time) should be 6 to 12 hours. If the risk analysis included in the OSCP indicated that an oil spill from the proposed activity would contact a shoreline or biological community in sooner than 6 to 12 hours, the response time would be reduced accordingly in order to protect the environmental resource. The MMS does not believe that it is appropriate to mandate a specific response criterion, such as time, without consideration of location, timing, potential spill size, trajectory, and risk. The MMS requires annual drills to test the lessee’s response capabilities under realistic environmental conditions. The MMS/USCG planning guidelines require additional drills for different environmental conditions. The MMS reviews proposed scenarios for response drills in cooperation with the USCG. Drills GP-7 are witnessed by the MMS and the USCG to ensure that personnel are capable of properly deploying response equipment. The MMS can require additional drills if the initial drill is unsatisfactory. The MMS routinely invites individuals from State, local governments, and community organizations to attend the oil- spill drills. Lessees are required to inspect response equipment, train personnel in response techniques, and maintain records of the inspections and training. The MMS also has a rigorous inspection program that ensures that response equipment is available and maintained in workable condition and that all personnel receive training. The MMS believes that the adequacy of spill response can be determined through reviewing the OSCP and viewing oil-spill-response drills in accordance with current MMS rules and guidelines. Response GP-21 Arctic tankering is not considered in the Sale 126 scenario since it is not anticipated that crude oil tankers would be used for oil shipment in the Chukchi Sea Planning Area. Tankering from the Valdez terminal since 1976 has provided an adequate regional database for North Pacific tankering. However, the exposure variable for the oil-spill rate is not the type of environment; the exposure variable is the amount of oil transported. Studies to elucidate spills by cause have been unsuccessful (The Futures Group, 1982). Spill rates for production in Cook Inlet and Endicott (State) have not indicated higher spill rates in ice-infested areas. A large-spill scenario is addressed in Section IV.J. The use of > 1,000 bbl is not intended to be misleading; it is the statistically correct method for writing about a database with spills as small as 1,000 bbl and greater. The tanker spill size distribution in the cumulative case is a statistical distribution based on the volume of oil transported through the Valdez terminal for the cumulative case (Table IV-A-1) including all OCS, State, and North Slope oil (Table IV-A-1). The tanker-spill-size distribution is derived from all the anticipated oil transported through the TAP and the Valdez terminal. Since fifteen tanker spills are estimated to occur in PWS/GOA, this is multiplied by the average tanker-spill size, 100,000 bbl, to derive the 1.65-MMbbI estimated spillage. The 1.65 MMbbI is then used to calculate the statistical distribution of spill sizes. For analysis purposes, this EIS assumes that this statistical distribution of spills would occur. Response GP-22 The commenter is referred to EIS Appendix I, Alternative Energy Sources. Appendix I summarizes and incorporates by reference Appendix C, Alternative Energy Sources, of the Final EIS for the Proposed 5- Year OCS Oil and Gas Leasing Program, 1987-1992 (USDOI, MMS, 1989c). GP-8 September 10, 1990 Paul Dubsky, Regional Director Minerals Management Service Alaska OCS Region 949 East 36th Avenue, Room 110 Anchorage, AK 99508-4302 Dear Mr. Dubsky: The Northern Alaska Environmental Center (NAEC) is a non- profit conservation group with 600 members and a student chapter at the University of Alaska in Fairbanks. For nineteen years we have been concerned with the impacts of resource development on the sensitive Alaskan environment. NAEC appreciates your invitation to review and comment on the proposed Outer Continental Shelf (OCS) Lease Sale 126 in the Chukchi Sea. We are concerned that the Environmental Impact Study (EIS process utilized by the Mineral Management Service (MMS) for Lease Sale 126 is flawed. The EIS’s conclusions are based upon inadequate scientific information and deficient, undertested oil industry technology. In light of these unsupported conclusions, we are forced to question MMS‘s "unbiased" position and believe MMS‘s apparent pro-drilling bias discredits the recommendation to hold Lease Sale 126. Additionally, the proposed lease sale directly contradicts long-term national interest by speeding domestic petroleum resource depletion which is expected to become essential in the future. Without full scientific information, improved oil industry cleanup technology and a clear need to develop limited domestic petroleum resources, oil leasing, drilling and production perilously jeopardize the Chukchi marine environment. Therefore, NAEC cannot support Sale 126 or drilling on previously leased tracts in the Chukchi Sea. Instead, we recommend Alternative II, that the entire area proposed for lease under Sale 126 be eliminated from further OCS Oil and Gas Leasing Program consideration. I. THE LACK OF INADEQUATE SCIENTIFIC DESCRIPTION OF THE CHUKCHI AND THE QUESTIONABLE USE OF AVAILABLE INFORMATION INVALIDATES THE PROPOSED ACTION. A. General Comments Of all OCS regions, the Chukchi Sea is probably the least popularly known and least scientifically understood. The remote geographic location and harsh arctic climate make scientific research difficult and sometimes life-threatening. However, in order to fully assess the potential impacts of oil drilling activities on the massive scale proposed by Alternative I, extensive knowledge of the coastal environment is required. Data gathering alone is not sufficient. The scientific community must be willing and able to submit ideas to the lengthy process of peer review, particularly necessary to sort out complex ecological relationships. In order to provide adequate protection for marine life cycles, endangered species populations and communities of species within the Chukchi, MMS must abandon Sale 126. B. Heavy Ice Conditions Insufficient research on ice conditions has been reason enough to jeopardize previous lease sales in the Chukchi. In 1985 Lease Sale 85 was deleted from the 5-year schedule "to NAEC 1 provide for assessment of operations in heavy ice conditions." Disregarding the need for adequate data and analysis on Chukchi ice conditions, 350 leases were issued (Sale 109 conducted in 1988). Now, again without a thorough understanding of the unique ice conditions on the Chukchi, another lease sale is being proposed by MMS. ©. Marine Ecology The impacts of potentially harmful oil industry activities on the Chukchi flora and fauna must be understood before the sale of leases. Yet, the current EIS descriptions of the arctic waters of the Chukchi and the marine life that thrive there inadequately explain the diverse, fragile relationships within the ecosystem. The EIS neglects to include consideration of the NAEC concepts of toxic bioaccumulation and synergistic effects. 2 NAEC found no mention of the ecological concepts of toxics bioaccumulation and synergistic effects. These concepts contraindicate the MMS assumption that because the concentration of fish, marine mammals, etc. is low in any given area, releases of petroleum or other toxic chemicals such as those contained in drilling muds (lead, mercury, zinc, cadmium) would have a correspondingly low, or even no, effect on marine life (EIS 126, II-29). The "low bio-concentration equals low/no biological impact" theory does not account for the fact that sediments and organisms, including plants, invertebrates, fish, birds, seals, whales, polar bears and humans will store some toxics associated with oil drilling. The stored toxics become concentrated, particularly higher in the food chain. Synergistic effects of discharged pollutants is also ignored NAEC zZ in the EIS. Although the concentrations may be sublethal initially or independently, complicated synergistic reactions may create chronic poisoning problems, perhaps even affecting subsistence hunters. Drawing conclusions based wholly on the chemical effects on a single trophic level is an inappropriate use of available ecological knowledge. In the EIS for Sale 126, MMS must evaluate the chronic and acute effects of synergistic combinations and bioaccumulation on the marine ecology. Until these data have been gathered and submitted to peer review, the lease sale should be indefinitely postponed. D. Endangered Species and Marine Mammals The effects of oil industry activities on the habits and population stability of marine life endemic to the proposed lease area, particularly on endangered species are currently not well NAEC S understood. Two species of endangered whales (bowhead, gray) summer in the Chukchi. Under the Endangered Species Act, MMS must ensure that the proposed action is not likely to jeopardize the continued existence of a threatened or endangered species and/or to result in adverse modification or destruction of their critical habitat. Inadequate data has been gathered on the effects of drilling activities on these endangered whales to comply with the Act. Despite an absence of baseline data, MMS makes assumptions describing the impact of oil industry activities on whales. For example, vessel avoidance behavior and NAEC startle responses demonstrated by bowhead whales are not 3 evaluated for their biological cost, although it is assumed to be negligible (EIS 126, IV-B-15). Also, MMS neglects analysis of the effects of bioaccumulation and synergistic combinations of chemicals released by the oil industry. Therefore, MMS’s proposed alternative is in violation of the federal Endangered Species Act. The high value placed on the protection of endangered species and marine mammals reinforces the need for complete data before allowing the oil industry open access to the Chukchi. In fact, under the Marine Mammal Protection Act, walrus, cetacean, pinniped and polar bear populations and habitats must not be diminished beyond the point at which they cease to be a significant functioning element in the ecosystem, or to diminish NAEC such species below their optimum sustainable population. Are we ready to calculate the effect of hundreds of wells and support vessels on critical breeding and feeding habitat? Can MMS point to the expected consequences of the discharge of thousands of tons of drilling muds and cuttings and the cumulative impact of large and small oil spills and chemical leaks? How will stable population thresholds for each marine mammal be known and maintained? Rich with arctic marine life, the Chukchi Sea and its associated polynya are without parallel. Proposing drilling activities without complete knowledge of the effects on unique and irreplaceable protected species is plainly irresponsible. To NAEC protect endangered populations and their habitat and to abide by 4 the Endangered Species Act and the Marine Mammal Protection Act MMS must incorporate thorough analysis including disturbance caused by industrial activity and the cumulative and synergistic impacts of unavoidable chemical releases. II. THE PROPOSED ACTION WILL RESULT IN CONTAMINATION OF THE CHUKCHI DUE TO TECHNOLOGICAL CONSTRAINTS ON OIL SPILL CLEANUP AND UNAVOIDABLE RELEASES OF TOXIC CHEMICALS. A. General Comments Although no one, including the oil industry, wants oil spills, spills occur and cleanup is imperfect. On this point, NAEC is in agreement with MMS. Unfortunately, oil industry drilling and cleanup technology is both deficient and undertested. Also, the crushing Chukchi ice and harsh, highly erratic weather conditions increase both spill probability and cleanup difficulty. Undesirable chemical releases, whether routine or accidental, must be considered an inherent part of oil development. For these reasons, we believe that a moratorium should be placed on drilling until the behavior and effects of the chemical discharges is known and spill response technology has been developed and tested in hazardous arctic conditions similar to the Chukchi. B. Unavoidable Adverse Effects 1. Oil Spill Risks MMS underestimates the overall oil spill risks for Lease Sale 126. The formula used to estimate these risks incorporates historical oil spill rates which are derived from the US and worldwide spill rate data (EIS 126, IV-A-4). Although the NAEC formula may predict spill risks accurately in average conditions, 5 no one can reasonably argue that the Chukchi is average. The exceptionally hazardous arctic conditions make the derivation of MMS’s spill risk formula unreliable when applied to the Chukchi. Therefore, NAEC views with skepticism the estimate that only two spills of 1,000 barrels or greater are likely to occur over the life of the field (base case scenario). Lessons learned in other seas cannot necessarily be applied to the Chukchi. 2. Oil Spill Behavior and Effects Winter spill modeling and tracking may not be possible with the variable behavior of oil under ice. The oil "may freeze onto sea ice and move with the ice throughout the winter" or it may not adhere to the ice undersurface as with smooth, first-year ice (EIS 126, IV-A-5 and C-2). Oil will flow under landfast ice NAEC until it freezes onto the undersurface in hours or days (EIS 126, IV-A-5). Given this type of information provided in the EIS, predicting oil spill behavior and tracking it through the dark winter months until spring breakup would complicate the already overwhelming task of oil spill recovery at sea. 3. Muds, Cuttings and Formation Waters Drilling muds, cuttings and formation waters are routine, unavoidable elements of oil exploration and production. Tens of thousands of tons of muds and cuttings would be discharged into the Chukchi during the exploration phase under the MMS base case. During production, the projected amounts of muds and cuttings discharged climbs into the hundreds of thousand of tons, although recycling of drilling muds can reduce these amounts somewhat (EIS 126, II-10 and II-13). Six platforms would be used for 214 NAEC production and service wells under the base case estimate. 7 Therefore, the combined volume of muds and cuttings (depending on mud quantities recycled) released would be approximately 37,000 to 58,000 short tons per platform (EIS 126, II-13). On top of the estimated quantities of toxics and sedimentation released during oil exploration and production, non-estimated quantities of formation waters (drawn from wells along with oil) containing hydrocarbons and metals (EIS 126, IV-C-19) are discharged at the drilling site, increasing stress on the ecosystem. MMS’s Alternative I base case analysis barely touches on the impact these unavoidable discharges have coming from six platforms, acting as concentrated pollution point sources. The use and discharge of phenomenal volumes of muds, cuttings, and formation waters is an inherent part of oil exploration and production. As mentioned on page three of this document, the fluids euphemistically called by the oil industry drilling "muds" are actually a mixture of highly toxic chemicals. We are gravely concerned with MMS’s dubious estimate of the contaminating effects such quantities of routinely discharged toxics will have on marine life cycles, endangered species populations and communities of species within the Chukchi environment. Cc. Spill Cleanup Oil spill drills and real-life cleanup attempts suggest that there are technical limits on current cleanup abilities. New cleanup technologies and strategies developed for the complicating weather and ice conditions in the Chukchi have not yet been proven capable. In fact, cleanup is an attempted process, not a result. MMS acknowledges that "cleanup at sea is ‘cag only marginally effective. Using mechanical equipment, spilled- oil recovery generally ranges between 10 and 15 percent" (EIS 126, IV-A-13 re: US Congress, OTA, 1990). Without solid examples of successful cleanup in waters analogous to the Chukchi, no drilling activities should commence. 1. Preparedness and Spill Drills Although MMS requires spill drills, these drills are intended to test personnel familiarity with the equipment, not to demonstrate response capability in any particular weather condition or combination of weather and ice conditions. For example, the Shell Western Exploration and Production Inc. spill drill on 12 July 1989 was preformed in the protected waters of Kotzebue Sound. Inside the sound waves were only three feet, but just the previous day at Shell’s exploratory drilling site in the Chukchi seas reached 16 feet. In a different spill drill held in the relatively calm Beaufort Sea, recovery of oranges (used to 10 model oil) was hampered by three foot swells and widely scattered icebergs (perhaps 5% ice cover). As a result, many of the oranges escaped under or around the boom before a skimmer could be deployed. These tests were hardly realistic representations of what weather or ice conditions would be likely to occur in the Chukchi. 2. Small Spill in Winter Actual oil response efforts show the difficulty of dealing with the sub-zero temperatures found in the nine month Chukchi winter. During efforts to cleanup a small spill in the lower Cook Inlet, booms broke and igniters would not light the spill at negative 20 degrees Fahrenheit. Also, the ability to burn oil decreases rapidly with increasing sea roughness (EIS 126, IV-A- 13). 3. Very Large Spill (Exxon Valdez) Lessons learned from the 11 million gallon Exxon Valdez tanker spill in March 1989 should be difficult to forget. Initial problems deploying the cleanup equipment and logistical snags hampered quick action, and the spill spread outside the confines of Prince William Sound. The oil emulsified, making chemical dispersants ineffective. During stormy seas (4-8 foot waves), mechanical cleanup became nonfunctional (EIS 126, IV-A- 13). Winter shut down cleanup entirely. 4. Multi-year Blowout The worse possible scenario would be a massive blowout that cannot be controlled during the first summer. The flow would have to continue unchecked through the winter and efforts to 11 drill a relief well would have to begin the following summer. Movement of the spilled oil through the winter and the corresponding difficulties of tracking it would hamper oil recovery efforts during the second summer. 5. Complicating Circumstances Circumstances which complicate oil recovery under any size spill scenario are adverse weather or ice conditions, combinations of adverse weather and ice conditions, equipment failure, inadequacy or absence and human error. The EIS neglects to consider, for example, the problem of spill response in fog and broken ice or in 16 foot seas and scattered ice. It is not sufficient for oil companies to be required to demonstrate response capability only in solid-ice, open-water and broken-ice conditions before being granted the right to explore or drill for oil. The combined weather and ice conditions, known to be so hazardous in the Chukchi, deserve more stringent spill drill demonstrations. III. THE PROPOSED ACTION WILL NOT BENEFIT THE LONG-TERM INTERESTS OF THE US. The base case scenario for Lease Sale 126 estimates that 1,610 million barrels of oil may be recovered. Using the current US rate of petroleum consumption, only about 95 days worth of oil would be gained. Instead of burning up this 95 day supply of oil (over the next 15 or 20 years), it would be contribute more to US national interest if that oil were added to domestic oil NAEC 12 resources in the future when tighter supplies make small quantities more valuable. Drilling now permanently revokes the possibility of having the oil later when we will need it more. A more reliable and safer alternative to Lease Sale 126 is to develop alternative energy sources and energy conservation and efficiency. Besides being sustainable, energy conservation and efficiency do not contribute to acid precipitation and climate change. Global economic relationships can best be described as interdependent. Oil deposits, in particular, require that policymakers realize that US petroleum demands will increasingly have to be met by Middle Eastern oil. Congress must face up to the reality of US dependence on Saudi Arabian oil reserves and work through diplomatic (or other) channels to maintain the oil supply. However, even global oil deposits are limited; long-term energy stability must include a greater emphasis on efficiency and conservation. IV. ALTERNATIVE II IS THE ONLY RESPONSIBLE, SAFE AND LEGAL OPTION. Lease Sale 126 jeopardizes the delicate Chukchi marine environment. Inadequate scientific data on the effects of oil spills and unavoidable chemical releases in the rich Chukchi environment along with pathetic oil industry cleanup records and spill drills which do not apply to Chukchi weather and ice conditions indicate that MMS’s proposed Alternative I should not 13 go forward. Additionally, federal laws concerning marine mammals and endangered species have not been followed in the development of Alternative I. Deferring Sale 126 will allow the scientific community time to develop more complete environmental data for the Chukchi and to improve oil industry technology necessary to cope with the hazardous weather and ice conditions. Historic data show that the spill rate declined between 1964 and 1987 (EIS 126, IV-A-4). As global petroleum resources are being depleted, domestic supplies are likely to become more valuable later. Therefore, it is within our long-term national interest to delete Lease Sale 126. NAEC cannot support Sale 126 or drilling on previously leased tracts in the Chukchi Sea. Instead, we recommend Alternative II, that the entire area proposed for lease under Sale 126 be eliminated from further OCS Oil and Gas Leasing Program consideration. Thank you for considering these comments. Sincerely, ‘i . 7 od ybrr 9 Whed Sylvia J. Ward Northern Alaska Environmental Center 218 Driveway Fairbanks, AK 99701 Northern Alaska Environmental Center Response NAEC-1 Lease Sale 85 was deleted from the 5-Year Oil and Gas Leasing Program to address the concerns of the State of Alaska and the Alaska Congressional delegation. The following sentences regarding those concerns are excerpted from a January 10, 1984, letter from the Honorable Bill Sheffield, Governor of Alaska, to William Clark, Secretary of the Interior: "The primary concern of the state was the pace of the Department of Interior’s current five-year oil and gas leasing program. Due to internal budget constraints, the MMS personnel assigned to Alaska’s OCS appear to be insufficient for their greatly expanded responsibilities under the accelerated program. A two year delay would enable valuable scientific data interpretation and synthesis effort of available information to continue." The assessment of working in heavy ice conditions was completed in the Sale 109 FEIS (USDOI, MMS, 1987b). Exploration is likely to continue in open-water conditions. It is estimated that development drilling will begin in 2000. This allows 9 years for the oil industry to study conditions. Drilling will be allowed when the oil industry demonstrates to MMS that they can operate safely in the ice conditions of the Chukchi Sea. The MMS agrees that ice conditions are a significant consideration for exploratory and development and production operations in the Chukchi Sea. While exploratory-drilling activities generally are conducted in the open-water season, ice-reinforced drillships and a specifically designed ice-class drilling unit with icebreaker support can operate in limited ice conditions. Over 10 wells in the U.S. and Canadian Beaufort Sea and 4 wells in the Chukchi Sea have been drilled using this technology. In the event of a major commercial discovery, detailed DPP’s would have to be submitted, including the technical specifications for platform design. Considerable research has already been conducted on ice and ice forces on offshore structures, and additional research is ongoing. Offshore production platforms would be subject to technical review by MMS; and MMS requires that the design, construction, and installation of bottom-founded structures be reviewed by MMS-certified third parties. The design of offshore platforms and multilevel technical review will consider all potential hazards, including ice. Response NAEC-2 The MMS finds no citations to support the many statements concerning bioaccumulation, synergism, etc., made by the commenter. The NEPA requires that EIS’s include adequate documentation of factors causing the effects concluded from the analysis, not all information used in an analysis. Drilling muds containing trace metals and other additives, as well as cuttings resulting from well drilling, generally have been shown to have low toxicity to marine organisms at the dilutions that are attained within a few hundred meters of a drilling platform. While there is little doubt that these materials accumulate in sediments and some organisms, and may reach higher concentrations at higher levels in a food chain, only a limited area downstream of a platform is likely to be affected. For example, if we conservatively assume that dilutions greater than values for all effects reported are achieved within a 1,000-m radius of a platform, only slightly more than 3 km? would be affected. Even assuming considerable accumulation in the food chain and possible synergistic effects with other compounds present, no animals concentrate to such an extent in the sale area that significant effects on their populations would result from the numbers of individuals likely to be affected in such a small area. Response NAEC-3 While more data are needed to fill certain information gaps, the current database is more than adequate to determine the likely effect of industrial noise and crude oil on whales; and it has been adequate for some time. Every authoritative study pertaining to the effect of these two agents on cetaceans has consistently shown that these agents have only a minor, short-term effect on some whales and no effect on the others. Because of the volume of data available, it was unnecessary to make assumptions for the larger part of the NAEC-1 assessment on endangered species. Assumptions were made in the encounter scenarios due to uncertainties associated with where, when, and how much industrial activity would actually take place and how many whales would actually be present during such times. While it is true that a low number of whales are likely to avoid about one exploratory operation per year (or may be startled by the same), it is also true that such responses would have only a minor, short-term effect. Further, most whales avoid naturally occurring obstacles on a daily basis during their migrations. There is no information available concerning "synergistic combinations of chemicals released by the oil industry." Further, due to the number of unknowns and variables associated with synergistic investigations, and the low probability of obtaining definitive results from studies of this type, relevant information is not likely to become available. The effects of contamination and bioaccumulation are discussed in Section IV.C.7.a(3)(d) of the EIS, which indicates that petroleum-based compounds are not likely to accumulate in marine mammals and would be likely to result in only localized effects on prey species. The EIS makes assumptions on the type and scope, level of oil and gas activities, and analyzes the potential effects of these activities on resources in accordance with the NEPA. This process includes consultation with NMFS and FWS under the Endangered Species Act (ESA) and adoption of mitigating measures based on reasonable and prudent alternatives and conservation recommendations. The EIS does not authorize activities that would violate the ESA. Specific lease activities, such as those described in the EIS, must be conducted under an approved EP/DPP that is subject to public review including NMFS and FWS. Activities taht could result in incidental taking of marine mammals are subject to the provisions of the incidental taking regulations and LOA, as provided by the Marine Mammal Protection Act, as amended. Response NAEC-4 The likely effect of Sale 126 on bowhead and gray whales has already been "calculated" and is discussed at length in Section IV of the EIS. The procurement of "complete knowledge" is unrealistic and does not exist for any field of endeavor. Because of this, a NEPA analysis does not require complete knowledge; rather, it requires that the EIS analysis be focused on what is likely to occur based on the best available scientific information. The commenter does not raise any specific effect that was overlooked. The analysis in the EIS placed in temporal and spatial perspective the relationships among resources and the various causal agents. The synergistic effects of noise on whales are discussed in Section IV.B.7.a(1)(e). However, the implication that the DEIS analysis should have discussed all synergistic effects is beyond the scope of the EIS. Response NAEC-5 Ice conditions in Cook Inlet and the Endicott Field have not resulted in a major platform or pipeline spill in State waters. The scientific method used by MMS in estimating the risk of oil spillage and a discussion of the causes of spillage are included in Section IV.A.1.a(2), Appendix C, and the references contained therein. The statistical exposure variable used by MMS is not the environmental condition but the volume of oil transported. A study by the Futures Group and Environmental Research and Technology, Inc. (1982) was unsuccessful in deriving any valid statistical relationships for predicting the occurrence of major spills from specific causes. Other estimation procedures, such as fault-tree analysis, have been considered by MMS but have been found to be less reliable than the method now in use. In addition, the commenter is referred to Figure IV-A-3 for an explanation of the most likely number and the distribution of spills. The most likely number of spills is two in the base case because two spills has the highest probability of occurring (27.06%). As many as six spills may occur but with a 1.28-percent probability of occurring. More than six may occur but with a <0.5-percent chance. The MMS does not estimate that only two spills would occur; the MMS estimates that two spills is the most likely number that would occur. Response NAEC-6 The interpretation of the commenter is in agreement with the analysis in Section IV.A.2.c(3) and NAEC-2 Appendix L. Furthermore, a winter spill would most likely move into U.S.S.R. waters prior to spring/summer breakup, resulting in additional complications. Response NAEC-7 Formation waters, including estimates of the amount produced and their composition, are discussed in Sections IV.C.2 and IV.D.2. Formation waters may be reinjected rather than discharged and, if discharged, would be subject to NPDES requirements. Response NAEC-8 Oil-spill-contingency measures are discussed in Section IV.A.2.e(3) and Appendix L. Figure IV-A-12 shows the applicability of oil-spill-response techniques in the proposed sale area. There have been spill responses in seasonal ice fields off the U.S. and Canadian East Coasts and in the Baltic Sea. Small, stand-alone response tests have been conducted with some degree of success. The MMS requires lessees to conduct oil-spill-response drills to demonstrate their capability to deploy and utilize oil-spill equipment. Several exercises have been conducted in the Beaufort and Chukchi Seas. Several offshore and tank tests have been conducted to evaluate major response equipment, in some cases with spilled oil or simulants. In situ burning remains one of the primary response strategies for oil-spill response in broken-ice conditions, which would limit or prohibit mechanical response. In situ-burn technology is well documented and has been demonstrated in several offshore trials and field and tank tests. Additional field trials of in situ burning, are currently being planned through an interagency and industry working group, are tentatively scheduled for 1991 and 1992. Response NAEC-9 This EIS indicates in Section IV.A.2.e(5) and Appendix L that weather and sea conditions become critical factors during oil-spill-response operations . The oil industry is regulated by 30 CFR 250.42 for oil-spill- contingency planning and spill drills. The MMS requires operators to conduct an oil-spill-response drill to demonstrate their capability to deploy and utilize oil-spill-response equipment at least annually. The MMS can require lessees to conduct additional drills if the first drill indicates that personnel are unprepared or the equipment does not function properly. In addition, MMS requires that operators train personnel in oil-spill- response and inspect and maintain equipment on a scheduled basis to ensure that the equipment is operational and functional. The MMS also inspects equipment both on and off the drill site. Due to the limited scope and timing of exploratory-drilling activities (60-90 days) and requirements for inspecting and maintaining equipment, MMS believes that oil-spill-response drills are being conducted as appropriate. In the event of development and production, the type, frequency, and scope of oil-spill-resonse drills will be modified commensurate with the level of development and production activity. NAEC-3 aaa re Trustees for ALASKA _ A Non-Profit, Public interest. Environmental Law Firm September 12, 1990 Minerals Management Service Alaska OCS Region, Room 110 949 East 36th Avenue Anchorage, AK 99508-4302 Comments of Trustees for Alaska on th Draft Environmental Impact sta Dear Sir or Madam: OCS Lease Sale No. 126 I enclose a "hard" copy of Trustees for Alaska's Draft Environ- mental Impact Statement, Lease Sale 126 which was sent to your office via fax transmission on September 11, 1990. Minor typograph- ical changes have been made to the comments I sent to you yesterday as well as some minor word changes. Please note that Trustees for Chukchi Sea, Ala: Alaska expressly incorporates its prior comments to the Draft TFA Environmental Impact Statement, Lease Sale 109 into the enclosed 1 Lease Sale 126 comments. Thank you for the opportunity to comment. Sincerely, Md, Nitza Delgado Prepared By: Nitza Delgado Law Clerk September 11, 1990 725 Christensen Drive, Suite 4 Anchorage, Alaska 99501 (907) 276-4244 > 100% Recycled Bond Chukchi Sea Oil and Gas Lease Sale 126 a : Comments to Praft EIS to make OCS decisio Moreover, in the DEIS, present data has Trustees for Alaska is a non-profit public interest been selectively gathered and used so as to encourage drilling in |TFA environmental law firm dedicated to the wise management of Alaska's these waters at the cost of proper environmental safeguards. This 2 natural resources, consistent with the protection of Alaska's problem is ever-present in the DEIS for Lease Sale 126. environment. Trustees welcomes the opportunity to comment on the The most glaring example is the DEIS selective "mis-reference" Draft Environmental Impact Statement (DEIS) for the proposed Outer to the Gerasi study which exposed crude oil to the skin of a living Continental Shelf (OCS) Lease Sale of 126 in the Chukchi Sea.! sperm whale. (DEIS IV-C-49). The DEIS cites this study to support Trustees proposes the adoption of the no sale alternative the conclusion that the exposed skin of a living whale is only (Alternative II) for a number of reasons, including the inadequacy mildly affected after 17 hours exposure to crude oil. (DEIS Iv-c- of scientific information concerning the effects of oil and gas 49). However, the EIS fails to mention that the study was done on exploration and production on the delicate balance of the arctic a beached whale which died before the experiment was concluded. i ecosystem, and the lack of oil spill cleanup technology given the (Gerasi Report pp. 154-154). In other words, although the DEIS environmental conditions in the Chukchi Sea, i.e., extremes in cites the study to support the position that, crude oil has no temperature, broken sea ice conditions, high wave conditions and adverse effects on living whales, the whale was alive for only high velocity sub surface water currants. Moreover, the Trustees approximately half of the 17 hour experiment. This problem of believe this sale would only discourage the inevitable -- the need "selective citation" of the Gerasi study is further exacerbated by for an aggressive energy conservation campaign and development of logical gaps in the presentation of the data. Specifically, alternative energy sources. although the crude oil experiment lasted for 17 hours, the DEIS implies that the gasoline experiment was only conducted for two GENERAL COMMENTS Trustees opposes Lease Sale 126 for numerous reasons. The 2 TFA This problem has been highlighted by the Improvements to foremost one being that there is insufficient information available the scientific Content of the Environment Impact Statement Process. Al The most glaring problem has been the lack of peer review in study g Pp design and in the review of results. The magnitude of this problem was touched upon in The Adequacy of Environmental Information for Quter Continental _ Shelf Oi] and Gas Decision: Florida and California y, National Research Council, 1989 (NAS Report). The Conclusions " Trustees incorporates by reference NRDC's and me |e in the NAS Report that there was insufficient data upon which to 1 comments to the Lease Sale 109 DEIS for the Chukchi Sea herein. make OCS Lease Sale determinations for Florida and California and this applies to Alaska as well. 4 hours. Later however, we discovered that the DEIS failed to mention that the Gerasi study reported "dramatic changes" after 17 hours of gasoline exposure. "(T]he original skin surface could not be defined and the upper 1/2 to 1/3 of the epidermis was pale gray and had the consistency of thick paste." (Gerasi Report p. 157). These gaps of logic in the presentation of information lead Trustees to conclude that no real evaluations of the underlying studies have ben performed as the DEIS cites portions of studies, including quotations out of context to achieve the end MMS desires. Another egregious example of “selective citation" is in the DEIS citation to the Gerasi study regarding the dolphin study. (DEIS Iv-C-49). The DEIS states that after 75 minutes of exposure to gasoline, the dolphin skin was unharmed. However, the DEIS fails to mention that there were four dolphins in the study and two of the four dolphins blistered after 30 minutes of exposure and the third blistered after 45 minutes of gasoline exposure. (Gerasi Report p. 153). This selective use of scientific data or “miscitation" is replete throughout the DEIS and belies the notion that OCS decisions are made after a careful weighing of existing scientific information. Moreover, the DEIS fails to present new information regarding the industry's ability to safely operate in the heavy sea ice conditions of the arctic environment. The DEIS itself admits that in February of 1985 a proposed Lease Sale in the Chukchi Sea, Lease Sale 85, was postponed in order to provide for "further assessment of operations in heavy ice conditions." Regardless this fact, in * TFA TFA TFA 5 1987 Lease Sale 109 in Chukchi Sea went forward. Te dis our position that a decision to proceed with Lease Sale 126 blatantly disregards the need for more information assessing the industry's ability to safely operate in arctic conditions. Trustees also oppose the sale because to date, there is no indication that the industry has the cleanup technology necessary to clean up an oil spill of any size in the arctic. Rather, history indicates the opposite - that the industry will not be able to clean up any sized spill in the ice-laden waters of the Chukchi Sea. History shows that oil spills are highly probable but cleanups are not possible. The following two spills highlight this point. The July 1987 S.S. Glacier Bay spill shows us that oil spill cleanups are simply not possible even under the best environmental conditions. Specifically, the S.S. Glacier Bay spill occurred in summer, in waters milder than the Chukchi Sea. Despite these facts, it was not possible to clean up more than 10 - 20 % of the S.S. Glacier Bay spill. Mechanical cleanup proved to be inadequate despite the fact that there were 20 vessels on site to perform the cleanup. On January 31, 1989 a second oil spill took place in Cook Inlet and history repeated itself. In relatively mild environmental conditions, when compared with conditions present in the Chukchi Sea, mechanical clean up was not attempted because of the cold weather and icy conditions. Moreover, oil burning techniques were not employed because responders determined that the TFA TFA 6 propane ignition system on the Heliotorch would probably not operate in -20 to -25 degree temperatures. That spill was only 520 barrels of an oil/water mixture containing a mere 110 barrels of oil. Query, if a small spill cannot be adequately cleaned up in Cook Inlet, where the logistical problems are not a fraction as severe as in Chukchi Sea, how can the industry represent that it can respond to any sized oil spill in the Chukchi Sea, an area characterized as a frontier area with extreme wind, temperature and ice conditions? The DEIS avoids addressing these real issues (as the treatment of the Cook Inlet spills are not addressed in the DEIS) and does little more than parrot statements from previous environmental impact statements. The DEIS suggests the use of chemical dispersants as an appropriate method to clean up a spill; however, it fails to mention the types of chemicals that would be used, their toxicity, and their decay rate in the cold saline waters of the Chukchi Sea. Chemical dispersants are problematic because, like oil, they too may be toxic. Dispersants, by definition, do not change the toxic nature of oil, but merely cleave long hydrocarbon chains into smaller ones. Therefore, the true danger of an oil spill remains and, in fact, may be further exacerbated by the addition of new toxins into the wate: Perhaps most troubling to Trustees (and a major reason for Trustees' opposition to the sale) is that the DEIS does not evaluate the alternative of developing an aggressive energy conservation campaign as well as the development of alternative TFA TFA TFA 7 energy sources as viable alternatives to the exploitation of oil reserves on the OCS. Ina simplistic fashion, the DEIS justifies Lease Sale 126 on the ground that the OCS is necessary to meet the nation's energy needs and aid in the reduction of dependency on foreign oil. However, the DEIS does not seriously address the possibility of an aggressive energy conservation campaign or the development of other energy sources to meet these goals. It simply proposes maintaining the status quo of consuming finite fossil fuel. The status quo is consumption at the alarming rate of 26.0% per year of the total world oil production. (British Petroleum Statistical Review of World Energy p.8). SPECIFIC COMMENTS I. No Lease Sale (ALTERNATIVE II) The DEIS claims that the importation of oil and gas would increase and as a possible alternative to this increase, lists the energy sources which may be developed as substitutes. (DEIS IV-E- 1). However, the DEIS fails to address any of these substitutes as serious, viable alternatives. The DEIS fails to propose that an aggressive energy conservation campaign be employed to encourage Americans to decrease fuel consumption and incorporate alternative energy sources-the technology for which has already been developed. For example, even though the technology for reducing automobile energy use exists today, it is not employed. The DEIS ignores the fact that this nation could save the equivalent amount of oil produced by Iraq and Kuwait through a 1.5 mile per gallon per year TFA 8 fuel economy increase over seven years. (NRDC News Release August 8, 1990). The DEIS' failure to discuss these realistic alternatives typifies the main problem facing American today - its inefficient and myopic dependency on fossil fuel. Ir. (ALTERNATIVE III) If the no lease alternative is not adopted, Trustees proposes that the Department of the Interior delay Lease Sale 126 until adequate environmental information is available upon which to make ocs decisions. At a minimum, the Sale should be delayed until the industry has conclusively demonstrated that it has the necessary technology to clean up oil spills in the arctic environment. In making this proposal, Trustees urges MMS to treat the delay alternative as a true alternative. Past experience shows that lease sale delays do little to encourage industry to develop reliable cleanup technology. (Lease Sale 85 at EIS I-5). The DEIS does not highlight any new developments in the area of oil spill cleanup technology, perhaps because there have not been any significant developments since 1985; the recent Valdez spill is testimony of the ineffectness of today's available technology. Any delay type of alternative to Lease Sale 126 must be accompanied by a mandate to improve cleanup technology. III. Point Lay Deferral Alternative (ALTERNATIVE III) The Point Lay Deferral alternative should be a deletion rather than merely a deferral. Moreover, the deferred area should be TFA TFA TFA 10 TFA 11 9 expanded to coincide with the areas of critical biological importance represented in Graphic No. 2. (DEIS opposite III- 28). Trustees notes that the areas represented in Graphic 2 extend well beyond the areas presented in the Point Lay Deferral Alternative. (DEIS Figure I-3 opposite I-18). In addition, as in the delay alternative, Trustees questions whether this is truly an alternative. Specifically, Trustees is concerned that deferral consideration in this instance would receive the same treatment as the deferral in Lease Sale 109. The area in question is the same which was analyzed in Lease Sale 109. In Lease Sale 109, despite comments in support of the Point Lay Deferral Alternative from the state of Alaska, North Slope Burough, NOAA, and the EPA, this area was leased and the rest of the area is included in proposed Lease Sale 126. (DEIS II-39). For this reason, Trustees urges MMS to expand the Point Lay area to include those areas in Graphic 2 and to delete the entire area from proposed Lease Sale 126 and future sales. Iv. Proposed Action (Alternative I) Trustees adamantly opposes this proposal for the reasons discussed in its general comments above, and based on the specific comments it presents below. A. Low/Base Case Effects 1. Air Quality DEIS admits that the USDOI regulating exemptions levels would be exceeded for nitrous oxides (NOx) but that air pollution TFA 11 TFA 12 10 concentration permitted by air quality standards would be attained. However, regardless of air quality attained, the DEIS fails to discuss the actual effects of air pollution on the fragile vegetation of the arctic ecosystem. The DEIS relies on information found for Lease Sale 87 to support its position that the effect of air pollution on the arctic vegetation would be low. (DEIS IV-c- 3). Once again the use of information is selective. The DEIS estimates that sulfur deposit of 0.1 kg/km2/year would occur as the result of development and juxtaposes it with the lethal amounts of sulfur deposit cited at 670 kg/km2/year which causes fish kills and the destruction of plant species. It then cites that 12.0ug/m3 for short periods can depress photosynthesis with damage occurring at 60 ug/m3 but the DEIS does not reveal how many ug/m3 would be deposited at any given point. (DEIS IV-C-2). In other words, once again the logic is skewed in that data is provided for lichen damage in terms of short period exposure yet it is juxtaposed with data corresponding to fish kills and die-out of plant species resulting from yearly sulfur deposits. The DEIS then fails to give us the data for lichen tolerance of yearly sulfuric deposits. The DEIS also fails to provide information on the importance of this vegetation to the wildlife of the Chukchi area. The schematic diagram of the food chain in the arctic only addresses the aquatic food chain, neglecting the effect of air pollution on the terrestrial food chain. (DEIS Figure III-B-3 opposite p. III- 20). 2. Effect on Marine Mammals TFA ab a TFA 1S 11 The DEIS alludes to the effects that oil development will have on marine mammals but it fails to seriously account for the effects that vessel traffic, air traffic, and oil spills will have on marine mammals. a. ve el Traffic and Drilling Noise The DEIS acknowledges that sound travels at a greater velocity in water and that it may alarm marine mammals and interfere with communication. (DEIS IV-C-42). This fact cannot be disregarded because underwater communication is important for whale migration. Whales depend on call reflection in order to determine ice thickness. By determining the thickness of the ice they can detect whether they can break out small breathing holes. (see Trustees comments to Beaufort Sea Planning Oil and Gas Lease Sale 124 p.7). In addition bowhead whales have exhibited strong reactions to vessel traffic from afar. They commence swimming rapidly from boats at distance of one to four kilometers away. (Id at p.8). Regardless, the DEIS treats the effect of industrial noise as insignificant in comparison to natural variation in habitat use migratory path selection, and whale behavior and as a short term problem since the whale are migrating. (DEIS IV-C-48). However, whales need to use underwater communication in order to maneuver through the arctic ice and find possible breathing holes. b. Air Traffic The DEIS notes that the walrus population is declining, yet, regardless of this fact, the DEIS disregards the Johnson and Salter studies which show that low flying aircraft panic both seals and TFA 14 TFA 15 12 walrus causing them to trample over calves and pups. (DEIS IV-C- 42). These studies can not be viewed as unimportant because, as the DEIS states, the North Pacific walrus population represents 80% of the total world population with roughly 40% inhabiting the Chukchi Sea and presently they exhibit population decline. (DEIS III-30). The DEIS response is that the mammals will be displaced and adjust at another site. However, is it truly possible for an animal to switch habitats and adjust to new predators in a new location without negatively impacting the species? c. Oil spills Both seals and walrus risk oil contamination from spills, even if the spill took place in the winter when the mammals are not in the area in abundant numbers. It is possible to suffer population loss due to oil contamination from a winter spill during the months of March through May. Seals and walrus give birth on the ice between the months of March and May. This is important to note as the report leads one to think that we only need to worry about summer spills when the animals are present in abundant numbers and that winter time spills do not affect the animals. Oil spilled during the cold weather may freeze in the ice or get trapped under the ice within a few days after the spill. Should this occur the toxicity of the oil will remain until it is released once again in during a thaw. This presents two problems which are not accounted for in the DEIS. The first problem is tracking. Assuming that contaminated floes can be identified, it would not be possible to track them TFA 15 TFA 16 13 throughout the winter, given the harsh conditions of the Chukchi Sea, ice movements, ocean currents, and limited daylight. Once these floes begin to melt, the result will have effects similar to a new oil spill in a new location. Then, a new generation of marine mammals face the probability of oil contamination. Young pups and calves face oil contamination which is as toxic as it was when it became frozen into the ice. This is especially problematic for the young ones as they are particularly vulnerable to oil. The second problem, of course, is that even if the oil could be tracked, history indicates it cannot be efficiently cleaned up. Subsistence Lifestyles In deciding whether to go through with Lease Sale 126 the effect of oil development on marine life should be analyzed as it interrelates to Native subsistence. Sale 126 would exacerbate the walrus population decline, and whales may alter there course which will make them more difficult to hunt. (DEIS IV-C-42). The DEIS is also somewhat callous in its disregard of the anticipated increase of alcoholism and domestic violence which may result. (DEIS III.C.3.d) The DEIS fails to analyze how these tangible problems affecting people, created by those who do not have to deal with the problems on a long term basis, would be addr ed. III. CONCLUSION In summary, Trustees opposes Sale 126 on the grounds that there is insufficient information upon which to make an informed decision regarding oil development in the Arctic waters of the TFA 16 TFA 18 TFA 19 14 Chukchi sea and the information which does existed is manipulated so as to encourage the desired outcome of further drilling in the arctic. Our opposition is based on the fact that present technology is incapable of coping with oil spills in the Arctic, and the DEIS does not fully explore the possibility of developing new energy resources or launching an aggressive energy conservation campaign, or even employing the energy efficient technology available today. Given the present situation in the Middle East and given the knowledge that oil reserves are finite we should strive to reduce American dependency on fossil fuel and develop new energy sources. TFA 19 Tru: For Alask: R -A’ The MMS considers the information currently available to be adequate for a basic understanding of the potential environmental effects of Sale 126 in and adjacent to the sale area. In addition, MMS has successfully evaluated the potential environmental effects of two other lease sales in the Chukchi Sea Planning Area. The first sale, Sale 85, scheduled for February 1985, was not held. The second sale, Sale 109, was held in May 1988; but the task of analyzing the effects of the sale had to begin long before the sale date. Since work began on the first sale, the amount of information available to analyze the effects of petroleum exploitation in the Chukchi Sea has been increasing. The MMS Environmental Studies Program has helped to increase the information base. As a measure of this contribution, MMS has expended over $120 million on environmental studies in the Chukchi and Beaufort Seas during the period 1975 to March 1988. The studies conducted have investigated major disciplines including geology, oceanography, sea ice, pollutant transport, living resources, endangered species, ecosystems, oil-spill effects, noise effects, sociocultural systems, socioeconomic systems, and transportation; and a considerable effort has been made to integrate and synthesize available information. Monitoring programs have been developed to study specific effects on resources of concern. Response TFA-1 The responses prepared by the MMS to the comments made by the Natural Resources Defense Council and Trustees for Alaska regarding Chukchi Sea OCS Lease Sale 109 are herein incorporated by reference. Response TFA-2 The commenter’s claim of insufficient information is not focused and does not offer any significant new relationships to the decision of what they claim is missing. The references cited in the EIS represent the best scientific information available for environmental description and analysis purposes. Additional references introduced in the FEIS, as a result of comments on the DEIS, improve the quality of the analysis (as shown, for example, by the analysis of polar bear in Sec. IV.C.6). Response TFA-3 The fact that the sperm whale being experimented upon was stranded and had been dead for 5 to 10 hours before the experiment was concluded had nothing to do with the experimental results. This reality is borne out on Page 160 of the 1982 Geraci and St. Aubin report, where it states that "The whale died during the course of the contact study. Yet the histological changes noted in the epidermis exposed to gasoline are noteworthy in that they are indicative of damage to living cells, and not postmortem autolysis." Consequently, according to the report, the death of the sperm whale had no bearing on the outcome of the experiments. This represents a demonstration of effects on living tissue. Regarding the "dramatic changes" after 17 hours of exposure to gasoline, the subject of the EIS analysis concerns the effect of crude oil on cetaceans, not the effect of gasoline on cetaceans. In the few places where the effects of gasoline are mentioned, they are mentioned for comparative purposes only, in the more realistic scenario of 75 minutes of exposure. The idea that free-ranging whales would somehow be exposed to gasoline for 17 hours due to activities associated with Sale 126 is clearly unrealistic. In all likelihood they would not be exposed to gasoline at all. In addition, gasoline is many times more damaging to tissues than crude oil and does not accurately reflect effects that would be expected from contact with crude oil. This, of course, is why the EIS does not elaborate on gasoline experiments. No attempt was made to imply that gasoline experiments were only 2 hours long. Regarding the actual damage caused by 17 hours of exposure to gasoline, the report also indicates that damage occurred only to the medial and superficial layers of the TFA-1 epidermis and states that "even this degree of damage seems to be reversible." Response TFA-4 See Response TFA-2. Regarding the blisters observed on two of the four dolphins tested, this is indicated on the chart on Page 90 of the 1982 Geraci and St. Aubin report. The chart shows (among other things) the effects of gasoline on the skin of four dolphins after 15, 30, 45, 60, and 75 minutes of exposure. However, the report also indicates that the blisters on the two dolphins at 30 and 45 minutes of exposure were small and that the same animals showed no visible reaction after 75 minutes. That is why the report stated on Page 89, concerning the chart on Page 90, that "In some cases, the exposed skin had a faint hobnail texture that disappeared within 5 minutes. Normal color was always restored within 2 hours. At no time was there any swelling, hemorrhage, or break in the continuity of the skin associated with exposure." The report concluded that "We found that dolphin skin exposed to gasoline and crude oil turned pale gray, and otherwise showed no evidence of damage or loss of integrity.” Response TFA-5 Lease Sale 85 was deleted from the 5-Year Oil and Gas Leasing Program to address the concerns of the State of Alaska and the Alaska Congressional delegation. The following sentences regarding those concerns are excerpted from a January 10, 1984, letter from the Honorable Bill Sheffield, Governor of Alaska, to William Clark, Secretary of the Interior: "The primary concern of the state was the pace of the Department of Interior’s current five-year oil and gas leasing program. Due to internal budget constraints, the MMS personnel assigned to Alaska’s OCS appear to be insufficient for their greatly expanded responsibilities under the accelerated program. A two year delay would enable valuable scientific data interpretation and synthesis effort of available information to continue." The assessment of working in heavy ice conditions was completed in the Sale 109 FEIS (USDOI, MMS, 1987b). Exploration is likely to continue in open-water conditions. It is estimated that development drilling will begin in 2000. This allows 9 years for the oil industry to study conditions. Drilling will be allowed when the oil industry demonstrates to MMS that they can operate safely in the ice conditions of the Chukchi Sea. Engineering studies indicate that a key consideration in the design of buried offshore pipelines in an arctic environment is to determine the optimum burial depths that (1) maximize the pipeline’s safety from rupture by ice gouging and (2) minimize costs. Prior to construction of subsea pipelines, operators would be required to conduct geological and geophysical surveys to determine potential hazards, including ice scouring, to the pipeline. The density, age, depth, and reoccurrence rate of ice gouging must be fully evaluated and considered in the design, construction, and placement of a pipeline. Any pipeline design must include devices to monitor damage or leaks, and redundant automatic and manual shutdown valves to shut off the pipeline and stop a continuous leak if a break in the pipeline occurred. Continuous monitoring techniques will enable the operators of such pipelines to be forewarned of potential scour problems and to take corrective actions. Response TFA-6 Cleaning up an oil-spill is a major and difficult task regardless of the location and type of environment. The reference to Cook Inlet provides an excellent example; although the commenter suggests environmental conditions are milder, Cook Inlet has the second-highest tides in North America. These high tides create extremely fast tidal currents that complicate oil-spill cleanup. A review of historical spills indicates that mechanical cleanup averages 10 to 15 percent recovery (U. S. Congress, OTA, 1990). Response planning for short response times (6-12 hr and 48 hr for additional equipment) is required for drilling operations on the Alaska OCS. Prior to the Oil Pollution Act of 1990, similar requirements were not previously in place for general ship traffic in Cook Inlet. Oil-spill cleanup and response is discussed in Section IV.A.2 and Appendix L. OCS exploration and development and production activities require approved oil-spill- contingency plans, which establish and commit equipment, manpower, logistical support, and communications resources to a specific activity. The MMS believes this will ensure greater response than in previous TFA-2 transportation or other non-OCS spills. Response TFA-7 Appendix L, Tables L-5 and L-6, contain a listing of dispersants aboard SWEPI’s oil-spill-response barge in the Chukchi Sea and the ACS warehouse at Deadhorse. Chapter 3, Toxicological Testing of Dispersant and Dispersed Oil, and Chapter 4, Intermediate-Scale experiments and Field Studies of Dispersant Applied to Oil Spills in Using Oil Spill Dispersant on the Sea, have been referenced and included in the discussion on dispersants. Response TFA-8 The DOI is charged by law (OCSLA) to develop the resources of the OCS. Energy conservation programs are the responsibility of DOE. The commenter is referred to Appendix I, Alternative Energy Sources. This information summarizes and incorporates by reference Appendix C, Alternative Energy Sources, of the Final EIS for the Proposed 5-Year OCS Oil and Gas Leasing Program, 1987-1992 (USDOI, MMS, in Press). Response TFA-9 The MMS believes there is adequate information available to prepare an EIS on a proposed OCS Chukchi Sea lease sale and to reach a reasoned decision on a proposed course of action. By means of an Exploration Plan, lessees must demonstrate to the MMS prior to exploratory drilling their ability to clean up oil spills and operate safely in the ice conditions of the Chukchi Sea. Should commercially marketable quantities of hydrocarbons be discovered in the Chukchi Sea, a developmental EIS would be required based on the plans for development, production, and transportation of such oil to market. At that time, more specific additional data should be available to plan for arctic-oil-spill cleanup. Response TFA-10 During the Exxon Valdez Cleanup Technology Workshop (1989), Jim O’Brien concluded from a detailed literature search and interviews that no technology, other that what has already been considered, is available to facilitate mechanical recovery and cleanup of oiled shorelines. During the 1980’s the major emphasis was on refining existing technology rather than major technology development. The MMS is in the process of developing minimum performance standards for response equipment once standard test protocols are established. This will be a milestone in developing effective containment and cleanup equipment for the Arctic. Since the Exxon Valdez spill, oil-spill research and development has been in the spotlight. The Oil Pollution Act of 1990, Public Law 101-380, establishes an interagency coordinating committee on oil- pollution research. Membership of the Committee includes representatives of NOAA, DOE, DOI (includes MMS and FWS), DOT, DOD, EPA, National Aeronautics and Space Administration, and the United States Fire Administration in the Federal Emergency Management Agency, and other Federal Agencies that may be designated by the President. In addition to Federal research, Marine Spill Response Corporation (MSRC), a consortium of oil companies and shippers, will administer a comprehensive research and development program to improve the knowledge and technology used to respond to and clean up spills. This program will complement programs in government, academia, and industry. Response TFA 11 Chukchi Sea Lease Sale 109 presented a proposal that included the entire Chukchi Sea Planning Area. Largely for this reason, three deferral alternatives were examined in the Sale 109 EIS. In the case of Sale 126, however, the existence of one deferral alternative is the result of having excluded from leasing--during the Area Identification phase of the lease-sale process--a large number of blocks on the southeastern (nearshore) boundary of the planning area. The MMS made a reasoned attempt, prior to defining any deferral alternatives, to protect the habitat represented by the nearshore blocks that were deleted from the TFA-3 proposed Sale 126 area. The southeasterly boundary of the proposed Point Lay Deferral Alternative in Sale 126 coincides with the same boundary for what was known as the Sale 109 Coastal Deferral Alternative. Numerous factors entered into the decision process by which the boundary of the deferral alternative was drawn--not the least of which were critical habitats and the flaw zone of the Chukchi Sea. The northwestern boundary of the flaw zone shown on Graphic 2, however, is only indicative of possible annual and seasonal boundary locations and cannot be used with precision to describe a lease-sale boundary. This is why a cautionary note to readers is provided on Graphic 2 to underscore the imprecision of the data described. Response TFA-12 The DEIS discusses, directly and by reference, potential effects of emissions from OCS operations on tundra. For comparison, three levels of effects are given. The first level, with an extraordinarily high level of pollutants, results in the death of plants. The second level, with about 10 times fewer pollutants, results in damage to plants. A third level, five times lower than the second, can depress photosynthesis. The maximum modeled concentration of sulfur, at the shoreline, is about 100 times less than the level that would cause damage to plants. While not modeled, further dispersion of pollutants would reduce concentrations to near ambient levels affecting only a local area. To some limited degree, tundra would be affected by the addition of pollutants to existing air. However, even the greatest effects from potential emissions would be localized and not measurable and would occur during the summer during the 10-year exploration period. Response TFA-13 Given that effects on tundra would not be measurable and localized, no effects on wildlife due to OCS emissions are anticipated. Response TFA-14 Since few exploratory operations are proposed, the likely rate of bowheads encountering industrial noise is very low to start with. In addition, whales that did encounter industrial noise would do so for only the brief period of time it takes them to swim past the operation. This period represents only a small fragment of the total time needed for migration. During the remaining portion of their migration, all bowheads are subject to naturally occurring noise (from ice, wind, waves, seismic events, and animals) and diversions around areas of thick or extensive ice cover on a daily basis. They are also subject to death during both migrations, due to the spring and fall subsistence hunts. For these reasons, it is clear that industrial noise is likely to result in only insignificant effects on bowheads, in comparison to effects due to other events. Hence, the commenter’s statements (which are based on speculation) regarding how whales use the reflection of their own calls to determine ice thickness, and thereby locate places where they can break out of the ice, are irrelevant, since only a small number of bowheads would be exposed to the minor, short-term effects of industrial noise for a small fraction of their total migration time. Consequently, even if whales did depend on the reflection of their own calls to navigate or communicate, it is unlikely that industrial operations associated with Sale 126 would affect them in any significant way. Response TFA-15 The analysis does not state that results of disturbance studies are unimportant for interpreting potential effects. However, available evidence suggests that the numbers of walrus and seals that might be affected are likely to be small and the effects mainly localized and short-term; thus, a conclusion of effect greater than low resulting from disturbance alone would be difficult to substantiate. Response TFA-16 In terms of adversely affecting substantial numbers of walrus or seals, an oil spill occurring or released from TFA-4 ice from late May through the open-water period is likely to be the most severe. It is not clear from this comment why the commenter feels it is important to track a winter oil spill trapped in the ice if, as is asserted, it cannot be cleaned up. We find no new evidence in the comment or elsewhere that would suggest that spills in winter or spring are likely to contact significant numbers of walrus or seals or result in greater- than-low effects. Response TFA-17 The commenter’s interpretations are consistent with the analysis in Section IV.A.2(e)(5) and Appendix L. The MMS OCS Oil Spill Task Force report to the Secretary of the Interior (1989) considered Orion tracking buoys, ice-marking dye, and the ACS trajectory model sufficient for detection and monitoring during SWEPI’s exploration drilling in the Chukchi Sea. Response TFA-18 The concepts of "sharing networks" and interrelationship of Inupiat family values/culture and their dependence on subsistence resources are discussed in Section III.C.3. The effects of the lease sale on wairus and bowhead are expected to be low and very low, respectively; thus, the overall effect of the sale on the harvest of these subsistence resources (and subsequent effects on sociocultural systems) may be similar. Section III.C.3 discusses life in North Slope communities and the various prevalent social pathologies as well as the North Slope Borough’s efforts to deal with them. It is unfortunate that the commenter finds the text’s impartial analysis "callous;" alcohol is currently the primary threat to public health and Inupiat family values on the North Slope and has been for decades. Long before the advent of the oil ang gas industry on the North Slope, whalers and traders introduced alcohol (and the means to make alcohol) into the Inupiat culture. Response TFA-19 See Responses TFA-A1 on sufficiency of information, TFA-2 through TFA-4 on the use of information in the EIS, TFA-5 through TFA-7 on oil-spill cleanup, and TFA-8 on energy alternatives and conservation. TFA-5 Bering Sea Fishermen's Association 725 Christensen Drive Anchorage, Alaska 99501 (907) 279-6519 September 11, 1990 George H. Allen EIS Coordinator US. Department of the Interior Minerals Management Service, Alaska OCS region 949 East 36th Ave Anchorage, Alaska 99508-4302 Re: Chukchi Sea Oil & Gas Lease Sale 126 Draft Environmental Impact Statement Dear Mr. Allen, Thank you for this opportunity to comment on the Draft Environmental Impact Statement (DEIS) for Lease Sale 126. In general. we find the DEIS for Chukchi Sea Lease Sale 126 to be fairly rigorous in its analysis and a useful and informative document. The errors we find in the document, for the most part, are not errors in analysis but generally errors of omission. The Bering Sea Fishermen s Association represents commercial and subsistence fishermen from western Alaska. Amongst this constituency are the Inupiat villagers of the NANA region. The DEIS does a good job of describing the subsistence activities, fisheries resources and areas of North Slope Borough (NSB) villages near and immediately adjacent to Sale Area 126. In assessing potential effects of oil development activities, the DEIS focuses on the impacts to these communities and resources. BSFA However, this is not the case for non-NSB villages that use resources 1 that may be affected by OCS development in the Chukchi Sea. The DEIS does not take note of nor analyze potential impacts to resources that migrate through either the Sale Area or the area suggested for the Pt. Belcher/NPR-A pipeline are utilized by residents from outside the North Slope Borough. There is absolutely no mention of the commercial fisheries located in these areas and potential impacts from oil development and possible spills. These omissions are the basis for most of our comments. As well, we wish to comment on other areas of the text, where we feel further analysis is necessary. Section III €.2. Subsistence Harvest Patterns This section fails to describe the resource harvesting patterns of non- NSB commuiiities that utilize resources which could be affected by Chukchi Sea develop (nent. [t would not be necessary to do as exhaustive an analysis for non-NSB communities but we feel that the following issues should be addressed with regards to the following resources utilized by non-NSB com munities). Caribi\y: The Western Arctic Caribou Herd forms a vital component of the subsistejice economy of NANA region residents. For example, it is the single most |mportant resource for Kotzebue and Kivalina residents, contributing roughly 24 percent and 26 percent, respectively, of the total subsistence \iarvest by edible weight. NANA region residents travel more than 100 miles to harvest caribou. The northern limit of their hunting range extends frori; Cape Thompson in the west then follows the Colville River drainage uniil it turns south at 151 50. The proposed pipeline across the NPR will pasii across the caribou hunting territory of NANA residents as it B passes along the Colville River. Small \iame (ptarmigan. grouse. hare. etc.) and Furbearers: NANA region reside nts also hunt small game and trap various furbearers hundreds of miles from their home villages. The northern boundary of their hunting range for sm il game extends from a point 30 miles north of Cape Beaufort, to the headwiters of the Meade River, then follows the Colville River drainage to a easternmost point at roughly 69 N, 153 W. The proposed pipeline acros\ the NPR will also pass close to or within the small game and furbearer harvesting territory of NANA villagers. Although it is a matter of debate as to the degree of impact to terrestrial mami)als from a pipeline, the DEIS does acknowledge that short- term disruptions to caribou migration will occur especially during the two years of pipeline and road construction. The DEIS states that possible short- term reductions «\f the season's harvest" of caribou (p. 1V-C-75) may occur due to these disri\ptions. Since non-NSB communities utilize the Western Arctic Caribou He1\d as well. the DEIS should state the possible impacts to NANA region resic\nts’ use of caribou. As well. the DEIS should acknowledge that (ANA residents harvest small game and furbearers in 2 SFA Marine Mammals: the DHtS also fails to note that non-N3B residents harvest marine mammals that migrate through the Sale 126 area. The marine mammal hunting territory of NANA residents extends up to Point Hope. Marine mammals are a major portion of the subsistence harvest by BSFA NANA residents. Walrus, bowhead whale, belukha, and bearded seal that NANA residents harvest migrate from the Bering Sea up to the Chukchi 1 Lease Sale Area. Harvests of these four species make up over 50 percent (by weight) of the total subsistence harvest by Kivalina residents, for example. The DEIS projects in Figure IV-C-1 that if an offshore oil spill occurred, there would be a high probability that migration corridors north of Pt. Hope would be contacted by oil. Therefore, the DEJS should state that any impacts to marine mammals that migrate through Sale Area 126 could have cesidents, Throughout the discussion of impacts to subsistence harvesting from development of Lease Sale 126, the DEIS makes repeated statements to the effect that though disruptions to harvests of particular species or harvesting activities within specific locales may occur, residents of villages will easily be able to make up “lost” harvests, by harvesting other resources or obtaining them from other locales (see especially section IV.C.11.b). While these statements are not false, they fail to appreciate the significant traits of a subsistence strategy. BSFA The subsistence harvesting cycles and resource use areas of Alaska Natives have evolved over several generations. Efficiency and high productivity characterize harvesting activities. People use areas that are easy to access and which will provide them a good and rapid return for their investment of time, money, and skill. Villagers affected by short-term disruptions to their harvesting will probably be able to make up the deficit in their harvests; indeed they will seek to do so since they know how much food they usually need. However, disruptions to their regular harvesting patterns could have significant repercussions. Villagers would have to travel longer or over more difficult terrain or sea conditions to harvest the amounts they need. One issue not addressed at all is the effect the presence a pipeline i toad will have in terms of increasing non-subsistence hunter access to game and fish populations of the northwest Arctic. The DEIS states that the NPR BSFA Ripeline road would be private. However, would the owner of the pipeline 3 be allowed to issue use-permits for hunters or guiding operations? Would the owner be able to monitor activity on the road should hunters trespass on it? Would employees working on construction of the pipeline and road be permitted to hunt and fish in the region? BSFA The North Slope haul road has allowed increased urban hunter access 3 to such areas as the upper Koyokuk drainage near Bettles and the upper Yukon River near Stevens Village. Given the proposed NPR pipeline through what is now an area isolated from urban Alaska, the DEIS should explore likely scenarios or regulatory options with regards to increased access to the region by non-local residents. discuss further the impacts the NPR pipeline road. The primary response to an oil spill or blowout would be to physically capture and retrieve the oil using oil spill response barges. Under icing conditions it would not be possible to use barges and booms; burning and BSFA dispersants would be the only options. Under rough seas and poor weather, 4 none of these response options would be viable. What would you do if a blowout or oil leak occurred under these conditions over a prolonged period of time? In closing on our comments, the Bering Sea Fishermen's Association supports delaying Lease Sale 126 (Alternative III). This would provide time to further develop oil spill prevention and cleanup technology for the arctic and to conduct additional research on impacts to marine mammals and fisheries resources. ce ee don Ito Member, BSFA Board of Directors Bering Sea Fishermen’s Association Response BSFA-1 While hunters from some NANA communities probably use the Colville River area, the pipeline route lies nearly 245 km north of interior communities such as Ambler and Kobuk. If it is conceded that these communities’ subsistence range includes the hypothetical pipeline route, then it must also be noted that such a range represents the limit of subsistence activities and not the core area of the communities’ harvest. This extent of activity would equate to similar maximum subsistence ranges of 245 to 320 km for the North Slope communities of Barrow and Wainwright. The core-area boundaries of community subsistence activity generally coincide with a day’s snowmachine ride (out and back) from the community (approximately 97 km). The effects of the pipeline on the subsistence harvest of migrating caribou would be moderate for Atqasuk. Atqasuk’s harvest zone would be substantially more affected by the proposal than the harvest area of NANA communities due to its proximity to the hypothetical pipeline corridor. Therefore, any effect on the NANA communities’ harvest of subsistence resources would be substantially less than on Atqasuk’s due to the extensive travel required to harvest resources near the pipeline. Regarding the potential disruption of the marine mammal harvest of NANA communities by the proposed action, the same argument is advanced as for caribou (Fig. IV-C-4 shows caribou range). The area immediately affected by the proposal lies outside the core subsistence area of the NANA communities, and effects of the proposal on NANA harvests are expected to be negligible. The development scenario of the proposed action includes those communities that MMS believes would be obviously and measurably affected by the proposal. This EIS is a prelease document; should recoverable quantities of hydrocarbons be discovered in the Chukchi Sea, at least one developmental EIS would be prepared by the MMS to evaluate in detail a greater number of issues than are covered in this EIS. Response BSFA-2 Disruptions to community harvest patterns may require hunters to travel longer distances or over more difficult terrain and thus may be a factor in the reduction of the subsistence harvest; however, due to the distribution of the resources available to North Slope communities (see Figs. III-C-6 through III-C-11 and IV-C-4), it is unlikely that long-term disruptions of subsistence resources would occur as a result of the proposal. An exception would be the potential high effect of the proposal on the Wainwright bowhead harvest, which would occur only if there were an oil spill. For all other North Slope communities, subsistence effects are expected to be low to moderate. It is unlikely that any effects would occur on NANA communities as a result of the proposal. Response To BSFA-3 Effects assessment of the use or nonuse of the Chukchi Pipeline Road by hunters are not within the purview of this document and is purely speculative at this point. We recognize that the renewable resources of the area could be affected if the pipeline road were used by hunters. However, road use and hunting regulations for the pipeline area will become a matter of public policy--a matter no doubt resolved only after extensive public debate. In general, effects of the pipeline on the resources of the interior would be addressed in a developmental EIS if recoverable quantities of hydrocarbons were found and one of the transportation options were a feeder pipeline to the TAP. Response BSFA-4 An under-ice, long-term-spill scenario is addressed in Section IV.J. Oil-spill response is addressed in Section IV.A.2 and Appendix L. Mechanical recovery, dispersants, burning, and natural dispersion are the general options for responding to oil spills. The best combination of these options would be used under the conditions at the time of a spill, providing that safety was the first consideration. BSFA-1 SEACO, A Division of SCIENCE APPLICATIONS INTERNATIONAL CORPORATION 2845 NIMITZ BOULEVARD, SUITED « SAN DIEGO, CALIFORNIA 92106 « (619) 225-3631 6 September 1990 Mr. George Allen EIS Coordinator MMS, Alaska OCS Region 949 East 36th Avenue Anchorage, Alaska 99508-4302 Dear Mr. Allen, In response to your request for written comments on the sections of the Draft Environmental Impact Statement (DEIS) for Chukchi Sea Oil and Gas Lease Sale 126 during our phone conversation today, | enclose three pages of the DEIS concerning SEA bowhead and gray whales marked to indicate where information should be updated. The 1 numbers marked on the draft text refer to numbered references (attached), all of which should be available through Dr. Jerome Montague, MMS, Alaska OCS Region. Most important of the changes, | think, is that Figure III B-5 indicates that the fall bowhead whale migration across the Chukchi Sea has a broad and well-defined component north of 72° N latitude. This is not supported by recent sighting data Although a few bowheads have been seen north of 72° N, most whales appear to disperse southwest from Point Barrow. Also, bowhead feeding has been described for SEA various areas across the Alaskan Beaufort Sea and in one case in the northeastern Chukchi Sea in fall, not just “in areas to the east of Barter Island” and “near the Plover 2 Islands". Finally, Wursig et al. (1985) and Nerini et al. (1984) should be cited when discussing feeding and likely bowhead mating and calving periods, respectively [found in ref # 5 LIT CIT]. Similarly, the information for gray whales is somewhat outdated and sketchy. | have marked suggested references to update the material, as for bowhead whales. | hope you find this submission helpful. Please call if there are any questions. Sincerely, es tn a teats Sue E. Moore Program Manager MMS Contract No. 14-35-0001-30468 encl. cc. P. Dubsky J. Montague SYSTEMS ENGINEERING @ OPERATIONS ANALYSIS e PRODUCT OESIGN « OOCUMENTATION e RESEARCH Comments on MMS DEIS for Chukchi Sea Oil and Gas Lease Sale 126 MARKED TEXT Endangered Species Act also are protected under the International Convention for the Regulation of Whaling (1946) and the Marine Mammal Protection Act of 1976. Endangered species likely to occur in or adjacent to the proposed Sale 126 area include bowhead and gray whales and the threatened arctic peregrine falcon. The biology of these species was described in Section III.B.5 of the Sale 97 FEIS (USDOI, MMS, 1987a), which is hereby summarized and incorporated by reference. Endangered fin and humpback whales rarely occur in the sale area and thus would experience no significant effect from the proposal. There are no listed endangered plant species in areas adjacent to the sale area. a. Bowhead Whale: The bowhead is an ice-associated whale. The western arctic stock of bowhead whales, estimated to number about 7,800 (Zeh, Reilly, and Sonntag, 1988), passes through the proposed sale area semiannually as they migrate between summering grounds in the Canadian Beaufort Sea and wintering areas in the Bering Sea. There are no reliable data on whether the western arctic bowhead population is increasing, stable, or decreasing. (However, the bowhead population is believed by some to have increased dramatically in recent years (thé scientific basis for these beliefs S unclear). Assuming the current population estimate (7,800) and the estimated historic population (prior to commercial whaling) cited by Braham (1984), [to be accurate}”the bowhead population is currently about 40 percent of the historic population level. If these assumptions are valid, bowheads are more abundant now than at the close of the commercial whaling period, when they were estimated at about 1,000 animals, . . , After summering in the Canadian Beaufort Sea, bowheads begin moving westward in August into Alaskan waters. Generally, few bowheads are seen in Alaskan waters until the major portion of the migration occurs, typically between mid- September and mid-October. The extent of ice cover can influence the timing and duration of the fall migrationé The primary migration corridor appears to be the area between the depth contours of 10 and 50 b mee Data on the bowhead fall migration through the Chukchi Sea is limited; however, it appears that before they move south into the Bering Sea, most 1 bowheads cross the Chukchi Sea in a broad front from Point Barrow to the - northern coast of the Chukotsk Peninsula (see Fig. II1-B-5X.~ The bowheads’ _ ior northward spring migration appears to be timed with the ice breakup, usually — beginning in April. In the Chukchi Sea, they follow leads in the flaw zone from outer Kotzebue Sound to Barrow. After passing Barrow frem April through mid-June, they move through offshore leads in an easterly direction. East of Point Barrow, the lead systems divide into numerous branches that vary in location and extent from year to year. Bowheads arrive on their summering grounds in the vicinity of Banks Island/Amundsen Gulf in about late May to June (Fraker, 1979). decd J testy Le Bowheads feed throughout the water columin{ Hen items most commonly found in the stomachs of bowheads killed by Eskimos include euphausiids, mysids, copepods, and amphipods. Most feeding has been observed to occur in the Canadian Beaufort Sea; however, bowheads are opportunistic feeders and may feed anywhere within their range where feeding conditions are favorable. For example, feeding has been observed off Wainwright and Point Barrow during the spring migration (Carroll and George, 1985) and in areas to the east of Barter Island during the fall wigration as bowheads migrate westward across the III-32 SS nas assets 4 73, 1 Sea Chukchi 704 LEGEND Chukchi Sea Proposed Sale 126 Area Generalized Bowhead Whale— Migration Areas Spring (April-May) Fall (September—October) Seasonal Land—Fast-ice for April-May (yearly and seasonal variation in the seaward boundary of the land— fast ice determine the neor— shore limit of the spring migration corridor) Source: ne et al., 19850, and uF et al, 1983. Figure \II-B—5. Bowhead Whale—Migration Areas Alaskan Beaufort Sea (Thomson and Richardson, 1987). Bowheads also have been seen feeding in areas east of Point Barrow near the Plover Isiands. Carbon isotope analysis of bowhead baleen indicates that a significant amount of feeding also may occur in wintering areas in the Bering Sea (Schell, Saupe, and Haubenstock, 1987). Bowhead mating and calving appear to occur during the spring migration. Late winter is the most probable mating season, at the time when most of the population is located in the Bering Sea. However, mating behavior also has been reported north of Point Barrow. The peak of calving probably occurs in May, although the calving season can extend from late March until early August. Although some mating, calving, and feeding occurs within the sale “area, these activities generally occur elsewhere (due in part to the relatively short time during which the whales are actually in the sale area). a b. Gray Whale: The eastern Pacific gray whale stock is estimated to number 21,000 individuals (Breiwick et al., In Press). The eastern Pacific gray whale stock has recovered to, or now exceeds, its size prior to commercial whaling (Rice, Wolman, and Braham, 1984). In recent years, the population has grown by an estimated 2.5 percent per year. Gray whales spend the summer-through-fall months feeding, calf rearing, and resting in the northern Bering and Chukchi Seas (see Fig. III-B-6). Their northern range generally extends to Point Barrow, but they have been sighted up to 445 km northwest of Point Barrow (Ljungblad et al., 1986) and ce occasionally to the east of Point Barrow. However, for the most part, grays tend to be more concentrated in nearshore waters (often within 15 km of shore) between Point Hope and Point Barrow. Although these nearshore areas are essentially outside the sale area, some grays are likely to feed and move about within the sale area. From 1982 to 1984 (July through October), Moore, Clarke, and Ljungblad (1986) reported 323 gray whales sighted between Point Hope and Point Barrow. Most whales were feeding within 14.5 km of shore. All cow/calf pairs were seen in July between Wainwright and Point Barrow and Cape Lisburne and Point Lay, within 4 km of shorg. Ljungblad et al. (1988) reported that 394 gray whales have been sighted in the nearshore area between Point Hope and Point Barrow since 1982 (September-October), that 85 percent were feeding in open water or light ice cover, and that they were also seen feeding 160 km northwest of Point Barrow. The southbound migration generally begins in mid-October (Johnson et al., 1981). a ee Gray whales are predominantly suction-bottom feeders, but in some areas they have been observed feeding on dense swarms of pelagic euphausiids (Guerrero,+ 1985). Most feeding activities are believed to take place on the northern feeding grounds (Oliver et al., 1983); however, feeding during the spring migration has been documented to begin as early as March (Braham, 1984; Folkens, 1985). Feeding occurred most often in the Point Belcher area but was also observed between Point Hope and Point Barrow (Ljungblad et al., 1985a},___ On the summer feeding grounds of the Chukchi and Bering Seas, gray whales feed primarily on benthic gammaridean amphipods; however, approximately 100 ‘ different prey species have been identified from stomach analysis. e. Arctic Peregrine Falcon: Threatened arctic peregrine -, falcons occasionally enter the coastal area adjacent to the eastern boundary 111-33 eee Comments on MMS DEIS for Chukchi Sea Oil and Gas Lease Sale 126 NUMBERED REFERENCES - Moore, S.E., J.T. Clarke and D.K. Ljungblad. 1989. Bowhead whale (Balaena mysticetus) spatial and temporal distribution in the central Beaufort Sea during late summer and early fall 1979-86. Rep. int. Whal, Commn. 39: 283-290. 2 - Ljungblad, D.K., S.E. Moore and D.R. Van Schoik. 1986. Seasonal patterns of distribution, abundance, migration and behavior of the western Arctic stock of bowhead whales, Balaena mysticetus in Alaskan Seas. Rep, int. Whal.Commn. Spec. Iss. 8: 177-205. 3 - Moore, S. Ee JT. Clarke and D.K. Ljungblad. 1286. A comparison of gray whale robustus) and bowhead whale (Balaena mysticetus distribution, abundance, habitat preference and behavior in the northeastern Chukchi Sea, 1982-84. Rep. int. Whal, Commn. 36: 273-279. 4 - Ljungblad, D.K., S.E. Moore, J.T. Clarke and J.C. Bennett. 1988. Distribution, abundance, behavior and bioacoustics of endangered whales in the western Beaufort and northeastern Chukchi Seas, 1979-87. NOSC TR 1232, prepared for MMS, Alaska OCS Region, 231 p. 5 - Moore, S.E. and Clarke, J.T. 1990. Distribution, Abundance and Behavior of Endangered Whales in the Alaska Chukchi Sea. Final Report prepared for U.S. Minerals Management Service, prepared by SEACO, a Division of SAIC, 240 p. 6 - Ljungbiad, D.K., S.E. Moore and J.T. Clarke. 1986. Assessment of bowhead whale (Balaena mysticetus) feeding patterns in the Aleskan Beaufort and northeastern Chukchi Seas via aerial surveys, fall 1979-84. Rep. int. Whal.Commn. 36: 265-272. 7 - Clarke, J.T., S.E. Moore, and D.K. Ljungblad. 1989. Observations on gray whale (Eschrichtius robustus) utilization patterns in the northeastern Chukchi Sea, July- October, 1982-87. Can, J. Zool. 67: 2646-2654. 8 - Moore, S.E., D.K. Ljungblad and D.R. Van Schoik. 1986. Annual patterns of gray whale (Eschrichtius robustus) distribution, abundance and behavior in the northern Bering and eastern Chukchi Seas, July 1980-83. Rep. int. Whal. Commn. Spec. Iss. 8: 231- 242. SEACO R -1 The suggested changes have been made to the text, as appropriate. Response SEACO-2 Figure III-B-5 is a generalized illustration of the fall bowhead migration areas and, hence, is not intended to define the area in a specific way. The area north of 72°N. is included in the diagram because a few bowheads have been sighted there, and it is likely that if aerial coverage were greater in that area, more bowheads would be sighted. Regarding bowhead feeding areas, those mentioned in the EIS are only examples that are not intended to be all-inclusive (Wainwright and Point Barrow were also mentioned). Additional citations have been added to the text, as appropriate. SEA-1 SEP @ '98 1625 NORTH SLOPE BOROUGH Pas TESTIMONY OF JOASH TUKLE ON LEASE SALE 126 Sept. 5, 1990 I had given my testimony the last you were here, but since you had also stated that written testimonies would also be accepted until a certain time as at the time you were here I felt I was taking too long. It has always been said by all oil companies that an oil spill would be taken care of right away. I always believed that, should a spill occur, it would be cleaned up right away. As has been said at all Public Hearings that all the technology is available for clean-up purposes. But all this talk has become questionable in my mind since I have viewed the Exxon/Valdez spill, there were efforts to clean-up the oil on the water. As I viewed this mishap it looked like that nothing was available at the moment to clean up the spill. For I have learned from experience that when your emergency equipment is available you take it with you at all times and at the first sign of trouble you have it with you to use for emergancy purposes. Some time later efforts were made to clean-up the spill after it had spread, come to think of it, it was only a barge load. Therefore we all have to have better communications and prepare for the worst better yet to have all the modern technology available here in Alaska, in fact by the shores of the Arctic ocean. So with everything available on hand we can be assured that should a blowout occur it wouldn’t spread. Another thing too should a blowout occur during a westwind storm the oil could easily spread on top our ocean then onto the lagoons then unto the rivers I know for a fact that during a storm that galt water goes up river, so therefore oil can go with the current upriver. Another thing too that we use outboard motors on our boats when we are out hunting and should the ocean water be mixed with oil from the blowout it is a fact the outboard won’t last long when both our ocean and the lagoons are filled with oil from the blowout for we depend on our livelihood from the rivers and oceans. For all the fish and the fowl depend on the emall fish for food, not only that but it will include the seals, and evary living thing we depend on for food. We have seen it takes a long, long time to clean up a spill, and since you wanted the les comments. We give our testimonies to at least let the oil companies know our viewpoints and comments. Like for instance should a fire brake out in our shores then we will be in a hazardous situation. So therefore we should have a permanent road to take us to safety further away from what Barrow already have so we can be able to escape. When all the sea mammals have died we want a positive road to take us to safety far away, where we can be able to do subsistence hunting. We need roads where we can get as far away as we can no JT 2 SEP @6 '9@ 16'27 NORTH SLOPE BOROUGH PSS matter how far away one gets. Each of the villages should decide where abouts would be the best place for subsistence hunting, when @ blowout occurs when we can no longer travel by boats like we once did. In the winter time it could be different when we would be able to use our snowmachines, but in the summer time when we travel by boats to get to the rivers, therefore should a blowout occur it is a fact we will no longer be able to travel by boat. Where we know game is available up in the rivers, so therefore we might have a better chance if we had a road we might be able to get to where game is plentiful. Take Barrow for instance, it may take years should a blowout occur, only if we had roads we would be able to go where hunting is available, there may come a time we are offered money but that won’t replace what we got from subsistence hunting we will go hungry, and too the money will not be sufficient to take care of all our needs, but if we had roads it might be different, where we will be able to get what the land has to offer. If there was a road to Collville area it wouldn’t be so bad, where game is plentiful including moose, white fish, and lots of other game. It really would benefit Barrow. So it will have to depend on each village to say where they would like to go should a blowout ocour in our waters. Kaktovik has it’s own choice, so does Nuiqsut. But me, I’m from the North Slope and therefore I’m talking for it. Like I said it’s up to each village to get together and find out where would be the best place for survival. I repeat, that our only chance of survival will be to have a road so we can be able to go where we want should a blowout occur. It is up to Wainwright to decide where they would like to be as we know should a blowout occur it will not be anything small. Since it was requested of us as citizens of the North Slope I am giving my comments so therefore I would request that roads be built 80 We would not be stranded here so to speak should a blowout occur in our oceans. Take for instance the Dalton Highway, I had the privilege to drive a vehicle from Anchorage to Prudhue and I had a chance to see first hand that a road is very convienent for hunting, as more than one vehicle bypassed me that were towing ATV, etc., behind them and were able to catch big gama like moose, etc., So therefore I say a road would really benefit us. Therefore, I say we who live here and you live there there ought to be better communications between us so we all can better understand ourselves. Mr. Joash Tukle R nse JT-1 Historically, including the Exxon Valdez, using mechanical equipment, spilled-oil recovery generally ranges between 10 and 15 percent (U.S. Congress, OTA, 1990). Locally available spill-cleanup equipment is addressed in Section IV.A.2(e) and Appendix L. Exploration wells drilled to date in the Chukchi Sea kept oil-spill-response equipment on a drillship, on a large icebreaker/support ship, and on an oil-spill-response barge. Having the oil-spill-response-barge on or near the drilling site is the option of the oil company and is not required by 30 CFR 250.42. Oil-spill-contingency plans approved to date for the Chukchi Sea (Spiltec, 1989, 1990) indicate that an oil-spill-response barge would be shared between companies drilling in the Chukchi Sea. R nse JT-2 The MMS understands your concern; however, there is little that the MMS can do in the matter of road construction. The construction of roads for local use is a matter of State and local government priorities regarding how State/local revenues should be spent. The Federal Government provides some funds for road construction; however, the State determines how and where those funds will be spent. Whether roads are constructed to serve North Slope communities is currently dependent on the State legislature’s desire to appropriate funds for this purpose. J. L. MOHR 3819 CHANSON DRIVE LOS ANGEL cA 90043-1601 (213) 295 64 7 September 1990 Regional Director Minerals Management Service, Alaska OCS Region 949 East 36th Avenue, Room 110 Anchorage, Alaska 99504-4302 Attn: Paul Dubsky COMMENTS ON OCS LEASE SALE 126 CHUKCHI SEA DEIS (ocS EIS/EA MMS 90-0035) John Luther Mohr included by reference: Comment on DEIS proposed sale 109 Chukchi Sea Comments on DEIS proposed sale 107 Navarin Basin Commenta on DEIS sale 124 Beaufort Sea which include background material on commenter, and much other material relevant to Sale 126. POSITION? ALTERNATIVE 11 NO SALE should be elected; the Draft Environmental Impact Statement omits too many significant matters, ignores too many essential facts, misuses much material. It is useful to address first the inevitable pressure to pro- ceed with more oil activities in the Chukchi Sea and other outer continental shelf areas because of reduction of supplies from "the Middle East". This is largely from the subliterates who wiped out Near East (Middle is now the west side of the East) and the oil industry, the automotive industry and co-conspirators who sabotaged the energy programs of the 1970's. MMS or its predescessor did not lack participants in that. Pushing OCS activity is not a reasonable answer. It would not provide petroleum quickly whereas conservation measures and alter- native energy programs could make virtually immediate improvement. Recommended reading for EIS preparers: Carter, Jimmy America still needs a policy to cut our oil habit. Washington Post National Weekly Edition, Aug. 20-26, 1990. U. S. Department of Energy Programs in Renewable Energy: Fiscal Year 1990. Experience with the Arctic research drifting station program operating under Office of Naval Research and through Naval Arctic Research Laboratory (NARL), Pt. Barrow (I was involved from 1959 through 1971 -and earlier with the Air Force from 1952 to 1957, including field work 1952 tO 1954) provides insights into the special difficulties and stresses of operations at Arctic posts and especially at Arctic offshore posts generally. One vivid experience was my having to phone the parents of one of our field biologists, Donald Robinson, that the plane on which he was returning from an ice island station had disappeared. I would keep them posted. As the account became more complete, I learned that that the NARL, Point Barrow, supply plane, the radio of which was mal- or non-functioning, carrying both the NARL director and assistant di- rector (contrary to policy), had been refueled in the dark at the ice island station. Fuel containers were snow- or frost-coated, obscuring labels. In the confusion wrong fuel was loaded into one of the plane's tanks. Men at the ice island station discovered the error shortly after the plane took off for return to NARL, but because the plane's radio was not working, they could not warn the pilot. It appeared certain that the plane would draw on the wrong fuel. Much of the way to NARL was over ice, but there was a stretch of open water. If the plane went down in the water, all would be lost. If it came down on pack ice, the question was whether even an exceedingly skilled bush pilot could land without disaster in the dark on a largely very irregular surface. Fortunately indi- cations of motor trouble came over ice and the pilot did bring down the plane without loss of life. However, 1) the plane should not have been flown without its radio functioning. 2) Either the director or his assistant should have remained on duty at NARL, Pt. Barrow. 3) Fueling should never be done without a double-check on kind being poured. Our big concern, of course, was that all were rescued, but(a big one) 1) our scientific collections and records for a third of a year were lost; 2) personnel effects, including Robinson's working library, were all lost; 3) the plane was lost. Because one of the preparers of DEIS 126, John F. Schindler, was a NARLer concerned with this episode, there should have been (should be) total awareness that stress and irrational acts are usual in the Arctic to a degree that they are not at lower latitudes and that the statistics on which Alaskan Region has relied, with most data from other latitudes and other light regimes, are NOT meaningful for this area. Nw A further look at the drifting station experience! In my Arc- tic projects from 1952 to 1971 more than 45 men, mostly, but not all, university students went into the field(s). In the several years I directed the University of Southern California Antarctic ship program a considerable group went to far southern latitudes. No advice on or provision for psychological testing (screening) was given, and in both sets we were rebuked, at least by implica- tion, for sending men not suitable for such stress situations. However, the episode that was most telling was not the fault of any of our men. In brief, two ice island workers got into a fight over who was getting an unfair share of some locally fermented material (home brew) and one of them, possibly scolded by the station leader, killed him. This episode should have been kept in mind by the DEIS 126 preparer. Behavior on Arctic rigs, drill- ing islands and drilling platforms is stressful for kindred reasons: lack of psychological screening, confinement in close quarters with other people, darkness, and work that is dangerous even under more ordinary circumstances. The tolls in Ocean Ranger, Java Sea, Piper Alpha, and numerous Gulf of Mexico accidents, to mention only ones that involve U. S. firms, can be constantly in the workers' thinking and alcoholism (as was mentioned in ONR: European Scientific Notes for North Sea operations out of Scotland) is a very real problem in the North. Again, the NARLer could not have been ignorant of this menace of aloholism in the special situations. It is almost impossible to accept the notion that the preparers of DEIS 126 and previous northern DEISs really believe that the statistical bases for their projections have reliability for this document: they work in Anchorage the scene of the impressive seismic liquifaction of substrate of 1964; they are not so far away from Prince William Sound as to have been unaware of the mishap involving an Exxon T/V of exquis- itely local name. Presumably they should have heard that drinking was thought to have been. a factor; that the U. S. C. G. was understaffed; that the U. S. C. G. was not sufficiently "on its toes", that industry assurances on lack of danger and of response capabilities, which MMS along with other agencies had accepted without critical examination, were less than reliable and so on! Again, it is obvious, particularly for the Alaskan area, that DOI-statistics-based predictions have not panned out. Under the extra-stressful circumstances of the Chukchi Arctic with the increased likelihood of erratic actions, new disasters are much more likely than indicated in Section IV. Other stressful episodes involving NARL also within the single decade of the 1960's should be noted. A 1964 storm forced the evac- uation of the entire laboratory facility. It did severe physical damage. The brief account in the book, Arctic Laboratory, would provide food for thought for the preparers of DEIS 126. At two different times major fires destroyed buildings at NARL and the ice stations had at least one blaze. A watchman at NARL started the engine of a laboratory Cessna and ran into two other Cessnas. Not involving NARL directly, but close by, an experienced bush pilot of Barrow, one with an excellent reputation, took off with an unbalanced load and a group of Alaskan officials. The plane tipped and all were killed in the crash. And a bit west of the town of Barrow is the monument to Wiley Post and Will Rogers who took off without refueling (and presumably without checking how much fuel they had) and crashed lethally. To those willing to think it is obvious that extrapolation of lower latitude experience to northern Alaska ignores the hugh lati- tudinal differences in the prices of misjudgement. Even if the data bases used were wholly respectable, which because much is | derived from industry or industry-influenced sources in DEIS 126,1sMtso, extrapolation should be avoided. Stuart Chase's estimate is worthy, "A dangerous abuse of mathematics appears in the practice of extra- polation - described earlier as riding a trend curve to ° Cloudcuckooland" as is his description of a practitioner as "making an extrapolating ass of himselz". Ly.Hugh Taylor, Princeton Dean and chemist and editor of the American Scientist in the 1960's, said more simply, but firmly, "Extrapolation is not science!" It is super-risky business in the praeter-high difficulties area of Arctic Alaskan 0. C. S. activities. The DEIS has departed from reality. DUBIOUS INFORMATION: The very fragmentary knowledge combined with the apparent astonishing confidence of the preparers of DEIS 126 is disquieting. In DEIS 109 preparers indicated that the shores of the area were uniform over large stretches. I pointed out that G. Dallas Hanna, Norman Wilimovsky and I had collected marine algae from a cobble bed in the area - not conforming to the DEIS descrip- tion. The DEIS 126 has a somewhat altered picture, but it is essentially as dubious as ever. I point out that Wilimovsky, Fehl- man and Horvath during the Cruise of the Red took numerous bottom samples between Barter Island and Barrow, presumably getting good representation of what was there. They missed entirely kelp beds in the Beaufort Sea studied more recently. And early this year off Huntington Beach in southern California T/v Pacific Trader got snagged because the nautical chart used (which may have been accurate earlier) did not indicate correct depth -- this in an area of intense activity. The fact is that Chukchi Sea studies are preliminary through- out. It is instructive to note in the current issue of The Journal of the Marine Biological Association of the United Kingdom, Vol. 70, No. 3, August 1990 in that part of the world Continuous OO el ee ee Plankton Recorder studies have been going on since 1931 and Plymouth "serial observations" since 1899 and charts much more precise than those for any part of Alaska have been available for decades. The charts did not prevent the skipper of the Torrey Canyon from taking a disruptive shortcut through the Scilly Islands (considerable knowledge of currents did not tell local scientists just where spilled oil would go or what would be hurt most; significant amounts did reach areas under long study by Plymouth M.B.A., U.K. biologists) nor the Amoco Cadiz from wrecking on a Brittany reef (its spill smothering the study area of the Roscoff laboratory). The work done over nearly a century at th venerable stations did make it possible to make meaningful calcu- lations of biological changes. [My Oberlin mentor, Prof. Hope Hib- bard, had worked at the Roscoff station and used Roscoff examples in some of her lectures and I spent a sabbatical year at the Ply- mouth Laboratory, so I have long followed the work of Mollie Spooner and Alan Southward.] In contrast with the areas about southwest Britain and the north coast of Brittany - or even with the Santa Barbara Channel area of the Platform A blowout, data, physical and biological, from the Chukchi Seaw¢ negligible. There could be a wipeout even greater than that by Amoco Cadiz devastating all of the lower organisms of the local food webs and the agencies concerned would be able to muster only miniscule evidence in court to prove that it was this event that resulted in subsequent losses. It is safe to predict that for every expert ("expert") Alaska or an environmental group mustered to testify that the spill had been the cause, industry would have a counter-"expert" to testify that there was no direct link, and with the current data base, the counter-"experts" could not be disproved. Dealing with them is tough enough in well-studied zones. [Consider tobacco industry scientists holding that cigarette smoking has not been proved to be harmful and a National Academy of Sciences panel insisting that it has not been proved that cotton linters in the mills caused textile workers brown lung di: fe and current insist- ence of Electric power industry "scientis el acid rain has not been proved to damage sorastes There is need to know in considrable detain at all places that may be exposed to changes by the industry what kinds and how many of the kinds of organisms besides the warm- blooded vertebrates are present during full population cycles. The Chukchi:Arctic is still overwhelmingly a we-don't-know area. For those involved with the manipulations of facts and figures in the DEIS 126, it would be useful to ponder John Allen Paulos" recent book, Innumeracy. o Study of Robert J. Meyers & Associates and Research Planning Institute, Inc. 1989 Oil Spill Response Guide derived from Arctic Oil Spill Response Guide for the Alaskan Beaufort Sea 1988 prepared for the U. S. Coast Guard Research and Development Cen- ter (but, strange to say, copyrighted) made some points clearer than the kindred portions of DEIS 126. Significantly, neither the federal government nor the publisher acceptyany liability for its use. I have not time to go into the detail that is desirable, but focus on a few matters. There is great detail about the booms and skimmers that might be available - how much they can handle, etc. Two things are reasonably clear (as they are also for kindred cov- erage in DEIS 126): 1) on the basis of abundant experience in gentler latitudes it is extremely unlikely that a considerable response fleet could or would get to a Sale 126 area spill/blowout and 2) even with American Trader off southern California, with 22 skimmers reported to be in action in calm waters, oil recovery was minor. To suggest, especially after the Exxon Valdez debacle, that there would be a response providing tidiness is absurd. The report contains such sentences as "However, with respect to the Beaufort Sea, this is much easier said than done". One may JLM correctly replace Beaufort with Chukchi in this and many other sen- 1 tences of the report. One such, by an EPA staffer at the 1983 Anchorage Dispersant Symposium, refers to the use of dispersants: "there are too many unknowns about the fates and affects (sic) of dispersed oil in the Beaufort Sea". I question the Report's gen- eral acceptance of the spill trajectory model: too little micro- scale current data over much too short a time is available for either Beaufort or Chukchi Sea to make these concoctions even prob- ably helpful guesstimates. Seven spill response scenarios are interesting, but where they are optimistic (there are some negatives), they are not -onvincing. Why, for example, should we think that recovery by skimmer would be effective in water er than 7 feet when skimming has had such limited success in Californian waters? A couple of interesting sections are that on modes of transport- ation (airports that could be used for a Chukchi Sea response are limited in number and length of runways and other capacities) and on dispersants (29 kinds are identified, but there were only Corexit 9527 -400+ drums- and ARCo D-609 -10 drums- in all of Alaska; there is quite a bit of information on toxicities of various disper- sants, including Corexit 9527, but none for ARCo D-609, and it is JLM toxicity for a crustacean, Mysidopsis bahia, with nothing about harmfulness for human beings. And nothing about flammability. 2 These are very real matters as made clear by the William Mason case to whicgh I have referred in the earlier Comments.) It also should be recalled that Jack Anderson, long special- izing in such work, has raised objections to using JLM Mysidopsis bahia, a warm-water species, to predict effects in cold- 2 water zones. The Oil Spill Response Guide obviously provides more to chew on in these matters than does DEIS 126. SCOPE: AVOIDANCE A primary concern with the 0. C. S. environmental impact docu- ments, and not just those of the Alaskan region, is that they neglect altogether issues after the exploratory drilling. This was true in 1980 with the Lake Buena Vista Symposium, in 1988 with the Calgary Conference and in between with the largely industry-produced National Academy of Sciences/National Research Council 1983 Drilling Discharges in the Marine Environment and lots more, (even though a public release of your agency in December, 1983 stated, obviously inaccurately, that Drilling Discharges showed that later stages of 0. C. S. oil field development had been shown to have little adverse environmental effect). Information on the exploratory phase is muddy in more senses than one, it is seriously incomplete (cf. the effects of withhold- ing proprietary information), and it has been used uncritically, but there is some useful data to work with. During the 1984 Santa Barbara EPA workshop, a former Gulf of JLM Mexico platform worker spoke of burns from a metallic salt being used. Maurice Jones, earlier of IMCO Division, dismissed this because it 3 was part of the completion process. J. A. Short's 1983 book, Drilling, mentions in Chapter 10: Completions, p. 498 for wellbore cleanup “an acid wash using hydrochloric acid with a small amount of hydrofluoric acid". P. 495 reports that in stimulation by acidization, "The size of the acid jobs ranges from 1000-100,0@gal." (Interestingly, hydrofluoric acid is not mentioned here and it is not listed at all in the index; it is in a University of Texas primer that I found about the use of hydroflouric (sic) acid for siliceous blockages and there the amounts are given as a few to thousands of gallons; HF is listed in API working literature). The concern here is that none of our steward agencies have in- formed affected or affectable sections of the public. This is parti- cularly interesting in Los Angeles County because attention had been focused for some time on the Mobil Torrance refinery and several others in the area that use hydrogen fluoride in their processing. No one has pretended that hydrogen fluoride/hydrofluoric acid is not a killer Why have the agencies involved in the preparation of DEIS 126 ignored the hazards in the completion phase and in stimulation by acidization generally? It would seem to be, at least potentially, criminal neglect as many lives could be lost if outlets of HCL and HF tanks were accidently or deliberately opened or a pilot from the associated airfield took off with an unbalanced load or an empty fuel tank and crashed into an acid tank. At whatever phase -exploration, development, production or transportation of the petroleum- there are compounds released that the DEISs continue to ignore though concern has been espressed formally. There is the problem of barium halides in barites. That they JLM are highly poisonous is indicated in Registry of Toxic Effects of 5 Chemical Substances. There are biocides (cf. acrolein mentioned in the Buccaneer Field Report} there are assorted components of drilling slurries that are simply talked around. NAC/NRC Drilling Discharges indicates that biocides are minimally bothersome, mention- ing among them carbonates (carbamates are used) and none of the ste- ward agencies picks it up, even after that has been pointed out. Drilling Discharges (p. 102) quotes amounts of metals in slurries as lower than in the papers it claims to use - steward agencies, including yours, have been informed of this, but they continue to use Drilling Discharges as authoritative. Drilling Discharges identifies Eunephthya, the common soft coral of the Chukchi and Beaufort Seas,as a plant. That also apparently does not suggest to Anchorage preparers (EPA and MMS) that such work is of questionable worth for an impact document. It must be concluded, therefore, that worked based on such, namely DEIS 126 and predecessors, is not trustworthy. More than that, because these have been pointed out in previous comments, one must question whether the preparers are honest. IN COMMENTS INCLUDED BY REFERNCE I dealt at some length with prob- lems of discharged formation derivatives ("waters"). The Brian Middleditch edited Buccaneer Oil Field Report, Marine Science 14 is the only substantial source I have found. It has evidences in most of its sections of being a first effort and some of the work is not even passable technology, but it does point up a number of seri- ous problems, among them release of large quantities of particulate sulfur, presence of a large number of aromatic compounds, including some primary pollutants (resulting, among other things, in the JLM presence of bewxo-alpha-pyrene in every bottom sample examined), 4 modified microbial communities, and so on. The editor's observation, "It was fully realized at the outset that the findings of such a study might not be legitimately applied by extrapolation to other fields,..,", should be appreciated. At the recent MMS Information Transfer Meeting in Santa Barbara, Dr, Russell T, Schmitt, Coastal Research Center, Marine Science Institute, University of California, Santa Barbara, reported that work is under way there on formation discharges in nearshore waters. Results are not ready for publication. As Middleditch says, results may not be legitimately applied to Chukchi Sea, but the indications are that careful, well-conceived studies on formation derivatives and their effects need to be made in the area - and in other Alaskan fields - and results of those studies need to be released for examination by the interested pub- lic before any further leases are offered for sale. THE WILLIAM MASON CASE As stated in previous comments, during the Pacbaroness sinking and spill off Santa Barbara, California, Mr. Mason, a response-boat first mate, was heavily sprayed with dispersant Corexit 9527 by a dispersant-spraying airplane. It turns out that the response crew had been instructed neither about poisonous- ness of the dispersant and what one should do if one were exposed by accident nor about its flammability and the need for special care in storage and application. Mr, Mason has not learned the full composition of Corexit~9527, but was informed that it contains 2-butoxy ethanol which is poisonous. That it is poisonous was con- firmed by a specialist's examination of Mr, Mason at the Medical School Hospital of the University of California at Los Angeles. Among the serious effects is marked depression of his immune system. The response-boat company at last report had not accepted any responsibility for Mr. Mason's medical expenses and does not pay wages. Clean Seas, Inc., the clean-up consortium formed by the offshore petroleum industry companies, which uses the response- boat under sub-contract and which ordered dispersant spraying by the airplane crew, has not accepted responsibility. The oil companies that fund Clean Seas, Inc, have not accepted responsi- bility. An analysis of the environmental potentialities of Corexit 9527 and of any other dispersant which may be considered for use in the area should be made and published for examination and comment before any further leases are offered for sale. RESPONSIBLE BEHAVIOR Corporate behavior in the William Mason case may be an import- ant indicator. It should be noted also that Royal Dutch Shell has decided to rent tankers rather than use its own in United States’ waters in order to avoid responsibility under U. S. law for any spills. Shell tankers in Chukchi waters are not an issue, but industry evasion of responsibility in these cases indicates a problem that MMS needs to analyse before proceeding with fur- ther leases. JLM JLM JLM 10 ADEQUATE MANPOWER Lack of time prevents more thorough examination of DEIS 126, however, one particular concern needs strong emphasis, At the 1984 Denver EPA Workshop, officials from the Gulf of Mexico regions presented, almost desperately one singte request: "Give us rules we can live up to; there are more than 2000 wells under our jurisdiction; we are few and our energies are limited!" In the Exxon Valdez mess, it is obvious, part of the cause was U. S, Coast Guard understaffing. With the recent sequence of Alaskan 0. C. S, environmental impact statements it is similarly obvious that too much work was required (and much could not get done) for both the EPA and the MMS regional groups. Washington Post writers in an unrelated matter stated that the normal bureau dictum is the dualistic "Cover your ass and don't rock the boat", The necessary one here, to the contrary, is a frank statement to the Administration, to the Congress and to the public, doing a job theffulfills the requirements of the law will take greater resources especially human, MMS AND EXXON VALDEZ As to the DEIS section on MMS and the Exxon Valdez events, it is conceded that the spill was not your fault. The point for the DEIS is that Exxon Valdez appears not to have changed your use of statistics. In addition to checking Paulos’ Innumeracy, you may want to consider how readers of Darrell Huff's How to L:8 with Statistics and Stuart Chase's Tyranny of Words will regard your applications. And a final quote (from Yen, 1986), "Thus the potential target for enhanced oil recovery is greater than the reserves that can be produced by conventional methods." Submitted ro pil Ph. D, Mr. J, L. Mohr Response JLM-1 Improvements in oil-spill response over the last decade have produced refinements to older techniques rather than development of new techniques. Thus, the effectiveness of response--in terms of percentage recovery-- has not increased from the 1979 Ixtoc I spill to the 1989 Exxon Valdez spill. Short response-time planning (6-12 hours and 48 hours for additional equipment) is required for drilling operations on the Alaska OCS. Spill-trajectory considerations in the EIS (see Sec. IV.A.2(c)(3)) are on the mesoscale. On the microscale (<10 km), the commenter’s suggestions are most appropriate and accurate. Skimmer recovery is not generally affected by water depth; the critical parameters are wave height and oil viscosity. Response JLM-2 In SWEPI’s 1990 oil-spill-contingency plan the following information on airports is presented: (1) Nome, 6,000-foot asphalt runway; (2) Kotzebue, 5,900-foot asphalt runway; (3) Kivalina, 3,000-foot gravel airstrip; (4) Point Hope, unattended 4,000-foot asphalt runway; (5) Cape Lisburne, military airstrip closed to the public , 24-hour advance permission; (6) Cape Beaufort, unattended 2,800-foot gravel runway at Cape Sabine; (7) Point Lay, 3,500-foot gravel strip with operations only on Tuesday and Friday; (8) Wainwright, unattended 4,700-foot gravel airstrip; (9) Barrow, 6,500-foot asphalt runway; and (10) Deadhorse, 6,500-foot asphalt runway. This was accepted by the MMS as adequate for conducting oil-spill-response measures. Section IV.A.2(e)(5) and Appendix L have been modified to include dispersant toxicity. R ni M- Hydrofluoric and hydrochloric acids are used only for specific reservoir acidification requirements, and large quantities are not stored on a production platform. Furthermore, it may not be economical to produce petroleum from a reservoir requiring large quantities of either acid. The EPA NPDES permits now prohibit the use of metal-contaminated barite. Barium ions are detoxified in seawater by the immediate precipitation of highly insoluble barium sulfate. If barium halides were exceedingly poisonous, as claimed by the commenter, they would not be used internally as a cardiac stimulant or bone-scanning agent in humans or for treatment of constipation in horses (Windholz et al., 1976). Response JLM-4 Alaska-specific information on formation waters is provided in Section IV.C.2. Neither the Middleditch volume nor the Santa Barbara study are cited in the discussion on the effects of formation waters on water quality. See also Response NAEC-7. Response JLM-5 Similar reports of observers rather than the slick being dosed with dispersant were made on the Exxon Valdez spill; however, no significant dispersant injuries were reported. Obviously, getting the dispersant onto the slick can be a problem. In terms of human safety, dispersant application is probably safer than mechanical recovery in many situations. One death did occur during nondispersant response to the Exxon Valdez spill. Dispersant application rather than mechanical response is considered the safer option from mid-September through April in Prince William Sound and other areas affected by the Exxon Valdez spill. Community right-to-know and worker right-to-know laws apply for oil spills. Chapter 3, Toxicological Testing of Dispersant and Dispersed Oil, and Chapter 4, Intermediate-Scale experiments and Field Studies of Dispersant Applied to Oil Spills in Using Oil Spill Dispersant on the Sea, have been referenced and included in the discussion on dispersant. JLM-1 Response JLM-6 The Oil Pollution Act of 1990 has strengthened oil-spill liability regulations for transportation of oil. Special regulations for Prince William Sound are included in this legislation. In addition, the formation of the Marine Spill Response Corporation indicates a stronger industry approach towards prevention of oil spills and response to oil spills. JLM-2 FR 31 We 1990 WEE Counce annT HOS Kar, TtouGd ORR TIBLE AS THEO ALC HRCMG OCS Swe ee (dean dom THE Byes CR HE BEHA RE, 13 OBSELUABLE RIGHT Ne Ober ELS. Fon kuneuk 7% kenbicsy gl THe ON, Stone, We st (s P~OeTIED — 4 Yetatet Glee) Pel ( Gib | Paieb To stone At me weuenG Fo BO ge ee 8 PY WALEN LOWkOUTS AEE Oia EEO ae FOR. i COMME _ TROT = -REEEVEIHAS § LE OVA NOTES - WE Ckedrle GhruD CF witrecELS fps Betone he oe OOo semen, wa, ue acs Libwy geal Annee. Ieee, 1 awe Bib TSE OF tHE mms W a AE isa pes ) Fl YoneS, LEG, oe GlwG bang Pours 0 TE Caveat] Ah WE Some Peesmupty eB) FESPA. Js sda Bo ONS femme WE Epo Yrose SL, |SS a ) Taayr mE SsellneT Ceppgests US, C7 t ae n a rope SUE fo WE bid tne stb yR t Lens wo tio Oley CPG At ERE, (i) CHILGT — agpecge BL tye Wrus Sass By Wee A yer. — Rite CFL THE FFI, sae oe Cues joe 6s @ We putcr Fasesy js MoT Veeeh TAL, ToD [Py 2 oF = ac an WO (5 bo BASED. (| Styalor, ToT Foe la lPd OS ADbf655EO : A, 4 PuaxiCoe ss D aher wie J her pe (we dee), pe = Kueh 0 cam a) 3 A. LOG Lange ft fotos Aeon. MomesT BE COTAIOT fs “AL — He YOU Lhe BF LOC THe lou ewe, we el Plebjor A Deerbtties aX aA S65 te =Diprery WW Tums avd Bias Tre Wine = BOSE aT GUE PE OEE @ we . LEAS, AD ObeUP HON, MT S&C -/oL OCLOT Te ba Pome, i 3. Steer Bunge (amebire Aes 4 aee4 ner, NE: MEI GouT , Saeco ® saris wer muppet, mister Us THtegd BF AO CPG TT WW THese D5? HETIL ss BT AT pone = Y HAPRES AND ABST -ASE - Toto _ ss Lets AnD Celeeenes, A Ate Spit wioub 2 Impeoerié — scawmo, CONE WIRE. Type Fate 5 Clog UP mote brome AMeLows , mtybe rhs Ai pv GN Stans, Tne Mov -ecien oF Keds We bins waaertios, al Ges Samy ad CULLENT Atiae 4 Eye AteiDar, 0 AbeB Som, BeFa 84g GD HE Corny, we KEL EWikW ea MiieT Bree @ cr LD (wees sees ) _ Is: Dost beet, Dow Ease, Dont SEtt 1 our, Mr. Scott Sunans (? Respon: - The Exxon Valdez oil spill was certainly an unfortunate incident, but a single incident such as this is insufficient to halt the continued national search for future oil and gas reserves. Although the timing may also have been unfortunate, the United States has a legal obligation to the successful bidders on Chukchi Sea Sale 109 blocks to allow them to carry out exploratory drilling under the conditions set forth in the leases and Federal law. Response SS-2 The Sale 126 Chukchi Sea area is shallow, ranging from 6 to 80 m deep. By oil industry-drilling standards these depths are not considered deep. The MMS requires the lessee to include provisions for drilling a relief well in the event of a blowout. The Alaska OCS Region requires that lessees obtain commitment from another rig in the area of operations for the purpose of drilling a relief well. If there are no other rigs operating in the area, the lessee is required to monitor rig availability worldwide and continually update the Alaska OCS Region as to the status of relief-well-rig availability. In 1990, SWEPI indicated that a relief-well tig was available onsite with an additional relief-well rig available in Canada. Surface circulation patterns in the Chukchi Sea generally move north. The Bering Strait provides the only avenue of exchange between the Pacific and Arctic Oceans. The mean flow to the north appears driven by a sea-surface slope downward toward the north of the order of 10° (Coachman and Aagaard, 1966). There is, however, evidence of atmospherically forced major variability in the flow, including reversals to southward transport (Aagaard, Roach, and Schumacher, 1985). The OSRA sampled the variability and did not indicate a risk to environmental resources south of the Bering Strait. Response SS-3 The EIS attempts to present a balanced portrayal of potential environmental effects and is not intended to present a biased reporting of such effects. Given that the search for truth and knowledge represents an ongoing learning process, additional facts collected through scientific research and monitoring studies may suggest different possible effects that in turn can be factored into subsequent developmental EIS’s should commercially marketable quantities of oil be found and intended for marketing. The MMS does not fund other groups to prepare what might be called "counter-EIS’s" to bring to light what the commenter seeks in the search for truth and avoidance of bias. The EIS is not a justification document. It is as objectively unbiased as an analytical document can be with the type and quantity of information available. The DOI is charged by regulation not to use the EIS to justify the proposal. The decision to lease is not made in or by this EIS. The decision, if made, is made by the Secretary of the Interior only after the environmental effects found in the document are considered and other national-interest and economic information is evaluated. Response SS-4 The cumulative case in this EIS (Sec. IV.H) attempts to portray the implications of the proposed lease sale beyond the confines of the sale area. Response SS-5 Major accidents are unfortunate and MMS tries to avoid negative effects from oil and gas operations through enforcing regulations and monitoring operations. Statistics are used in the EIS as a means of predicting possible effects-causing agents. These statistics serve as a basis for analysts to assess the possible effects on the resource under study. SS-1 C. Public Hearing Comments and Responses The Sale 126 DEIS public hearings were held in the following Alaskan communities during the month of August 1990: August 27 in Barrow, August 28 in Wainwright, August 29 in Point Lay, and August 31 in Anchorage. For the hearings in Barrow, Wainwright, and Point Lay, MMS arranged for the services of a professional translator from the NSB Inupiat History, Culture, and Language Commission to translate testimony given in Inupiaq for the hearing record. Transcripts of the oral testimony are not reproduced in the FEIS because of the volume of material involved. Instead, summaries of significant issues from each speaker’s testimony are presented here and marked for response. A copy of the complete transcript of each of the hearings is available at the Alaska OCS Region, Public Information Library, in Anchorage. A copy of the hearing transcript was also mailed to the mayor in each of the NSB communities in which the hearings were held. During these hearings, many residents of the NSB expressed concerns about how their culture, lifestyle, and subsistence resources and activities might be affected by oil and gas development in the Chukchi Sea. The MMS is making a strong effort to ensure that the government and industry are aware of the importance of the subsistence lifestyle to the Inupiat. The testimony given at the Sale 126 DEIS public hearings will help in understanding the importance of culture, lifestyle, and subsistence resources to the people living along the coast of the Chukchi Sea. Speakers at the public hearings are listed below in the order of their appearance. 1. Barrow Public Hearing Forrest Olemann Don Long, Sr. Tom Albert Eugene Brower Tom Lohman Warren Matumeak Alfred Leavitt Walter Akpik, Sr. Arnold Brower, Jr. Raymond Neakok, Sr. James Neakok Johnny Brower Beverly Hugo Morgan Solomon Joash Tukle Patricia Brower 2. Wainwright Public Hearing No one presented public testimony for the record. 3. Point Lay Public Hearing Geoff Carroll Marie Adams Robert Suydan 4. Anchorage Public Hearing Robert Haines Stu Hirsch Dorothy Smith vV-4 B , . 2. 1990: Forrest Olemann, NSB: Oil clean-up demonstrations by industry have not convinced me that they can cleanup an vilspill under real arctic conditions. Don Long, Sr, Mavor, City of Barrow: The No Sale or Delay the Sale alternatives are endorsed ia order to allow time for communities to develop contingency plans and gain the means to carry them out. These plans would include expanded EMS PH facilities, airports, and VPSO forces, as well as the ability to handle the influx of workers as happened in 1 Valdez. This aspect should be added to the EIS. Tom Albert, NSB: Analysis of the effects on whales not a fair representation of the references used to justify the conclusions PH reached. Work of Dr. Gerasi misinterpreted--a misrepresentation of the data in Dr. Gerasi’s work in order to support minimal effects on whales. 2 ilspill cleanup in arctic conditions has not been demonstrated by industry, even when they had the chance to do so in winter spills in Cook Inlet. Enea Barmow Whaling Captai — The BWCA consists of 4 active whaling captains, along with roughly 400-plus whaling crew members. In Barrow, the spring whaling seasoa lasts from around mid-April to the first or second week in June, depending on ice conditions. The fall season starts about the end of August and gencrally extends through October. Sensible development should be based om proven cleanup capabilities. Oil developmeat should proceed onshore before it extends offshore. Tom Lohman, NSB: In review of Chukchi Sea contingency plans, the following should be considered: © There should be time available to stop and drill a relief well in a late-season spill. How is this PH possible without a seasonal drilling restriction? Ss © There must be the ability to track a winter spill. The DEIS does not address ways of tracking oil | PH multi-year under the ice. The movement of secund-yeur ice should be understood as to its distribution over 4 time. © There must be the ability to mitigate noise effects. | ' ke Warren Matumeak, NSB: Industry may clean up a spill but they do nvt replace the lost animals. Can Responder operate in 25-30 knot winds? That's the vessel stutioned out there now and we don't think ic | PH is capable of cleaning up oil in these conditions, which are common for the area. 6 Alffed Leavin: Sea mammals come north with their young. Whales may deviate [rom their historical route with development. Do not say one thing and do the other, The animals know when this happens and things are ‘not in harmony. This hurts our subsistence. Walter Akpik, Sr: Oil has been good for me and for everyone in Barrow. But I fear for the sea mammals. But we need vil and gas for subsistence to run our machines. I fear for the time the oil is depleted. Amold Brower, Jr: The deception in the whale analysis must be corrected. a Icebergs can be grounded even in the depths of the Chukchi. Cilspill cleanup should be localized. Local villages should have cleanup equipment in warehouses and PH training to use such equipment. MMS should fund this through set asides from leusc sales as well as local impacting effects. PL 93-636 (Indian Self-dctermination Act) should be used to contract for this. 8 We need to develop a positive program to replenish the lost subsistence resources. R Si Pras { the Council, Native Village of B iat Traditions Government: Money is owed to us by the federal government und we have not received anything. We exist oa bingo receipts. James Neakok: Who is going to clean it (an oilspill)? You guys? Think about it, Johnoy Brower: What would be the effects of injecting chemicals into wells, as in Prudhoe Bay? —] PH 9 Anxiety, hatred, and frustration produces long-term sickness among the people. Beverly Hugo: We are not expendable--we have the right to cultural privacy--young people are so impacted that they are not rooted--stay out of the Arctic Occan--what goes on touches our lives. Morgan Solomon: Cleanup; what are you going to do? ee PH — 10 Oil Ucilling should stop in spring and fall whale migrativas—bowhead whales are easily disturbed by nuise and | PH may take a different migratioa path. 1 You nced a food-chain analysis for food supplies and chains for fish and mammals. The local water table is getting very low due to oil being pumped out of the ground. There should be an agreement worked out in advance among ADF&G, FWS, and others so that if there is a PH major oil spill or blowout there would be ao restrictions on subsistence hunting so that local residents can 12 m: in their subsistence livelihood. This would allow land animals and fowl to replace sea mammals and fishes and should be in effect until all areas area cleaned up and the mammals and fishes return. Patricia Brower: PH You need to study the effects on subsistence foods if there were an oil spill. 13 Wainws i i 2 No one wished to testify in Wainwright. Pog int Lay publ ic hearing, August 29, 1990: Geoff Carroll, ADF&G: Boat and other traffic has diverted belukha whales out of Kotzebue Sound and this could happen in Point PH Lay. Contact Kathy Frost for ADF&G harvest data. 14 Marie Adams: Need strong local input for oilspill research program. Use local radio stations as means of distributing information locally rather than through formal conferences. Impacted communities should get impact funds from the Federal government directly rather than through the state. The Federal govenment should review its energy policies and develop for oil where there is the lesser change of impacts--and that is onshore. The International Whaling Commission is now considering the human activities that impact bowhead whales, | PH and {am afraid that increased OCS development offshore could reduce our quotas fur bowhead whales, 15 4 Robert Suydan, NSB: Belukha whales are quite sensitive to noise. The area has the largest congregation of spotted seals in the world. These can be eilected by noise and PH industrial activity, especially aircraft noise. 16 ider the possibility that the entire population of North Slope ciders could molt at sea off Point Lay and PH be effected by an oilspill. ie W, i lo i o Mobil supports the continuation of lease sales in accordance with the 5-year OCS oil and gas lease sale schedule, Mobil supports Alternative | and feels this alternative is supported by the DEIS. Alaska Oi Gas A: ii 1G. AQGA supports the lease sale as part of the OCS 5-year leasing program and supports Alternative I of Sale 126. Failure to proceed on schedule with the evaluation of the hydrocarbon potential of the Chukchi Sea area would be a mistake which could aot be reasonably justified or rectified. Industry has spent years of effort and millions of dollars on the development of Arctic technology to explore and develop this area in an environmentally sale and sound manner. D , ; : Greenpeace USA supports the No Action Alternative II for Chukchi Sea Lease Sale 126. It is the position of Greenpeace that further proposed leasing in the Arctic planning areas is being carried out hastily without deserved consideration of the effect accelerated exploration and development will have on wildlife, habitat, and Native cultural values and without a critical eye toward the energy future of the United States. The DEIS states that the first Chukchi Sea sale was scheduled in 1985 but was deleted from the 5-year PH schedule to provide for further assessment of operations in heavy ice conditions. The DEIS does not explain what new information is available now regarding operations in heavy ice conditions. . 18 The DEIS asserts that because of the low density of species in the Arctic, any damage will only affect a small area of habitat and small number of animals. Such sweeping assumptions are used to support conclusions of low effects. For example, the DEIS states that an vil spill could result in high mortality of sea birds, but the | PH impact will be low because of the ability of sea birds to recover. This conclusion is erroneous and appears to 19 be an excuse rather than an acceptable measurement of impact. It is aot acceptable for MMS to conclude that because the action is not likely to cause the demise of whole species that the impact on the species will be insignificant. The low density of Arctic animal and plant life, and their slow rate of recovery, makes the species extremely vulnerable and the impacts longer lasting than those in some temperate regions. The DEIS does not adequately portray the complexity and delicate nature of the Arctic environment. tm the | pyy discussion of the short Arctic food chain, the DEIS does not describe the extreme vulnerability of the benthic, eponic, and higher trophic species (o industrial intrusion. The DELS states that Arctic species are 20 subject to extremes in temperature and light, but the document fails to explain how the slightest interruption in that dynamic process has the potential to cause severe damage. A report by the NMES states that even 4 short-term losses of food source due to spilled oil could affect food availability for an entire season causing PH significant decline in marine mammal populations. The NMFS also states that the tolerance threshold of 20 marine mammals to industrial intrusioa is unknown. The DEIS estimates that several spills greater than 1,000 barrels will occur in the proposed lease sale area. PH This is a conservative assessment and does not present the worst case scenario of an uncontrolled blow-out. 2 1 The impact of a catastrophic event should not be disregarded because of the statistical manipulation that predicts it should not happen. The oil spill response described in the DEIS is grossly inadequate. MMS requires that industry respond to a major spill within six to twelve hours, quote, “geography permitting.” This qualifier is admission that PH response is not expected to be possible under common conditions in the Arctic. Regardless of the presence 22 of a response barge with mechanical clean-up or containment equipment on board, current technology will not be effective under common conditions. Oil spill response demoastratioas discussed in the DEIS are also not reliable preparation for clean-up. The current Middle East situation is a signal for the U.S. to establish an aggressive energy conservation PH program which would replace foreign imports and OCS oil and yas many times over. It is unconscionable that the federal government, via the Minerals Management Service, would permit putting the entire Alaskan 235 Arctic coast at risk through more development before exploiting renewable energy resources available to us at a fraction of the cost to society and to the great benefit of the environment. Summarized by George Allen, Sale 126 EIS coordinator October 2, 1990 Public H R nse PH- The subject of community contingency planning has been added to the discussion in Section IV.F, Alternative III, Delay the Sale. R PH- The analysis on the effects of industrial noise and crude oil on whales was taken directly from the statements and conclusions of the most authoritative studies available. The work of all investigators was presented in terms of the likely effect of these agents on whales. Response PH-, For the Alaska OCS Region, MMS requires lessees to submit, with an exploration plan, their contingency plans for drilling a relief well should a blowout occur. This includes information on the availability of backup equipment, including a relief-well rig and support craft (including icebreakers, when appropriate) and the timing to obtain, initiate, and complete a relief well. The lessee is required to provide the MMS with updated information on the location and availability of drilling rigs capable of operating in the environment where operations are proposed prior to each drilling season and of any changes during the drilling program. The MMS requires mutual assistance/relief-well-drilling-rig agreements between the two operators conducting concurrent operations in the same area to facilitate and expedite relief-well drilling. The adequacy of the relief-well plan is determined based on individual circumstances including the type and location of proposed activities, the type of drilling unit, other operations in the area, and company plans for monitoring environmental conditions and well status and curtailing operations and securing the well prior to the end of the drilling season. In the Chukchi Sea, floating drilling units will be used for exploratory drilling. Floating drilling units are capable of moving offsite in the event of a blowout and starting a relief well almost immediately. There are currently four drilling units and associated icebreakers and ice-class support vessels that have been successfully used in the U.S. and Canadian Arctic, and which are available in the Arctic and can be mobilized to support a relief-well-drilling program in the Chukchi Sea. The likelihood of an oil blowout occurring during exploration drilling is extremely low. There has never been an oil spill resulting from an OCS exploratory-well blowout. Blowouts typically are a result of shallow gas without any oil that lasts for short periods of time. Bridging (including depletion) of blowouts (oil and gas) occurs greater than 70 percent of the time, with bridging occurring shortly after the blowout. Relief-well drilling has been attempted for approximately 4 percent of those blowouts that did not naturally bridge (Norwegian Oil Review, 1985). Prevention is the key to mitigating the risk of an oil spill resulting from a blowout. MMS regulations establish strict requirements in the form of performance standards to ensure that operations will not result in an unsafe condition. Plans, equipment, equipment inspection and maintenance, testing, and training requirements all contribute to the low risk of a blowout on the OCS. Recent technological advances and continuing high levels of research are improving the safety of drilling in the Arctic, thus reducing the already negligible potential for a blowout. The MMS maintains a near-continuous inspection presence at each exploratory-drilling location and monitors the progress and status of the well and environmental conditions on a daily basis, including well depth, type of operation (drilling, coring, logging), next planned operation, the timing for completing current operations, the next planned operation, downhole conditions, and potential problems in maintaining well control. The MMS has the authority to require that operations be suspended in the event that ongoing operations could PH-1 increase the risk of well-control problems or, continuing with the next operations following completion of ongoing operations such as drilling to the next casing point following setting and cementing casing, could not be completed before the end of the drilling season. The costs associated with drilling an exploratory well in the Chukchi Sea are high. Same-season relief-well capability significantly affects an already restrictive and short drilling season in the Sale 126 area, which could require a second season to complete the drilling of a single well or maintain a second drilling unit at the site. The costs associated with such a requirement would be substantial and would not significantly increase safety or reduce risk. The MMS recognizes the importance of relief-well planning for exploratory-drilling activities in frontier areas such as the Chukchi Sea. The MMS believes that regulatory requirements for documenting relief-well capabilities in conjunction with MMS’s inspections and monitoring of well status and environmental conditions on a real-time continuous basis for each site-specific activity, and authority to require operations be suspended, provide an effective and prudent mechanism to ensure that drilling activities are not continued if there is a significant risk of lost well control and remedial action, including drilling a relief well could not be conducted. Response PH-4 The text in Section IV.A and Appendix L has been amended to address this concern. During the Alaska Arctic Offshore Oil-Spill Response Technology Workshop held in Anchorage, Alaska, on November 29 through December 1, 1988, the mechanical containment panel identified tracking oil spills as a subject area requiring further attention. In the same workshop proceedings the Arctic and Marine Oilspill Program (AMOP) and the Alaskan Clean Seas (ACS) Research and Development Program identified current research in tracking spills in ice. Acoustic studies have produced prototype hardware that has performed well in field tests for detecting oil encapsulated in ice. The ACS, AMOP, and MMS are working on induced florescence for detecting oil under ice. Currently for exploration drilling the MMS OCS Oil-Spill Task Force has accepted the ACS oil-spill-trajectory model, Orion tracking buoys, and ice marking dye as sufficient for tracking oil spills in the Chukchi Sea. Response PH-5 All authoritative studies to date have shown that industrial noise has only a minor, short-term effect on whales. Stipulation No. 5 and ITL No’s. 1 and 6 were evaluated to mitigate the minor, short-term responses of whales that encounter industrial noise. As indicated in the EIS, the number of whales actually encountering industrial noise is expected to be relatively low for bowhead whales and zero to low for gray whales. Response PH-6 The Responder is a 400-by-105-foot response barge with a 5,000 HP tug that is used to store oil-spill response equipment onsite at SWEPI’s exploration sites. Section IV.A.2 and Appendix L address environmental conditions in the Chukchi Sea which may preclude response to an oil spill. The Responder was used in two oil-spill-response drills, one in 1989 and one in 1990. Each spill drill was conducted in seas of a few feet. Response PH-7 See Response PH-2. PH-2 R PH- The MMS agrees that local cleanup efforts and response capabilities are as important as the more centralized capabilities provided by such organizations as the USCG Pacific Strike Team and the oil industry/transportation cleanup group, Clean Seas. The U.S. Congress has recently been considering legislation to direct impact-assistance funds to the local communities that could be directly affected by offshore OCS operations. At this time the exact outcome of such legislation is unclear as is the method by which funds might be directed to local communities. R PH-' The injection of chemicals into the well is regulated by MMS in the APD and the EPA through an NPDES general permit. Test fluids are discharged from the well upon completion of drilling. These may consist of formation water, oil, natural gas, formation sand, any acids or chemicals added downhole or any combination thereof. Test fluids are generally stored and treated for oil removal and pH before being discharged or flared. The permit will require neutralization (pH 6.5 to 8.5) of all spent acidic fluids before discharge. Response PH-10 The potential effects of major adverse factors on food chains, as well as possible accumulation of toxic materials, were considered in the analysis; specifically, potential effects on lower-trophic level organisms, including those in food chains, and the potentially toxic effects of drilling discharges, are discussed in Section IV.C.3. Inclusion of all information used in the determination of the potential effect of each factor on each species would result in an excessively large EIS in which it would be difficult to find the essential information. Response PH-11 All authoritative studies to date have shown that industrial noise has only a minor, short-term effect on some whales and no effect on others. Hence, whales are not easily disturbed by industrial noise. Further, indications are that it is the type of noise, and the animal’s aversion to that noise, that determines a whale’s response, rather than only the quantity of noise involved. This has been most clearly demonstrated in cases where marine mammals learn to associate a particular noise, or combination of noises, with a threatening situation (e.g., when they are hunted). Response PH-12 The MMS has no authority over the subsistence use of fish and wildlife resources in Alaska. However, the idea presented--substitution of terrestrial-subsistence resources for marine resources during the period of recovery from an oil-spill event--has merit. The commenter might wish to present the idea to the FWS and the Arctic Regional Fish and Game Advisory Council established by the State of Alaska pursuant to the Alaska National Interest Lands Conservation Act. Response PH-13 The comment is appropriate and will be considered in future studies. There have been some studies of oil- spill effects on subsistence foods conducted by the Alaska Department of Fish and Game in Prince William Sound in the aftermath of the Exxon Valdez spill. The findings of these studies are largely nontransferable due to the incongruency of species in Prince William Sound with those of Chukchi Sea coastal waters. Response PH-14 It is unlikely that boat traffic generated by the proposed action would divert belukha whales out of Point Lay waters. According to the development scenario on which the analysis is based, Point Lay would not ‘serve as PH-3 an offshore-support center; thus, there would be little--if any--increase in marine traffic due to the proposed action. Response to PH-15 Whether increased human activity offshore will decrease the quota of bowheads available for harvest is a question central to the effects of the proposal. Indeed, the question implies that the proposal would reduce the bowhead stock and accordingly reduce the quota and the opportunity to harvest. In the base-case analysis for endangered species (Sec. IV.C.7), the effects of the proposal on the bowhead stock are estimated at very low, while the subsistence-harvest analysis (Sec. IV.C.11) indicates a high effect on the bowhead harvest for only one community--Wainwright. In the latter case, that effect would occur only as the result of an oil spill and the resulting perception by potential harvesters that bowhead flesh was tainted. However, this issue will always be one that demands additional data and further study. Any additional scientific information the IWC may provide on human/bowhead interaction is welcomed. R PH- The MMS recognizes that large concentrations of spotted seals occur along the Chukchi Sea coast and that they can be adversely affected by activities associated with petroleum development; consideration of disturbance effects is a basic element of this analysis. R PH- The southward migration of eiders is rather protracted, with males and nonbreeding birds initially proceeding in July, and females with young following later from August to November; hence, it is not likely that the entire North Slope eider population would be simultaneously vulnerable to an oil spill in the sale area. Response PH-18 Lease Sale 85 was deleted from the 5-Year Oil and Gas Leasing Program to address the concerns of the State of Alaska and the Alaska Congressional delegation. The following sentences regarding those concerns are excerpted from a January 10, 1984, letter from the Honorable Bill Sheffield, Governor of Alaska, to William Clark, Secretary of the Interior: "The primary concern of the state was the pace of the Department of Interior’s current five-year oil and gas leasing program. Due to internal budget constraints, the MMS personnel assigned to Alaska’s OCS appear to be insufficient for their greatly expanded responsibilities under the accelerated program. A two year delay would enable valuable scientific data interpretation and synthesis effort of available information to continue." The assessment of working in heavy-ice conditions was completed in the Sale 109 FEIS (USDOI, MMS, 1987b). Exploration is likely to continue in open-water conditions. It is estimated that development drilling will begin in 2000. This allows 9 years for the oil industry to study conditions. Drilling will be allowed when the oil industry demonstrates to MMS that they can operate safely in the ice conditions of the Chukchi Sea. Engineering studies indicate that a key consideration in the design of buried offshore pipelines in an arctic environment is to determine the optimum burial depths that maximize the pipeline’s safety from rupture by ice gouging and minimize costs. Prior to construction of subsea pipelines, operators would be required to conduct geological and geophysical surveys to determine potential hazards, including ice gouging, to the pipeline. The density, age, depth, and reoccurrence rate of ice gouging must be fully evaluated and considered in the design, construction, and placement of a pipeline. Any pipeline design must include devices to monitor damage or leaks, and redundant automatic- and manual-shutdown valves to shut off the pipeline and stop a continuous leak if a break in the pipeline occurred. Continuous-monitoring techniques will enable the operators of such pipelines to be forewarned of potential scour problems and to take corrective actions. PH-4 Response PH-19 The EIS describes areas where animal populations are at high density as well as low density. Over most of the sale area for most of the year, densities of most species are low; and, together with the generally low probability of oil-spill occurrence and contact over most of the sale area and vicinity, results in the expected effects fall in the low range for most species. Those portions of the analysis stating the potential effects that could occur--if an oil spill contacted an area where, for example, sensitive marine birds were vulnerable--are included to indicate the potential range of effects. They always will conclude a higher level of effect than the final analysis because the probability of a spill occurring and contacting an area is not considered. Nowhere in the analysis is it stated that the effect of high bird mortality would be low because of the ability of seabirds to recover. However, the populations of most seabirds are sufficiently numerous to allow them to recover fairly quickly, even after substantial mortality. Likewise, the analysis does not conclude that, because it is unlikely the sale would cause the demise of an entire species, the effect would be insignificant. Statements such as this confound attempts to convey the expected level of effect through the use of rational analysis. Response PH-20 Statements are attributed to a NMFS document, but without a citation, it is difficult for us to find it. The potential effects of major adverse factors on food chains and other biotic processes were considered in the analysis. Inclusion of all information used in the determination of the potential effect of each factor on each species is not practical or informative. R PH-: A very large oil-spill event is analyzed in Section IV.J. Response PH-22 The MMS planning guidelines provide that, if local conditions and geography permit, the target for initiating recovery operations with pre-staged equipment (i.e., the response time) should be 6 to 12 hours. If the risk analysis included in the OSCP indicated that an oil spill from the proposed activity would contact a shoreline or biological community in sooner than 6 to 12 hours, the response time would be reduced accordingly in order to protect the environmental resource. The MMS does not believe that it is appropriate to mandate a specific response criterion, such as time, without consideration of location, timing, potential spill size, trajectory, and risk. The MMS requires annual drills to test the lessee’s response capabilities under realistic environmental conditions. The MMS/USCG planning guidelines require additional drills for different environmental conditions. The MMS reviews proposed scenarios for response drills in cooperation with the USCG. Drills are witnessed by the MMS and the USCG to ensure that personnel are capable of properly deploying response equipment. The MMS can require additional drills if the initial drill is unsatisfactory. The MMS routinely invites individuals from State, local governments, and community organizations to attend the oil- spill drills. Lessees are required to inspect response equipment, train personnel in response techniques, and maintain records of the inspections and training. The MMS also has a rigorous inspection program that ensures that response equipment is available and maintained in workable condition and that all personnel receive training. The MMS believes that the adequacy of spill response can be determined through reviewing the OSCP and viewing oil-spill-response drills in accordance with current MMS rules and guidelines. PH-5 Response PH-23 The commenter is referred to EIS Appendix I, Alternative Energy Sources. Appendix I summarizes and incorporates by reference Appendix C, Alternative Energy Sources, of the Final EIS for the Proposed 5- Year OCS Oil and Gas Leasing Program, 1987-1992 (USDOI, MMS, 1989c). PH-6 Vi CONSULTATION AND COORDINATION Vd VI. CONSULTATION AND COORDINATION A. Development he Pri The proposed Chukchi Sea Sale 126 is one of 38 proposed OCS sales included in the 5-Year OCS Oil and Gas Leasing Program. Official coordination with other government agencies, industry, and the public regarding this proposal began on January 12, 1989. At this time, the MMS requested resource reports from all Federal agencies with expertise pertinent to the proposal and the proposed sale area. On January 13, 1989, a Call for Information and Notice of Intent to Prepare an EIS were issued requesting expressions of industry interest in blocks within the Call area and requesting comments on environmental issues related to possible oil and gas leasing in the area. Responses were received from 9 companies, the State of Alaska, the National Marine Fisheries Service, the U.S. Fish and Wildlife Service, the Environmental Protection Agency, the City of Wainwright, and the North Slope Borough. Following evaluation of the area nominations and environmental information received in the process described above, the MMS submitted a recommendation for the area selection to the Secretary. On May 9, 1989, the Secretary of the Interior selected 4,319 blocks as the Sale 126 area for further environmental study. (See Sec. I.A for more details.) B. Development of the EIS During preparation of this and past EIS’s for the Chukchi Sea, Federal, State, and local agencies; industry; and the public were consulted to obtain descriptive information, identify significant effects and issues, and identify effective mitigating measures and reasonable alternatives to the proposed action. All of the information received has been considered in preparing the Sale 126 EIS. In addition, a scoping meeting was held in Barrow, Alaska, with local agencies and the public to more clearly and specifically identify potential issues and alternatives to be studied in the EIS. Scoping information can be found in Section I.D. Departmental agencies with interest and expertise in the OCS were consulted during the development of the potential mitigating measures for this proposed action (see Sec. IL.F). Public hearings on the Sale 126 DEIS were held in the NSB communities of Barrow, Wainwright, and Point Lay and in Anchorage during August 27 to 31, 1990. C. List of Contacts for Review of the EIS Federal, State, and local government agencies, academic institutions, industry, special-interest groups; other organizations; and private citizens were consulted prior to and during the preparation of this EIS. These agencies, institutions, groups, and individuals are listed below and were sent copies of the DEIS for review and comment. Federal Services Centers for Disease Control Department of the Interior Executive Branch - Departments Bureau of Indian Affairs Department of Commerce Bureau of Land Management National Oceanic and Atmospheric Bureau of Mines Administration Fish & Wildlife Service U.S. Army Geological Survey Corps of Engineers National Park Service Waterways Experiment Office of Environmental Assessment Station Department of Transportation Cold Regions Research and Commandant, U.S. Coast Guard Engineering Laboratory Alaska District Legislative Branch Department of Health and Human U.S. House of Representatives VI-1 Committee on Interior & Insular Affairs Committee on Merchant Marine & Fisheries Subcommittees on Panama Canal & OCS US. Senate Committee on Energy and Natural Resources Senator Frank Murkowski Library of Congress Congressional Research Services Administrative Agencies and Other Agencies Environmental Protection Agency Marine Mammal Commission National Science Foundation Division of Polar Programs Nuclear Regulatory Commission Division of Site, Safety, and Environmental Analysis Other Organizations Smithsonian Institution State of Alaska Alaska State Legislature Senate Resources Committee Alaska Oil & Gas Conservation Commission Alaska State Library Department of Community & Regional Affairs Department of Commerce & Economic Development Department of Environmental Conservation Department of Fish & Game Department of Labor Department of Natural Resources Department of Health and Social Services Office of the Governor Division of Governmental Coordination University of Alaska Arctic Environmental Information and Data Center Elmer E. Rasmuson Library Fossil Energy Research Council Geophysical Institute Institute of Social and Economic Research Institute of Arctic Biology Institute of Marine Science Marine Advisory Program Petroleum Development Lab VI-2 Water Research Center Department of Civil Engineering Governments, Native Organizati Libraries Alakanuk Public Library Alaska Eskimo Whaling Commission Alaska Federation of Natives Alaska Native Foundation Aleut Corp. Arctic Slope Regional Corp. Brevig Mission Community Library Bristol Bay Coastal Resource Service Area Buckland Public Library City of Atqasuk City of Barrow City of Chevak City of Diomede City of Kake City of Kaktovik Kaveolook School Library City of Kotzebue George Francis Memorial Library City of Nuiqsut City of Point Hope City of Point Lay City of Saint Paul City of Valdez City of Wainwright Cenaliulriit Coastal Management District Cully Corporation Davis Menadelook Memorial Library, Diomede Elim Native Corporation Elim Community Library Eskimo Walrus Commission Eyak Corporation Gambell Community Library & Learning Center Golovin Community Library Halibut Cove Library Inalik Native Corporation, Little Diomede Island Kasilog Public Library Kegoyah Kozga Public Library, Nome Kenai Community Library Kiana Elementary School Library Kingikme Public Library, Wales Koyuk City Library Kuukpik Corporation, Nuigsut Maniilaq Association, Kotzebue Martin Monsen Library Matanuska-Susitna Borough Municipality of Anchorage Z.J. Loussac Public Library NANA Regional Corporation, Inc. Native Village of Barrow (Inupiat Traditional Government) Nellie Weyiouanna Ilisaavik Library, Shishmaref North Slope Borough Northwest Arctic Borough Olgoonik Corporation Point Lay IRA Council Quinhagak Public Library Savoonga Public Library Shishmaref Native Corporation Sitnasuak Native Corp Soldotna Public Library Stebbins Community Library Ticasuk Library, Unalakleet Tikigaq Library, Point Hope Wainwright Tribal Council Whittier Public Library Canada Canadian Wildlife Service, National Wildlife Research Centre Circumpolar Affairs, Government of the NWT Department of Fisheries & Oceans Department of Indian & Northern Affairs Geological Survey of Canada Institute of Ocean Sciences, Dept. of Fisheries & Oceans, Sidney, BC Joint Secretariat, Fisheries Joint Mgt. Com., Inuvikon, NWT Special-Interest Groups Friends of The Earth Greenpeace National Audubon Society National Wildlife Federation Natural Resources Defense Council Northern Alaska Environmental Center Sierra Club Trustees for Alaska Petroleum Industry A Ruddy Petina Company Alaska Clean Seas Alaska Oil and Gas Association Alaska Support Industry Alliance Amerada Hess Corporation American Petroleum Institute AMOCO Canada Petroleum Co., Ltd. VI-3 AMOCO Production Company ARCO Alaska, Inc. Baroid Drilling Fluids BP Exploration Chevron USA Inc. Columbia Gas Devel. Corp. Conoco Inc. ELF Aquitaine Petroleum Enserch Exploration Inc. Exxon Company, USA Global Marine Halliburton Geophysical Services, Inc. Home Oil Company, Ltd. Hunt Oil Company Kerr-McGee Corporation M-I Drilling Fluids Marathon Oil Company Murphy Oil USA, Inc. Mobil Oil Corporation ODECO Oil & Gas Company Pennwell Publishing Co. Pennzoil Exploration & Production Co. Petro-Canada Inc. Petroleum Information Oil & Gas Journal Shell Western E&P Inc. Tennessee Gas Pipeline Texaco Inc. Tide Petroleum Company Union Texas Petroleum Corporation UNOCAL Regional Technical Working Group Paul Gronholdt, Sand Point Perry Adkison, Dillingham Alaska Draggers Assoc., Executive Director, Kodiak Bering Sea Fishermen’s Assoc., Extension Specialist, Anchorage Chevron USA, Inc., Exploration Representative, Anchorage Department of Natural Resources, Petroleum Mgr., Div. Oil & Gas, Anchorage Environmental Protection Agency, Anchorage Exxon Company, USA, Alaska Coordinator, Houston, TX FWS, Chief, Div. Tech. Support, Anchorage Halliburton Geophysical Services, Inc., Mgr., Alaska Division, Anchorage National Wildlife Federation, Alaska Resource Center, Director, Anchorage NOAA, National Marine Fisheries Service, Anchorage NSB, Planning Director, Barrow Shell Western E&P Inc., Mgr., Development Engineering, Alaska Division, Houston, TX U.S. Army Corps of Engineers, Chief, Regulatory Branch, Alaska District U.S. Coast Guard, Juneau Individuals, A ‘ati C . 1 Ot Groups Adriaan Volker Worldwide Dredging BV Alaska Geographic Society Alaska Map Service Alaska Journal of Commerce Alaska Land Use Council Alaska Legal Services Corporation Alaska Oil and Industry News Alaska Pacific University, Center for Polar Research and Education Alaska Power Authority Alaska Public Radio Network Aleutian Eagle, Barrow Sun Advocate, Borough Post, Bristol Bay News Amax Mineral Resources Co. Anchorage Chamber of Commerce Anchorage Daily News Andrews University Antilles Resources Ltd. 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Whale Center Harry Wilson Whaling Museum (Old Dartmouth Historical Woodward-Clyde Consulting Society) D. Contributing Authors and Supporting Staff Members Allen Adams, Physical Scientist George Allen, Community Planner Judith Balfe, Public Information Specialist Kevin Banks, Regional Economist William C. Chambers, Cartographic Technician Edie Deaton, Clerk-Typist Paul Dubsky, Chief, Subarctic Unit Cora Fullmer, Secretary Shawna Hampton, Visual Production Clerk Tim Holder, Economist Ken Holland, Endangered Species Specialist Michele Hope, Program Analyst/Archaeologist Joel Hubbard, Wildlife Biologist Dale Kenney, Oceanographer Maureen McCrea, Social Science Analyst Cathy McFarland, Secretary Jerome Montague, Wildlife Biologist Barbara Nather, Minerals Leasing Specialist Walter Nijak, Geologist Joel Nudelman, Cartographic Technician Mazelle O. Parker, EIS Assistant/Typing Rose Paul, Minerals Records Coordinator Dudley Platt, Petroleum Engineer Dick Prentki, Oceanographer Sharon Rathbun, Paralegal Specialist Rich Rothley, Cartographic Technician Paul Schepler, LAN Administrator John F. Schindler, Chief, Environmental Assessment Section Carolyn Shepard, Clerk Typist Luke Sherman, Social Science Analyst Caryn Smith, Oceanographer Jean E. Thomas, Illustrator Evert E. Tornfelt, Social Science Analyst John Tremont, Geographer Monte Wallace, Secretary Jeff Walker, Section Supervisor Frank Wendling, Marine Biologist Robert Wienhold, Fisheries Biologist Glen Yankus, Natural Resources Specialist VI-6 BIBLIOGRAPHY = Oo < cc ) e) | a aa} BIBLIOGRAPHY Aagaard, K. 1984. Current, CTD, and Pressure Measurements in Possible Dispersal Regions of the Chukchi Sea. Environmental Assessment of the Alaskan Continental Shelf, Annual Reports of Principal Investigators for the year ending December 1983, RU 91. 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Wickersham and Flavin. 1983. Comprehensive Plan - North Slope Borough. Barrow, AK: North Slope Borough. Wilson, D.W., S.D. Pace, P.D. Carpenter, H. Teas, T. Goddard, P. Wilde, and P. Kinney. 1982a. Nearshore Coastal Currents, Chukchi Sea, Summer 1981. Environmental Assessment of the Alaskan Continental Shelf. Final Report of Principal Investigators, RU 531. June 7, 1982. USDOC, NOAA, OCSEAP, and USDOI, BLM, Alaska OCS Office. Wilson, J.C., W.W. Wade, M.L. Feldman, and D.R. Younger. 1982b. Barrow Arch Planning Area (Chukchi Sea) Petroleum Technology Assessment, OCS Lease Sale No. 85. Anchorage, AK: USDOI, MMS, Alaska OCS Office, Alaska OCS Socioeconomic Studies Program. Wilson, R.D., P.H. Monaghan, A. Osanik, L.C. Price, M.A. Rogers. 1974. Natural Marine Oil Seepage. Science 184:857-865. Windholz, M.S. Budavari, fL.Y. Stroumtsos, and MLN. Fertig, eds. 1976. The Merk Index, Ninth Edition. Rahway, NJ: Merk and Company, 1,313+ pp. Wing, B.L. 1974, Kinds and Abundance of Zooplankton Collected by the USCG Icebreaker Glacier in the Eastern Chukchi Sea, September-October 1970. NOAA Technical Report NMFS SSRF-679. August 1974. USDOC, NOAA, NMFS. Wing, B.L. and N. Barr. 1977. Midwater Invertebrates from the Southeastern Chukchi Sea: Species and Abundance in Catches Incidental to Midwater Trawling Survey of Fishes, September-October 1970. NOAA Technical Report NMFS SSRF-710. April 1977. USDOC, NOAA, NMFS. Winters, K. and P.L. Parker. 1977. Water-Soluble Components of Crude Oils, Fuel Oil, and Used Crankcase Oils. In: Proceedings of the 1977 Oil Spill Conference, New Orleans, LA, March 8-10, 1977. Washington, DC: American Petroleum Institute, pp. 579-582. Wise, J.L., A.L. Comiskey, and R. Becker, Jr. 1981. Storm Surge Climatology and Forecasting in Alaska. Report for Alaska Council on Science and Technology. Anchorage, AK: University of Alaska, AEIDC. Wiseman, W.J., Jr. and LJ. Rouse, Jr. 1980. A Coastal Jet In the Chukchi Sea. Arctic 33(1):21-29. Wolfe, RJ. 1981. Yukon Delta Sociocultural Systems Study (AA 851-CT-29). Anchorage, AK: USDOI, BLM, Alaska OCS Office. Wolman, A.A. and D.W. Rice. 1979. Current Status of Gray Whales. Report of the International Whaling Commission 29:275-279. Wolotira, R.J., T.M. Sample, and M. Morin. 1977. Baseline Studies of Fish and Shellfish Resources of Norton Sound and the Southeastern Chukchi Sea. Environmental Assessment of the Alaskan Continental Shelf. Final Reports of Principal Investigators, RU 175. Boulder, CO: USDOC, NOAA, OCSEAP. 31 Woodby, D.A. and G.J. Divoky. 1982. Spring Migration of Eiders and Other Water Birds at Point Barrow, Alaska. Arctic 35:403- 410. Woodward-Clyde Consultants. 1981. Coastal Analysis of Alaska and the Northwest Passage. Prepared for Dome Petroleum Ltd., Victoria, B.C., Canada. Worl, R. 1978. Beaufort Sea Region Sociocultural Systems. Technical Report 9. NTIS Access No. A13/PB 281634/AS. Anchorage, AK: USDOI, BLM, Alaska OCS Office, Alaska OCS Socioeconomic Studies Program. Worl, R. 1979. Sociocultural Assessment of the Impact of the 1978 International Whaling Commission Quota on the Eskimo Communities. Anchorage, AK: University of Alaska, AEIDC. Worl, R. and C.W. Smythe. 1986. Barrow: A Decade of Modernization. Technical Report 125. OCS Study, MMS 86-0088. NTIS Access No. A19/PB 87-204673. Anchorage, AK: USDOI, MMS, Alaska OCS Region, Alaska OCS Social and Economic Studies Program. Wright, J. 1987. Documentation of Peregrine Falcon Nest Sites in Relation to State Land Use Proposals. Section 6 Endangered Species Act Final Report, Project SE-2-2. Juneau, AK: State of Alaska, ADF&G, Div. of Game. Wursig, B., E.M. Dorsey, M.A. Fraker, R.S. Payne, and W.J. Richardson. 1985. Behavior of Bowhead Whales, Balaena mysticetus, Summering in the Beaufort Sea. Aquat. Mammals 15:27-37. York, A. and P. Kozloff. 1987. On the Estimation of Numbers of Northern Fur Seal, Callorhinus ursinus, Pups Born on St. Paul Island, 1980-86. Fishery Bulletin 85:367-375. Zeh, J., S. Reilly, and R. Sonntag. 1988. Bowhead Population Estimate and Variance. Report of the International Whaling Commission 38, In Press. Zimmerman, S.T. and M.D. Melovidov. 1987. The 1986 Subsistence Harvest of Northern Fur Seals, Callorhinus ursinus, on St. Paul Island, Alaska. Marine Fisheries Review 49:70-72. APPENDIX A RESOURCE ESTIMATES Estimates of Quantities of Undiscovered Resources Resource Assessment Methodology Estimates of potential quantities of undiscovered oil and gas are vital to essential long-range national planning. The Federal Government’s offshore oil and gas leasing program depends in part on projections of the potential amounts of undiscovered hydrocarbon resources on the Outer Continental Shelf (OCS) and estimates of those resources which may be technologically and economically recoverable. The pace of discovery and development of these resources affects national security, the economic health of a large sector of the economy, the balance of trade, and many other important national issues. The Minerals Management Service (MMS) develops estimates of the undiscovered oil and gas resource base and economically recoverable undiscovered hydrocarbons in support of the OCS leasing program. These estimates are used in a number of public and internal documents related to leasing, such as sale-specific Environmental Impact Statements (EIS), Secretarial Issue Documents (SID), the Biennial Report to Congress (Section 606, OCS Lands Act), formulation of the 5-Year Leasing Program, and technical publications. The EIS’s for specific lease sales and events such as the development of a 5-Year Leasing Program use the estimates as a basis for analyzing potential environmental impacts of a proposed activity, e.g., oil spill risk analysis, sale alternatives and deferral options, or any other requirement for which the potential resources in specific areas may serve as the basis for evaluating potential actions. In the SID, estimates of the amounts and locations of potential resources are used to assist the Secretary of the Interior in balancing the economic benefits of development against the environmental consequences resulting from the leasing of offshore areas for petroleum exploration and development. Estimates provided in the Biennial Report to Congress may be used by the legislative branch and others for national strategic and economic planning purposes. Estimating the undiscovered resource base and economically recoverable amounts of oi] and gas remaining to be discovered on the OCS is a difficult task because of the uncertainties inherent in the process. The actual existence of hydrocarbon accumulations is not known with certainty prior to exploratory drilling. The only information concerning the existence of a potential producing field is derived from inferences, extrapolations, and subjective judgments. Geophysical data provide clues as to the existence and location of possible traps (prospects) and their general dimensions, but geologic data on the quality of any potential reservoir rocks or source materials are usually absent. Generally, until drilling operations commence, no data will be available on the nature and distribution of included hydrocarbons, or indeed whether hydrocarbons are present at all. Obviously, an exact prediction of resource quantities under such circumstances is impossible because the uncertainties in the input data set translate directly to uncertainties in the estimates. Two main types of undiscovered resource estimates are commonly used, conditional and risked, each responding to different needs. Conditional, A-1 undiscovered resource estimates represent the amount of resources anticipated if a certain condition exists, the condition being that recoverable quantities of oil and/or gas are present in the area of study. In other words, if oil and/or gas are found to exist in an area, the conditional estimates represent the amount of hydrocarbons determined to be ultimately recoverable. These estimates are used, for instance, to assess the full range of potential environmental impacts in an area if leasing, exploration, development, and production were to occur; the condition that hydrocarbons exist must be assumed, otherwise impacts would not be a concern. However, if the economic value of a resource is being considered, conditional estimates are not the appropriate measure. In these cases, such as the economic analyses prepared for sale-specific SID’s, the resource estimates must incorporate the probability (or risk, which is often extremely high in frontier areas) that recoverable hydrocarbons may not be present in the entire area. The conditional estimates are modified by consideration of this probability that recoverable resources do not exist (that is, factoring in the risk) and are then said to be risked resource estimates. Considering the uncertainty of geologic and engineering variables associated with hydrocarbon traps, resource estimates are usually presented as a range or distribution of values; reporting just one value lends a false sense of precision to the estimate. If a single estimate is required, the mean value of the distribution of possible values is the single best indicator of central tendency, since it reflects both the probability and magnitude of the estimates. The mean, also known as the expected value, is the arithmetic average of all values in the distribution. It is not the "most likely" estimate. The most likely estimate is a probability-weighted average called the mode. Another indicator is the median, which is the value that divides a probability distribution into two equal parts; it corresponds to the 50th percentile on a cumulative frequency distribution. The figure below is a diagram depicting these three measures on a sample probability density curve, which displays the amount of resources versus the relative probability of occurrence. The 95 percent estimate shown on the graph indicates a low estimate having a 19-in-20 chance that the actual amount will be greater. The 5 percent value is a high estimate with a l-in- 20 likelihood that the actual amount will be greater. mode median mean Probability of X Amount Occurring 95% ss X Resources eeeeeeeeneeensiel A-2 The resource estimation process used by the MMS to generate estimates under conditions of uncertainty, incorporates a computer program called PRESTO (Probabilistic Resource ESTimates Offshore). This program provides MMS with a range of estimates, both conditional and risked. The program is objective and utilizes a large geological and geophysical data base, not only from the offshore areas but also from onshore and offshore State lands. The results produced from the model are reproducible and updatable. This allows new data or new interpretations to have a quantifiable effect on the resource estimates. Results are presented as ranges of values rather than as single-point estimates, so that useful limits can be provided for planning purposes. The program is also functional under a wide range of uncertainty since our knowledge of potential offshore petroleum provinces varies from considerable to general regional knowledge. The current PRESTO model is in its third generation and incorporates many new, state-of-the-art enhancements. The program uses the types of geologic and geophysical data normally used by the oil industry to locate and define potential hydrocarbon-bearing geologic features. These data are analyzed, interpreted, and eventually refined to a set of input values which numerically model all known potential prospects in the study area. Since these input values are rarely exactly known, uncertainty is accounted for by range-of-values estimation, i.e., the inputs for variables can be entered as distributions over an appropriate range of possible values with associated probabilities of occurrence. The variables used to define prospects and their resource potential are: 1. areal extent (acres), 2. zone pay thickness (feet), oil recovery factor (stock tank barrels/acre-feet), gas recovery factor (thousand cubic feet/acre-feet), proportion (PROP) of the zone pay thickness consisting of gas, ao on > WwW solution gas-to-oil ratio (standard cubic feet/stock tank barrel), and 7. condensate yield (stock tank barrels/million cubic feet of gas). Dependencies among these input variables can be specified where appropriate. Two other zone properties that may be specified are (1) probability of all oil (OPROB) and (2) probability of all gas (GPROB) for each zone. Before calculating resources, the model first uses the input geologic risks to determine if hydrocarbons are present in each specific prospect. Next it determines whether a reservoir contains all oil, all gas, or both (by using OPROB, GPROB, PROP). PRESTO then calculates volumes of oil, associated A-3 and nonassociated gas, condensate and solution gas, as appropriate, for all hydrocarbon-bearing prospects on each trial by the following equations: 1. volume of oil, barrels = (acres) (thickness) (1-PROP)(o0il recovery factor), 2. volume of nonassociated and associated gas, million cubic feet = (acres) (thickness) (PROP)(gas recovery factor) (.001), 3. volume of condensate, barrels = (condensate yield) (nonassociated and associated gas), and 4. volume of solution gas, thousand cubic feet = (gas-to-oil ratio) (oil, barrels)(.001). Using the above set of inputs as the basis for estimates of resource volumes, the program uses sophisticated statistical sampling techniques to calculate resources. Since each input can be represented by a distribution of values, one point on the distribution for each variable is randomly sampled and the selected values are entered into the volumetric equations to solve for resource amounts. This process is called a "drilling simulation trial" or "pass" and can be repeated as many as 10,000 times. On each of these trials, the model simulates a state of nature by "discovering" which prospects will be hydrocarbon-bearing by using input risks to simulate drilling of each prospect. To determine the number of trials in which a prospect or zone contributes to the total, the model uses a risk assessment considered at four levels: zone, prospect, basin (or play), and area (or basin). The evaluator must enter risk values which measure the probability that the prospect or zones within a prospect will be dry and the overall probability that the basin (and area) may be dry. Additional estimates of minimum economic field size for each prospect, and minimum economic basin and area reserves (in barrels of oil equivalent (BOE)) are required to determine the portion of the undiscovered resource base that is economically recoverable. Minimum economic field sizes are calculated exogenously through use of a discounted cash flow (DCF) model. They represent the smallest resource amount which would balance development and operating costs (including transportation costs for the gathering system) for a prospect and yield a minimum rate of return. The minimum economic field size is tailored to the prospect, considering factors such as water depth, distance from shore, depth to the potential pay horizon, and current and projected economic conditions. PRESTO develops estimates of economically recoverable resources on a trial by comparing the calculated resource volumes of each successful prospect to the minimum economic field size. The gas volumes calculated for a prospect are converted to a volume of oil equivalent on the basis of energy or economic equivalency and then added to the oil volume to yield a total BOE for the prospect (BOE conversion is described further in Appendix A, Section II, categories of Resource Estimates). If the calculated prospect resource volume in BOE exceeds the minimum economic field size, the prospect is considered to be economically viable and its resources contribute to the A-4 total. If the calculated prospect resources are less than the minimum economic field size, then the prospect is considered noncommercial and its resources are set equal to zero for that trial. Resource amounts greater than the minimum economic field size for prospects within a basin are aggregated on each trial and compared to a minimum economic basin reserve. The minimum economic basin reserve, also calculated exogenously, is the minimum amount of resources necessary to justify a regional production infrastructure in a basin. Finally, resource amounts for all basins in an area on a given trial are compared to a minimum economic area reserve to determine whether enough resources are present to justify production facilities for the area. This feature is more appropriate for frontier areas than for mature areas with an existing infrastructure. When the specified number of trials is completed for either the undiscovered resource base or economically recoverable estimates, the solutions of each trial are sorted and ranked and the results are defined by distributions of solutions. Thus, the full range of possible volumetric solutions are represented by a single curve with each point on the distribution having an equal probability of occurrence. PRESTO outputs include both conditional and risked distributions. Since the output of PRESTO is a distribution of resource estimates, for convenience, the results are usually reported using only the mean value and the 5th and 95th percentiles. The 5th percentile can be considered a high estimate where there is a 5 percent chance of that amount or more occurring, the 95th as a low estimate where there is a 95 percent chance of that amount or more occurring, and the mean is the average value of all trials. An important number associated with conditional estimates is the marginal probability. The condition is quantified by assigning it a numerical value (the marginal probability (MP)). The MP is a measure of the probability that hydrocarbons exist in an area and is represented as a decimal fraction. (For economically recoverable resources, the MP is a measure of the probability that commercial hydrocarbons exist in the area.) An MP of 1.00 indicates certainty of hydrocarbon occurrence in the area; an MP of zero indicates no chance whatsoever. The MP applies to the entire conditional distribution. As an example, consider an area having an MP equal to 0.25. This means that the area has a 25 percent chance of containing a hydrocarbon accumulation. If hydrocarbons do exist, then the conditional distribution represents the range of possible values. By removing the condition and incorporating the risk that the entire area may be barren of hydrocarbons, the estimates are said to be risked. The following graphs illustrate conditional and _ risked resource distributions. Cumulative percentages are given on the vertical axis and oil volumes on the horizontal axis. The conditional curve has a corresponding MP of 0.25 and if hydrocarbons do exist, the conditional curve displays the calculated range of values. It can be seen on the conditional curve that the 50th percentile corresponds to 2.9 billion barrels of oil, j.e., there is a 50 percent probability that at least 2.9 BBO will be found if there are accumulations of oil present in the area (the mean or average value is 2.8 BBO which corresponds to the 54th percentile in this case). A-5 The graph on the right shows the risked distribution of estimates. Note that the risked mean estimate is only .7 BBO (.25 x 2.8), reflecting the low probability of success in this hypothetical area. The risked curve also shows the chance of resource amounts being greater than or equal to zero is 25 percent (corresponding to the MP); there is a 75 percent chance the area is. dry. CONDITIONAL MEAN = 2.8 BBO (54th PERCENTILE) ry CUMULATIVE CUMULATIVE RISKED MEAN = 0.7 880 PERCENT so PERCENT 7 GNEATER THAN GREATER THAN . ee MARGINAL PROBABILITY = 0.25 OR EQUAL TO T ° 20 se e ESTIMATED VOLUME OF Olt, BBO 2 se ESTIMATED VOLUME OF O, BBO Conditional resource estimates are constrained by a number of statistical caveats which are not intuitive. PRESTO calculates planning area resource estimates (or any subset such as an alternative sale configuration) by statistically aggregating the estimates of resources in each individual prospect. It does not follow, however, that the total planning area estimate is the arithmetic sum of the prospect estimates. This is because each prospect has a different condition (i.e., the chance that hydrocarbons occur in the prospect). Prospect resources can be aggregated to planning area totals only by rerunning the program using all prospect data and making any required risk adjustments. The conditional mean multiplied by the MP yields the risked mean, i.e., the average value factoring in the potential risk of no hydrocarbons existing in the area. However, this is statistically valid only for the mean value; the 5th and 95th percentiles cannot be multiplied by the MP for risked 5th and 95th percentiles. (The 5th and 95th percentiles on the conditional distribution, when multiplied by the marginal probability, will correspond to different percentiles on the risked distribution.) The risked mean values can be added or subtracted. However, conditional means are not additive; conditional or risked percentile estimates (such as the 5th and 95th percentile estimates) cannot be added or subtracted, but must be aggregated statistically. Risked mean resource values are most useful in comparing different areas for ranking purposes. However, as mentioned earlier, it is the conditional and not the risked mean that is the amount anticipated if recoverable (or commercial) quantities of oil and gas occur in nature. The following example illustrates the essential difference between the two types of estimates and the need to consider both in making informed judgments and decisions. Two areas have been assessed, resulting in very different conditional mean resource levels and marginal probabilities. A-6 ie Conditional Mean Risked Mean (Million BBLS) MP (Million BBLS) Area A 1,000 10 100 Area B 125 .80 100 The risked mean values calculated for both areas are the same. However, Area A has a larger potential (eight times larger than Area B), with only a small chance (10 percent) of hydrocarbons existing in the area. If Area B contains hydrocarbons, the average amount anticipated is much smaller, but the chance of hydrocarbons existing in the area is greater (80 percent). The distinction between conditional and risked results is _ further illustrated by the following example. The undiscovered resource base for a fictitious OCS basin is estimated to be between 1 and 7 billion barrels of oil with an average of 3 billion barrels if_oil is present in the basin. However, it is estimated that there is only a 25 percent chance that this condition will be met (oil present in the basin). In other words, if there were 100 basins in the world similar to this fictitious basin, 75 would be dry and 25 would contain oi]. The 25 basins containing oi] would each have between 1 and 7 billion barrels with the average size being 3 billion barrels. The average amount found in the 100 basins would be reported as 750 million barrels. This is the "risked mean" estimate. Therefore, based on current geologic, engineering, and economic knowledge, if this one fictitious basin is fully explored and oil is found, the amount found will be between 1 and 7 billion barrels with an average value of 3 billion barrels. There is, however, only a 25 percent chance of oil being present, so the risked mean estimate is reported at 750 million barrels. In actuality, the amount found would be either zero or between 1 and 7 billion barrels and not the risked mean estimate of 750 million barrels. Categories of Resource Estimates Various categories of undiscovered resource estimates, each responding to a different question or need, can be developed using the models and methodologies described above. These estimates can be derived from a baseline data set comprised of all prospects in the area. These resource estimates form a nested hierarchy, where each estimate is a subset of previous estimates. Planning Area Estimate (Undiscovered Resource Base) Planning Area Estimate (Economically Recoverable) Sale Area Estimate (Economically Recoverable) A-7 Economically Recoverable Resources Estimated to be Leased Due to Sale Resources Estimated to be Leased Due to Alternative Sale Configurations (or Deferral/Deletion Options) Planning Area Estimates are the top tier of undiscovered resource estimates. These estimates are for policy guidance and as such, they are broad and all encompassing in nature. They are used, for example, to develop the 5-Year Leasing Program and the Biennial Report to Congress (Section 605, OCS Lands Act). These estimates include both prospects identified through interpretation of geologic and geophysical data and prospects postulated by the extrapolation of geologic trends into areas having scant data. They also include adjustments for the fact that current exploration tools and analyses are not perfect in identifying all potential accumulations. The undiscovered resource base includes estimated quantities of oil and gas resources which can physically be produced at the surface by conventional technological means, without regard to any economic constraints. Planning area estimates that are described as economically recoverable include resources only from those prospects that are of sufficient size to be economically producible and marketable, based on current and projected economic conditions and foreseeable technological trends. Gas production is presently uneconomic in all cases, assuming it must be marketed on the U.S. West Coast. The cost of platforms, wells, pipeline, liquefaction plant, tankers, and regasification is much higher than any projected return based on current price forecasts for the gas. The market price is not forecast to rise sufficiently during the sale scenario to change this conclusion. Produced gas, not flared or used as fuel, will be reinjected for pressure maintenance. For more information on the economics of gas, see pages B-3 and B-4 in Appendix B. For the Chukchi Planning Area, the undiscovered economically recoverable estimates (leased and unleased) follow: Undiscovered, Economically Recoverable Resource Estimates * Chukchi Planning Area (leased and unleased) Oil Gas (Billion Barrels) (Trillion Cubic Feet) Conditional 95th Percentile 1.19 0.00 Mean 5.96 0.00 5th Percentile 13.10 0.00 Marginal Probability = 0.23 A-8 Oil Gas (Billion Barrels) (Trillion Cubic Feet) Risked 95th Percentile 0.00 0.00 Mean 1.36 0.00 5th Percentile 8.76 0.00 * The above estimates are an update of the resource estimates developed for the National Resource Assessment (NRA) published in 1989. The updated estimates are higher than those published for the NRA. The increase in the updated estimates is attributed to the identification of many new prospects found in subsequent mapping in preparation for OCS Sale 109 (May 1988). Also, several high quality prospects were found to be larger than originally mapped. A much larger seismic data base was available for the Sale 109 mapping effort. (Although estimates are shown at the 95th percentile, 5th percentile, and mean cases, these are only three possible numbers from a full and continuous distribution of possible values. The figure below shows a conditional distribution for the economically recoverable resources, in barrels of oil equivalent. Gas volumes are converted to barrels of oi] on an energy equivalent basis and then added to the oi] volume. One barrel of oil equivalent equals 5.62 Mcf of gas based on 5,800,000 Btu/barrel and 1,032 Btu/cubic feet of gas. Every point on these curves is equally likely to occur. However, the low and high estimates indicate the range of possible values and the conditional mean represents the average amount anticipated, given that recoverable hydrocarbons exist in at least one of the prospects modeled. ) Cc 1.8 ; T U Ny M Me U Sa L S <a ii 95% = 1.19 I ~ Mean = 5.96 7 U 5% = 13.10 E Nx F ae R 0.8 Le E I Q 0.81 10.50 20.20 BOE - BILLION BARRELS Conditional Results - Chukchi Planning Area A-9 Sale Area Estimates are prepared to comply with sale-specific analytical requirements related to environmental analyses and cost/benefit studies. Oftentimes the area offered for lease is smaller than the entire planning area. Therefore, prospects lying outside of the proposed sale area must be deleted from the assessment. These estimates are undiscovered, economically recoverable resources which are based on current economic and technological conditions and projections. Since these estimates are more area-specific and of nearer term use than planning area estimates, postulated (unmapped) Prospects generally are not included, except where justified on a case-by-case basis. Economically recoverable resource estimates for the entire area offered for lease (excludes acreage already leased) in the proposed Chukchi Sale 126 are shown below: * Undiscovered Economically Recoverable Resource Estimates Chukchi Sale Area (unleased) Oil Gas (Billion Barrels) (Irillion Cubic Feet) Conditional 95th Percentile 1.11 0.00 Mean 4.16 0.00 5th Percentile 9.14 0.00 Marginal Probability = 0.21 Risked 95th Percentile 0.00 0.00 Mean 0.88 0.00 5th Percentile 5.72 0.00 * The above estimates differ considerably from the National Resource Assessment (NRA) estimates published in 1989. The NRA was conducted over a period of more than 2 years and reflects data and information available as of January 1, 1987. The updated estimates were developed using additional geophysical data not available for the NRA and also they incorporate the results of the Chukchi Sale 109, held in May 1988. The sale area estimates represent the amount of undiscovered economically recoverable resources offered for lease. The Resources Estimated to be Leased represent an assessment by MMS of the amount of resources which would be leased, discovered, and produced as a result of the sale and, therefore, the amount upon which the impact analysis is to be based. For proposed Sale 126, MMS considered previous leasing rates, industry interest, prospect distribution, economic and technological considerations, and infrastructure distribution to determine the resources estimated to be leased. Low, base, and high case estimates are developed to analyze the range of possible outcomes which could result from holding the proposed sale, as explained further in Section III, Rationale for Multiple Scenarios. A-10 To arrive at the base case estimate, a judgment is made as to what percentage of the unleased conditional mean oi] resources is expected to be leased and developed. Some of the major considerations in the judgment process include (but are not limited to) the quality and size of the prospects, their locations, reservoir and water depths, and historic patterns from previous sales. For the prospects that are expected to be developed (those that appear to offer the greatest potential for a sizeable discovery), an estimate is made as to what percentage of resources these prospects contribute to the unleased mean resource. However, the resources for each developable prospect are conditional resources with varying marginal probabilities, and therefore cannot be used directly in the process. For this purpose, risked resources can be used because the probabilities that resources do not exist have been factored into each prospect. Therefore, the risked resources are normalized and have the same condition. It follows that by using the risked resources for the prospects, an estimate can be made as to what percentage the developable prospects contribute to the risked mean. This percentage is then applied to the unleased conditional mean to arrive at the base case volume. An estimate was made that the prospects that are expected to be leased and developed represent approximately 39 percent of the risked mean. This factor was then applied to the unleased conditional mean to arrive at the base case estimate (4.16 billion barrels of oi] X approximately 0.39 = 1.61 billion barrels of oil. The yield does not equal the product of the components because numbers have been independently rounded). The 39 percent factor was then applied to other levels of the resource distribution. For the high case estimate, this factor was applied to the unleased conditional 5 percent volume to arrive at the high case estimate (9.14 billion barrels of oi] X approximately 0.39 = 3.54 billion barrels of oil. Again, the yield does not equal the product of the components because numbers have been independently rounded). This factor was also applied to the unleased conditional 95 percent volume to arrive at the low case estimate (1.11 billion barrels of oil X approximately 0.39 = 0.43 billion barrels of oil). For the low case, leased acreage will be drilled, but no development will occur. The low case estimate is uneconomic because it is below the estimated minimum economic basin resources of .810 billion barrels of oil needed for development. Undiscovered, Economically Recoverable Resources Estimated to be Leased Due to Sale 126 Oil Gas (Billion Barrels) (Trillion Cubic feet) Base Case 1.61 0.00 High Case 3.54 0.00 Marginal Probability = 0.21 A-11 Resource estimates are also developed for Alternative Sale Configurations (or Deferral/Deletion Options). These estimates allow comparison of the Proposal and the various sale alternatives, using procedures developed to estimate the relative resource contribution of each alternative. To make this comparison, the analysis of the sale area alternatives is based on the same condition as the Proposal, that is, that economically recoverable resources exist in the sale area. Therefore, each alternative has the same marginal probability as the sale area. The alternative estimates are based on the prospect data set used for the resources estimated to be leased at the base case. Risked resource estimates are developed for each prospect and used to compute the relative contribution of the prospects for each alternative. Risked resources for prospects located in deferred areas, outside of the alternative, are deleted from the base case estimate. The resultant total risked estimate for the alternative is then divided by the marginal probability to obtain the conditional amount shown below. This amount can then be compared to the amount estimated to be leased for the Proposal to determine the relative effects of the Alternative. The following resource estimates have been prepared for Sale 126 Alternatives: Undiscovered, Economically Recoverable Resources Estimated to be Leased as a Result of Alternative Sale Configurations Oil Gas Alternative (Billion Barrels) (Irillion Cubic Feet) Point Lay Base Case 1.61 0.00 Marginal probability for all alternatives = 0.21 Our current interpretation of available data suggests a negligible difference in resources expected to be developed and produced for Sale 126 between this alternative and the base case. The reason for this negligible difference is that the highest potential prospects capable of supporting and creating an infrastructure lie north of the Point Lay Deferral, and were the only prospects included in the base case. The prospects that fall within the Point Lay Deferral have lower potential and are not large enough to create an infrastructure based on our interpretation of data. Therefore, none of the deferral prospects are included in the base case. However, this does not indicate a total lack of potential in the deferral. In fact, we would expect some blocks in the deferral to be leased and possibly drilled, and perhaps sub-economic volumes of hydrocarbons discovered. This would significantly contribute to area delineation of geology. Also, if an infrastructure is created for a major discovery in the alternative, any sub- economic discoveries in the deferral could become economic in the future by linking into the infrastructure. Furthermore, although our current interpretation of data does not provide any evidence to support a major A-12 HT, discovery in the deferral, it is certainly possible. Therefore, the blocks within the deferral are important for the upcoming sale. The procedures used to determine these different categories of resource estimates are similar in all cases. While subjectivity exists in determining inputs and which prospects are likely to be leased, judgments are consistently applied by specialists in each discipline. For example, inputs such as acreage and net pay are provided by geologists, reservoir engineering parameters are estimated by petroleum engineers, and so forth. The advantages of the model are that subjective judgments of subject matter experts are handled in an objective manner and written documentation of the various judgments is provided so that the estimates can be readily updated in the future as new information and interpretations become available. Rationale for Multiple Scenarios in Environmental Impact Statements (EIS’s) Estimates of remaining undiscovered, economically recoverable oil and gas in a proposed sale area are reported in E1S’s to provide the basis for an assessment of the environmental, social, and economic impacts which might realistically be assumed to result from a specific sale. Resource estimates serve as the focus of the assumed exploration and development activities that are fundamental to a rigorous assessment of the potential effects of a proposed sale. Formerly, the impact analyses for sales were conducted on the conditional mean sale area resource (except in the Gulf of Mexico) with a much abridged high (5th percentile) and low (95th percentile) case analysis separated from the primary analysis. The assumption that the total resources estimated to be present in the sale area would be leased, developed, and produced as a result of the sale overstated the level of activity that would result. Since the bulk of the analysis involved the mean resource, a perception developed among some readers that this amount of resource would, in fact, be discovered and produced. This and the resulting estimates of subsequent exploration and development activities acquired a validity among some readers that generally could not be supported by the available leasing data. The uncertainty inherent in the estimates and by inference in the complex series of environmental, economic, and social effects predicated on them needed to be emphasized. Recognizing the inherent uncertainty associated with resource estimates, the EIS includes an analysis of a range of potential outcomes as represented by three distinct scenarios. This procedure acknowledges the uncertainties associated with estimating the amounts of resources which will be leased and emphasizes that the resource estimates reflect a range of possibilities. The limits of the range of resources are constrained by a low case and a high case, both of which represent realistic levels of exploration and development activity. Within the range is a base case estimate of resources which are believed likely to be leased, developed, and produced as a result of the sale. The low, base, and high cases and their attendant impacts are presented in the EIS for the proposed action. A-13 The low case presented in EIS’s is used in frontier planning areas where there is a high probability that commercially exploitable resources do not exist and development activities may not occur as a consequence of leasing. Therefore, for most frontier planning areas, the low case analysis considers impacts associated with industry efforts related only to exploratory activities because the resource estimated is usually below that which would be economic to produce. However, in the event that resource estimates for the low case justify commercial development, then development and production will be included in the low case scenario and analyzed. The low case is used in all areas except the Gulf of Mexico and Southern California which have established production or significant discoveries which may lead to production. The base case includes undiscovered resources estimated to be leased, developed, and produced, assuming that hydrocarbons exist in the area (i.e., a conditional estimate), and an estimate of the exploration, development, production, and transportation activities appropriate to that level of resources. The base case estimate is presumed to be the likely result if hydrocarbons are present in the sale area in commercial quantities and if the sale occurs as proposed. Most of the analytical effort is focused on the base case because it represents the resource quantity that is expected to be found and developed as a result of the sale if hydrocarbons are present in economic volumes in the sale area. Post-exploration National Environmental Policy Act analysis is obviously pointless if commercial oil and/or gas does not exist; therefore, the base and high case resources are reported as conditional estimates because these estimates assume that economically recoverable hydrocarbons exist and will be discovered, developed, produced, and transported to the market. The base case estimate reflects the following: successes or failures since the previous sales in a planning area; previous leasing rates; perceived industry interest; costs associated with exploration and development; existing infrastructure to transport oil or gas to market; and so forth. The high case is an estimate of a significantly higher level of resource recovery and attendant exploration and development activity which could result from leasing more acreage than may occur in the base case, or which could result from the discoveries of larger oi] and gas accumulations than estimated under the base case assumptions. The high case estimate is a larger but still reasonable quantity of resources which very likely produce distinctly different impacts. Ordinarily, the effects of this scenario would be higher than those of the base case because they are predicated on more and larger discoveries. It represents a more optimistic scenario and assumes higher than expected leasing rates, favorable geologic conditions, or improved economics. An examination of these three levels of resources and subsequent development will cover the range of probable outcomes and impacts which could be anticipated to occur as a result of a sale. The object of the three-case analysis (base and high cases only in mature, producing planning areas) is to scrutinize a spectrum of activity levels, rather than to assess a single scenario which can change because specific A-14 estimates change during the 2- to 3-year prelease process. Representing resource estimates as a range recognizes the uncertainties associated with the estimation methodologies and allows some flexibility if the estimates should change. Regional offices develop base case resource estimates consistent with the data available to them. The Gulf of Mexico Region uses a historical approach which derives the base case from a rigorous analysis of past leasing rates. The result is a time-dependent decline in resource volume for a succession of sales, wherein each sale is assumed to contribute a percentage of the total planning area resource. Other Regions use (with variations) a methodology which extracts and aggregates the resource volumes of those prospects considered most attractive from the PRESTO data base. These prospects usually have high industry interest and are the most likely to yield the highest rate of financial return by reason of size, distance from shore, proximity to transportation infrastructure, water depth, etc., and are thus the most likely to be leased as a result of the sale. IV. Exploration and Development Scenarios Infrastructure for each Environmental Impact Statement (EIS) scenario (low, base, and high cases) is estimated for the Exploration and Development (E&D) Report based on the amounts of conditional resources estimated to be leased and subsequently discovered and developed. An exploration-only scenario results when there is an insufficient quantity of resources in the low case to justify development but only an exploration effort is carried out. The E&D Report is composed of timetables with the yearly numbers of successful and unsuccessful exploration, delineation, and production wells for oi] and gas, the number of platforms, oil and gas pipeline miles and production schedules. The E&D infrastructure is estimated using methodologies which are specific to each Minerals Management Service Region and which are based on the amount of historical information available, evaluator’s professional judgment, and the geologic, engineering, and economic uncertainties associated with each sale area. An EIS impact analysis based on these three distinct scenarios that are derived from a range of resource estimates, provides decisionmakers with a realistic assessment of the consequences of leasing. V. Resource Estimates for Cumulative Analysis* In August 1989, the U.S. Geological Survey and the Minerals Management Service published the National Oil and Gas Resource Assessment (NOGRA) of the undiscovered conventionally recoverable oil and natural gas resources of the United States (Mast, et al., 1989). It considered new geological, technological, and economic information and uses more definitive methods of resource appraisal than previous assessments. The assessment was conducted over a period of more than 2 years and reflects data and information available as of January 1, 1987. The resource estimates for Chukchi *This discussion is limited to the methodology used to determine the resource estimates for the OCS in the Arctic Subregion. A-15 Beaufort, and Hope Planning Areas included in the NOGRA were updated as of January 1, 1990, to include use of geological and geophysical data in these planning areas purchased and available through January 1, 1989. The updated NOGRA is the basis for the generation of both the sale area resource estimates and the cumulative case resource estimate. The cumulative case number will be arrived at by use of a probabilistic method (known as the USGS Crovelli model) which will yield a range of values. The methodology aggregates distributions (not single point estimates) while honoring the marginal probabilities for each of those distributions. Conditional resource estimates are not directly comparable between planning areas since they are generally based on different marginal probabilities. A regional or subregional resource estimate derived from the NOGRA will be provided for the cumulative case analysis for individual lease sale EIS’s. This resource estimate takes into consideration the different marginal probabilities of each planning area. It provides a resource estimate that gives a better indication of the likelihood of oil and gas activities occurring within the region or subregion over the life of the proposal, and provides consistency in the cumulative analysis from one EIS to the next in the region or subregion. Therefore, the life of the proposal considers past and future sales as well as the current sale, and includes both leased and unleased resources. For the purposes of EIS analysis, conditional mean resource estimates derived for any subregion assume that the sales on the 5-Year Schedule in that subregion will result in exploration, development, and production. Although a precise schedule will not be developed for when that activity will occur, it is logical to assume that some exploration and/or development could occur from more than one sale in the subregion at the same time, and this could continue throughout the life of those sales. The cumulative number will remain the same until the NOGRA is changed. Consequently, the analysis of the cumulative case for a sale in a given region or subregion will be similar for all other sales in that region or subregion, provided the NOGRA does not change. There will likely be some differences in the discussion of the contribution of the proposal to cumulative impacts from EIS-to-EIS. This will provide a consistent analysis of the cumulative case for all sales on the 5-Year Schedule in a given region or subregion. This avoids the problem of using a different basis for the cumulative analysis in a given area from one EIS to the next, which would result in inconsistent, conflicting analyses in the EIS’s. For Sale 126 the updated NOGRA resource estimates for the Chukchi, Beaufort, and Hope basins were aggregated using the USGS Crovelli model to develop a cumulative Arctic Subregion resource estimate. For the cumulative estimate the marginal probability increases as we would expect to 0.32 with an A-16 associated conditional mean estimate of 5.48 billion barrels of oil. The cumulative resources for the Arctic Subregion are as follows: Undiscovered, Economically Recoverable Resources for the Arctic Sea Subregion (leased and unleased) Oil Gas (Billion Barrels) (Trillion Cubic Feet) Conditional 95th Percentile 4.29 0.00 Mean 5.48 0.00 5th Percentile 6.87 0.00 Marginal Probability = 0.32 Risked 95th Percentile 0.00 0.00 Mean 1.74 0.00 5th Percentile 6527 0.00 For a full analysis of the cumulative case impact, please see the section of the EIS addressing the analysis of the cumulative case. That discussion contains analyses of cumulative considerations that go beyond just the cumulative resources described above. A-17 APPENDIX B EXPLORATION AND DEVELOPMENT REPORT SALE 126 CHUKCHI SEA Exploration and Development Scenarios Three scenario schedules for the Sale Area Proposal of figure 1 are attached. The first schedule shows a low case, the second a base case, and the third a high case. The base case is designed for oil discoveries totaling 1,610 million barrels (1.61 BBO) and the high case for 3,540 million barrels (3.54 BBO). Also discussed is the mean cumulative case and the Point Lay Deferral Alternative case. The mean cumulative case will combine exploration and development efforts from each of three planning areas, including the Chukchi Sea, the Beaufort Sea, and the Hope Basin. The table below outlines the principal locations for shorebase facilities as well as the _ principal transportation mechanisms. Alternative scenarios are provided for the Beaufort Sea and Hope Basin Planning Areas, but are economically less attractive than the primary scenario. Two scenarios are provided for the Chukchi Sea Planning Area, their relative economic attractiveness varying according to specific development assumptions. PLANNING AREA Chukchi Sea Chukchi Sea Beaufort Sea Beaufort Sea (ALT) Hope Basin Hope Basin (ALT) SHOREBASE FACILITY Nome Pt. (PT.) Belcher West Dock or Oliktok Pt. Barrow area, Pitt Pt., Oliktok Pt., and Pt. Thomson Nome Kivalina B-1 TRANSPORTATION MECHANISM Pipeline south across Lisburne and Seward Peninsula to tanker terminal at Nome Pipeline tie-in to Trans-Alaska Pipeline System (TAPS) Offshore Gathering System tied into TAPS Onshore Gathering System tied into TAPS Offshore pipeline via Bering Channel to tanker terminal at Nome or pipeline across Seward Peninsula to Nome terminal Pipeline tie-in to the Trans-Alaska Pipeline System (TAPS) The mean cumulative case, with 5,480 million barrels (5.48 BBO) of oil resource, is programmed for 48 exploratory wells, 20 delineation wells, 11 production platforms, and 685 development wells, one-fourth of which are assumed to be service wells. The most likely choice for exploratory drilling vessels for Sale 126 will be drillships with icebreaker support or arctic-class semisubmersibles. Drilling rate would be 1.5-2 wells per year per exploratory rig. Production platforms would be inverted cone shaped, gravity based concrete structures suitable for extreme ice conditions. Each platform will use two rigs to maximize well drilling rates. At least one rig will remain on each platform for remedial workovers. For the base case, produced oil may be transported to domestic markets under two scenarios. The first scenario employs an offshore trunk and lateral gathering system (200 miles) with landfall at or near Cape Lisburne. Oi] would be transported south across the Lisburne and Seward Peninsulas (310 miles) and the Kotzebue Sound (40 miles) via elevated and trenched pipelines, respectively. Oil would be loaded into Class 3 tankers at a Nome shorebase facility and transported to market. The second scenario employs a similar offshore gathering system with landfall at or near Point Belcher, where oil would be transported via a 400-mile elevated pipeline across the National Petroleum Reserve-Alaska and tied into the Trans-Alaska Pipeline System (TAPS) at Pump Station No. 2 or Pump Station No. 3. Oil would be pumped to Valdez and loaded into conventional tankers destined for the U.S. West Coast. Under exiting TAPS tariffs, the first and second scenarios are economically equivalent. However, any future increase in the TAPS tariff suggests an economic advantage to the first scenario. Under the high case, the first scenario has a 5 to 10 percent economic advantage over the TAPS tie-in scenario. If non-domestic markets become available, the first scenario has a 20 percent economic advantage in the base case and a 35 percent economic advantage in the high resource case. This advantage is largely due to the use of non-Jones Act Vessels. Gas production is presently uneconomic in all cases, assuming it must be marketed on the U.S. West Coast. The cost of platforms, wells, pipeline, liquefaction plant, tankers, and regasification is much higher than any projected return based on current price forecasts for the gas. The market price is not forecast to rise sufficiently during the sale scenario to change this conclusion. Produced gas, not flared or used as fuel, will be reinjected for pressure maintenance. Also, no economically recoverable natural gas is indicated in a recently released Department of Interior document entitled Estimates of Undiscovered Conventional Oil and Gas Resources in the United States - A B-2 Part of the Nation’s Energy Endowment (Mast etal, 1989). This NOGRA document received considerable review within the Department as well as peer review from outside agencies and organizations. It relates the Los Angeles future market price of natural gas to the Los Angeles future aa price of oil, on a heat energy basis, with gas at an indicated iscount. Oil must be priced at about $30 per barrel in that market, in 1987 money, for Alaska’s lowest cost gas to be marketed there, and at about $100 per barrel for Alaska’s highest cost gas to be marketed there. Potential gas from Chukchi would fall near the $100 per barrel price extreme. When using current price forecasts, Chukchi gas would clearly be even less economic, for a Los Angeles or West Coast market, throughout this lease sale scenario. Additional insight into the economics of Alaska’s natural gas may be gained by considering the status of known very large reserves of gas at Prudhoe Bay. The Yukon Pacific Corporation has endeavored to promote a complete pipeline, LNG plant, and tanker system for marketing about 2 billion cubic feet per day in the Orient. On December 3, 1987, an "Application of Yukon Pacific Corporation for Authorization to Export Liquefied Natural Gas from the United States" was placed before the Economic Regulatory Administration. This included a study paid for by ARCO, one of the Prudhoe gas owners, which concluded that the project was not economically feasible. Its scenario included favorable foreign flag vessels to a Japanese market, and its unfavorable heavy up-front cost was the pipeline at $6.8 million per mile. Exploration and delineation wells will average 10,400 feet measured depth, ranging to nearly 14,000 feet. Production and service wells would be 11,000 feet average direcionally drilled total depth. Leases are assumed to be for 10 years. Note that the schedules assume no litigation or regulatory delays. Platform years shown on the schedules are the years of final placement of platforms on location and hooked up for commencement of production drilling. Offshore loading facilities, if used, are constructed at the same time as the platforms. Muds and Cuttings for Base Case The average exploration well will dispose 660 short tons of dry mud and produce 850 short tons of dry rock cuttings. The average delineation well will dispose 660 short tons of dry mud and produce 850 short tons of dry rock cuttings. The average development well will dispose from 110 to 700 dry net short tons of mud and produce 925 short tons of dry rock cuttings. B-3 The mud discharged will have this typical composition: Component Weight % Barite 63.0 Clay 24.0 Lignosulfonate 2.0 Lignite 135) Sodium hydroxide 125) Other 8.0 Total 100.0 Source: Petrazzuolo, 1983. Change _in the Level of Activity from the Base Case to the Deferral Alternatives The estimated volume of hydrocarbon that is expected to be discovered in the Point Lay Deferral Alternative shown in figure 1 is 1610 million barrels of oil. An exploration and development schedule for this alternative is shown in table 4. Our current interpretation of available data suggests a negligible difference in resources expected to be developed and produced for Sale 126 between this alternative and the base case. However, this does not indicate a total lack of potential in the deferral. In fact, we would expect some blocks in the deferral to be leased and possibly drilled, and perhaps sub-economic volumes of hydrocarbons discovered. This would significantly contribute to area delineation of geology. Also, if an infrastructure is created for a major discovery in the alternative, any sub-economic discoveries in the deferral could become economic in the future by linking into the infrastructure. Furthermore, although our current interpretation of data does not provide any evidence to support a major discovery in the deferral, it is certainly possible. Therefore, the blocks within the deferral are important for the upcoming sale. B-4 U.S. DEPARTMENT OF THE INTERIOR MINERALS MANAGEMENT SERVICE CHUKCHI SEA LEASE SALE 126 162° 169° ° 165° 69 “4 yg OR age —— PROPOSED CHUKCHI SEA SALE 126 AREA (ALTERNATIVE |) 72° ALTERNATIVE IV—POINT LAY DEFERRAL # LEASED BLOCKS 166 169° + 71° ; eZ. at Sh Peard Bay @ SS & Wainwright J | ° NRA-4 ss Map Location NR2-6|NR3-5 NR3-6 | 69° ~6; 4 LE + az » [ Lisburne a am” Source: MMS Alaska OCS Region Pt. H ae NOVEMBER 1989 Cape Thompson NR2-8 | NR3-7 rs 1. 9-4 1. EXPLORATION AND DEVELOPMENT SCHEDULE SALE 126 LOW CASE Sale Exploration Delineation Explor/Delin Production Prod/Service Production Number of Production Pipeline Year Wells Wells Rigs Platform Wells Rigs Shorebases _MMB_ BCF Miles Oil__ Gas Oil___Gas Oil__ Gas Oil _Gas__Oil_ Gas * nore rm nm eee eR PWNHMH/OCOUWU OND Ww — ion eee wooOna IW PO PO PO PIP | PY PY Po |P SCO ONDNSWMHr-|O TOTALS 2 oO Oo ' oO Oo Oo Oo ' O** 430** 0 Oo oO * Sale Year 1 = Calendar Year 1991 ** This resource is below the minimum economic resource required for development. c-4 2. EXPLORATION AND DEVELOPMENT SCHEDULE SALE 126 BASE CASE Sale Exploration Delineation Explor/Delin Production Prod/Service Production Number of Production Pipeline Year Wells Wells Rigs Platform Wells Rigs Shorebases MMB BCF_ Miles Qil__ Gas Oil Gas Oil Gas Oil Gas Oil Gas |* 2 4 4 3 6 4 5 wie. 4 6 3 5 4 5 4 8 4 4 6 3 1 3 7 3 3 8 2 2 9 200 10 2 8 4 200 11 2 40 8 150-200** 12 2 60 12 101 13 80 12 135 14 26 12 135 15 135 16 135 17 135 18 119 19 103 20 92 21 82 22 73 23 64 24 58 25 52 26 47 27 42 28 37 29 34 30 31 TOTALS 28 11 0 - 6 0 214 0 - 1.0 1610 0 550-600** 0 * Sale Year 1 = Calendar Year 1991 ** Pipelay schedule is ranged to encompass two development scenarios (see text). 8-d 3. EXPLORATION AND DEVELOPMENT SCHEDULE SALE 126 HIGH CASE Sale Exploration Delineation Explor/Delin Production Prod/Service Production Number of Production Pipeline Year Wells Wells Rigs Platform Wells Rigs Shorebases MMB __ BCF Miles Oil __Gas Oil Gas Oil___Gas Oil Gas Oil Gas \* 2 4 4 3 6 4 6 ae 4 6 3 5 4 5 5 3 5 4 6 4 2 4 iL 4 2 4 8 3 1 3 9 2 1 2 10 2 2 2 200 11 1 1 6 40 8 200 12 4 80 16 150-200** 13 140 24 223 14 140 24 297 15 72 24 297 16 297 7 297 18 297 19 262 20 227 21 202 22 181 23 159 24 142 25 128 26 113 27 103 28 92 29 82 30 74 ol 67 TOTALS 37 16 0 - 12 0 472 0 - U 3540 0 550-600**0 * Sale Year 1 = Calendar Year 1991 ce es ee ee a EEE! 6-4 4. EXPLORATION AND DEVELOPMENT SCHEDULE SALE 126 POINT LAY DEFERRAL ALTERNATIVE Sale Exploration Delineation Explor/Delin Production Prod/Service Production Number of Production Pipeline Year Wells Wells Rigs Platform Wells Rigs Shorebases MMB BCF Miles Oil___Gas Oil Gas Oil __Gas Oi] _Gas__Oil__Gas 1* 2 4 4 3 6 5 5 2 4 6 3 5 4 5 4 3 4 4 6 3 1 3 7 3 3 8 2 2 9 200 10 2 8 4 200 11 2 40 8 150-200** 12 2 60 12 101 13 80 12 135 14 26 12 135 15 135 16 135 17 135 18 119 19 103 20 92 21 82 22 73 23 64 24 58 25 52 26 47 27 42 28 37 29 34 30 31 TOTALS 28 11 0 - 6 0 214 0 - 1.0 1610 0 550-600** 0 * Sale Year 1 = Calendar Year 1991 ** Pipelay schedule is ranged to encompass two development scenarios (see text). APPENDIX C OIL-SPILL-RISK ANALYSIS OIL-SPILL-RISK ANALYSIS I. OIL-SPILL-TRAJECTORY SIMULATIONS For the Sale 126 base and high cases and the Point Lay Deferral Alternative, oil-spill trajectories were simul- ated by the Rand Corporation in Santa Monica, California, using Rand’s three-dimensional circulation, weather, and spill-trajectory models (Liu and Leendertse, 1987). The Rand Corportation model description and documentation as contained in Liu and Leendertse (1987) is incorporated by reference; a summary of this description, as augmented by additional material, as cited, follows. A three-dimensional hydrodynamic model is coupled to a two-dimensional stochastic weather model and an oil-spill-trajectory model. The three dimensional hydrodynamic model is formulated according to the equations of motion for water and ice, continuity, state; the balance of mass, heat, salt, pollutant; and turbulent energy densities, on a three-dimensional finite grid (Liu and Leendertse, 1987). The vertical momentum, mass, heat, and turbulent energy exchange coefficients are computed from the turbulent energy; thus, the model contains a turbulence closure (Liu and Leendertse, 1987). The basic equations are derived in Liu and Leendertse (1978). Local wind stress was modeled using a method called the unit-response function. Response functions are generated by the differences in the currents in the three-dimensional field with and without the wind stress under identical tidal conditions. Under ice-free conditions, the response function (coupled with the stochastic weather model) together with the local residual current was used to compute the movement of oil. The stochastic weather model periodically interrupts to enter a storm track model. Oil movement underneath the ice is more complicated. When the relative speed between the ice and water is below a critical threshold value, the oil will be contained by the underside roughness of the ice. The threshold value is a function of the density of oil and water, the surface tension between oil and water, the underside roughness of the ice, and the thickness of the oil. When the threshold value is exceeded, the oil begins to move at a speed proportional to the speed of the water. The details of these computations can be found in Liu and Leendertse (1981a,b). Essential model components and their interrelationships are shown in Figure C-1. Weathering, toxicity, and oil dispersion are considered and taken into account in this EIS, but are not part of the trajectory analysis; see Section IV.A.2. The actual modeled trajectories are center-of-mass trajectories. Rand Corporation transmitted 12-hour-trajectory positions to Minerals Management Service (MMS), Branch of Environmental Modeling (BEM). The BEM applied trajectories to land/boundary segments and to environmental-resource areas identified by MMS, Alaska OCS Region, to determine the environmentalrisk factors. A. Winter Trajectories: The modeled winter is 227 days from November 1 to June 15. For winter, the Rand Corporation simulated 45 trajectories from each of 26 hypothetical spill sites (J3-J13, J18-J25, and J30-J37; Fig. [V-A-2 of this EIS) totaling 1,170 winter trajectories. Oil spills are staggered, representing an equally likely occurrence chance throughout the entire 7.5-month winter season. Winter trajectories were simulated for the entire winter period to account for oil frozen into winter ice (see Sec. IV.A.3 of this EIS) until breakup. Thus, some winter trajectories were modeled for up to 7.5 months. In the modeled winter, oil moves with ice or water depending on the differential velocity of ice and underlying water. The oil-spill-trajectory model does not include the time-dependent oil freezing into ice. For smooth first-year ice, the differential velocity of the water has to be greater than about 15 cm per second to strip oil from the underside of the ice. Rough first-year ice or multiyear ice requires greater velocities to strip oil. Because ice and underlying water are being moved by the same forces, the necessary differential velocity is seldom reached; and oil almost always moves or stays with the ice, regardless of whether the oil was spilled onto, into, or underneath the ice (see Sec. IV.A.3). Simulated winter-spill trajectories were stopped when (1) the oil contacted land, (2) the oil moved beyond the boundaries of the model, or (3) breakup occurred. B. Summer Trajectories: The modeled summer is 138 days from June 16 through October 31. In June, the average ice concentration near the 70th parallel is approximately 4 oktas and the water column is strongly stratified. Trajectories are computed using the ice-concentration data and a three-dimensional Cc-1 model reflecting the stratified water column. Summer trajectories were computed from the 26 hypothetical spill sites (J3-J13, J18-J25, and J30-J37). Under equally likely probability, oil is spilled every 5 days from the 26 hypothetical spill sites, providing 30 trajectories per launch point, totaling 780 summer trajectories. Simulated summer-spill trajectories were stopped when (1) oil contacted land, (2) the oil moved beyond the boundary of the model, or (3) the trajectory simulations reached 31 days. The MMS emphasizes that the simulated trajectories represent hypothetical oil-slick pathways. The simulated trajectories do not account for cleanup, dispersion, or weathering processes that could determine the quantity or quality of oil that might eventually come in contact with environmental resource. C. Conditional Probabilities: Trajectory-simulation results are presented as conditional and combined probabilities. The probability that if an oil spill occurred at a specific spill site, it would contact either a land/boundary segment or an environmental-resource area is termed a conditional probability. Conditional probabilities assume that a spill occurs; they do not consider the likelihood of a spill occurring--a function of the presence and amount of oil and transportation assumptions. The conditional probabilities give the percentage chance of oil from that hypothetical spill site contacting specific land/boundary segments and environmentalresource areas. The conditional probabilities are useful in identifying areas that pose the highest chance of contact to specific environmental-resource areas and land/boundary segments, should spills occur. Two sets of conditional probabilities are used in this EIS: (1) contacts with summer spills during open water (this appendix, Tables C-1 through C-6) and (2) contacts with winter spills during winter (this appendix, Tables C-7 through C-12). II. ESTIMATED OIL-RESOURCE AND RESERVE VOLUME Uncertainties exist in estimating the oil-resource volume that may be discovered and produced as a result of an OCS lease sale. The Sale 126 analysis uses three oil-resource levels to represent the amount of oil that could be found if economic oil quantities are discovered (Sec. II.A). There is a 21-percent chance that commercial hydrocarbon quantities may be found as a result of the Sale 126 base and high cases and the Point Lay Deferral Alternative. For the low case, the estimated oil- resource volume is considered uneconomic, and only exploration is assumed. For the base and high cases and the Point Lay Deferral Alternative, the estimated oil-resource volume is assumed to be leased, found, and produced. The estimated mean number of > 1,000-bbl spills and, accordingly, the OSRA results reflect the estimated oil-spill risk based on the oil-resource-volume estimates for the base and high cases and the Point Lay Deferral Alternative. The entire oil-resource volume is used in simulating OSRA combined-probability results for both the summer and winter simulations. Seasonal production is not accounted for in the OSRA. The cumulative case OSRA includes only the estimated mean number of > 1,000- bbl spills and the probabilities of one or more > 1,000 bbl-spills; no trajectory simulations and, therefore, no conditional or combined probabilities are calculated. The cumulative-case mean-spill number is based on oil-resource and oil-reserve volume estimates for the U.S. Arctic OCS, ANWR, NPR-A, State of Alaska leases, other leases, and Canadian Beaufort Sea (Table 1V-A-1 of this EIS). Oil resources are undiscovered resources. Oil reserves are discovered resources. Where oil-reserve estimates are not available--for example, OCS dis- coveries at Tern, Sandpiper, and Hammerhead Prospects--these discoveries are not included in the estimated mean-spill number. Additional offshore lease sales have been held or are planned by the State of Alaska; but no reserves or resources have been reported for these State sales, and these sales are not included in the mean-spill number for the cumulative case. The Geological Survey of Canada estimates Canadian Beaufort Sea reserves at 1.74 Bbbl and (undiscovered) resources at 3 Bbbl (Dixon et al., 1988). The Sale 126 cumulative-case OSRA includes the discovered 1.74 Bbbl; the additional 3 Bbbl of resources are not included in the cumulative-case estimated-mean-spill calculations. Ill. TRANSPORTATION ASSUMPTIONS In the analysis of the Sale 126 base and high cases and the Point Lay Deferral Alternative, a transportation c-2 scenario is assumed: oil is transported from offshore drilling units by offshore pipeline (Fig. IV-A-2 of this EIS). For the base and high cases, J4-J8, J11-J13, J20-J25, and J30-J37 are considered hypothetical platform and pipeline spill sites; and J3, J9, J10, and J18 are considered hypothetical pipeline spill sites. In the Point Lay Deferral Alternative, J4-J8, J11, J20, J22-J25, J30-J32, J35, and J37 are considered hypothetical platform- and pipeline-spill sites; and J3, J9, J10, J12, J13, J21, J33, J34, and J36 are considered hypothetical pipeline- spill sites. The Point Lay Deferral Alternative removes hypothetical platform-spill sites J12, J13, J21, J33, J34, and J36 but retains them as hypothetical pipeline-spill sites. The offshore pipeline landfalls at Point Belcher. The onshore pipeline traverses NPR-A to a connection with the Trans-Alaska Pipeline (TAP). From there, it is transported south by TAP to Valdez and then shipped to the continental U.S., Panama, Hawaii, or the U.S. Virgin Islands by tankers. Although cumulative-case trajectory simulations are not included in this EIS, an assumed transportation scenario is necessary to calculate a cumulative-case estimated-mean-spill number. The transportation scenario used for the base and high cases is assumed for the cumulative case with the addition of tankering along the TAP route. Note that these transportation scenarios are hypothetical and are put forth only to aid in analyzing possible effects. Use of any transportation route would depend on finding commercial quantities of oil, where that oil is found, and subsequent environmental and economic analyses of transportation modes and routes. IV. PROBABILITY OF OIL SPILLS OCCURRING The procedures and statistics MMS uses to calculate frequencies and probabilities of > 1000-bbl spills are described and discussed in detail in Nakissis (1982), Lanfear and Amstutz (1983), Amstutz and Samuels (1984), and Anderson and LaBelle (1990). This information is incorporated by reference; a summary of this information, as augmented by additional material, as cited, follows. A. Projected Spillage: The expected number of > 1,000-bbl spills is calculated as proportionate to the volume of oil produced and transported. The spill-rate constant is based on historical accidents, expressed in terms of the number of spills per 10° bbl of oil produced or transported (Table C-12a). The spill-rate constant is multiplied by the estimated oil-resource volume to derive an estimated-mean-spill number. Spill Rates: Oil spills > 1000 bbl from tankers, platforms, and pipelines were analyzed (Anderson and LaBelle, 1990). Platform- and pipeline-spill rates were derived from U.S. OCS-spill data from 1964 to 1987. For U.S. OCS platforms and pipelines, nonparametric tests indicated that the spill rate, based on volume of oil handled, had declined over time (Anderson and LaBelle, 1990). For worldwide tankers, the spill rate, based on volume of oil handled, had remained constant. U.S. OCS-platform- and pipeline-spill-rates are 0.60 and 0.67, respectively, per 10° bbl (Anderson and LaBelle, 1990). Worldwide tanker-spill rates are 0.90 at sea and 0.40 in part per 10° bbl (Anderson and LaBelle, 1990). Table IV-A-1 of this EIS shows the statistically estimated mean number of spills > 1,000 bbl that could occur as a result of the base and high cases, the Point Lay Deferral Alternative, and the cumulative case. Sale 126 estimated-mean-spill numbers are derived using the platform-, tanker-, or pipeline-spill rate according to the assumed transportation scenario. For example, the base-case oil-resource estimate is multiplied by the pipeline-spill rate (1,610 MMbbI x 0.67 spills/Bbbl = 1.08 pipeline spills) and the platform-spill rate (1,610 MMbbI x 0.69 spills/Bbbl = 0.97 platform spills). Combining platform and pipeline spills for the base case, the total estimated-mean-spill number is 2.05 (1.08 + 0.97 = 2.05; Table IV-A-1). B. Most Likely Number of Spills: In this EIS, analysts use the "probability of one or more spills" occurring or contacting a resource. For situations where the probability of two or more spills becomes greater than the probability of one spill, the analysts also refer to and use the "most likely number of spills." Poisson Distributions: Devanney and Stewart (1974) showed that the probability of oil-spill contacts can be described by a negative binomial distribution. Smith et al. (1982) noted that when the actual exposure is much less than the historical exposure, as is the case for most oil-spill-risk analysis, the negative binomial distribution can be approximated by a Poisson distribution. The probabilities of > 1,000-bbl spills occurring are calculated from the estimated-mean-spill number through use of standard (Poisson) statistical c-3 distributions governing the occurrences of rare, random events (Smith et al., 1982). The relationship between the most likely number of spills (mode), the estimated-mean-spill number, and the probability distribution for various numbers of spills is shown in Figure IV-A-3 of this EIS for the base and high cases, the Point Lay Deferral Alternative, and the cumulative case for the Arctic. For the base case and the Point Lay Deferral Alternative, the most likely number of spills > 1,000 bbl is two. For the high case, the most likely number of spills > 1,000 bbl is four. For the cumulative case, the most likely number of spills > 1,000 bbl is 10 for the Arctic Ocean, 15 for PWS/GOA, and 26 total. C. Probability That Spills of at Least 1,000 bbl Would Occur: The likelihood of one or more spills > 1,000 bbl occurring under the base and high cases and the Point Lay Deferral Alternative is high due to the high estimated-oil-resource volume. For the base case and the Point Lay Deferral Alternative, MMS estimates an 87-percent chance that one or more oil spills > 1,000 bbl would occur in the Chukchi Sea over the life of the field (Table IV-A-1) and a 99-percent chance that one or more spills would occur for the high case. For the cumulative case, there is a >99- percent chance that one or more oil spills > 1,000 bbl would occur in the Chukchi Sea over the life of the field (Table IV-A-1). D. Probability th: ills > 1. 1 Woul Wi n horeline or Environmental- Resource Areas: As part of the OSRA, the conditional probabilities (probabilities that if a spill occurred, it would contact shoreline or environmental-resource areas) are combined with the spill rates, transportation scenarios, and the unrisked base-case and high-case oil-resource estimates to yield overall, combined probabilities for contact with spills > 1,000 bbl. Thus, these probabilities include both the likelihood that a spill would occur and whether the spill would contact shoreline or environmental-resource areas. The associated Monte Carlo error for combined probabilities--because all trajectories and spill information for all spill sites are incorporated--is much lower than that for conditional probabilities, ranging from +1 to +2 percent. Combined probabilities for the base and high cases and the Point Lay Deferral Alternative are introduced in Section IV.A.1 and are used by EIS analysts to evaluate the likelihood of effects throughout Section IV. Combined- probability tables are provided for the base and high cases and the Point Lay Deferral Alternative in Tables C-13 through C-20 of this appendix. Land/ boundary segments are identified in Figure IV-A-1 and environmental-resource areas in Figures IV-C-1, IV-C-2, IV-C-3, and IV-C-7. c-4 Bibliography Amstutz, D.E. and W.B. Samuels. 1984. Offshore Oil Spills: Analysis of Risks. Marine Environmental Research 13:303-319. Anderson, C. and R.P. LaBelle. 1990. Estimated Occurrence Rates for Analysis of Accidental Oil Spills on the U.S. Outer Continental Shelf. Oil and Chemical Pollution 6:21-35. Devanney, M.W., III, and R.J. Stewart, 1974. Analysis of Oilspill Statistics, April 1974. Report No. MITSG-74-20. Prepared for the Council on Environmental Quality. Cambridge, MA: Massachusetts Institute of Technology, 126 pp. Dixon, J., G.R. Morrell, J.R. Detrich, R.M. Procter, and G.C. Taylor. 1988. Petroleum Resources of the MacKenzie Delta-Beaufort Sea. Open-File Report 1926, Geological Survey of Canada, 74 pp. Lanfear, K.J. and D.E. Amstutz. 1983. A Reexamination of Occurrence Rates for Accidental Oil Spills on the U.S. Outer Continental Shelf. In: Proceedings of the 1983 Oil Spill Conference. Washington, DC: American Petroleum Institute, pp. 355-365. Liu, S.K. and J.J. Leendertse. 1987. Modeling the Alaskan Continental Shelf Waters. Report R-3567-NOAA/RC. Prepared for USDOC, NOAA. Santa Monica, CA: The RAND Corporation. Liu, S.K., and J.J. Leendertse. 1981la. A 3-D Oil Spill Model With and Without Ice Cover, Mechanics of Oil Slicks. Paris, France: Association Amical des Ingenieurs, and International Association for Hydraulic Research, pp. 247-265. Liu, S.K. and J.J. Leendertse. 1981b. A Three Dimensional Model of Norton Sound Under Ice Cover. In: Proceedings of the Sixth International Conference on Port and Ocean Engineering Under Arctic Conditions, POAC, Quebec, Canada, pp. 433-443. Liu, S.K. and J.J. Leendertse. 1978. Multidimensional Numerical Models of Estuaries and Coastal Sea. Advances in Hydroscience, Vol. II. New York, NY: Academic Press, pp. 95-164. Nakissis, A. 1982. Has Offshore Oil Production Become Safer? Open-File Report 82-282, 26 pp. USDOI, USGS. Smith, R.A., J.R. Slack, T. Wyant, and K.J. Lanfear. 1982. The Oilspill Risk Analysis Model of the U.S. Geological Survey. USGS Professional Paper 1227. Washington, DC: US Government Printing Office, 40 PP. c-5 Table Table Table Table Table Table Table Table Table Table Table Table Table Table Table Table C-1 c-2 c-8 c-9 c-10 c-11 c-12 C-12a C-13 C-14 c-15 Oil-Spill-Risk Analysis List of Tables Conditional probabilities (expressed as percentage site will contact a certain environmental resource Conditional probabilities (expressed as percentage site will contact a certain environmental resource Conditional probabilities (expressed as percentage site will contact a certain environmental resource Conditional probabilities (expressed as percentage chance) that during within 3 days chance) that during within 10 days chance) that during within 30 days chance) that during site will contact a certain land segment within 3 days Conditional probabilities (expressed as percentage site will contact a certain land segment within 10 Conditional probabilities (expressed as percentage site will contact a certain land segment within 30 Conditional probabilities (expressed as percentage site will contact a certain environmental resource Conditional probabilities (expressed as percentage site will contact a certain environmental resource Conditional probabilities (expressed as percentage site will contact a certain environmental resource Conditional probabilities (expressed as percentage chance) that during days chance) that during days chance) that during within 3 days chance) that during within 10 days the the the the the the the the summer summer summer summer summer summer winter winter chance) that during the winter over the entire winter season chance) that during the winter site will contact a certain land segment within 3 days Conditional probabilities (expressed as percentage chance) that during the winter site will contact a certain land segment within 10 days Conditional probabilities (expressed as percentage chance) that during the winter site will contact a certain Land segment over the entire winter season oil oil oil oil oil oil oil oil oil oil oil oil Spill rates per billion barrels of oil produced or transported for platforms, pipelines, spill spill spill spill spill spill spill spill spill spill spill spill starting starting starting starting starting starting starting starting starting starting starting starting at at at at at at at at at at at at a a hypothetical hypothetical hypothetical hypothetical hypothetical hypothetical hypothetical hypothetical hypothetical hypothetical hypothetical hypothetical spill spill spill spill spill spill spill spill spill spill spill spill and tankers, based on historical trends Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) occurring and contacting environmental resources over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, base and high cases, based on summer trajectories only Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) occurring and contacting land/boundary segments over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, base and high cases, based on summer trajectories only Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) occurring and contacting land/boundary segments over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, base and high cases, based on winter trajectories only Table Table Table Table Table C-16 C-17 c-18 c-19 c-20 Oil-Spill-Risk Analysis List of Tables (Continued) Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the occurring and contacting environmental resources over the assumed production life of the lease 126, base and high cases, based on winter trajectories only Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the occurring and contacting environmental resources over the assumed production life of the lease 126, Point Lay Deferral Alternative (Alternative IV), based on summer trajectories only Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) area, Chukchi Sea OCS Lease Sale estimated number of spills (mean) area, Chukchi Sea OCS Lease Sale estimated number of spills (mean) occurring and contacting land/boundary segments over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, Point Lay Deferral Alternative (Alternative IV), based on summer trajectories only Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) occurring and contacting land/boundary segments over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, Point Lay Deferral Alternative (Alternative IV), based on winter trajectories only Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the occurring and contacting environmental resources over the assumed production life of the lease 126, Point Lay Deferral Alternative (Alternative IV), based on winter trajectories only c-7 estimated number of spills (mean) area, Chukchi Sea OCS Lease Sale Table C-1. -- Conditional probabilities (expressed as a percentage chance) that during the summer an oil spill st rting at a hypothetical spill site will contact a certain environmental resource within 3 days Environmental Resource Hypothetical Spill Sites J J4 JS J6 J7 J8 JI J10 J1 J13 J18 J20 J21 J22 J23 J24 J25 J30 J31 J32 J33 J34 J3£ J36 J37 Land n n n Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment 10 Seabird Concent. I Seabird Concent. II Bering Strait Area Migrat. Corridor A Migrat. Corridor B Migrat. Corridor C Whale Area A Whale Area B Whale Area C Peard Bay Area Barrow Subsis. Area Wrght. Subsis. Area P. Lay Subsis. Area P.Hope Subsis. Area Any Subsis. Area * * * BREAD DHDDHDDADAPHDDHDHDPaRaD ena aaS PPPAPDPDPDA DADA AaAAPDD eH HPP ReaD WOMYAUEYNH PRaRPRDPDRDABaAaP DAD HDaBDHPoHDHDAAHASD * * POPS PPP HDDBD Ppp penn BBD apoaos x PO PPPPDDDD SPP DD DD DPSS BEB BD * PeaPPPAPDDAD AD DPA APDHPHADBHeH DAD * B PPPPPAPAPAPPDD #eDPPPPDDAPAPDAPDP PAN * PPPPPP ADD P FP PPPAPRPRPAaABAPAB * POD SPP D DDD DSDHA DDDBRABBaBD * * DPE SD ASD DBS SDSS PSB Sas eee POD ASD DASD DAS DS DDD DDS Ds HB BBB AG DOD ASD DDD DDD DASA S ASDA Baa aaa DOD OAD DADS DSDNA D NSB e sees eoo ADD FD FD DAD DD FD HDD HDDS HDHD ADDED FDO DD DDD DAD HBSS BeBe B EDO POPP PDAS DSP DSS DAD DSP D BBE ADD DDD DAD DS OHS HAAS HB BHABHA PUD DAD DDD SDS PHD DBD aH Be Bea PO DDH DDB OD SPH PHA BPRPSDDSASADSDSPSHSHDSPDDDESHSDaPAaSHSaS POD DDD SDD SDDS HBSS HBB BBW eB PODS DODD DAS D DDD SSDS HDD HBB ADD PRPOPRDPRPRDHPHPAaPe Hae Aae PHP Hees HPHePePaS PSUS SDS SSS DSS DSHS BSB On Ha ADS DOS SSSSSDSD BABS a eae ae eAa AAD PSSDDSSDSASD DDD SDH AS Baa D AAAS * * * Note: ** = >99.5 percent; n = <0.5 percent. Table C-2. -- Conditional probabilities (expressed as a percentage chance) that during the summer an oil spill starting at a hypothetical spill site will contact a certain environmental resource within 10 days Environmental Resource Hypothetical Spill Sites J3 54 JS J6 J7 J8 J9 J1O J11 J12 J13 J18 J20 J21 J22 J23 J24 J25 J30 J31 J32 J33 J34 J35 J36 J37 Land Ramin a al nan nm nl eB a an in oa om a a oR Un le Oe) oll ol Sea Segment 1 Biaoaim im 2) sn Pp al fia sa mw om alm oe on alm mn ale oD) lf Sea Segment 2 aoa min 2 n an A FR Ran m2 np mp no a a am a nls lou Sea Segment 3 Qa Ra fa na a A nef) hm a a na Aa em a ee Sea Segment 4 Te am mt oS ae a) cae a ee lon, Sea Segment 5 Rn mo nm a am nm mn api nian @ 2 nm 23 m nn of 2m, mR) A om A a Sea Segment 6 won @* om ia nn ia) alm ie le) ie) ole i) en one in om) on | | Sea Segment 7 n** nm 7 fh D AR ff HR nonaf 5 nm on n on on 40 2 om on on lll lt Sea Segment 8 fa) a.) fa a | a jn ay ah an (na) ee a ain i eo. Sea Segment 9 ayn! mm ie) oo ee le et in in in |) i em | on | a Sea Segment 10 ae an a ae ee i en ee ee ee ee Seabird Concent. I Rom nin ww) alin fm ala in im 2) am ip of) ne on emo om) 2 |e ol) of Seabird Concent. II n n n n n n n n n n n n n n n n n n n n n n n n n n Bering Strait Area Roa) nia B wm nm fn a) a i/o m@ n\n is) a) ois io) ma i) al oe Migrat. Corridor A nf) 2 | w) a 8) A) mh |e 93) Wm) nm |e) a) oe A) ee |) |e le) Migrat. Corridor B hoo) m2) ft on) a) A on a ee ee 28 lee elle) lc lll) lo Se lh OR on Migrat. Corridor C Ro.) mim ot) alia iP a) a in om me le oe) le le ln) oe | oe) le ll lo) ln c-8 Table C-2. (Continued) -- Conditional probabilities (expressed as percent chance) that during the summer an oil spill starting at a hypothetical spill site will contact a certain environmental resource within 10 days Environmental Resource Hypothetical Spill Sites J J10 J11 J12 J13 J18 J20 J21 J22 J23 J24 J25 J30 J31 J32 J33 J34 J35 J36 J37 n n n n wei n wee n n ee a =. a a a a a x a oO i} Whale Area A Whale Area B Whale Area C Peard Bay Area Barrow Subsis. Area Wrght. Subsis. Area P. Lay Subsis. Area P.Hope Subsis. Area Any Subsis. Area * * apaepppoas pppppapaan pons pasa oD poaopnpppaoan peepee aaS praepnanpaDaS epwrepoaass pppRBRaPHSD Peppa aaaD pee PP PED pepper popper aS pppppeaoon ppppppoos ppeppppnas peaoppeanos prppppeanos pppppopoaos ppaepppnpanas PoeepwpDaoD peaprpRpeoaD ppp DoD prppnppopeas ppppppnoas * Pep EBABaD * Note: ** = >99.5 percent; n = <0.5 percent. Table C-3. -- Conditional probabilities (expressed as a percentage chance) that during the summer an oil spill starting at a hypothetical spill site will contact a certain environmental resource within 30 days Environmental Resource Hypothetical Spill Sites J J J J12 J13 J18 J20 J21 J22 J23 J24 J25 J30 J31 J32 J33 J34 J35 J36 J37 non n n a t=} SD LSODRDPDAN FAD DDDADDDAaADDADAwWwOo a Be q a a ry a x PRBPPDDSDDDAHAHDHDASHP DSDHA HDSSHD ae a Land Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Seabird Concent. I Seabird Concent. II Bering Strait Area Migrat. Corridor A Migrat. Corridor B Migrat. Corridor C Whale Area A Whale Area B Whale Area C Peard Bay Area Barrow Subsis. Area Wrght. Subsis. Area P. Lay Subsis. Area P.Hope Subsis. Area Any Subsis. Area BN PRPPHPHDRDADPPHAHDHEHSSHDBPHDHAHwonHaS © © PPDRBDHDHD PADD DAADHAHDHDHDHDDwonaeanHSS PeMmyaueunr ° PPP DPPDPDADPADAD BADD wYNYDEASAaS * * * NB DNAP DSP PDwSeD DDB PAA DDBADHP SD * WED DDDAAADDDBPDDO PRPPPADDDADADD eH RPDwnpanananaaeaesAaaS nN B wo a * * * w w o * 5 5 * SDP FD RDD DDD BNND PPP PEEPS PRPPPRDBRDSPDHADDDSD SDD RDwONND SBD DB Dw * * * * PRPPPPDADDDDDHD DDD DDD eH HDDs aaS te --) PRPRDPDPADDDADADADAPDAD DDD DDD PRPPPPRPRPPPP eon nD aaAaAaAaDaEEaaS PRPAPPADDADD FPDP HDHDDBAPAaPPBAN PRPRPRPRPRPDRPRPRPREPHaHPHE PEPE EE HHA D PRBRDAPAPDDHSDD eH HDHD wAeeeaeeaaHHe HSB PRBRPDRPPPDDEDSDADPPAP DDD HD DwenDD HSS BPSD SSP SASS SBS PSB SBP ese PRPRPRPPPPPDADRPDHPHPAPHPHPHEDBeHDHeHH DS PRPRBADAPDDDDDAHDHDHDHDHDHDDBaHaHaHHHaS PRPRPPAPDDPDDPHPHAHPHDHEHBBFOHPRPAAAS POPPA APRPAaHPPDaDAaDePaaADD ewnagn PRPPPAADAADD eoHNnDDDDeaaHPHaHDHHBSD PPODDRDRDDHBAARPPAaPPAPAPB BPE HHAS PODDADDDDDBAPAaDAaPDDHDHB DPE Note: ** = >99.5 percent; n <0.5 percent. c-9 Table C-4. -- Conditional probabilities (expressed as a percentage chance) that during the summer an oil spill starting at a hypothetical spill site will contact a certain land segment within 3 days Land Segment Hypothetical Spill Sites J3 J4 JS J6 J7 J8 J9 J1O J11 J12 J13 J18 J20 J21 J22 J23 J24 J25 J30 J31 J32 J33 J34 J35 J36 J37 Notes: Land segments having rows with all values <0.5 percent are not shown. For Table C-4 all land/boundary segments have conditional probabilities <0.5 percent. Table C-5. -- Conditional probabilities (expressed as a percentage chance) that during the summer an oil spill starting at a hypothetical spill site will contact a certain land segment within 10 days Land Segment Hypothetical Spill Sites J3 J4 JS J6 J7 J8 JX J10 J11 J12 J13 J18 J20 J21 J22 J23 J24 J25 J30 J31 J32 J33 J34 J35 J36 J37 Notes: Land segments having rows with all values <0.5 percent are not shown. For Table C-5 all land/boundary segments have conditional probabilities <0.5 percent. Table C-6. -- Conditional probabilities (expressed as a percentage chance) that during the summer an oil spill starting at a hypothetical spill site will contact a certain land segment within 30 days Land Segment Hypothetical Spill Sites J3 J4 JS J6 J7 J8® JX J1O J11 J12 J13 J18 J20 J21 J22 J23 J24 J25 J30 J31 J32 J33 J34 J35 J36 J37 16 nononn»aon,»ainnnana?Z7?nr_Aannannn nan nan nanan a 21 nonnn,»aeirnarnass nan nnn nnn nnn nn nn nian a Notes: n = <0.5 percent. Land segments having rows with all values <0.5 percent are not shown. c-10 Table C-7. -- Conditional probabilities (expressed as a percentage chance) that during the winter an oil spill starting at a hypothetical spill site will contact a certain environmental resource within 3 days Environmental Resource Hypothetical Spill Sites J10 J11 J12 J13 J18 J20 J21 J22 J23 J24 J25 J30 J31 J32 J33 J34 J35 J36 J37 a o a rs a a a a a a a oO a © Land Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment 10 Seabird Concent. I Seabird Concent. II Bering Strait Area Migrat. Corridor A Migrat. Corridor B Migrat. Corridor C Whale Area A Whale Area B Whale Area C Peard Bay Area Barrow Subsis. Area Wrght. Subsis. Area P. Lay Subsis. Area P.Hope Subsis. Area Any Subsis. Area appo5 Be PRPRPPPDPRPAPHDPDEPP EPPA E Bap oS * B PPDPPADDASDADDSDSB HBP DD PP wEeeoD ie *ppppss PPRPRPHPHDPAP PHP HPHPHPEDDHDHDHEHEDPoOoHDHRASD * PROPOR PPDHPHPP PPP EBD HPNoOAD AAAS S *ppppsos PPOBDPPODHPDHASDP EDP PPBaHBHPOrFE EADS * XN WOVAUEWNHE PRPRBRBHSEDPPHPHAPHDHDHDHDEPSDRDHPND PHP HPD » » NEVES SP DDD DODD DDD De BBB BaD PRD DSP PDD DOS DDD D DD DHA BBA BD » PPOPDODPODDPDDPwLDDDADAPD DDE DHDADD ra PRPRPRORPDP PPP wYONDPPDDHAP PDD DoD ray SD DOD RDP LD DPD EPPA PPePHoD PRPRDAODAPD PP Pw DDD AaHP PBA PBB ip i * * N PN*SD DDD RDDHDwLYAP PADD HPPA DS PRPRPPPPDPDSD DENA HDADP Pe nD aoD PHORPOPHAeP PPP HDHe HPP aHa Heep PPD * #*D eD DODD DRDDrPRaP Papas epaAOD POPP PDDEDHDPERPHPaaHPPPeAaapeDaD i) PRPRPDAODPPHPPHPPHP PED PPDAaHP PAD PRORBDDDHDHDHDHD DHHS PDD HPD eaHPHHoD OP FoOADADADDANWAP DDD HSPEDH PPD PPODAPPPDOEPAPRDDHDDAPAHDBaAHPEBHBaD PPOPODAODEPHPPPEHEHPHeHPAPpPHEDAaPPAAD PRPRPRPSPPRPaED Pape EBED PPPPPPPP PPP PDR HBHP PD PPRPPHDPAPAaPAaEAB Pea BHEeoB * ap5 ee * Notes: ** = >99.5 percent; n = <0.5 percent. Whale Migration Corridor A (Migrat. Corridor A) is an environmental resource between April 15 and June 15. Whale Migration Corridors B and C are environmental resources between April 1 and June 15. Table C-8. -- Conditional probabilities (expressed as a percentage chance) that during the winter an oil spill starting at a hypothetical spill site will contact a certain environmental resource within 10 days Environmental Resource Hypothetical Spill Sites J3- J4 JS J6 J7 J8 J9 J1O J11 J12 J13 J18 J20 J21 5322 J23 J24 J25 J30 J31 J32 J33 J34 J35 J36 J37 Land no oa nem ne pe a nm nm nm RHR 2 nA nh nA no nm n an nm no n n no n nin Sea Segment 1 non naennnnnnn»ninainnnnannnonnnaonnananaina Sea Segment 2 nonenenonnnn2onnin 2 n n n n n nb n n n 12 tn _n 2 Sea Segment 3 n n on on 20 7 no nilln nn 2 n n n nn nn an aill nn 7 non Sea Segment 4 noneonaioon 58 33 n n n n n no n nn 7 2 on non 7 ** no n 4 no Sea Segment 5 2 n 7 9 n 36 n n mn no n no nn 22 40 n n nn 27 n 2 2 n a _t Sea Segment 6 117 ** 62 n n 2 n n no n n n _n 7 n an n 2 8 n 2 n 2 1n_te Sea Segment 7 2 ** n 24 n no no no n n _nnonnv nan oon n27?7 anonon van avai ona Sea Segment 8 4 non 2 n n 4 n n n n n n n npn no no nnn aonavaonvaona Sea Segment 9 no aoe oe eo luelmelmlmemmhmemlmlUmrmUlUrrmUlUcRmUlUcRlhlcRlhlcRlhlcRlhlcRl lhl lhl ln huR okR lk lk lt Sea Segment 10 no nm oe pe ne nm n nm 28 nm n n n n n n n n no n nm n n n nn Seabird Concent. I non a am ep nem nm nm n n 20 nh n n n n n n n n nn n n n 4 8 Seabird Concent. II nome ne ae RF nm nm n Rn R n2 n2 n n n n n n np n nm n n 2 no Bering Strait Area n a ae a Re Re nm nm nm RP n n n n n n aA on an n n n n no no in Migrat. Corridor A 2 n no no non 18 22 n n n 16 n n n n n n nn n 12 16 2 2 2 1 c-11 eT-9 “ST sunc pue [ Tjady usenjeq seornoser [equemOITAUS OTe OQ puUe g{ STOPTIIOD uoTIeIBTW eTeyM “CT euNC pue CT TTIdy UseNIEq eornosez TequeWUOITTAUS Ue ST (Y AOPTIIOD *IeIBTW) VY AOPTzI0D uoTIezBTW eTeyM “ueozed ¢*g> = u !juecred ¢°GG< = yy :S2I0N uouiowuiowi<qwmTuweiuwuuwuuwuvuwiwu yy U 6 UU wx we Uo uwiuiu uiu eeay ‘stsqng suy uouiwiuuuwuwu uw uw uwuwuwiuwiuwiuviuwiuuviuuojupuiuiu every “stsqng edoy'g u u u u ” u u u u u u u u u aye U 6 u I¢ u u u u u u u eaay ‘stsqng seq *g uouwuiowiwuiqiyuwiuwuwwwuuwu wu ui uiu ye yy Uo uw iwiouiuiu wary ‘stsqng *34824 uwouowwuiuiuwuwuwuuwuwuwuwuwuwuuwiuwuwuuuiuuiuiu eveay ‘stsqng aorieg wouowwuwuuuwuuwuwuwuwuwuwuwuvuviuiui yz uouwiuiuiuiu every Aeg preeg uouiwwuiuwuuwuwuwu vw www uuwiuwuwuuiuiuiuiuiu 2 Peery eTeUM uwouwuwwuiuuiuwuwwuwuwuwuw uy, wuuwuwuwuuwiuiuiuiu q eery oTeuM 6 ££ @ @ &@weuwuuuwwu fg 6 & eee wuwygiuiuui Vv eazy eTeuM uouiwuiwuwiuiuuwuwuwuwuwuwuwuwuw g¢ uuuwww#iuuwuiuiuiu 9 AOpTzz0g “3erBTW u ¢t u ot eT uouwuiuiuwuiuit gt u 6 4 oY ETL BUuiutuitwiu @@ AOpTzz0g *3er8TW uwuwtwtgeggort#wzeeweuwuwuwetwee twee eu 4 ete ee ee V AOpTrzIOD *3ez3TW uouiowiuiuwiuiuuwuuwuwuwuwuwuwuwuwuuuuuuiuiui every aterig Butr0g uouowiuiwuiuuwuwuuwuwuwuwuwuwuwuwuwuiuuwuiuiuiuiu II ‘3ueoucg prtqeas uo, uwuwuuwwu uw uwiuiuwiuiwiu gg uoiuiuiuiuiuviuiu iui I ‘3ue0u0g prtqres u u u u u u u u u u u u u u u u u u u u u u u u u u OT uUeWBeg eas uoiouwuwuwuiwuweueiuweuuuwuweuwe eeu ewuwuuwiuuwuuwiuwitiu 6 uUeWw8es kag uwuouwuouwwuwiuiuuuwuww eww ww uwuwuuuwiyuugguiou ye 8 UeWZesg vag uiouiuiw uiow u “zou u u u u u u u u u u zs u u zou ae 9 L Juew8eg vag uweweweietdwweet#wreweweéseseretP?TFtmUumraemtrmhUrheetmhUch TU hTU lh TT Ce eT Th lw |e €€ 9 UeWBes ees uowuiolo Tt etwu ge u ui iui oy ge uuiyg ui14oouwu _g¢tr¢ se u gst ez u ge S$ UeWw8eg vag uo oui gt 62 @ ** 9T YU UU Z@ 4@ 9T @ OF we Ot Z@ TT €T “£9 2 % UW Ui gt 4 JuewFes eas uoo€t Ov TT £ 72 ee @ee F Té IT TT 6 @ 4t 4 z 8st Ov f¢ wu Zz € Wuew8es ees It 8st €T 9% ze 2eeeewze a 4@ 4 eT 2 gf Z 7 a tr www y Z Jueweg vag ce 6 ¥ ” y 2 uuwuweeee¢ tt st t ste 6 @ 8 9 4 uuiuiw T Juewesg vag 9T Of v2 BT 9T @ ET 2 € L 6 8t 72% % 8T TT Of TE OF £2 9T 6@ L 6 s €T puey der ger Ser ver cer wer Ter O€£ S@L ver Ete ezr T7e O@F BIC EIL ZIf Tir or 6f BF we OF SF we ELF se1TS TITds TeoTzeyi0déy eornosay Te\UeWUOI TAU uosees OIUTA e1TIUS eY3 JeAO voINOSeI TeUsWUOITTAUS UTeIIVD e JORWUCO TTTA aITs TITds TeoTIeyIodsy e ae Suzqzeqs TITds [TO ue TeqUTA ey BuTINp ey (soueYS eSequeoized © se pessezdxe) setat{Ttqeqoiad Teuotatpuog -- ‘6-9 ®T9eL “ST ounce pue [ TT2dy weenjeq seoinosez [ejUeWUOITAUe ere OQ pue g SIOPTIZ0D UOTIeIBTW eTeEYM “CST euNC pue CT TTIdy Usenqeq aoinoser Te UeUUOTTAUS Ue ST (Y JOPTIIOD “IeABTW) Y AOPTAI0D uoTIeIBTW eTeYM ‘uUecIed ¢*Q> = U tquedred ¢'6G< = yx :S2I0N uo uwiuiwuwiqiytuw we witwuuw ui ay U 6 u ae oye UO U UW U Ui iu eeazy ‘stsqng Auy uouwuouwuwuwuuwu uw uwuwu uwiuuwuuviuwuuwuiuide eveay ‘stsqng edog:g uouwowuwuwuiy wuuwuuuuuiui iy u 6 UU Oy U uiuiuviuiuil” every ‘stsqng sey “g¢ u u u u IT u u u u u u u u u u u u u ae o4ye u u u u u Peay “stTsqns “24224 uouwwiuuwuw wu uv uvwuwuwuwuwuwuwuwuwuwiuuuwuiuiu eeiy ‘sTsqns mozzeg uwouwuouwwiuiuwwuwuw www uwuwuwuuiuiui iy, uoiuwuiowiuiuiu every heg pieeg uouwiwuiuiuwuwuwwweeewewu uvwuuwu uuu wus 2 every eTeuM uouiwuuuuww ewww uwuwuwuwuwuuvuwuuuiuwiuiuias q eery eTeuM uowuoiwuwiuwuwuwu uuu wu uwuuwuwuiuwuuuwu wu Vv eazy eTeuM uouwiwuwiuiuuuwuwuwwwwuwuwuuvuuuiuviuwiuiuwiuila 2 Aoptzz0g *1eIzsTW uel u ot ¢f wouiuiuiuviuiu gt u 6 4 OF UZ y» UVUiuiuiuiu @ AOptrz0p *3eIBIW Ler oer ser ver cer zer Ter O€f Ser ver eer cer ter O@r BIC Elf cif Tir otr 6F Br “LF OF SF wf EF seats T1tds Teotaeyiodéy @ornosey TequewuoITAUY shep OT UTYITA POANOS|T TeQUSWUOITAUS UTeIIa9D & JOeIUOD TTTA eITS Titds Teotqeyqod4y e& ae Sutqzeas T{[Tds [To ue eqUTA ey. BuTINp Jey. (soueYyo eBequeored e se passeidxe) satat{tqeqoad Teuotatpuog -- (penutquog) ‘g-5 eTqeL Table C-10. -- Conditional probabilities (expressed as a percentage chance) that during the winter an oil spill starting at a hypothetical spill site will contact a certain land segment within 3 days Land Segment Hypothetical Spill Sites J3 J4 JS J6 J7 J8 JX J1O J11 J12 J13 J18 J19 J20 J21 J22 J23 J24 J25 J30 J31 J32 J33 J34 J35 J36 J37 Notes: Land segments having rows with all values <0.5 percent are not shown. For Table C-10 all land/boundary segments have conditional probabilities <0.5 percent. Table C-11. -- Conditional probabilities (expressed as a percentage chance) that during the winter an oil spill starting at a hypothetical spill site will contact a certain land segment within 10 days Land Segment Hypothetical Spill Sites J3 J4 JS J6 J7 J8 JX J1O J11 J12 J13 J18 J20 J21 J22 J23 J24 J25 J30 J31 J32 J33 J34 J35 J36 J37 Notes: Land segments having rows with all values <0.5 percent are not shown. For Table C-11 all land segments have conditional probabilities <0.5 percent. Table C-12. -- Conditional probabilities (expressed as a percentage chance) that during the winter an oil spill starting at a hypothetical spill site will contact a certain land segment over the entire winter season Land Segment Hypothetical Spill Sites J3. 54 JS J6 J7 J8 JX J10 J11 J12 J13 J18 J20 J21 J22 J23 J24 J25 J30 J31 J32 J33 J34 J35 J36 J37 21 27 28 30 39 40 41 42 44 46 59 60 61 62 n 2b E non 13° 20 1l nina n 22 11 16 Revs spy peeNes PeppRpraesapeaasewos RONDE SSSR DONND BBS SSDS SB BNAB DO ND BSS DBD END BUDO DSB SNEBooD BOSS SS DSB DNOED BPD DSS BSED RNED PRB BNE BBD BEB PX DDS ENON SD DOP USSR NDBNS PRPPDOND DP DDNDND BRB BS SS BRB Deve DED DSS NNNENNOD DOP SPS SNDDNN PRD SDSS DD DNVOD DROS PS SHSDNeEND FNNDSBSSSDSD SD SeND PRED SSDP DOB END PPD BSD BPD SoD PROB DDD ENEDO PPP DPSS PDE WND PRP DPD PDB DDE DUDS PDE NB DEN DOB BSNS SB VSNOD PRPPPPOAND eFND OND Notes: n= <0.5 percent. Land segments having rows with all values <0.5 percent are not shown. c-13 Table C-12a Spill Rates per Billion Barrels of Oil Produced or Transported for Platforms, Pipelines, and Tankers, Based on Historical Trends Source Rate 21,000 bbl Platforms 0.60 Pipelines 0.67 Tankers, Total 1.30 At Sea 0.90 Per Port Call 0.20 Source: Anderson and LaBelle, 1990. c-14 Table C-13. Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) occurring and contacting environmental resources over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, base and high cases, based on summer trajectories only --- WITHIN 3 DAYS --- --- WITHIN 10 DAYS --- --- WITHIN 30 DAYS --- Environmental BASE HIGH BASE HIGH BASE HIGH Resource CASE CASE CASE CASE CASE CASE * 5 Prob Mean Prob Mean Prob Mean Prob Mean Prob Prob Mean Land Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment 10 Seabird Concentration I Seabird Concentration II Bering Strait Area Whale Migration Corridor A Whale Migration Corridor B Whale Migration Corridor C Whale Area A Whale Area B Whale Area C Peard Bay Area Barrow Subsistence Area Wainwright Subsistence Area Pt. Lay Subsistence Area Pt. Hope Subsistence Area Any Subsistence Area » Pe VorpaarH o a w ~ uw > WODVYAUELONKE S ~ 5 ~ a VPNLOP ODP ADDS De wn » w » wo » w PUPDRDPANDDrYPRBDDN w uw we we rOOrFONDDOCOADODOOOOOUCOCOOOND wo NBPPBNDODP DDD ERP DPD ADD DoOrSD DOS eeeceoCKCC COC OO COCO OCC CO OCOCCCCD NP DNS USDA SSNAO DDD DD ANwODDoD ecooeoKoC Oo C OF COCO OCOOCOrKCOCOCOSD WOOWSOFODOCDCDCOWODDSCSCOCSCOrFOKROOOSD WPrPWOPODADADwYEAP DADA ED POrFUDDOD eeoececeoDDC COCO OCC OOOO OCC C OCOD FOOFONDODOCOCONDCOCOCCONOHOOCOSO OPrPODUADADSANS DSP SDS OMOrPDEES eooccnececCoC CCC OrFSCOOOCOOOrFCOOCOCOSD WOOWSOFOSCSCOrPWODDCOCOCOUFRPROOOS eoccoc0ceocC CoC OKC OOOO COOOCCCOCOSD FOP FONDOCOCONNDOCODCOCO@NKFOOCOO eeeoeoeo oC OOO OrFOCOCOCOCOOrFCOCOOCOD WONLWOHKFOOCCOFWODDDOCCONWNOCOSD wir opea w w w we w Note: n = <0.5 percent Gas Table C-14. Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) occurring and contacting land/boundary over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, base and high cases, based on summer trajectories only ---WITHIN 3 DAYS --- --- WITHIN 10 DAYS --- --- WITHIN 30 DAYS --- Land/Sea BASE HIGH BASE HIGH BASE HIGH Segment CASE CASE CASE CASE CASE CASE Prob Mean Prob Mean Prob Mean Prob Mean Prob Mean Prob Mean 21 n 0.0 n 0.0 n 0.0 n 0.0 1 0.0 =I 0.0 Notes: n= <0.5 percent. Land segments having rows with all values <0.5 percent probability of one or more contacts within 3,10, and 30 days are not shown. Table C-15. Combined Probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) occurring and contacting land/boundary segments over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, base and high cases, based on winter trajectories only --- WITHIN 3 DAYS --- --- WITHIN 10 DAYS --- --- ENTIRE WINTER --- Land/Sea BASE HIGH BASE HIGH BASE HIGH Segment CASE CASE CASE CASE CASE CASE Prob Mean Prob Mean Prob Mean Prob Mean Prob Mean Prob Mean 21 n 0.0 n 0.0 n 0.0 n 0.0 2 0.0 5 0.0 27 n 0.0 n 0.0 n 0.0 n 0.0 1300 (0.1 27. 0.3 28 n 0.0 n 0.0 n 0.0 n 0.0 9 0.1 19 0.2 30 n 0.0 n 0.0 n 0.0 n 0.0 2 0.0 4 0.0 40 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 1 0.0 46 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 Z 0.0 61 n 0.0 n 0.0 n 0.0 n 0.0 Z 0.0 3 0.0 Notes: n= <0.5 percent. Land segments having rows with all values <0.5 percent probability of one or more contacts within 3 and 10 days, and entire winter are not shown. c-16 Table C-16. Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) occurring and contacting environmental resources over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, base and high cases, based on winter trajectories only --- WITHIN 3 DAYS --- --- WITHIN 10 DAYS --- --- ENTIRE WINTER --- Environmental BASE HIGH BASE HIGH BASE HIGH Resource CASE CASE CASE CASE CASE CASE Prob Mean Prob Mean Prob Mean Prob Mean Prob Mean Prob Mean Land n 0.0 n 0.0 n 0.0 n 0.0 25 0.3 46 0.6 Sea Segment 1 n 0.0 n 0.0 n 0.0 n 0.0 3 0.0 6 0.1 Sea Segment 2 n 0.0 n 0.0 n 0.0 n 0.0 5 o.1 12 o.1 Sea Segment 3 n 0.0 n 0.0 S 0.0 w 0.1 11 0.1 22 0.2 Sea Segment 4 5 0.1 11 0.1 ae 0.2 33 0.4 31 0.4 56 0.8 Sea Segment 5 10 0.1 20 0.0 23 0.3 a7 0.6 38 0.5 65 1.0 Sea Segment 6 44 0.6 72 0.5 53 0.7 81 1.6 54 0.8 82 de? Sea Segment 7 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 1 0.0 Sea Segment 8 n 0.0 n 0.0 1 0.0 2 0.0 x 0.0 2 0.0 Sea Segment 9 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 Sea Segment 10 n 0.0 n 0.0 a 0.0 a 0.0 a 0.0 n 0.0 Seabird Concentration I n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 Seabird Concentration II n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 Berin: Strait Area n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 Whale Migration Corridor A 7 0.1 16 o.1 10 0.1 21 0.2 11 o.1 23 0.3 Whale Migration Corridor B 1 0.0 3 0.0 4 0.0 8 0.1 6 0.1 13 0.1 Whale Migration Corridor C n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 Whale Area A n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 Whale Area B n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 Whale Area C n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 ®n 0.0 Peard Bay Area 18 0.2 35 0.2 18 0.2 35 0.4 18 0.2 35 0.4 Barrow Subsistence Area n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 Wainwright Subsistence Area 33 0.4 59 0.4 34 0.4 59 0.9 34 0.4 59 0.9 Pt. Lay Subsistence Area 5 0.1 11 0.1 8 0.1 a7 0.2 10 0.1 21 0.2 Pt. Hope Subsistence Area n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 n 0.0 Any Subsistence Area 33 0.4 59 0.5 34 0.4 59 0.9 34 0.4 59 0.9 Notes: n = <0.5 percent. C-17 Table C-17. Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) occurring and contacting environmental resources over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, Point Lay Deferral Alternative (Alternative IV), based on summer trajectories only --- WITHIN 3 DAYS --- --- WITHIN 10 DAYS --- --- WITHIN 30 DAYS --- Environmental POINT LAY POINT LAY POINT LAY Resource DEFERRAL ALTERNATIVE DEFERRAL ALTERNATIVE DEFERRAL ALTERNATIVE Prob Mean Prob Mean Prob Mean Land Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment Sea Segment 10 Seabird Concentration I Seabird Concentration II Bering Strait Area Whale Migration Corridor A Whale Migration Corridor B Whale Migration Corridor C Whale Area A Whale Area B Whale Area C Peard Bay Area Barrow Subsistence Area Wainwright Subsistence Area Pt. Lay Subsistence Area Pt. Hope Subsistence Arean Any Subsistence Area Be Vora Dy w w COP RPLUP ODED RPA weD PDP PRaPoOeFUDDSD WOYVAUVEWNKY w S FOOrFONOCCOCOMDOCOCOOCONOOKFOCOS S S pp Ors BB a BDH b » » we PORPFONODOONADOOOOOOM@NHOOOCO wo w eooeceecee CCC CODCOD ODDO OOS OOOO SD ecocececDeC CC CCC CDC COCO COCO OCCO POOFONDDOCDOADOOOOOOUDOD000 ecocecocoe ce C CC CCC CCC COC OCCCS NOBDNDODDD ADD SDD HDDD Doren eCDneSDODD w wo w Notes: n= <0.5 percent. c-18 Table C-18. Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) occurring and contacting land/boundary over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, Point Lay Deferral Alternative (Alternative IV), based on summer trajectories only ---Within 3 days --- --- Within 10 days --- --- Within 30 days --- Land/Sea POINT LAY POINT LAY POINT LAY Segment DEFERRAL ALTERNATIVE DEFERRAL ALTERNATIVE DEFERRAL ALTERNATIVE Prob Mean Prob Mean Prob Mean 21 n 0.0 i 0.0 1 0.0 Notes: n= <0.5 percent. Land segments having rows with all values <0.5 percent probability of one or more contacts within 3, 10, and 30 days are not shown. Table C-19. Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean occurring and contacting land/ segments over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, Point Lay Deferral Alternative (Alternative IV), based on winter trajectories only --- Within 3 days --- --- Within 10 days --- --- Entire Winter --- Land/Sea POINT LAY POINT LAY POINT LAY Segment DEFERRAL ALTERNATIVE DEFERRAL ALTERNATIVE DEFERRAL ALTERNATIVE Prob Mean Prob Mean Prob Mean 21 n 0.0 n 0.0 2 0.0 27 n 0.0 n 0.0 13 0.3 28 n 0.0 n 0.0 9 0.1 30 n 0.0 n 0.0 2 0.0 61 n 0.0 n 0.0 1 0.0 Notes: n= <0.5 percent. Land segments having rows with all values <0.5 percent probability of one or more contacts within 3 and 10 days, and entire winter are not shown. c-19 Table C-20. Combined probabilities (expressed as percent chance) of one or more spills 21,000 bbl, and the estimated number of spills (mean) occurring and contacting environmental resources over the assumed production life of the lease area, Chukchi Sea OCS Lease Sale 126, Point Lay Deferral Alternative (Alternative IV), based on winter trajectories only --- Within 3 days --- --- Within 10 days --- --- Entire Winter --- Environmental POINT LAY POINT LAY POINT LAY Resource DEFERRAL ALTERNATIVE DEFERRAL ALTERNATIVE DEFERRAL ALTERNATIVE Prob Mean Prob Mean Prob Mean n 0.0 n 0.0 25 0.3 Segment 1 n 0.0 n 0.0 3 0.0 Segment 2 n 0.0 n 0.0 5 0.1 Segment 3 n 0.0 3) 0.0 ad) 0.1 Segment 4 5 0.1 17 0.2 31 0.4 Sea Segment 5 10 O.1 23 0.3 38 0.5 Sea Segment 6 44 0.6 53 0.7 54 0.8 Sea Segment 7 n 0.0 a 0.0 n 0.0 Sea Segment 8 n 0.0 1 0.0 1 0.0 Sea Segment 9 n 0.0 n 0.0 n 0.0 Sea Segment 10 n 0.0 n 0.0 n 0.0 Seabird Concentration I n 0.0 n 0.0 n 0.0 Seabird Concentration II n 0.0 n 0.0 n 0.0 Bering Strait Area n 0.0 n 0.0 n 0.0 Whale Migration Corridor A th 0.1 10 o.1 lal 0.1 Whale Migration Corridor B 1 0.0 4 0.0 6 0.1 Whale Migration Corridor C n 0.0 n 0.0 n 0.0 Whale Area A n 0.0 n 0.0 n 0.0 Whale Area B n 0.0 n 0.0 n 0.0 Whale Area C n 0.0 n 0.0 n 0.0 Peard Bay Area 18 0.2 18 0.2 18 0.2 Barrow Subsistence Area n 0.0 n 0.0 n 0.0 Wainwright Subsistence Area 33 0.4 34 0.4 34 0.4 Pt. Lay Subsistence Area 5 0.1 8 0.1 10 0.1 Pt. Hope Subsistence Area n 0.0 n 0.0 n 0.0 Any Subsistence Area 33 0.4 34 0.4 34 0.4 Notes: n= <0.5 percent. c-20 APPENDIX D ENDANGERED SPECIES ACT SECTION 7 CONSULTATION AND DOCUMENTATION OCT 1 9 1989 Mr. Steve Pennoyer Director, Alaska Region National Marine Fisheries Service P.O. Box 1668 Juneau, Alaska 99802 Dear Mr. Pennoyer: The Minerals Management Service has initiated the planning process for the leasing and exploration associated with the proposed Outer Continental Shelf Oil and Gas Lease Sale 126. This lease sale is proposed for July 1991 in the Chukchi Sea Planning Area (map enclosed). In accordance with the Endangered Species Act section 7 regulations governing interagency cooperation, we are providing a notification of the listed and proposed species and critical habitat that will be included in our biological evaluation. It is our understanding that there are no designated or proposed critical habitats for any listed species in Alaska. In our biological evaluation, we will review the following listed species that may be present in the proposed lease area for Sale 126: Common Name Scientific Name Status Gray whale Eschrichtius robustus Endangered Bowhead whale Balaena mysticetus Endangered Please review our list, and notify us of your concurrence or revisions and any new information concerning the species occurrence in relation to the proposed project area. To facilitate the review, we have provided a copy of this letter to your Anchorage field office. Upon receipt of your letter, we will begin the preparation of the biological evaluation to review the potential effects of the proposed action. We look forward to working with you and your staff in protecting and conserv- ing endangered and threatened species. If you have any questions concerning this proposed action, please contact Ken Holland at (907) 261-4684. Sincerely, (sgnd) Irven F. Palmer, Jr. PNG atonal Director Enclosure cc: Anchorage Field Office, NMFS, NOAA act + 9 1989 Memorandum Tos Regional Director, U.S. Fish and Wildlife Service From: Acting Regional Director, Alaska OCS Region, Minerals Management Service Subject: Endangered Species - Proposed Oil and Gas Lease Sale 126 (Chukchi Sea) The Minerals Management Service has initiated the planning process for the leasing and exploration associated with the proposed Outer Continental Shelf Oil and Gas Lease Sale 126. This lease sale is proposed for July 1991 in the Chukchi Sea Planning Area (map attached). In accordance with the Endangered Species Act section 7 regulations governing interagency cooperation, we are providing a notification of the listed and proposed species and critical habitat that will be included in our biological evaluation. It is our understanding that there are no designated or proposed critical habitats for any listed species in Alaska. Our biological evaluation will evaluate the effects of proposed Sale 126 on the threatened arctic peregrine falcon (Falco peregrinus tundrius) that may be present near the proposed lease area. Please notify us of your concurrence with or revisions to our species list and any new information concerning the species' occurrence in relation to the proposed project area. To facilitate the review, we have provided a copy of this letter to your Anchorage field office. Upon receipt of your response, we will begin preparation of the biological evaluation that will review the potential effects of the proposed action. We look forward to working with you and your staff in protecting and conserving endangered and threatened species. If you have any questions concerning this proposed action, please contact Ken Holland at (907) 261-4684. (sgnd) Irven F. Palmer, Jr. Attachment ec: Anchorage Field Office, USFWS UNITED STATES DEP ‘TMENT OF COMMERCE National Oceanic and ...mospheric Administration National Marine Fishertes Service P.0. Box 21668 Juneau, Alaska 99802-1668 November 27, 1989 Irven F. Palmer, Jr. Acting Regional Director Minerals Management Service 949 E. 36th Avenue, Room 110 Anchorage, AK 99508-4302 Dear Mr. Palmer: Your letter of March 3, 1989, requested information on endangered species that may be present in the proposed Outer Continental Shelf Oil and Gas Lease Sale 126 in the Chukchi Sea. [In your letter you identified two endangered species of whales that may be present in the lease area - the bowhead whale and the gray whale. You also state that there is no designated critical habitat for these species. This letter is to notify you that we concur with your evaluation. There are no additional endangered species to be included, and no critical habitat listed. Sincerely, lie Ge vnsutys L Steve Pennoyer, Director Alaska Region — ee . * United States Department of the Interior =a FISH AND WILDLIFE SERVICE IN REPLY REFER TO: 1011 E. TUDOR RD. DOS /NAES ANCHORAGE, ALASKA 99503 NOV 2 7 1989 Memorandum To: Regional Director Minerals Management Service Anchorage, Alaska From: pOYocional Director Region 7 Subject: Endangered Species - Proposed Oil and Gas Lease Sale 126 (Chukchi Sea) This responds to your subject memorandum of October 19, 1989. We concur with your finding that one listed species is present in the proposed sale area, the threatened Arctic peregrine falcon (Falco peregrinus tundrius). There is no designated or proposed critical habitat in Alaska. Thank you for your concern for endangered species. If you have questions or comments, please contact Ronald L. Garrett, Endangered Species Coordinator at (907) 786-3505. ees PECEIVE)] NOV 3.01989 REGICNAL DIRECTOR, ALASKA OCS Minerals Management Service ANCHORAGE,’ ALASKA e iN PIE 5) United States Department of the Interior src= ATER WI EPA MINERALS MANAGEMENT SERVICE ee ieee WASHINGTON, DC 20240 JUL | 2 1990 Dr. William W. Fox, Jr. RECEIVED Assistant Administrator for Fisheries National Marine Fisheries Service JUL 19 19°) 1335 East-West Highway nic or Aaa |Paee ees | anee REGIONAL DIRECTOR, ALASKA OCS Minerals Managemen! Ssrvice Dear Dr. Fox: ANCHORAGE, ALASKA The Minerals Management Service (MMS) is preparing a draft Environmental Impact Statement (EIS) on proposed oil and gas lease Sale 126 and associated exploration in the Chukchi Sea Planning Area offshore northern Alaska. This is the third sale proposed for this planning area and is tentatively scheduled for August 1991. The first sale (Sale 85) was dropped from the leasing schedule in July 1984. The second (Sale 109) was held in May 1988. The enclosed biological evaluation describes the specifics of Sale 126, as well as potential effects of postlease activities on endangered species. (The information in the appendices is from the preliminary draft EIS and may be modified for the final EIS.) These details and effects are similar to those projected for Sale 109, which the National Marine Fisheries Service (NMFS) examined thoroughly before issuing its Endangered Species Act (ESA) section 7 biological opinion for that sale (September 1, 1987) and its revised opinion for the entire arctic region (November 23, 1988). Because these data still represent the best scientific and commercial information available, we believe the Sale 109 and revised arcticwide opinions apply equally well to proposed Sale 126. Because Sale 126 is a separate action and "may affect" listed species, we hereby request, under ESA section 7 (a)(2), formal consultation on the leasing and any exploration that may occur as a result of this sale. To facilitate a timely start of consultation, we are sending a copy of this letter and the enclosed evaluation to the NMFS field office in Anchorage. We believe there is no need for lengthy formal consultation for Sale 126 as the Sale 109 data are still current. After reviewing the evaluation, NMFS may wish to affirm in writing the applicability of the Sale 109 and revised arcticwide opinions to Sale 126. Such an action would avoid unnecessary paperwork and time delays and is consistent with the statement in the arcticwide opinion that "Opinions on future lease sales should incorporate by reference this Opinion if it contains the best information available." Dr. William W. Fox, Jr. 2 This approach will result in a speedy conclusion of consultation. It is similar to confirming an early consultation's preliminary biological opinion as a final opinion (as described in 50 CFR 402.11(f)). We hope that NMFS would issue the affirmation within the 45 days noted for confirming a preliminary opinion. While we believe the affirmation approach has compelling merit, we recognize that NMFS may prefer to conduct a full-scale formal consultation for proposed Sale 126 that might require the entire 135-day period allowed by ESA section 7 for consultation and delivery of a biological opinion. If, during such a prolonged consultation, NMFS considers a potential finding of "jeopardy," new conservation recommendations, or new incidental take measures, terms, and conditions, we request that our respective staffs discuss these aspects as early as possible in the consultation. Such discussions would be essential to ensure that the alternatives, recommendations, and/or measures are within our authority to control or implement and that they would be feasible, appropriate, and effective. Through these discussions, if they should be needed, MMS believes it would be possible to minimize or prevent later problems or misunderstandings and greatly expedite timely and effective conclusion of the formal consultation. It is understood that by extending existing biological opinions to proposed Sale 126, or by providing us with an entirely new opinion for this sale, NMFS will not be foreclosing on opportunities to reconsider that opinion as new sales are proposed for this area. If you have any questions regarding this matter, please contact Mr. Jackson E. Lewis, Minerals Management Service, Mail Stop 4330, Parkway Atrium Building, 381 Elden Street, Herndon, Virginia 22070-4817 (commercial telephone: 703-787-1742; FTS 393-1742), or Mr. Ken Holland, Minerals Management Service, Alaska Region, 949 East 36th Avenue, Anchorage, Alaska 99508-4302 (commercial and FTS telephone: 907-261-4684). Sincerely, /s/ Ed Cassidy Ed Cassidy Deputy Director Enclosure cc: Mr. Ron Morris National Marine Fisheries Service 701 C Street, Box 43 Anchorage, Alaska 99513 Dr. William W. Fox, Jr. bee: (all copies without enclosure) Official File (BEO) (Sale 126; ENV 7-14) AD/OMM Deputy Director DAD/Leasing DAD/Operations RD, Alaska Region RS/LE, Alaska Region Ken Holland, Alaska Region Chief, OLMD Chief, ORED OEAD RF Chief, BEO Lewis/Turner/Sun BEE/BEM/ BES jes Chron (1)/(2) BEO RF LMS :MS644:OEAD: Lewis: 1m: 6/26/90: 9-787-1728: Lewis: NMFS126.mem Retyped:1m:7/6/90 We = : : PROGINS United States Department of the Interior C= SL a RASS SPELT PLT MINERALS MANAGEMENT SERVICE = WASHINGTON, DC 20240 PEGE VI JUL | 2 |999 JUL 19 198: Memorandum REGIONAL DIRECTOR, ALAS . . . . . Minerals Management S TOs Director, U.S. Fish and Wildlife Service ANCHORAGE, ALASK From: Deputy Director, Minerals Management Service /5/ £4 Cassidy Subject: Endangered Species Act Section 7 Formal Consultation for Leasing and Exploration Attendant Proposed Chukchi Sea Oil and Gas Lease Sale 126 The Minerals Management Service (MMS) is preparing a draft Environmental Impact Statement (EIS) on proposed oil and gas lease Sale 126 and associated exploration in the Chukchi Sea Planning Area offshore northern Alaska. This is the third sale proposed for this planning area and is tentatively scheduled for August 1991. The first sale (Sale 85) was dropped from the leasing schedule in July 1984. The second (Sale 109) was held in May 1988. The attached biological evaluation describes the specifics of proposed Sale 126, as well as potential effects of postlease activities on endangered species. (The information in the appendices is from the preliminary draft EIS and may be modified for the final EIS.) These details and effects are similar to those projected for Sale 109, which the U.S. Fish and Wildlife Service (FWS) examined thoroughly before issuing its Endangered Species Act (ESA) section 7 biological opinion for that sale (June 24, 1986). Because these data still represent the best scientific and commercial information available, we believe the Sale 109 opinions apply equaily well to proposed Sale 126. Because Sale 126 is a separate action and "may affect" listed species, we hereby request, under ESA section 7 (a) (2), formal consultation on the leasing and any exploration that may occur as a result of this sale. To facilitate the earliest possible start of this consultation, we are sending a copy of this memorandum and the attached evaluation to the FWS Regional Director in Anchorage. In this way, we expect the consultation to officially start on the date he receives his copy of this request. We believe there is no need for lengthy formal consultation for Sale 126 as the Sale 109 data are still current. After reviewing the evaluation, FWS may wish to affirm in writing the applicability of the Sale 109 to Sale 126. Such an action is consistent with the conclusion in the Sale 109 opinion that FWS opinions for earlier Chukchi Sea Sales remain valid. It would also avoid unnecessary paperwork and time delays. This approach will result in speedy conclusion of consultation. It is similar to confirming an early consultation's preliminary biological opinion as a final opinion (as described in 50 CFR 402.11(f)). We hope that FWS would issue the affirmation within the 45 days noted for confirming a preliminary opinion. While we believe the affirmation approach has compelling merit, we recognize that FWS may prefer to conduct a full-scale formal consultation for proposed Sale 126 that might require the entire 135-day period allowed by ESA section 7 for consultation and delivery of a biological opinion. If, during such a prolonged consultation, FWS considers a potential finding of "jeopardy," new conservation recommendations, or new incidental take measures, terms, and conditions, we request that our respective staffs discuss these aspects as early as possible in the consultation. Such discussions would be essential to ensure that the alternatives, recommendations, and/or measures are within our authority to control or implement and that they would be feasible, appropriate, and effective. Through these discussions, if they should be needed, MMS believes it would be possible to minimize or prevent later problems or misunderstandings and greatly expedite timely and effective conclusion of the formal consultation. It is understood that by extending existing biological opinions to proposed Sale 126, or by providing us with an entirely new opinion for this sale, FWS will not be foreclosing on opportunities to reconsider that opinion as new sales are proposed for this area. If you have any questions regarding this matter, please contact Mr. Jackson E. Lewis, Minerals Management Service, Mail Stop 4330, Parkway Atrium Building, 381 Elden Street, Herndon, Virginia 22070-4817 (commercial telephone: 703-787-1742; FTS 393-1742), or Mr. Ken Holland, Minerals Management Service, Alaska Region, 949 East 36th Avenue, Anchorage, Alaska 99508-4302 (commercial and FTS telephone: 907-261-4684) Attachment cc: Regional Director U.S. Fish and Wildlife Service 1011 East Tudor Road Anchorage, Alaska 99503 bec: (all copies without attachment) Official File (BEO) (Sale 126; ENV 7-1d) AD/OMM Deputy Director DAD/Leasing DAD/Operations RD, Alaska Region RS/LE, Alaska Region Ken Holland, Alaska Region Chief, OLMD Chief, ORED OEAD RF Chief, BEO Lewis/Turner/Sun BEE/BEM/BES Offshore Chron (1)/(2) BEO RF LMS :MS644:OEAD: Lewis: 1m: 6/25/90:9-787-1728: Lewis: FWS126.mem ue UNITED STATES OCEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administretion . . NATIONAL MARINE FISHERIES SERVICE \ - 1335 East-Weet Highway nee Silver Spring, MO 20810 THE ORECTOR AUG 28 1990 Mr. Ed Cassidy Deputy Director Minerals Management Service Department of the Interior Washington, D.C. 20240 Dear Mr. Cassidy: Thank you for the opportunity to comment on the biological evaluation for threatened and endangered species prepared by Minerals Management Service (MMS) relative to proposed Outer Continental Shelf Lease Sale 126. After reviewing the evaluation, we believe it is not necessary to reinitiate consultation under Section 7 of the Endangered Species Act for Lease Sale 126 because the Arctic Region Biological Opinion issued to MMS in November 1988 continues to reflect the most current scientific knowledge regarding potential effects on marine mammals. The Arctic Opinion concludes that leasing and exploration activities are not likely to jeopardize the continued existence of any endangered or threatened species. However, we believe that development and production activities within the spring lead system of the bowhead whale would be likely to jeopardize the population of that species, and reinitiation of consultation will be necessary regarding these activities. Also, the Incidental Take Statement recently issued to MMS for the Arctic Region Biological Opinion requires compliance with 50 CFR Part 228 - Subpart D - Taking of Marine Mammals Incidental to Oil and Gas Exploration in Alaska. These regulations prohibit the take of any marine mammal in the spring lead system used by bowhead whales in the Chukchi Sea and Beaufort Sea. The regulations apply to any exploration activities associated with Lease Sale 126. If you have any questions, please contact Dr. Nancy Foster, Director, Office of Protected Resources, at (301) 427-2322. Sincerely, ee THE ASSISTANT ADMINISTRATOR i ‘ FOR FISHERIES y — United States Department of the Interior sc Bes See BET MINERALS MANAGEMENT SERVICE — = WASHINGTON, DC 20240 Dr. William W. Fox, Jr. Assistant Administrator for Fisheries SUL 26 1940 National Marine Fisheries Service 1335 East-West Highway Silver Spring, Maryland 20910 Dear Dr. Fox: On April 5, 1990, the National Marine Fisheries Service (NMFS) issued an emergency interim rule listing the Steller (northern) sea lion as threatened under the Endangered Species Act (ESA). As required when a species is newly listed, the Minerals Management Service (MMS) has reviewed its proposed oil and gas and other lease sales in Alaska to determine whether any sale and/or associated exploration might affect sea lions. Specitically, MMS has reviewed its proposed oil and gas lease Sales 107 (Navarin Basin), 124 (Beaufort Sea), and 126 (Chukchi Sea), as well as the proposed Norton Sound Mining Program Lease Sale. The areas proposed for oil and gas leasing in the Beaufort and Chukchi Seas are far from Steller sea lion habitat. We have therefore determined that no "may affect" situation exists for any exploration or subsequent activities that might result from Sales 124 and 126. Neither is it likely that activities associated with proposed mining in northern Norton Sound would affect the one or two individuals that reportedly may use the area from time to time (Frost, Lowry, and Burns (1982)). Accordingly, MMS has determined that reinitiation of ESA section 7 formal consultation for the sales proposed for the Beaufort and Chukchi Seas and Norton Sound is not justified or necessary. Our review of proposed oil and gas lease Sale 107 has, however, caused us to recognize that exploration and subsequent activities (particularly aircraft and vessel support traffic to, from, or near St. Matthew, Hall, St. Lawrence, and the Pribilof Islands) might affect locally present sea lions. In light of this "may affect" situation, and because NMFS's existing ESA section 7 biological opinion for Sale 107 did not address Steller sea lions, MMS hereby requests, under ESA section 7(a)(2), reinitiation of formal consultation for Sale 107 and amendment or revision (as appropriate) of the existing opinion for the sale. (The existing opinion was issued on June 1, 1989.) To facilitate start of consultation, we are sending a copy of this request directly to the NMFS Anchorage Field Office. The draft Environmental Impact Statement (EIS) for proposed Navarin Sale 107, issued in May 1990, contains information on the Dr. William W. Fox, Jr. 2 distribution of sea lions and on the types and levels of effect that might result from Sale 107. (We enclose a copy for your information and understand that NMFS Anchorage Office staff are reviewing a separate copy.) You will note that the draft EIS lacks the detailed population data used by NMFS in its rule listing Steller sea lions as threatened. Presumably, all this information will be considered and summarized in the amended or revised opinion for Sale 107. The MMS plans to describe the status and specifics about Steller sea lions in the endangered species section of the final EIS, and to insert the amended or revised opinion into the appropriate final EIS appendix. To be appropriately factored into the final EIS, we request receipt of the amended or revised opinion at MMS headquarters before October 1, 1990. If during this formal consultation NMFS considers for Steller sea lions a potential finding of "jeopardy," new conservation recommendations, or incidental take measures, terms, and conditions, we request that our respective staffs discuss these aspects as early as possible during the consultation. Such discussions would be essential to ensure that the alternatives, recommendations, and/or measures are within our authority to control or implement and that they would be feasible, appropriate, and effective. Through these discussions, if they should be needed, MMS believes it would be possible to minimize or prevent later problems or misunderstandings and greatly expedite timely and effective conclusion of the formal consultation. It is understood that by amending or revising the biological opinion for Sale 107, NMFS will not be foreclosing on opportunities to reconsider that opinion as future lease sales are proposed for this area or as significant new information is developed on impacts or changes in the proposed action. If you have any questions regarding this matter, please contact Mr. Jackson E. Lewis, Minerals Management Service, Mail Stop 4330, Parkway Atrium Building, 381 Elden Street, Herndon, Virginia 22070-4817 (commercial telephone: 703-787-1742; FTS: 393-1742), or Mr. Dan Benfield, Minerals Management Service, Alaska Region, 949 East 36th Avenue, Anchorage, Alaska 99508-4302 (commercial telephone: 907-261-4672; FTS: 907-869-4672). Sincerely, /s/ Ed Cassidy Ed Cassidy Deputy Director Enclosure Dr. William W. Fox, Jr. cc: (without enclosure) Mr. Ron Morris National Marine Fisheries Service 701--c Street, Box 43 Anchorage, Alaska 99513 bec: (all copies without enclosure) Official File (BEO) (Sale 107; ENV 7=-1d) AD/OMM Deputy Director DAD/Leasing DAD/Operations RD/Alaska Region RS/LE/Alaska Region Dan Benfield/Alaska Region Chief, OLMD Chief, ORED OEAD RF Chief, BEO Lewis/Turner/Sun/Middleton BEE/BEM/BES Offshore Chron (1)/(2) BEO RF LMS :MS4330:0EAD: Lewis: 1m:7/16/90:9-787-1742: Lewis:NMFS107S oe Kr ™~, UNITED STATES SEPARTMENT OF COMMERCE £ , | Nations! Oceanic end Aomoapheria Adminiatration \ 4 NATIONAL MAANNE RIGHERES SERVICE Crores # 1733S Geeo-Waae Horwey Stver Goring, MO BOE0 CPRCE OF THE ORECTOR OCT 25 1999 Mr. Ed Cassidy Deputy Director Minerals Management Service U.S. Department of the Interior Washington, D.C. 20240 Dear Mr. Cassidy: Thank you for your letter regarding the reinitiation of Endangered Species Act (ESA) section 7 consultations as a result of the emergency listing of the Steller sea lion.. We concur with your determination that proposed oil and gas lease sales 124 (Beaufort Sea) and 126 (Chukchi Sea) and the proposed Norton Sound mining program are not likely to affect the continued existence of the Steller sea lion. We also concur with your determination that lease sale 107 (Navarin Basin) may affect the Steller sea lion and reinitiated formal consultation for the lease sale. The enclosed Biological Opinion concludes that the proposed activities are not likely to jeopardize the continued existence of the Steller sea lion. However, we believe these activities will impact Steller sea lions in the lease sale area. We, therefore, are providing Conservation Recommendations to minimize the impacts on sea lions. We also recommend that the appropriate parties apply for incidental take authorization under Section 101(a)(5) of the Marine Mammal Protection Act so the incidental take of Steller sea lions can be considered. This concludes consultation responsibilities for these actions. However, consultation must, once again, be reinitiated if new information reveals effects of these activities that may affect listed species or their habitat in a manner or to an extent not previously considered, the identified activities are modified in a manner that causes an effect to listed species or critical habitat that was not considered in the biological opinions, or if another species is listed or critical habitat designated that may be affected by the proposed activities. If there are any questions please contact Steve Zimmerman in Alaska on 907-586-7939 or Robert Ziobro on 427-2323. Sincerely, Cj William W. Fox, Jr. ee Enclosure l Tre ASSISTANT ADMINGSTRATOR FOR PSHERES ‘_ . 9t72*d Ud/4‘WO/4-SAWN 2S:8T 86. S2 190 United States Department of the Interior FISH AND WILDLIFE SERVICE IN REPLY REFER TO 1011 E. TUDOR RD. DOS /NAES ANCHORAGE, ALASKA 99503 OCT 3 1 1990 Memorandum To: Regional Director Minerals Management Service, Alaska From: pe. ional Director e 1 ir Region 7 i Subject: Biological Opinion for Lease Sale 126 RESICHAL D, This responds to your July 12, 1990, request for formal consultation pursuant to Section 7 of the Endangered Species Act (Act) of 1973, as amended, for Chukchi Sea Oil and Gas Lease Sale 126. Your request was mailed to the Director, Fish and Wildlife Service (Service), who in turn mailed the request to Region 7 in Alaska. The request was received in Region 7 on August 27, 1990, and the consultation period began on that date. The only species considered in this opinion is the threatened Arctic peregrine falcon (Falco peregrinus tundrius). Biological opinions were issued for the Beaufort Sea Region on August 22, 1980, and the Arctic Region on November 9, 1981. Additional opinions were issued for the Navarin Basin (Lease Sale 83) and the Diapir Field (Lease Sale 87) on July 15, 1983, the Beaufort Sea Planning Area (Lease Sale 97) on July 30, 1985, the Chukchi Sea Lease Sale 109 on June 24, 1986, and the Beaufort Sea Lease Sale 124 on May 17, 1990. This opinion addresses only Lease Sale 126 and those activities associated with leasing and exploration. Since it is impossible to predict with certainty the occurrence or location of commercially significant deposits of oil and gas, this consultation will proceed incrementally. Leasing and exploration are considered the first incremental step in the action; development and production are considered the second incremental step. This biological opinion addresses only leasing and exploration. Any development or production proposals will require separate consultation. oject Lease Sale 126 is located off the northwestern coast of Alaska from the vicinity of Icy Cape westward to Cape Lisburne. The proposed lease sale encompasses about 23.68 million acres extending from 3.5 to 200 nautical miles offshore in water depths that range from approximately 98 to 164 feet. The most likely exploration scenarios and facility locations are presented in the "Biological Evaluation for Threatened and Endangered Species with Respect to the Proposed Chukchi Sea Oil and Gas Lease Sale 126" (Minerals Management Service 1990). A total of 7055 seismic-line kilometers of shallow surveys are expected. Thirty-nine exploration and delineation wells are expected to be drilled during the period 1992 through 1998. Drilled depths of exploration and delineation wells should average 10,000 feet. The most likely choice for drilling vessels would be drillships with icebreaker support. On-shore support would be from existing facilities, such as Barrow and Wainwright. Approximately 2,340 helicopter flights are expected (150 flights per month). Vessel support would be 312 supply trips during open-water season, and two standby vessels for each drilling unit. Effects on Arctic Peregrine Falcons The Arctic peregrine falcon is geographically distributed throughout the tundra regions of North America. In Alaska, this includes the area north of the Brooks Range and along the west coast south to and including Norton Sound. The Service estimates that 200 pairs historically occupied Alaska. Beginning in the late 1940s, the use of the pesticide Dichloro diphenyl trichloroethane and its metabolites (hereafter referred to as organochlorine pesticides) greatly affected Arctic peregrine falcons, causing birds to lay thin-shelled eggs which often failed to hatch and consequently lowered reproduction. In Alaska, the population declined to approximately 30 percent of historical levels by 1972, at which time the United States restricted the use of organochlorine pesticides. The population remained stable for the next six years, and in 1978 the population began to increase. In 1984 the Service, prompted by markedly improved numerical levels, changed the status of the Arctic peregrine falcon from endangered to threatened. Based on 1990 surveys, the Service estimates the population of Arctic peregrine falcons in Alaska to be between 150 and 175 pairs and increasing. Arctic peregrine falcons are present in Alaska from about late April to mid- September. Egg-laying in northern Alaska begins in early May, and young fledge from late July to mid-August. A few nest sites are known to occur along the northwest coast in the area between Cape Krusenstern and Cape Lisburne. No nest sites are known from the coastal bluffs adjacent to the proposed sale area or along the northern coast of Alaska, where all known nest sites occur about 25 miles inland. The most frequent sightings of Arctic peregrine falcons in the vicinity of the proposed sale area occur along the northwest coast and in the uplands south of the proposed sale area. Additional sightings have been made along the northern coast of Alaska east of the Colville River where adults and immature birds stage and hunt prior to and during migration. Oil spills, noise and disturbance associated with exploration activities are sources of potential impacts to Arctic peregrine falcons. If oil is spilled near migration routes or hunting areas, peregrine falcons could be adversely affected by eating contaminated prey or through reduction of prey availability. The Minerals Management Service concluded that there is less than 0.5 percent probability that one or more oil spills of 1,000 barrels or greater would contact land within 3 or 10 days, or seabird concentrations within 3, 10, or 30 days (based -on summer trajectories). The Oil Spill Risk Analysis shows a probability of 1 percent for a spill of 1,000 barrels or greater contacting land within 30 days of the spill. When the probability of oil spills is considered in conjunction with the relatively small amount of time that peregrine falcons spend along the coast, it is not likely that peregrine falcons will be significantly affected by oil spills. If oil spills affected peregrine prey populations, then localized reductions in food availability could occur. Nesting peregrine falcons could be disturbed by aircraft overflights related to the proposed sale. The extent of such disturbance would depend on locations of support facilities. Barrow and Wainwright are the most likely support facilities and are located on the coast. Aircraft based in Barrow or Wainwright would not typically fly over nesting areas, and thus, significant disturbance of nesting peregrine falcons during the exploration phase is unlikely. Cumulative Effects Cumulative effects are those effects of future State or private activities on endangered and threatened species or critical habitat that are reasonably certain to occur within the action area of the Federal action subject to consultation. Future Federal actions will be subject to the consultation requirements established in Section 7 and, therefore, are not considered cumulative in the proposed action. State and private activities reasonably certain to occur include oil and gas near-shore and on-shore leasing, exploration, development and production; gravel mining, support facilities and road construction to support these activities; pipelines and related oil and gas transport facilities, including feeder lines, Trans-Alaska Pipeline operation and maintenance, and oil tanker traffic from the Valdez terminal to points in the lower 48 states; and all associated activities in support of these projects. Biological Opinion It is my biological opinion that leasing and exploration activities associated with Lease Sale 126 are not likely to jeopardize the continued existence of the Arctic peregrine falcon. Although this opinion addresses only leasing and exploration, the Service believes there is a reasonable likelihood that the entire action (leasing, exploration, development and production) will not jeopardize the continue existence of the Arctic peregrine falcon. As described in the Biological Evaluation (Minerals Management Service 1990), development and production facilities would be tied closely to existing facilities. New pipelines, if required, would likely be routed along the coast away from nesting areas. Consultation will be required prior to development and production phases. Incidental Take Section 9 of the Act, as amended, prohibits any taking (harass, harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or attempt to engage in any such conduct) of listed species without a special exemption. Under the terms of Section 7(b)(4) and Section 7(0)(2), taking that is incidental to and not intended as part of the agency action is not considered taking within the bounds of the Act provided that such taking is in compliance with the incidental take statement. The Service does not anticipate that the proposed Lease Sale 126 (leasing, exploration and associated activities) will result in the incidental take of Arctic peregrine falcons. No incidental take is anticipated and accordingly no incidental take is authorized. Should any incidental take occur, Minerals Management Service must reinitiate formal consultation with the Service. This concludes formal consultation on leasing and exploration activities associated with Lease Sale 126. Reinitiation of formal consultation is required if any incidental take occurs; if new information reveals effects of the action that may impact listed species or critical habitat in a manner or to an extent not considered in this opinion; if the action is subsequently modified in a manner that causes an effect to listed species or critical habitat that was not considered in this opinion; or if a new species is listed or critical habitat designated that may be affected by the action. Thank you for your concern for endangered species. Endancered : - Secti ms ls: BIOLOGICAL OPINION Agency: Minerals Management Service Activities: Oil and Gas Leasing and Expleration - Arctic Region (Beaufort Sea, Chukchi Sea, and Hope Basin) 2) Snes By: National Marine Fisheries Service (NOAA Fishe: The Minerals Managément Service (MMS) of the Department of the Interior has, to Gate, cffered or proposed five Federal oil and gas weese sales in the Beaufort Sea, three in the Chukchi Sea, anes obe? the Eope Basin. Chukchi Sea Lease Sale 85 and Hope Basif\tease Sale 86 were cancelled. Since 1980, NOAA Fisheries fs conducted Section 7 consultaticns for Cuter Continental Shelf (OCS) lease sales in the Arctic Region and has issued the following Biclogical Opinions: sstic Regicn April 1, 1982 - Arctic Region in general Beautor= Sea June 24, 1980 - Joint Federal/State Sale BF, April 1, 1982 - Revised Opinion ‘cz Sale BF, May 13, 1982 - OCS Sale No. 71 (Diapir Field), December 19, 1983 - OCS Sale Nc. 87 (Diapir Field), May 20, 1987 = CCS Sale No. 97 (Zeaufort Sea), Chukchi Sea September 1, 1987 - OCS Sale 109 ion (1980) found there was insufficient The cricinal BF Ori jeopardized infornaticn te determine whether bowhea by the lease sale. In 1982 tnese uncerta the basis to find bewhead whales were likely to be jeopardized by activities asscciated with the lease sale. Activities associated with Lease Sales 71, 87, and the Arctic Region in general were also fcund t ly jecr ze bowhead w pepulations. Jeccardy fin ‘ is about the effects ef cil spills and of cil exploraticn-asscciated noise on the bewheac pepulation. Insufficient data existed ts adequately examine these issues, and a conservative apsreach was taken to pretect the pepulation. Subsequent research has been and is being conducted to determine better estinates of population abundance and. distribution, investigate the probability of the occuzzence and effects cf an oil spill when whales are present, and investigate the effects cf exploraticn-asscciated noise on the whales. A‘tter considering results from the mest recent research ava. le at that time, NOAA Fisheries issued opinions for Lease Saies 97 and 109 that bowhead whale populations were not likely to be jecpardized by oil expleration activities. Both opinicns, hewever, expressed concerns abcut oil spill and noise effects and recommended placement of restziccions cn drilling asscciated activities, especially when whales were present in the spring lead systems. MMS believes the "jeopardy" conclusions in the earlier opinions, based on infcrmation then available, are no longer warranted. MMS cites the substantive information investigating oil spill risks and effects to bowhead and other whales of noise from OCS oil- and gas-related operaticns. On April 9, 1987, MMS requested NCAA Fisheries to re-initiate cecnsultation and amend these opinions where appropriate. is Opinicn is for leasing and exploraticn activities in the entire Arctic Region (Lease Sales BF, 71, 87, 97, and 109), and replaces the earlier Opinions fer Arctic Region sales. Opinions on future lease sales shculd incorporate by reference this Opinion if it contains the best information currently available Pees ivities: This is an incremental step consultation covering leasing and exploraticn activities of OCS lease sales in the Arctic Region (Lease Sales BF, 71, 87, 97, and 109). The activities considered are oil and cas lease sales, and the subsecuent exploratory drilling, testing, and surveying. Separate consultations for develcement and preduction activities will be conducted if oil is discovered and develcpment plans are prercsed. The details for past or potential exploration, development, and production scenarios are contained in each respective Final Environmental Impact Statement for each proposed sale. Details for future lease sales will be provided by MMs. The expected resource potential for the Arctic Region is 1.74 billion barrels of oil with a marginal prebability of discovery of 0.82 (Powers 1987). These estimates arrly to all undiscovered eccncnically recoverable rescurces in the ufort Sea, Chukchi Sea, Eere Basin Planning Areas. The activities associated with lease sales in the Regicn are fores to be similar to the act. ties asscciated with past and proscsed lease sales, with expleraticn beginning cn newly leased tracts the first year 2 A total of 23 sy wells are pr: the Beaufort Sea, pe Basin Pl panning Areas. these, 9 likely fzsm mebile gravity ips. Drilling t=cm ice-streng—nanec @sill ships cr cther floating Flat‘sras will be conducted in water depths cver 25 nm, working in the late summer ance when there is miz sea ice. For the purposes of this cpinion late summer and f “are consid d July through mid-Neventber in the southern Chi Sea and in ie Hope area, August thzcugh Octsber in the Beaufort and Icebreaker assistance would be necessary 1g season into f. In water depths of and ice islan Sle steel drilling structures may be used for exploration (MMS @ islands may be used in water depths to G units, or other round drillships or ice- ng platfcrms, may be used for exploration in gesths over 30 m. Mcnoccne-type structures (mobile, founded structures) have been designee but not yet sicted fcr the 30 to 50 m water depths. Sub-sea well ly. Associated activities incluce ice-breakers in support of erillships, helicepter flights, suppl y beat trips, and dredging ut seme well locations pricr tc installaticn of the well-head. In the Chukchi Sea, drillship cperations may be supported from barges towed ints the area from the west ccast. The most. practical methce cf support may be to load all equipment and supplies abcard a large ship and keep it near the drilling site (x8S 1985). Basin Planniz RNerthern Chukch. to excend the d=. less than 25 nm, caisscns, or conc: 1985). Caisson reta. 30 m. Conical ¢: const: completicns are ur Shallew-hazards seisnic surveys are expected to cccur on leases in the Beaufor= Sea, Chukchi Sea, and Here 3asin Planning Areas. The total shallow-hazards seismic activity is estimated to cover 80,000 line kilemeters. Low resolution, deep seisnic surveys (air guns) are primarily a pre-lease acx. <y and few, if any, are projected ts cccur as post-lease activities. Listed Stecies and Critical Habitats: There are six species of endansered whales that inhabit Arctic Regicn waters of Alaska. Tnese are: Bowheac Whale Balzena mysticetus Right Whale Eubaleana clacialis Fin Wral Balzencotera physalus Sei Whal B. borealis Euapbeck Whale Mececsera novaeancliag Gray Whale Escorichsius roi cai habiczat has been designated fcr any endangered whale under Secticn 4 cZ the Endangered Ssecies ac= (ESA). Tne right and sei whales are rare in Arctic waters. They are representec by isolated records in the Cnukshi Sea, probably of stray individuals well outside the normal ranges of their Populaticns. The humpback and fin whales are occasicnal inhabitants ef the Chukchi Sea, usually in lew numbers. Both are at the ncrthern edge cf theiz summer range wren in the Chukchi Sea. The few migrants that reach Arctic waters in the summer are foune primarily on the Siberian side of the southern Chukchi Sea and have been only irregularly sighted in the Alaska sector. Only the Ecwhead and gray whales commonly ecccur in the Arctic Regicn with gray whales only occurring infrequently in the Beaufort Sea. Grav Whale: The ncrthern Bering and Chukchi Seas are the main summer feeding grounds for the gray whale pcesulation. Gray whales are regular summer inhabitants of the Chukchi Sea from June through October, althcugh the majority of the pcpulation probably summers south of the - The Bering Strait is an impertant migratory corridor for whales moving north between lat te May and August and returning to the Bering Sea from September to Ncvember on their return tc scuthern waters. From July through midc-Octsber, scme gray whales are found regularly as far north as Peint Barrow, anc a few occasicnally travel as far east as the Canadian Beaufort Sea. Present kicwledsge of the distribution anc abundance of the gray whale is incomplete. Up to cne-fourch of the total gray whale pepulaticn of an timatad 21,113 (IWC In press) may enter the horshern Chukchi Sea to feed during the csen water season (July-Octcber). Gray whales have been cbserved feeding in the Alaskan Chukchi Sea well into October (Ljungblac et al. 1983).. However, it is not known if this is a summer resident feeding population of gray whales. Many gray whales have been observed feeding in coastal waters of ncrthwest Alaska during summer anc fall aerial surveys (Ljungblad et al. 1985a, 1987). Most recent sightings of gray whales feeding in the Chukchi Sea are in nearshore waters averaging 2C.5 m in depth and within 14.5 k& of shore (Moore et al. 1986). They normally avoid heavy ice ccnditions, remain scucn ef the pack ice edge, and leave ncrchern areas before freeze-up, an exception being the Fall of 1988 when 3 gray whales were trappec by ice off Barrow, Alaska. Other reports of whales feeding farther offshore are knewn, and fee ing appeazs to be widespread. Bowhead Whales: The bowheac whale is the nerthernmost ranging of the great whales. The size cf the Western Arctic population of is whale has recently been estimated ts se 7,800 aninals 4 5706-10,600) (wc =. ia the spring f=c= Vv pass through the eastern Chukchi Sea f=cm late March to mid: opened leads anc pelynyas in the shear zcne = ice and offshore pack ice. Recent accustic su> that bewhead whi Ss also swim thrsugh the area within several cemeters of the leads. The sath followed through the leads alcng the edge of the sh fast ice varies in distance from shore with water depth and the =crcegraphy of the esast. At ccastal promcntories such as Pt. e, Cape Lisburne, Icy Cape, and Pt. Barrow the leacs are a few kilometers of the coast. At indentations, the she: e zone is wider and the leads far=n cm shere. The spring sion of bewhead whales pas= Cape Lisburne seems to follow er mere corridors, depending on the nuzber of leads, 2-10 ke cffishcre (Braham 1984). This migraticn essentially spans the peric¢ =id-April to early June, with a few whales migrating before and after depending on annual variability in ice conditions. ass). These wintering areas Strait and through newly im the shorefast data indicate ice In the Beactcort Sea, the fast-ice zcne is =zsader and the leads are progressively farther offshcre as they excendc eastvard. The lead system at Pt. Barrow is especially naz=s~ anc close to shore, and all whales are believed to func ough the near- shore leads cr under the ice adjacent to the ieads. The width of the lead system varies with ice mcvements anc sometimes less than ene k=. East of Pt. Barrow, the spring @ system begins to branck cffshkez' asz cf 151° W (apers: ly the longitude ef the Colville 3 >), the leads dissipate <o numerous branches that vary in lecaticn and extent year to year. Here, the nigra m corzsider widens as mul e leads are used by the whales in theiz movements to the Canad. Arctic (Ljungblad et al. 1982). The spring migration appears <s be contained between 71°20’ N and 71°45’ to at least as far east as the longitcde cf Ba>= Island. Past Barter Isiand, the path of the eastward migration is less predictable, anc complex leads branch north and east towards Banks Islanc. In spring, bowhea¢c whales use the Alaskan 2ea: fc: i icn path. A ities such as calving, socialization, and seme cpeertunistic feeding also cccur, generally the whale nev “s are purpeseful thrcugh the area (Braham et al. 1980, ijungblad et al. 1932, 198Sa, 1987 ‘or example, three whales taxen by Barrow natives in the spring cf 1985 had stomachs full of zcoplanktsn (Geerge anc Tarpley 1986), as did 4 of 7 harvested in 1936 (George et al. 1987), indicating that at least in scne years feeding e¢ces cccur aleng the =i¢graticn path. skan Beaufort Sea still heavily ice- askan Beaufort Sea eys beginning in Bowhead whales apcear to be scarce in the during July when the offshcre water is u: bound. Bcwhead whales retz. as early as the beginning cf August. A August have beer ccncucted in the Beaufort Sea since 19382. During 1982 and 1983, keowhead whales were ‘cund in the offshore area east of Bazcer Island as early as August 2 (Ljungblad et al. 1985a,5). Distrisbuticnal data for an offshcre compenent does not exist, hewever, such an offshcre component cculd partially account for the small number of nearshore sightings compared to the estimated size cf the pepulation. In addition, they apparently do nct ccommcnly occur inside the Beaufort Sea barzier islands. From 1974 to 1988, only one contizned sighting of a bowheac whale has been made insice the Islands. In the fall, Ecth feeding and migration accivities. occur in the Alaskan Beaufcrt Sea. Certain areas appear to be regularly used for feeding resting. The b ad feeding area is east of Basser Island including ¢fshore of Demarcaticn Bay, where bowhead whales repeatedly were observed feeding and resting in the fall (Ljungblad et al. 1982, 19837 McLaren and Ric! ‘dson 1985, Richardson et al. 1986). Bowhead whales have also been ckserved feeding nerzh of Flaxman Island (Ljungblad et a 1982), in cuter Harriscn 3ay north and east of the Colville River plume (Ljungblad et al. 1983), and in the waters offshcre cf Smith Bay and east of Barrow (Braham et al. 1983, 1984, Ljungblad et al. 1985a). A two year study (Richardson, 1987) on the importance of the Eastern Alaskan Beaufort Sea to feeding bewhead whales indicates that, for the population as a whole, focd resources consumed in the Eastern Alaskan Beaufort Sea do not ccncribute significantly to the annual enersy needs of the Western Arctic bowhead stock. However, it was also ncted that in some years those animals that feed in the study area longer than others nay acquire a significant fsaction of their annual energy needs in the study area. Bowhead whales tend to congregate at locaticns with significantly higher ccncentraticns of zocplankton (prinarily copercds, mysids, and euphausiids) than are present in surzcunding waters (Richardsen et al. 198Sa). Such feeding deep water areas has been inferred in the Canadian Beaufort cn a regular basi (McLaren and Richardson 1985). Feeding in late summer and autumn may be especially important tc bcwhead whales as this may be the last major feeding period for several months and the energy content of the zocplankton prey is highest at this time (Lowry and Frost 1984, McLaren and Richardson 1935). In addition, bowhead whales appear to feed while wintering in the Bering Sea (Schell, Saupe and Haubenstcck 1987). Depending cn ice ccrditions anc proximity ts freeze-up, the bowhead whales appear to alternate feedinc and westward migratior activities, probably stcpping to feed in areas containing suitable prey. In 1985, there was evidence of feeding while times when they Cc areas (Thomsen 19386, tess). es that oil spills and ncise associated with ies in the Alaska OCS Arctic Region have the 1 ts acversely affect endangered whales. Because of atively low population numbers, their habit of ig confined csastal waters, and theiz apparently low ve rate, bowheac whales may be pazcicularly vulnerable to impacts from cffshcre oil and gas activities throughout theiz range. Since the issuance of the Arctic Region Biolegical Opinion in 1982, several studies have been conducted on the possible effects ef OCS acc. ies on bowheac anc gray whales. Studies on the effects ct cn marine mammals have continued (Geraci and St. Aubin 1986), hcwever, none has been conduczed cn living baleen whales but cnly on the baleen from dead ssecinens. Noise ¢Gistussance c= bowhead whales related tc industrial activities have been scx ec curing a 5-year program in the Canadian Beautcrz Sea (Richardson and¢ Green 1983, Richardson et al. 1985a,5, 1986, 1987). Seme studies have investigated noise Gistuzsance cf bcwhead whales in Alaskan waters (LGi et al. 1987, Miles ec al. 1987). Qil sili prskabilities: Oil spills from ocS crilling are a j & Sau 1 spilled in the spring lead systems might be ead whales contacting the oil while migrating OQi1 spills in the fall night affect bowhead whales in feed. areas or along migraticn paths cner through cpen water or amcng multi-year or newly forming sea ice. oy ks from gravel islands or cther bottcm-founded perhaps generally less than’ from drillships. cns from these structures are generally spread out over a cd that does not have to ccincide with the bowhead migration because theiz cperation is not constrained by ice conditions. Because bcttsm-fcunded structures are used in the shallower waters, the probability cf oil frcm a blowcut contacting bowhead whales is pare dependent ‘on whether or not the structure is lecatad spring migration path. Although much of the oil may be ec cn the structure, any ssilled oil that entered tne water may be difficult to contain and clean up. cil spill cr blowout asscciated with a drillship, on the other y to enter the water. Alsc, drillships, which are e for use in deeper water, are more likely to igzation path. Drillships crerating in the nc cperations temrcrarily and move of: because cf pack-ice encrcachment. The risk of well- a con i problems may increase secause of suszensicn of cperaticns and subsequent seentzy into the well, however, MMS (J. Lewis, MMS, pers. comm.) believes that the creased risk is minimal. Easley (1987) repcerted that althcugh circulation cf heavy mud was the mcst commcn methce of well control fcr blowouts of wells silled fzom staticnary platicras, this methed may not work for drillship blewcuts. Due to safety requirements, drillships may have to move c2= location if a blowout occurs. Therefore, it cannot circulate mud for well control but must rely on cther remedial acticrs. In additicn if a relief well is required to halt a blowout, it may nct be possible to complete it during the normal drilling seascn. However, MMS believes that the drilling season can be extended into early winter if necessary through the extensive use cf ice-management programs. MMS (Powers 1987) estimates a mean of four szills of 1,000 barrels or greater in size in the Arctic Region over the projected life of all fields discovered and develcped in the regicn. is assumes full develcpment of the resource estimate of 1.74 billicn barvels and tr portation of that oil to shore. MMS alsc estimates that mcst 1 iy zero spills of at least 100,000 barrels will occur. MMS has concluded that the probability of an oil spill resulting from 2 bleweut iG explcratcry drilling. is extremely low (Martin 1986). In fact, to date, there has been no oil spilled as a result of a blewcut during exploratory drilling on the U.S. OCS. They cite several studies of cffshcre drilling statistics that indicate the probability cf a blewout curing cffshore exploraticn cn the U.S. OCS is around 0.64 percent or about 1 blewcut per 1 wells drilled, hcwever, mest of the data is from ézill in the Gult of Mexics. MMS believes that such a low probability dces not pose a threat to bowhead whales as a result of an cil blowout from exploratory drilling. In fact, based on the U. S. record and technically advanced equipment, procedures, and cperational training employed in exploratory drilling in Arctic, MMS expects a substantially lower probabilisy of an oil blowout during expleratsry crilling in the Arctic Region. Easley (1987) reviewed MMS’s cil spill probability statistics and suggested that the factors asscciated with historic data used by MMS to calculate the statistics may be entirely different from those asscciatec with future blowouts. He also suggested oil ties should be computed using mcre systematic techniques ault-T> e Analyses and/or Failur Ge and Effect i er of blowouts by of Mexico wells) as cf wells drilled Cc eccne by MMS. An oil spill from a blowcut has net cecurred to date in the Alaska CCS. Fer this reascn it seems reascnable tc examine data from the remain U.S. CCS to get apersxinate values that may be applicable Ze: Alaskan OCS. Because che number cf blowouts in other U.S. OCS regions is very small csnsared to the large number cf drilled vells, NCAA Fisheries believes the probability of an cil spill resulting from a bleweut during exploratory Grilling in the Arctic Region is low. Ecwever, we recognize that cther techniques may be available ts calculate oil spill probabi ies anc we urge MMS to investicate these possibilicies. Finally, MMS cites legal authcrities and crerational procedures (Murrell et al. 1987) that are in place ts ensure safe drilling practices on ccs leases, providing further assurance that an oil spill from exploratery drilling would be uniikely. Such authcrities include cperaticnal requirements contained in regulaticns, OCS Operating Orders, lease stipulations, inspecticn requirements, and conditicns.of approval c* Exploration Plans, Applications for a Permit to Drill, and Critical Operations and Curtailnent Plans. If, hewever, an cil spill sheuld occur during exploration es {>om either a bloweut or an cperecional discharge, the eondizicnal probabilities (expressed as percent chance) that an oil spill will contact a cert tain bowhead whale habitat (i.e., spring er fall migration csrziders, feeding areas) within 3 to 30 days have been calculated to range from nil (less than 0.5 percent) ts nearly 100 percent depending cn spill location and seascn (MMS 1985, 1987a,5)- Effects of O33: Assuming an cil spill were ts cccur and contact whales, the worst adverse imracts to from contact with spilled oil include death or illness caused by ingestion or inhalation ef oil, irritation of skin and eves, fouling of ng mechanisms, and reductien of focd stzplies through centaminatien or lesses cf focd organisms. Although no data exists cn effects of oil on bewhead whales in the open ocean, iberz (1981) speculated that the mest likely adverse effects of eil contact to bewhead wha es would be 1) esnjunctivitis and ccrneal eye inflammation leading to reduced vision and possibly blindness, 2) develcpment of skin ulceraticns from existing eroded areas on the skin surface with subsequent possibility of bacteremia, 3) compromising cf tactile hairs as sensory structures, and 4) develcrment of Ersnchitis or pneumonia as the result of inhaled irritants. In a laboratcry study using baleen plates from bowhead whale specimens, plates fouled by oil had decreased filtering efficiency fer at leas= 30 days but 85% of the efficiency was restcredc a eight ‘keurs (Braithwaite et al. 1982). This fculing possibly may resulz in oil ingestion whi cally, could leaé tc bleckace cf the narrow channel cf the stomach (Albert 1981). Ecwever, the extent of ig) oiling that weuld be necessary ts produce these effects is unknewn. Nei is it knewn) hewever, if ciling wculd produce such ects. Experiments Ey Geraci and St. Aubin (1982, 1985, 1986) cencnstrated that effects of accual ciling of certain marine mammals (nc bewhead whales were tested) are probably short-tera, transient, minor, and reversible. Altheugh direct evidence is lacking, Geraci and St. Aubin (1986) reascned that Ecwhead whales have the visu: capabil ity to detect spilled cil which sufficiently alters the crtical properties cf the surface, and may also be able to detect cil by tactile senses. Cataceans may be initially attracted to an oil slick but May subsequently beccme conditioned to avoid them. Such behavicrs, as displayed in dolphin studies, nay help individuals avoid multiple esntacts with cil. Geraci and St. Aubin indicated, hcwever, that in heavy ice conditions, the ability of bowhead whales to avoid oil trapped among ice weuld be limited. Ahmacgak (1986) suggested that kowhead whales may not detect oil fouled waters and, even if they could, they may not avoid it. Observations f=cm the Recal Swers spill of2 Cape Coed (Goodale et al. 1982) shcwed that large whales ( ., fia, humpback, and probably right whales) did net avoid areas c# oil spills and apparently perfcrmec nermal activities, such as feeding, in and ameng cil slicks. This may indicate that either the whales were unaware cf or unable to detect the oil slicks, or were nct bothered by them. Gray whales cfs Coal Oil Peint in Califcrnia shewed mixed reacticns to the oil seeps there (Geraci and St. Aubin 1882). Seme whales aprarently avoided the area, and others mecified theiz behavior while passing through the area. Whether this indicates detection and learned avoidance among individuals, or adverse reaction, is unclear. In any case, these examples indicate that whales may not readily avoid cil spills, and may, therefcre, be susceptible to the effects of contact with a spill. Ecwever, nc ill e*fects to whales have been crserved in these areas. Geraci and St. Aubin (1986) corcluded that the skin of tocthed whales and dolphins is at least partially resistant to oi il, and subtle effects caused by shert-term contact with volatile components are reversible. They believe the structure of the skin ef bowhead whales should afferd at Lees’ equal protection. Eowever, the questicns of adhesiveness of oi! to the skin and the effects of long-term exposure to persistent ait remain unanswered. Albert (1981) and Ahmaogak (1986) suspect that the skin ercsions cn bewhead whales will facilitate adherence while Geraci and St. Aubin (1986) believe that unless whales are trapred in a lead and remain in continuous csntact with newly lied cil fer a period of heurs or days, fetroleum hydrocarbons would have little effect on the intact ep derais of whales. 10 acm varcrs, pa: ularly the low mclec. arscns, inhaled wichin a few hours c2 5 Evaperation rapidly removes these c: they are the =st to disperse into the a. be slcwed in the cold Arctic waters, pessibiy lessening the spread cf harnful ccncentzations of tcxic vapors. Inhaled volatile hyédrscarbons may aggravate lung diseases or be absorbed into the circulatory system and liver. Bcwhead or gzay whales enccuntering a weathered cil spill in cpen water would not be exposed to harnful vapors (Geraci and St. Aubin 1986). Althcugh bewhead and gray whales may feed cn contaminated prey, it appears tc be difficult for them to ccnseme enough oil in this manner to be sciscned by absorbed hycrsocartcns. As in humans, cetaceans cculd develop lung damage from aspirating regurgitated hyerocarbens (Geraci and St. Aubin 1986). Bowhead whales rely primarily on ice leads, cracks and small pools ice during their spring migration. Cracks and small pocis kely ts concentrate spilled oil entering the water. Bowheac whales, in a lead system, may be unable to avoid encounters with oil in cracks and small peels, and, therefore, would be acre susceptible to oil contact than would whales in open water. Hansen (1985) reviewed the erature on the potential effects cf oil sz. > marine mama!s, and suggested that the level of effects would be related to the degree of expostre of a cetacean to an oil spill. Baleen whales, such as the bcwhead, may be less likely to avoid cil slicks than more mebile small cetaceans, and the bowhead whales’ asscciation with may also provide less ability or crscrtunity for avcidance than fer subarctic species (Geraci and St. Aubin, 1986). ffects cf oil spills on whales may include reduction in ity cf feed within localized areas near the spill site areas where the cil slick occurred. Ecwever, Richardson (1987) suggests that it is unlikely that accidental oil spills would have a significant or lasting effect on zooplankcon in the study area, or on the availability cf zooplankton to bowheads. Nonetheless, there may be uncertain long-tera effects of oil ingestien ané hydrocarscn accumulaticn. Noise disturbance: Many of the sounds produced by industrial acti es are at low frequencies (below 1000 Bz), which is also the equency range of nost bowhead vocalizations. Such low frequency noises could travel long distances to waters used by bowhea¢ whales for migration and feeding in spring and fall. m noise ial impacts to whales that may result ¢: i vity, short- or clude diszzption of feeding ac 12 n sccialization, res uctive behavior and iegicai stress, and pessibly even onal areas. Geophysical seismic noise, = 2 ction, icebreaker activicy, and other vessel noise in areas where whales are present, possibly, could cause such impacts. e 1 ef noise required to produce these effects depends on the distance of the ncise frcem the animals, the ambient ncise levels, the scurce level of noise, and the acoustic provagaticn properties of the environment. 5 abandcmment cf tra e@rilling, const= To date, there has been littl impacts of Gustrial activities on bow! whales in Alaska waters. Tnis is because of seasonal dr: ng restrictions imposed fcr the first three Beaufort Sea Federal oil and gas lease sales and because mest prior OCS acti es in Arctic Alaska (all cf which are still in the exzloration phase) have eccurzec in the Beaufort Sea during the winter when bowhead whales are nct present. During the spring, the ice leads used by the migrating whales are cffshore and away from any gravel islands where mcst Beaufcrt Sea wells have been drilled to date, and Sxplcraterd ¢zilling in the spring lead systems has not occurzed. to directly assess the Explcraticn at a few drilling lccaticns has recently been Fernitved during the fall migration. Mcst of these locations have also been shoreward cf the main migration ccrzidor. In 1985, Unccal Exsloraticn was allowed, ky waiver of MMS’ Stipulaticn #4 fcr Lease Sale 87, to conduct drilling during the fall whale migzaticn frcm a drillship cperation in the Alaskan Beaufort Sea. However, the dr. ng Was completed before the onset of the fail migration. Drilling of a second nearby well in 1985 by Shell Western was prevented by heavy pack ice. In 1986, Shell Western concucted exploratory drilling during the beginning of the fall migration, and Unocal subsequently drilled an exploratcry well, during the migration. The two wells, which were located in the nearshore migration path cf the bowhead whales, were d>illed using a drillship, an icebreaker and icebreaking support vessels. Drill-asscciated noises were monitcred to determine their effects on the migrating whales (IGL et al. 1987). Data from these studies suggested that migrating bowhead whales avoided and cculd have been displaced by the offshore drilling eperaticn. No whales were sighted closer than 9.5 km from the drillship, and few were sighted closer than 15 ka (LGL et al. 1987). Significant numbers of bowhead whales passed south of the as well as north of it. One whale was tracked for 6.8 hours while it travelled 32 ka. The whale moved in an arc-around the saticn maintaining a distance cZ# about 23-27 km from Bewhead whales ckserved between 15 and 30 km from apparently cid net exhibit "strong" (i.e.. definite 12 cived najecr e cycles) behavicral There was ne e nee that the dz: ng cperzticn (including the SUPECT= ve: czed as a barz o migzation (LGL et al. 1987). Ecwever, during the study period ice conditions were very light and animals cculd pass north cr south cf the rig. No evidence exists to determine if whales woul or would not approach an crerating rig to continue their nigration during heavy ice conditicns and if the rig was lecsced in the migration path. Althcugh recent research indicates whales travel under the ice near leads, it is not known how far whales travel from the leads. nce respenses to industrial activicies of bowhead whales i¢ in the Canadian Beaufcr= have been the focus of a S-yea> study (Richardsen 1981, 1982, 1985; chardsen et al. 1985a,5, 1986, 1987). Sound scurces, besi¢es ambient noise, included gecphysical seismic exploraticn, illing and associated machinery ncise, dredging, ice: ker activicy, beat and aircraft traffic, and constructicn ef grav islands cr other offshore stzuccares. Behavicr near actual and simlaced activities associated with cffshore oil exploraticn was compared with prestzably undisturbed behavior. In ge 4, bowhead whales Sora ecnsideras. ance cf oncoing ncise from dredging or azillisg, but ten to react mere strongly to a moving or rapidly changing ni aiz: ez the stascaup cf noise scusces ( 198Sa,5, 1986, 1587). In the Canadian Beaufort studies, behavicrai respcnses of powhead whales were nct apparent beyond 4 ko from an active driliship. Eowever, playbac: iments showed that scue whales reacted, althersh nct stz neises a= intensities sinilar to these e Griliship (Richardson et al. 1885a,b, 1986, 1987). Why bewhead whales reacted mcre strongly to playback noises than to actual ncises is not clear. Richardsen concluded that sightings near d¢rillships and the limited reactions ts playbacks show that a ast some bowhead whales su=m iG in the Canadian Beaufort tslerate considerable @rillship neise. In fact, comparisen cf behavior of bowhead whales senmering in the Canadian Beaufort with that of migrating whales in the Arctic Regicn (LGiL et al. 1537) indicates that summering whales may be considerably mere tclerant of drillship ncise than migrating whales. duced behavioral avoidance and Playback cf dredge ncise in Canadian waters respenses f: scme kewheac whales, includ: changes in ex cut to 2.25 ka, al scur whales cbserved beyend 2.8 i. Hcwever, there are differences in reacticns cf these whales ts dredge ncise. @ whales seen near ezedses y have beer less sensitive animais; these more ve may have mcved away earlier or aay have avoided the area (Richardscn et al. 1985 a,b, 1986, 1987). Tne eftec= cf neise associated with a drilling operation on bowhead whales has also been investigated using simulation medels. In an MMS-ccntracted, 2-year study cf noise characteristics and prepagaticn, the underwater acoustic envircnments of five specific drill sites in the Alaskan Beaufort Sea were measur during 1985 and 1986. ‘This infcrnaation was used to simulate preliminary estimates cf zcnes of responsiveness of bewhead whales to these noise sources. The zones cf potential responsiveness (where half cf the whales would prebably respond at a 30db signal to noise ratio) were estizated for continuous noise scurces at 6 drill sites through mcdceling studies. The of respcnsiveness ranged from 1 to 8 ia for a tug underway in open water, 1 to 4 km from an active driilship, 0.02 to 0.2 ka from nan-nade. gravel island drilling noise, 2 to 12 ka from an icebreaker underway in open water, and 1.6 t9 12 k= from two tugs forcing a barse against an islané (Miles et al. 1987). Because the study by Miles et al. involved no direc= observaticns of whale behavicr relative to real or playback sound, they relied on Richardsen et al.’s earlier reported crsezvations of whales behavioral responses to comparable scunds in the Canadian Beaufcrt Sea. Therefore, Miles et al. were able to insert Richardson’s ckservations ints a broader framework wherein roughly hal? cf the bowheac whales shew avcidance respcnses (prebabi: cf avoidance of abcut 0.5) ts industrial sounds which have a 30 G3 S:N (signal-ts-nei ratio). A smaller prepercicn cf the bewhead whales ckserved ty Richardsen, et al. reacted when che S:N is abcut 20 43, which wculd occur at greater ranges than those estimated above by Miles et al. and a few bowhead whales may react with even lower $:N. However, some bowheads cbserved by Richardcscn, et al. apparently tolerated S:N ratios cf 40 @B without exhibiting an avcidance reacticn. physical sounds from seismic surveys are the loudest 1 scunds emitted into the marine environment. Seismic surveys are of two general types: (1) lew-resclution, high- penetration and (2) high-resclution, low-energy, shallow-genet>aticn seismic surveys. Lew resoluticn surveys (airguns) are used to study ceep geolegic ‘crmations. They are, gene: , authorized under a geolegical and geophysical permit te occur pricr to a lease sale, and usually are not expected to eccur during post-lease sale exploration. Companies most often esnéuct hich sclution seismic surveys ¢ iS exploration on ate potential shallow haza to drilling. MMS s 1987) e ‘cimated that the total high-resolution seismic ty in the Arctic Regicn will be 80, dco line ka. ls whales tented away from a le airgun deployed ( Y, low- system) at a range cf 0.2 ts 4.5 ka 2>cm the scund source (Richardscn 1585). There was nc reacticn to the single airgun vessel at a range cf 3 tc 5 ko in the other three ents. We believe the fects cn bowheac whales from hich- resolution smic disturbances are mincr because low-resoluticn seisnic effeccs disappear (i.e., whales’ surface-respization-dive characta: ¢s return to nermal) within 30 ts 60 minutes (Ljungblad et al. 1985c). Heavy tcat anc aircraft traffic could also affect bowkead whales acversely. In the Canadian Beaufort Sea, responses of whales to meving beats is the mest consistent and second-most prenounced of all disturbance factcrs tested (Mcntague 1985). In mest cases, bowheac whales criented away from a mcving vessel up to 4 ka away and actively swam away from vessels 2 ka or less away. There was nc clear relationship between the size of the vessel and the distance of the response (Richardson 1982, Richardson et al. 1985a). The whales ceased theiz avoidance when the vessel passec cut of range, but may have remained scattered fcr longer pericds. Ccllisicns between vessels and bowhead whales are unlikely if the whales are able to detect and avoid the vessels, cr if the vessels take aporcpriate stess to avoid the whales. Tne reaction cf bowhead whales to aizcraft is more variable than to vessel ncise. Mest reacticns to fixed-wing aircraft cccur at tudes of less than 1,500 feet (Richardscn et al. 1985a). to heliccpters may have a sizilar area of inZluence (M. ia, NOAA Fisheries, pers. ccmm.). DisturSance cue to aizrcratt traffic, unless sustained and intense, is likely to cause cnly temporary disturbance tc these whales. With proper altitude cbservance, mest inpacts from aircraft can be avoided. Noise producing activities, such as drilling and vessel traffic, in the scring lead systems used by bowhead whales have a high potential cf significantly effecting the whales. If migrating Eowhead whales are concentrated within the lead systems in the spring, the noise could sericusly disrupt the migration. However, according to MMS, exploratory activities using floating drill ships within the spring lead systems are not expected during the bowhead migration since the ice at this time of year typically would be too thick for drilling ship and supply vessels operations. Althcugh marine exploration activities generally ecsur for about 90 days, in August, September and Octsber, exploration in the Chukchi Seas anc Ecpe Basin Planning Areas may also cecur in July through mid-November. Additicnal Impacss: To date, the expcsure of bcwhead whales to the efiects of OCS aczi s has largely been confinec to the Canacien Be st Sea. Alaska waters, lizited ¢rilling during the fail migzation of the whales has cnly recently begun. The 15 e2feccs from planned c sre sales will be limited exploratery drilling, i es in boat and air traffic in relation to supsere act: ies, anc the small increased risk of an cil spill cccurzing prior to or during the migraticn period. " The ability of tne bowhead whale to acccmmccate increasing industrial disturbance is uncertain. Some accommodation undoubtedly can cccur, but the level of stress imposed on the species as a result cannot be predicted. A decreased use by bowhead whales of the Canadian Beaufcrt Sea industrial areas, as evidencec from aerial surveys during the summer, has been noted (Richardscn et a. 1985a,b, 1986, 1987). Ecwever, changes in bewhead whale abundance has also occurred cutside as well as i the main industrial area. One suggested cause for the Gecreased use is the effect of increased disturbance from industrial activity that began in the early 1970’s and significantly increased since 1980. Variation in fcod pees eed (zeoplankton concentraticns) may also have been olved. Present and propesedOCS explcratory and development activities in the Arctic Region may eventually adversely affect the successful life cycle of bowhead whales. At present, we are unable ts predict what these tolerance thresholds might be, but we do not believe the foreseeable additive effects of previous and planned sales shculd exceed this level c? concer. Continued efforts ts menitor distribution patterns and indicators of populaticn health, such as reproductive success, recruitment, Growth rates and behavior are important ts assure the combined. effects from all ocsS activities are nct lixely to jeopardize the continued existence cf the bowhead whale perulatiocn. Based cn review of the information provided to us by MMS and from information available on endangered whales, NOAA Fisheries has reached the fsllcwing clusions on progcsed oil and gas leasing anc expleraticn activities in the Arctic Region. Richt. Sei, Fin and Humpback Whales: The prcposed activities are net likely ts jecpardize the continued existence of the right and sei whales. Right and sei whales rerely cccur in Arctic waters, being found there cnly as isolated, possibly stray, individuals, and are unlikely to be affected adversely by the identified i Ss. The prepesed activities are also not likely to e the continued existence of humpback and fin whales 16 ties are not < waters gray Grav <shaies: We conclude that she likely <s jecra: ze the gray whal whales are mcst y tc be southern Chukchi Sea anc the Bering Strait r m and would be affected mest by oil anc gas exsicration acc: ies in these areas. chaps as much as one. asch of the gray whale perulaticn may enter the Rershem Chuk: thrcugh the Bering Strait. Althcugh some individuals may er Gisturbances cr other impacts from the propesed activities, due to the gccd overall condition of the gray whale pcpulation and to its widespread distributicn in the ing and Chukchi Seas, such impacts are nct likely to jecparzize the existence of the species. additive impacts that cculd result from past and future ivities in the Arctic Regicn, the Bering Sea, and in other regicrs outside Alaska, may have the pctential to affect the Ppepulaticn adversely. Csntinued moenitcring of the health of the gzay whale porulaticn and the effects cf OCS activities in these as are impcrtant to assess whether the combined impacts are eczing the gray whales acversely. Bewheac Whales: We conclude that the prcrcsed activities are not the continued existence of the bowhead whale. Ecwever, the primary concerns cf NCAA Fisheries in the Arctic Regicn fcczus on the bcwhead whale. The entire rorulaticn of this whale is susceptible to impacts in this area during its spring migraticn thrsugh nearshcre leads. In the fall, a large Pers. ef the bewhead whale perulation may acain be expcsed to S anc disturbance from ncise when they migrate through ¢ Regicn bcth nearshcre and offshere with the pack ice. Qi. seit) Prsbabilisies: Based cn infczaation utilized by MMS (Marcin 1986), an uncontrolled cil bleweut or a major oil spill in the Arctic Region as a result of expleratcry drilling is an unlikely event. Therefore, we conclude that exploratory drilling itselt does not constitute a significant level of risk of oil spills. Neise Disturbance: Large cr widespread ncise disturbance along ing or fail migration paths cr in feeding areas could y i Sing *% successful feeding, behavioral activities. The range or level of uca these effects derends on the location and on the acoustic proragation properties Although some impacts to individuals may le do “net. “yelieve anticipated prepesed exploratory e noise levels e: ec to reduce a@l and recovery of the seucti nuabers, or ien is based cn the asscapton eccur w. che sz m. If new exploratory es tacknolesy, procedures, ets., are develcped that would allow activity in spring leads, MMS shoule reinitiate our iz other activities in the ssring lead systems az scussedc further under the subsequent section cn "Incremental Step Consultation". Althcugh individual ispacts may occur, we able exploratory activities in the Arctic negicn are unlikely to produce a level of physical impacts, such as collisions with vessels or structures, shat are likely to jecparaize the species. Based on jecpardy conclusions in previous consultations, expleratsry Grilling cperations in lease areas have been restricted by lease stipulaticn to avoid cz reduce their ccinciding with bewhead whale fresence dur the fall migraticn. However, new infornation indicates the probability of an oil spill during oil exploration is very small (Marcin 1986) and other recent research suggests that bowhead whales continue their migration while avciding noise fren drilling operations by Getcuring azsund the é>i conditicns (LGL et 2. 1987). eratory drilli times cf years and Eeeiaeat of the lease azea whe: whales are net present may nct be necessary to preverc jecpardizing the population. Because few Ecwheac whales have been sichze< inside the Beaufort Sea bazz: rations during the bewhead migraticn shculd nct be res side the barrier islands. However, menitoring CCS expleratcry drilling outside the barrier islands especially curing heavy ice conditions, when concurrent ice-breaking activity would be createst, should be conducted to insure that migrations are nct blocked or impeded, resulting in whales being trarced in the 3eaufort Sea at freeze up. Additionally, several drill sites crerating simultaneously, even in cpen-water years, coulc form an acsusti whale migration. However, present MMS ¢eril? include this possibility. ing schedules do not eries believes that ccntinued menitcring of bowhead rations at industrial sites is necessary to detect any isturbance. Results from monitoring studies and other enal infornaticn will prsve valuable for future suitation on OCS activities, particularly these associated with cevelcpment and product icn. Conservaticn Recommendations iS research neecs ane additional actions that MMS and/or ze adverse e2fects to bowheac the c itiat: # Consulsati During the post-lease exploration phase, MMS should provide NOAA Fisheries with all exploration plans and any subsequent revisicns of these plans. MMS should review these plans to determine if further Section 7 Consultation is necessary during exploration. Consultation mist be reinitiated for the development and production phases in the Arctic Region. Consultation must also be reinitiated if (1) new information reveals impacts from the proposed activities that were not previously considered, (2) the activities are modified in a manner that causes effects that were not previcusly considered, or (3) a new species is listed or critical habitat is designated that may be affected by the proposed activities. 19 ces cf leasi. m to our cpinion cn cn), NCAA Fisheries is cluding development Fer the Federal acer proceed with the there must be a reascnabie likelihccd that the net violate Secticn 7(a)(2) of the ESA (50 CFR increnental entire accicn 402.14(x)). ion and technolegy and the absence cf e2factive nitigatiag measures, NCAA Fisheries believes that develcpment and preducticn act. ties in the spring lead Systems used by Eowhead whales have the potential to jecpardize the co ues existance of the bowkead whale populaticn. We base is b £ cm cur present knewledge of the confined nature of this pathwi and cur cencerns fcr the risks cf oil spills and ncise di ance. Although recent accustic studies indicate that bewhead whales swim beneath the ice within several kilometers cf the leads, it is nct clear how leng whales remain under the ice before _returning to the leads. In parcicular, we believe that ni Ssducing activities in the pathway cf the spring migzaticn csuld bleck or sericusly disrupt the successful movements of the cies along the Chukchi Sea coast and into the Beaufcrt Sea. We believe this potential for jeopardy should be ognized and addressed at the leasing st2ce. NOAA Fisheries 1 recsnsider this conclusion when new information, technology anc/cr mea: es that would e+ vely elininate cr otherwise mitigate this sctential jecparay sizuation become available or are propesec. Baseec cn c Therefore, NOAA Fisheries provides the follewing reascnable and prudent altezmatives that MMS can adcpt to avoid the Likelihood ef jecsardy f=cm spills and noise. We believe that either (1) the lease blocks within 25 miles of the nearshore lead systen should be det ed from the lease sale (fcr example see the Coastal Defesral Alternative VI (MMS 1987a) for Lease Sale 109 and the Barrcw Deferral Area ident. ed by MMS during consultation for Lease Sale 97] or, (2) iz these blocks are leased, develcement and producticn activities should not be approved unless anc until further consultation results in a no jeccardy clusion cr a reascnable and prudent alternative is @ and adopted that would avcid the likelihood of . ifi i tives may be Gevelcred during further consultation, particularly as new crnaticn cr technolcgy is devel: cific development aticn 3 measures 2 posed. Eowever, we reascnable and atives to ave . ced of jecpardy from preducticn and deveicsment activities. 2c INCIDENTAL TAKE STATEMENT Section 7(b) (4) (C) of the ESA specifies that in order to provide an incidental take statement for an endangered or threatened species of marine mammal, the taking must be authorized under Section 101(a) (5) of the Marine Mammal Protection Act of 1972 (MPA). Since no incidental take in the Arctic Region has been authorized under Section 101(a)(5) of the MMPA, no statement on incidental take of endangered or threatened marine mammals is provided. 21 CONSERVATION RECOMMENDATIONS NOAA Fish es c#ters MMS the fcllowing recsmmendations to further promcte the conservaticn of endangered whales in the Arctic Region. 1. MMS, with the assistance of NOAA Fisheries, should establish Measures tc recuce, as far as practicable, pessible impacts from noise asscciatec with drilling and other activities. During the spring (April thrcugh June) and fall (August through October), @rilling, construction, and vessel traffic should not be conducted in a manner that will significantly affect any whales present. Specific measures to reduce impacts of drilling and associated activities at individual well lcecations cannot be Geveloped until these locations are known and exploration plans are submitted. Case-by-case informaticn cn the location, times, and manner cf Grilling operaticns, along with planned mitigating measures to protect bowhead whales, shculd be providec to NOAA Fisheries for review. In addition, MMS siculd limit the number of active indcust: 1+ sites to ensure that the potential for adverse effects is low. 2. To minimize petential harassment to kewhead and gray whales from daily activities associatec with OCS exploration in the Arctic Region, MMS shculd advise operators that aircraft should observe a minimum distance of 1,500 feet (approximately 500 m), horizentaily or vertically from cbhserved whales, anc f=cm areas where whales are believed to be present: and vessels, including seismic geophysical vessels; should avoid concentzaticns of : whales and attempt to keep a distance of at least 1 mile from any observed whales. 3. To avoid adverse effects shcule a majer oil spill cccur, MMS should cocperate th appropriate Federal agencies to ensure that areas occupied by either bowhead or gray whales are clear ef spilled cil. Special precautions should be taken to ensure that spilled oil dces not persist in areas located in or near (a) lead systems used by bowhead whales during their spring migration (April thrcugh June), (b) the bowhead whale coastal migratory corrider from the U.S./Canada Border to the Bering Strait in the fall (August threugh October), and (c) feeding areas used in the fail. . 4. Except for explcratory drilling operations inside the Beautcrt Sea barr. islands, exploratory cperations conducted in the area cf and during the fall migration should be monitored using appropriate survey techniques to dete=mine the movement and activity cf whales near the ¢rill sites, whale migration and ether habitat use, such as f ing. The behavior of the whales shculd be ncnitsred by qualified researchers to deteraine the 22 behavicr cf whales present and if they are being affected. Use of feeding areas is_pa arziguiarly impertant to document. NOAA Fisheries shoui¢ be involved in monitoring efforts and then kept infcrned of the stattS cf ménitsring efforts and of any potential indications of significant disturbance or displacement of bowhead whales. Each year’s research should be ccnducted so that it is comparable wi=t srevicus years. At the end of the seascn all years data shcuic be reviewed and a decision made by MMS in consultation with NOAA Pisheries as to the need and kind of further research. 5. If an unacthcrized take of bcowhead whales cccurs as a result of OCS activities, MMS should halt the activities immediately. It is strongly reccommended that NOAA Fisheries Conduct or participate in the monitoring efforts to make these deterninaticns. 6. MMS is enccuragedc to continue to spenscr research needed to improve knowledge of the seascnal movements and habitat utilization of endangered whales in the Arctic Region, and of the eZteczs of spills and other OCS activities on these whales. Possible areas cf continued research are ts (a) identify and characterize feecing areas anc habitat use of gray and bowhead whales, and determine their importance to the populations, (>) determine the nature and e cts of industrial noise in the Arctic Regicn cn micrating bowhead whales, including geophysical seismic scunds using airguns and drilling noise from beth fixed ane ficating units and their suppert activities, including icebreakers and dredges, and (c) detect cumulative effects. 7. The lecaticn of the spring lead system and distribution ot whales in this system should be investicated to deternine as precisely as possible the lecation, extent and yearly variation of this migratcry corzidor, sc that this information can be used in leasing decisions. 8. The resul<=s cf MMS sponsored research on bowhead and gray whales should be made available to NOAA Fisheries and other perties interested in management of these whales in a timely manner. To provide for greater interdisciplinary coordination among researchers, anc between researchers and agencies, the information gained during the research effcrts should be made available at meetings such as the Biennial Conference on Marine Mammals, Biennial Bowhead Whale Biology Conference, and MMS Infornation Transfer Meetings. 9. The Beautcrt and Chukchi Biolcecical Task Forces should be utilized by MMS for input for sales in the Arctic Regicn to ensure that e@ OCS cperaticns are planned and conducted in a Banner consist with MMS’s responsibilities to protect and conserve endcan iG marine rescurces and the habitacs upen which these rescurces depend. 23 REFERENCES Ahmaocak, G., 1586. Integraticn of relevant data regarding Potential impacts to the bowhead whale from contact with spilled cil. attachment to a May 13, 1986 letter to the Commissicners of Alaska Dept. of Environmental Conservation, Fish anc Game, and Natural Resources. 24 pp. Albert, T.P. (ec.), 1981. Tissue structural studies and other investigations on the biology of endangered whales in the Beaufort Sea. Rpt. to the Bureau of Land Management from the Deparment of Veterinary Science, University of Maryland, College Park, Md., 20742. 953 pp. Braham, H.W., 1984. The bowhead whale, Balaena mvsticetus. Mar. Fish. Rev. 46(4):45-53. Braham, H. W., M. A. Fraker, and B. D. Krogman, 1980. Spring migzaticn cf the Western Arctic pcpulation of bowhead whales. Mar. Fish. Rev. 42:36-46. Braham, H. W., B. D..Krogman, and G. Carroll, 1983. Population biology of the bowhead (Balaena mvsticetus) whale in the Bering, Chukchi, and Beaufort Seas, with notes on the distzibution and life history cf white whales (Relphinasteris leucss). U. S. Dept. of Commerce, NOAA Tech. Rpt. SSRFOO (Reviewed as Final Report to the Alaska Outer Continental Shelf Envircnmental Assessment Program, RUGS.) Braham, E. W., B. D. Krogman, anc G. Carzsll, 1984. Bowhead and white whale migration, distrituticn, and abundance in the Bering, Chukchi, and Beaufort Seas, 1975-1978. NOAA Tech. Rept. NMFS SSRF - 778. USCOC, NOAA, NMFS. Braithwaite, L.F., M.G. Aley, and D.L. Slater, 1983. The effects cf cil on the feeding mechanisa of the bowhead whale. Final Report Prepared for U.S. Dept. of the Interior under Contract No. AA&@S51LT055. June 10, 1983. 45 pp. Easley, R. 1987. North Slcpe Borough comments on probability of an oil spill from offshore exploration drilling: A summary by: Minerals Management Sexzvice (MMS) November, 1986. Attachment of letter dated November 11, 1987 to Rennie Holt, NMFS, 1825 Connecticut Avenue, N.W., Washington, D.C. 20235. 7 pp. George, J. C., and R. J. Tarpley, 1986. Observation on 1984 and 1985 subsistence harvest cf bowhead whales, Belaena mysticetus, ma ncte cn the fall 1983 harvest. Rep. Int. Waal. Comm. 36:339-342. 23 George, J. C., G. M. Carroll, 2. 3. Tarp2 T. F. Albert, and R. VYackley, 1987. Reperc cf field aczivities pertaining to spring 1986 census of Bowheacé Whales, Baleena mvsticetus, cf! Pt. Barzcw, Alaska with cbservaticn on the subsistence bunt. Rep. Int. Whal. Comm. 37:301-308. Geraci, J.R. and D.J. St. Aubin, 1982. tudy cf the effects of cil cn cetaceans. Final Rest. U.S. Dept. Interior, Bureau cf Lan@ Management, Washington, D.C. 274 pp. J.R. and D.J. St. Aubin, 1985. Exzanded studies of the effects of oil cn cetaceans. Final Rept. Contract #24-12-0001-29169 U.S. Dept. Intericr, Minerals Management Service, Washingten, D.C. 144 pp. g.R. anc D.J. St. Aubin, 1986. An assessment of the ects of cil on bowhead whales Balzene myvssicetus. Rerort sxbmicted to Amoco Production Company, Anchorage, AK. 42 pp + appendices. Gocdale, D.R., M. A. Hyman, and E.E£. Winn, 1982. Cetacean responses in association with the Recal Sword cil spill. ch. XZ In: A Characterization of Marine Mammals and Turtles the Mic and North Atlantic Areas cf the U.S. Outer Csntinerntal Shelf. Cetacean and Tuz<le Assessment Progran, Univ. Rhede Island, Annual Report, 1979, For U.S. Dept. asicr, Bur. Land Manag., Washingtsn, D.C. , XI-1 to X2-15 Hanser, D.5., 1985. The potential effeccs cf oi1 spills and ether chemical pollutants on marine mammals occurring in Alaskan waters. OCS Repors MMS 85-0031. Minerals Management Service, Anchorage, AK. 21 pp. 1 Whaling Commission, In press. Rer see on Protected Species and Abo of the nal Subsistence GL and Greeneridse Sciences Inc. 1987. scnses cf Sewhead whales to an offshore drilling operaticn in the Alaskan Beaufort Sea, Autumn 1986. Draft Rercrt prepared for Shell Western E & P Inc. Anchorage, Alaska. 368 pr. Ljungtlad, D.K., S.E. Moore, and D.R. Van Schoik, 1983. Aerial surveys cf endangered whales in the Beaufort, eastern and northern Bering Seas, 1932. Final Rpt: April Ceteber, 1982. Tech. Mem. 605, Naval Ccean Systems Center, San Diesc, CA. Prepared for Minerals Management Service, U.S. Depaztnent of the Interior. 25 Ljungblac, D. X., S. E. Mcore, J. T. Clas! 1987. Distribution, abundance, behavicr, and bicacoustics of endancerec whales in the Alaskan Be rt and Eastern Chukchi Seas, 1979-1986. NOSC Tech. Res. 1177. prepared for MMS OCS Stucy. 187 pp. + appendices. , and J. C. Bennett, Ljungblad, D. K., S. E. Moore, D. R. Van Schoik and c. S. Winchell. 1982. Aerial surveys of endangered whales in the Beaufort, Chukchi and northern Bering Seas. NOSC TD 486, preparec for MMS Alaska OCS Office. 374 pp. Ljungblad, D.K., S.E. Moore, J.T. Clarke, D.R. Van Schoik, and J.C. Bennett, 1985a. Aerial surveys of endangered whales in the northern Bering, eastern Chukchi, and Alaskan Beaufort Seas, 1984: with a six year review. 1979-1984. Tech. Rep. 1046, Naval Oceans Systems Center, San Diego, CA., 104 pp. + appendices. Ljungblac, D.K., S.E. Moore, J.T. Clarke, and J.C. Bennett, 198Sb. Fall data summary: Endangered whale aerial surveys in the Chukchi and Beaufort Seas, 1988. SEACO, Inc., San Diego, CA. Prepared fcr Minerals Manacement Service, Anchorace, AK. 8 pp + appendices. Ljungblad, D. K., B. Wursig, S. L. Swartz, and J. M. Keene. 1igsSc. Behavicral responses of bowhead whales (Balaena Dvsticetus) elicited by close approaches of active gecphysical vessels in the Alaskan Beaufort Sea. Prepared fer USCOI, MMS. San Diego, CA: Naval Ccean Systems Center. Lowry, L. F. and K. J. Frost. 1984. Foods and feeding of bowhead whales in western and ncerthern Alaska. Sci. Rep. Whales. Res. Inst. 35:1-16. Martin, F. B. 1986. The probability of a major oil spill froma Beaufcrc Sea OCS exploratory blowout. Rept. submitted as Amcco Producticn Company Written Testimony to State of Alaska Concerning Beaufort Sea Seasonal Drilling Restrictions. Amoco Production Company. 9 pp. McLaren, M. A. anc W. J. Richardson, 1985. Use of the eastern Alaskan Beaufort Sea by bowhead whales in late summer and autumn. ppd. 7-35 in: LGL and Arctic Sciences, Importance of the East Alaskan Beaufort Sea to feeding bowheads: literat review and analysis. Rep. by LGL Ecol. Res. Asscc., Inc., Bryan, TX, and Arctic Sciences Ltd., Sidney, B. C., for Minerals Management Service, Reston, VA. 158 pp- 26 ime, and W.J. Richardscn. 1987. Prediction specific interacticn of industrial acoustic ‘timuli and endangered whales in the Alaskan Beaufort Sea. Rep. by B2N Laboratories Incorpcrated, Cambricge, MA for the Minerals Management Service, Anchorage, AX, Under Contzact No. 14-12-0001-30295. OCS Study MMS 87-0084. 341 pp. Minerals Management Service, 1985. Scenario cf Sale 109 Envircnmental Impact Statement. Memcrandum to Regional Directcr, Alaska OCS Region from Regional Supervisor, Leasing and Environment, Dec. 19, 1985. Minerals Management Service, 1987a. Chukchi Sea Sale 109 Draft Environmental Impact Statement, MMS 87-0009. U.S. Department of the Interior, Minerals Management Service, Alaska OCS Region. Minerals Management Service, 1987b. Alaska cuter continental shelf Beaufort Sea Sale 97, Final Environmental Impact Statement, MMS 87-0G69. U. S. Depar=nent of the Interior, Minerals Management Service, Alaska OCS Region. Montague, J. 1985. Respenses of endangered whales tc offshore oil industry activities. Paper presented at 6th Biennial Conference on the Biology cf Marine Mammals, 22-26 November 1985, Vancouver, B.C. 8 pp. Moore, S.£., J. 7. Clarke, and D. K. Ljunghlad, 1986. A compazisen of gray whale (Zschzichsius rebustus) and bowhead whale (Balaena mysticetus) distribution, abundance, habitat preference and behavior in the northeastern Chukchi Sea, 1982-1984. Rpt. Int. Whal. Comm. 36:273-279. m@urrell, T. L., J. R. Levine, J. B. Regg, and E. J. Tennyson. 1987. Alaskan Outer Continental Shel? oil-spill-response measures for cffshore oil and gas operations. Rpt. prepared by Minerals Management Service. OCS Rpt. MMS 87-0062. 165 PP. Powers, A. D., 1987. Letter presenting statistics on the frequency and probabilities of oil spills in the Alaskan OCS dated November 18, 1987 from MMS to Rennie S. Holt, NMFS, 1825 Connecticut Avenue, NW., Washington, DC. 3 pp. Richardson, W.J., 1981. Behavior, disturbance responses and feeding of bowhead whales in the Beaufort Sea, 1980. Rpt. by LGL Ecclegical Research Associates, Inc., Bryan, TX, for U.S. Bureat of Land Management, Washington. 273 pp- Richariscn, W G.), 1982. Behavior, disturbance responses and dis=: n of Ecwhead whales Balzena mvsticetus in the Beautor= Sea, 1980-81. Ret. by LGL Eccl. Res. Assoc. Inc., Bryan, TX, for the U.S. Bureau cf Land Management, Washington. 456 pp. Richardscn, W.J. (ed.), 1985. Behavior, disturbance responses and distribution of bowhead whales Balzena mvsticetus in the eastern Beaufort Sea, 1960-1984. OCS Study MMS 85-0034, NTIS PB87-124376. Rpt. from LGL Ecol. Res. Assoc., Inc., Bryan, TX, for Minerals Manage. Serv., con, VA. 306 pp. Richardscn, W. J. (ed), 1987. Importance cf the Eastern Alaska Beaufort Sea to feeding bowhead whales, 1985-1986. ocs Study MMS 87-0037. Rpt. from LGL Ecol. REs. Assoc., Inc. Bryan, TX, for Minerals Manage. Serv., Reston, VA 547 PP. Richazéscn, W.J., and Greene, C.R., 1983. Issue 3 - Noise and Marine Mammals. Draft R7pt. of Diapir> Field (Sale 87) Synthesis Werkshop. 27 pp. Richardscn, W.J., C.R. Greene, and B. Wursig, 1985b. Behavior, disturbance responses and distributicn cf bowhead whales in the eastern Beaufort Sea, 1980-1984: a summary. LGL cslegical Research Associates, Inc., 3ryan, TX for U.s. Minerals Management Service, Reston, VA. 30 pp. Richaziscn, W.J., M.A. Fraker, B. Wursig, R.S. Wells, 1985c. Reece, of Bowheac Whales Belaena myszicetus summering in e Beaufort Sea: Reactions to industrial activiti Conserv. 32 (1985) 195-230. 7 aa os Richazdscn, W. J., B. Wursig, and G. W. Miller. 1987. Bowhead Gistzibution, mumbers and activities. pp. 257-368 in Richardson, ‘ ‘ a) . pamporcence cf the Eastern Alaskan usore Sea to ing bowhead whales, 1985-1986. Pre; for MMS, Reston VA. OCS MMS 87-0037. _ Richardson, W.J., B. Wursig, G. W. Miller, and G. Silber, 1986. Bowhead distribution, numbers and activities. pp. 146-218 in Richardson, W. J. (ed). Importance cf the Eastern Alaskan Beautczt Sea to Ging bowhead whales, 1985. LGL Ecological Researce aeecesa es, Inc. Prepared for MMS. Reston VA. OCS 0026. Rugh, D., 1984. Fall migration and census of the whale at Uninak Pass, Alaska. In M.L. Jones, S.L. svaee, and J.J. Leatherweod (editors), The Gray Whale. Acad. Press, N.Y. 28 Schell, D.M., S. M. Saupe and N. Haubenstock. 1987. Bowhead whale feeding: Allecation of regional habitat importance based on stable isctope abundances. pp. 369-415 in Richardson, W. J. (ed). Inportance of the Eastern Alakan Beaufort Sea to Feeding bcwhead whales, 1985-1986. Prepared for MMS, Reston, VA. OCS 87-0037. Thomson, D. H., 1986. Energetics of bowneads. pp 220-244 in Richardscn, W. J. (ed). Importance of the Eastern Alaskan Beaufort Sea to feeding bcwhead whales, 1985. IcL Ecological Research Associates, Inc. Prepared for MMS, Reston, VA. OCS MMS 86-0026. Thomson, D. H., 1987. Energetics of bowheads, pp 417-448 in Richardson, W. J. (ed). Importance of the Eastern Alaskan Beaufort Sea to feeding bowhead whales, 1985-86. IGL Ecological Research Associates, Inc. Prepared for MMS, Reston VA. OCS 87-0037. 29 APPENDIX E MAJOR PROJECTS CONSIDERED IN CUMULATIVE-EFFECTS ASSESSMENT MAJOR PROJECTS CONSIDERED IN CUMULATIVE-EFFECTS ASSESSMENT Information in this appendix supplements and updates material contained in Appendix B of the Final Environmental Impact Statements (FEIS’s) for Sales 71, 87, and 97, which are incor- porated by reference (USDOI, MMS, 1982, 1984, and 1987a, respectively). The 18 projects described in this section are depicted on Graphic No. 3 and summarized in Table IV-A-2. Projects in this table are numbered to correspond to the project number in the text. As on the table, projects are segmented under three broad categories: Existing Development (Projects 1 through 8), Exploration and Potential Development (Projects 9 through 16), and Future Lease Sales (Projects 17 and 18). This appendix also contains a list of projects from the S-Year Supplemental FEIS (USDOI, MMS, 1990) that are used to assess the effects of projects and activities on migratory species in other parts of their ranges--this includes the Bering Sea, Prince William Sound and the Gulf of Alaska, and the Pacific coastal area of the U.S. and Canada. EXISTING DEVELOPMENT Lz Trans-Alaska Pipeline (TAP): Approximately 16.3 mi* are occupied by the 800-mi pipeline that runs between the Prudhoe Bay Unit and Valdez. Between Prudhoe Bay and Fairbanks, the Dalton Highway (Haul Road) was constructed parallel to the pipeline. Ten pump stations move about 1.7 million barrels of oil per day (MMbpd) through the pipeline. Two additional pump stations could be added and drag-reduc- tion agents introduced that would take capacity past its design capacity of 2 MMbpd to approximately 2.4 MMbpd. The Valdez terminal handles four tankers at once and has an average turnaround time of 24 hours. Approximately 900 tankers visit the Port of Valdez each year. The TAP is presently delivering crude oil from Prudhoe Bay and Kuparuk. The Alyeska Pipeline Service Company designed, constructed, and now operates the TAP (Alyeska Pipeline Service Co., 1984). 2. The North Slope Borough (NSB) Capital Improve- ments CIP): One of the goals in the formation of the NSB was the improvement of living conditions in North Slope Inupiat villages. With revenues from the Prudhoe Bay field, a network of NSB and construction subcontractor management, and maximum participation of Inupiat men and women in each project, this massive CIP has been used to construct schools and housing in every village, acquire gravel and land, improve airport runways, improve fuel generation and water and sewer systems, acquire maintenance equipment and search-and-rescue helicopters, and initiate areawide com- munications and solid-waste-disposal improvements for every village of the North Slope during the 1970's and early 1980's. Many of the projects have been completed. The focus of future expenditures emphasizes health and human services, safety, and the maintenance of facilities already built (NSB Ordinance 86-10 et seq.). Previously, the CIP proposed the development of conceptual master plans for service bases at Bullen Point and Kuparuk (NSB, 1983). Although these areas still may serve as industrial centers for North Slope oil and gas development, the focus of the CIP has been redirected. 3. Prudhoe Unit The PBU produces 1.5 MMbpd from the Sadlerochit formation, approximately 17 percent of the total U.S. production. Sixteen companies are included in the unitized field. ARCO Alaska, Inc., operates the east half of the field; and Standard Alaska Production Company operates the west half. Approximately 4,000 persons are employed for this field. Major facilities include base camps for Standard and ARCO personnel, a crude-oil-topping plant, a central gas facility, airstrip, flow stations, gas-injection facilities, two docks, seawater-treatment plant, water-injection plants, and a power system. Additional facilities for support activities have been located at Deadhorse. Approximately 348 km of roadways and 1,160 km of oil and gas pipelines have been constructed E1 within the PBU (this includes 80 km of pipeline constructed for Lisburne production). Original well spacing was based on 160 acres per well; spacing is being reduced to 80 acres per well. As the field matures and “infill drilling" increases, spacing in some locations may be reduced to 40 acres. Gravel pads, which typically are 46 m by 400 m, accommodate up to 40 wells. Waterflooding, a second- ary recovery technique, is expected to increase production by approximately 1 Bbbl. Initially, the waterflood process was accomplished by reinjecting into the reservoir formation waters produced with Prudhoe Bay oil. Subsequently, seawater processed at the treatment plant has been injected. The processed seawater is distributed via 13 mi of 40-in-diameter pipe to the eastern injection plant and 11 mi of 36-in-diameter pipe to the western injection plant. Operating the waterflood system increased employment at Prudhoe Bay by 42 persons per shift. Waterflood equipment, including the world’s largest seawater-treatment plant and two injection plants, was shipped by barge in the summer of 1983. The 26,000-ton, 11-story treatment plant is the largest module ever shipped to the PBU. By 1989, water-injection rates had reached 1.2 MMbpd, with 900 MMbbI of this amount composed of source water. Water-injec- tion levels could reach 1.5 MMbpd by 1993 (Weeks, 1989). In addition to waterflooding and infilling, production was increased further when the world’s largest gas-processing plant came on line. During the 12-month period ending June 30, 1989, Prudhoe gas production totaled 1,418 Bef. Of that figure, 1,133 Bef were reinjected into the gas cap to maintain formation pressure, while another 125 Bef were injected into the oil-field tim to further assist resource recovery (Weeks, 1989). As much as 50,000 bpd of liquefied natural gas (LNG) can be com- mingled with the Prudhoe Bay crude oil and piped through the TAP (Oil and Gas Journal [OGJ], 1987). In addition to the main Prudhoe Bay field, the PBU also contains smaller satellite fields. Three are worthy of mention here: the West End (Eileen) field, Sag River, and Point McIntire. The West End field, as its name implies, is located to the west of the main Prudhoe field, between it and the Kuparuk field. The Eileen reservoir currently produces 52,000 bpd. By 1990, ARCO expects to have 72 producing wells and 4 gas-injection wells in operation on the West End field. The Sag River formation is located 50 ft above the Sadlerochit formation (the Prudhoe production formation). As of May 1989, the Sag was being serviced by 96 producer wells and 36 injector wells. Production in the Sag field is calculated at 15,000 bpd (Weeks, 1989). The Point McIntire field lies at the northern edge of the PBU about 400 to 500 yd to the west of the West Dock. Discovery of the field was announced in 1989; field reserves are estimated at 300 MMbbI. The McIntire field may be subunitized within the PBU; however, no development plans have been made public. 4. Lisburne Field: The Lisburne field is part of the PBU. ARCO committed $575 million in 1984 to develop the first phase of a commercial field. Permits have been issued for expanding five onshore drill sites, roads, and gathering facilities; plans for an offshore drilling platform have been placed on hold, ARCO has constructed 80 km of pipeline and drilled approximately 80 wells on five pads for an initial production rate of 35,000 bpd in 1988. During the Lisburne production phase, ARCO plans to upgrade and expand housing and support facilities at the ARCO camp to accommodate workers for 60 permanent positions. Filling these positions could require 200 to 250 employees (Maynard and Partch et al., 1985). 5. E.wparuk River Unit: The Kuparuk River oil field lies approximately 30 mi northwest of Prudhoe Bay. ARCO, the major shareholder, operates the unitized field for the eight owner companies. Oil in place is estimated to range from 4 to 5 Bbbl. Total recoverable oil with a successful waterflood is estimated at 1.6 Bbbl; and, in 1983, a water-flood-demonstra- tion project was begun. During 1989, 337,000 bpd are expected to be processed from the field, making Kuparuk second only to Prudhoe Bay in U.S. daily production. A total of 800 wells (including oil, gas, water, and injection wells) ultimately will be drilled. Almost 500 persons will be employed at full production to operate the field. Facilities include living and dining quarters; a water- and sewage-treatment plant; warehouses; offices; a central processing plant; an operations center; construction camps; and a 1,700-ft gravel airstrip. A bridge across the Ku River connects the 150 km of roads in the Kuparuk Field to those of the PBU. Oil is transported via 668 km of pipeline. Pipeline distance includes a 24-in pipeline running 26 mi to the TAP. In 1984, the 24-in pipeline replaced a 16-in pipeline that had been in operation since 1981 (Snapp, 1984). 6. West Sak Formation: The West Sak formation lies within the boundaries of the Kuparuk River Unit. Construction information is included in the totals for the Kuparuk River Unit. ARCO conducted a pilot project in this formation to determine the potential for full-scale production. ARCO used eight wells to produce the oil and five additional wells to inject hot water to drive the production. Through this project, ARCO demonstrated that the oil could be recovered by conventional methods; however, development would not occur until oil prices improved and became more stable (Anchorage Daily News, 1987). If the field is developed fully, wells spaced every 20 acres would produce between 100,000 and 200,000 bpd. Total production could reach 2 Bbbl. ARCO estimates 15 to 25 Bbbl are in place, of which 20 percent ultimately might be recovered (OGJ, 1984). ae Duck Island Unit: Development drilling began on the unit’s two causeway-connected islands in 1987. By February of 1989, the unit possessed 51 operational production wells, which produced at a rate of 100,000 bpd. Developmental drilling within the Duck Island Unit will continue into 1989 with only one rig allocated for both islands. Approximately 1.3 percent of Duck Island’s production consists of natural gas liquids. With the exception of gas used for fuel and that used to extract LNG, all gas is reinjected into the formation water. In 1988, a waterflood project was begun in the unit, so 35,000 to 40,000 bbl of water per day are injected into the Endicott formation from each of four wells. This extensive waterflood project has repressurized the Endicott, which lost its formation pressure in an unexpectedly rapid manner after production was initiated. 8 Milne Point Unit: Conoco operates Milne Point, an (approximate) 21,000-acre field that is located north of the Kuparuk River Unit. The field was identified by Conoco in 1970 but was not considered economic to develop until 1979 when the area was unitized. Housing modules for both the 50-person permanent camp and the 300-person construction camp were delivered in 1984. Development modules were shipped on three barges during the 1985 sealift. During the period of construction, approximately 300 persons resided in camp. The construction camp is located adjacent to the permanent camp and can be opened and closed in segments to facilitate accommodating varying sizes in the work force. About 30 km of roadways were built. Approximately 24 km of oil pipelines were constructed from the drilling sites in the Milne Point field to the West Kuparuk pipeline. Production from 24 wells located on two pads began in November 1985 at ap- proximately 10,000 bpd. Production was suspended in 1986 and reinstituted in 1988. Recoverable resources are estimated at 100 MMbbI (Anchorage Daily News, 1985, and Hastings, 1986, personal commun.). EXPLORATION AND POTENTIAL DEVELOPMENT 9. Discovered Resources (Oil Fic! Gas _Fie! and i Possible new projects that are described in Maynard and Partch et al. (1985) primarily include oil resources too viscous to produce and gas resources. Although these projects are not on the immediate horizon, given appropriate technology, market prices, and infrastructure, they could be processing E-2 commercial quantities of oil or gas on short notice. Oil Fields: Gwydyr Bay oil is thought to be pooled in a very small area between two faults. The 27,160-acre field, located north of the west operating area of the PBU, was unitized in 1979 and is still being evaluated. Conoco, Hamilton Brothers, Cities Service Company, and Mobil/Chevron have drilled approximately nine wells. Between 6 to 11 BbbI of oil have been identified in the Ugnu Sands, which lie in the northern part of the Kuparuk River Unit and the Milne Point Unit. Because the oil is extremely viscous, no plans to develop the field have been proposed. The Simpson Lagoon Field consists of two wells drilled during the late 1960’s. Although oil was found, no additional work on the field has been undertaken. Gas Fields: Several gas fields contain resources that could be recovered should the infrastructure for transporting the gas be constructed. Two fields that fall in this category already are associated with oil production. Estimates for gas from the Prudhoe Bay gas cap indicate 2 Bef per day could be extracted for 25 years without substantially affecting the production of oil. Proven resources total 28,183 Tcf. Estimates of gas resources at Endicott indicate initial production could reach 250 MMcf per day for 20 to 30 years. Other fields with significant gas potential include Point Thomson and Gubik. The Point Thomson Unit is located between the Canning River and Bullen Point Camp. Exploration began in 1975 and 15 wells have been drilled to date. Although 350 MMbbI of gas condensate have been estimated for the Point Thomson Unit, no announcements of field development have occurred. Production is contingent on a gas-marketing scheme for the North Slope (OGJ, 1985). Gubik is located near the eastern border of the National Petroleum Reserve-Alaska (NPR-A) on land owned by the Arctic Slope Regional Corporation (ASRC). Estimates of gas resources reach 317 Bef. The Kemik, Kavik, and East Umiat fields contain lesser accumulations of gas resources. Kemik and Kavik could be commercial only if a gas pipeline were constructed adjacent to them. East Umiat is considered noncommercial. Mining: The Red Dog Mine, located in the Northwest Arctic Borough, currently is being developed by Cominco Alaska, Inc. The mine is owned by the Northwest Arctic Native Association (NANA) Regional Native Corporation. The port through which the ore will be shipped is south of Kivalina. The NANA share- holders will hold the majority of the jobs for this project. Coal (and its development) also is a potential source for cumulative effects on the North Slope, especially near Cape Beaufort, along the Chukchi Sea coast from Cape Lisburne to Wainwright. A State-funded study of coal resources during 1984 in the western Arctic was conducted to determine if the resources could be used as an economic replacement for the fuel oil currently being imported into the villages. The coal deposit of the Deadfall Syncline, located 6 mi from the Chukchi Sea and about 40 mi south of Point Lay, was identified as the best source for this use. A detailed feasibility assessment was completed in 1986. Development of this resource has been recommended and awaits further funding (Arctic Slope Consult- ing Engineers, 1986). 10. Seal Island: Seal Island is a gravel island constructed on a lease obtained by Shell during the Joint Federal/State Beaufort Sea Lease Sale held in 1979. Recovery of 300 MMbbI of oil has been estimated from a discovery announced by Shell in January 1984. Shell would like to start producing about 100,000 bpd of oil, possibly by 1992. An oil discovery from the nearby Northstar gravel island was announced in January 1986. This discovery helps to define the Seal Island reservoir (Alaska Report, Jan. 22, 1986). Amerada Hess drilled one well and spudded a second from Northstar during the 1985 to 1986 drilling season (Van Dyke, 1987, personal commun.). In 1989, a proposal to unitize the Seal Island and Northstar Island fields as the Northstar Unit was submitted to the State of Alaska as well as the U.S. Department of the Interior (USDOI) by Amerada Hess. Upon approval of the unitization plan, a development plan for the Northstar Unit will be forwarded for review and approval. 11. National Petroleum Reserve-Alaska: The NPR-A is ad- ministered by the USDOI. Resources are estimated at 6.4 Bbbl of oil and 11 Tcf of gas; recoverable reserves are estimated at 1.85 Bbbl of oil and 3.74 Tef of gas. More than 90 wells have been drilled on NPR-A (Schindler, 1983). Although none has proven commercial, the wells that have been drilled in Simpson Field (35 wells with an estimated 12 MMbbI in place) and Umiat (11 wells with an estimated resource of 66 MMbbi) may eventually become commercial (Maynard and Partch et al., 1985). In compliance with the 1981 Department of the Interior Appropriation Act, as amended, the USDOI has undertaken studies and initiated a leasing program in NPR-A. Two lease sales were held in 1982, in which the most promising areas were leased. Plans called for one lease sale a year for 5 years beginning July 20, 1983. However, no acreage was leased in 1984. Due to lack of interest, no sale has been held since then. Two areas have been deleted from lease-sale plans, removing approximately 3 percent of the estimated oil resources. One deletion is the core of the Western Arctic caribou calving area and the other includes approximately 85 percent of the black brant molting area north of Teshekpuk Lake. Leasing on the First Creek Delta salt- marsh waterfowl area has been deferred 5 years. In 1985, drilling began on areas leased under the NPR-A program. The first well, drilled on the Brontosauris Prospect about 30 mi south of Barrow, was plugged and abandoned. 12. Oil and Gas ing in the Arctic National Wildlife Refuge (ANWR): The ANWR is situated in the northeastern part of Alaska. The boundaries of the coastal plains portion of the ANWR facing the Beaufort Sea extend from the Canning River Delta on the west to the Canadian border on the east. Controversy as to whether or not the coastal plain of ANWR should be open for oil and gas exploration and development led Congress to create Section 1002 of the Alaska National Interest Lands Conservation Act (ANILCA). This section laid out guidelines for the Secretary of the Interior to follow prior to reporting to Congress with recommendations for the use of the coastal plain, or 1002 area. The U.S. Fish and Wildlife Service (FWS) released its final legislative FEIS on the potential effects of exploration and development on the coastal plain in April 1987 (USDOI, FWS, 1987). The FEIS analysis was based on a 150-mi pipeline that would extend from the easternmost development hypothesized in ANWR to TAP Pump Station No. 1. The conditional, economically recoverable resource in the base case was estimated at 3.2 Bbbl with a 19-percent proba- bility of oil being present. Approximately 12,650 acres, or 0.8 percent of the 1002 area, would be modified from its initial condition. Approximately 200 to 300 mi of all-season gravel roads within several oil fields and about 110 mi of road between the Canning River and the marine facilities at Pokok Lagoon are assumed. The Secretary of the Interior recommended to Congress that the entire Arctic Refuge coastal plain (Alternative A) be made available for oil and gas leasing. Other alternatives identified in the ANWR FEIS for consideration by Congress are: (1) limited leasing of the 1002 area (Alternative B)--there would be no leasing or other oil and gas activities in the traditional core-calving area of the Porcupine caribou herd; (2) allow further exploration (Alternative C)-this would include ex- ploratory drilling and allow permits for obtaining additional data by the Government, industry, or both to determine whether or not to authorize leasing of the 1002 area; (3) take no further legislative action (Alternative D)--this would allow the prohibition against oil and gas leasing, exploration, and development to continue; and (4) designate the area as wilder- ness (Alternative E)--no further study or public-review process E3 would be necessary for this action. Section 1003 of ANILCA states "production of oil and gas from the Arctic National Wildlife Refuge is prohibited and no leasing or other development leading to production of oil and gas from the range shall be undertaken until authorized by an act of Congress." This prohibition on downhole-hydrocarbon explora- tion was modified as a result of the land exchange between USDOI, the Kaktovik Inupiat Corporation (KIC), and the ASRC. Through this exchange, the Native corporations received 92,000 acres within the refuge. As a result, the KIC was able to have a well drilled on refuge lands. No hydrocar- bon discovery was announced. Up to three exploratory wells may be drilled on this acreage prior to congressional action. As noted above, however, no development can proceed without congressional approval. Another activity permitted in ANWR is geophysical fieldwork. This work must be conducted consistent with USDOI guidelines developed to protect the renewable resources of the refuge (ANILCA Sec. 1002[d]). Three types of geologic surveys have been permitted—surface geology, gravity-magnetic, and seismic. Between 1983 and 1985, 18 permits were issued to conduct surface-geology studies. Some of these permitted work in multiple years. One permit was issued to conduct a gravity- magnetic and control-net survey. Only 1 of 12 applications for seismic surveys was issued. More than 2,460 km of seismic lines were run over the course of two winters (1984 and 1985). This work provided the FWS with the necessary data for the report on ANWR that was delivered to Congress in April 1987. No future seismic work is anticipated until authorized by Congress. 13. Recent State of Alaska Arctic Lease Sales: Sale 34: This sale was held in May 1982 for acreage in the Prudhoe Bay uplands. The lease area straddled the Arctic Slope and Northern Foothills petroleum provinces. The northeastern quadrant is adjacent to two significant discoveries at Point Thomson (State of Alaska, Div. of Policy Dev. and Planning [DPDP], 1982b). The State offered 1.23 million acres in 261 tracts; 119 tracts were leased. Many of the leased tracts were along the Canning River, the western boundary of the ANWR. Two wells were drilled in 1984; both were abandoned. No further drilling has been proposed (Van Dyke, 1985, personal commun.). Sale_36: This sale was held in September 1982. Acreage offered equalled 56,862 acres—41,500 acres were submerged lands north of Prudhoe Bay near Midway Islands and ap- proximately 15,500 acres included both submerged lands in the Flaxman Island-Canning River area and uplands along the northwest border of the ANWR. Oil potential is considered high for the eastern tracts and low for the Midway Islands tracts. The scenario for this lease sale assumed development from the eastern tracts would begin within 10 years of the sale and that production would join a pipeline previously built to accommodate production from Point Thomson (State of Alaska, DPDP, 1982a). One well was drilled in the spring of 1983. Sale 39: This sale, held in May 1983, was for 211,956 acres between the Colville River Delta and Gwydyr Bay. Nine tracts totalling 43,000 acres along the delta were eliminated for environmental reasons, and 5,000 acres along the boundary of the territorial sea were deleted because title to them was in dispute. Thirty-nine mitigating measures were stipulated to safeguard against environmental and sociocultural effects. Leases in Sale 39 are eligible for "exploration drilling credits" for the first exploratory well drilled on each tract (State of Alaska, Department of Natural Resources [DNR], 1983). Sale 43: This sale, held in May 1984, offered tracts immediately west of Sale 9. Tracts extended west from the Colville River Delta to Pitt Point (at the east end of Smith Bay). Sale 43A, offering nine tracts at the mouth of the Colville and six tracts much farther south, was held concurrently. All tracts, except three offshore, received bids. Three stipulations and 41 additional terms of the sale are applied to these leases. Sale_47: In May 1985, the eastern portion of the Kuparuk Uplands was offered in Sale 47. This area includes ap- proximately 600,000 acres between the Kuparuk and Sagavanirk- tok Rivers. Petroleum potential is considered moderate to high. Sale 48: In February 1986, the Kuparuk Uplands south of the Kuparuk oil field was offered for lease in Sale 48. Of 54 tracts offered, 104 received bids; 266,736 acres were leased. Sale 48A: Eleven tracts totalling 42,053 acres in the Mikkelsen Unit were reoffered in February 1986. All tracts received bids. Sale 51: The Prudhoe Bay Uplands lease sale was held on January 27, 1987. One hundred and nineteen tracts were offered; 26 were sold. Total acreage sold was 100,632. Petroleum potential in the lease-sale area is thought to be moderate. Sale 50: The Camden Bay lease sale was held on June 30, 1987. Thirty-five tracts were offered and all were sold. Total acreage sold was 118,147. Petroleum potential in the lease-sale area is thought to be moderate to high. Sale 54: The Kuparuk Uplands lease sale was held on January 26, 1988. Eighty-nine tracts were offered; 72 were sold. Total acreage sold was 338,687. Petroleum potential in the area is thought to be moderate. Sale_55: The Demarcation Point lease sale was held on September 28, 1988. Fifty-six tracts were offered; 26 were sold. Total acreage sold was 96,631. Petroleum potential in the lease-sale area is thought to be moderate to high. Sale 69A: The Kuparuk Uplands lease sale was held on September 28, 1988. One hundred and fifty-five tracts were offered; 75 were sold. Total acreage sold was 368,490. Petroleum potential in the lease-sale area is thought to be low to moderate. Sale 52: The Beaufort Sea lease sale was held on January 24, 1989. The tracts were located between Pitt Point and Tangent Point and centered on Smith Bay. Forty-three tracts were offered; 15 were sold. Total acreage sold was 52,463. 14. __Postsale Activity on Areas Leased in Previous Outer Continental Shelf (OCS) Sales in the Beaufort and Chukchi Seas: Beaufort Sea: Four sales have been held for Beaufort Sea OCS oil and gas leases. The first sale, a joint Federal and State Sale, held in December 1979, offered Federal and State submerged lands and State offshore islands. The second sale, held in October 1982, offered tracts primarily west of Prudhoe Bay and east of Smith Bay. The third sale, Sale 87, offered tracts between Barrow and Canada and generally out to the 200-m isobath. Leases were awarded on 372 tracts totalling 786,617 ha. The fourth and most recent OCS sale, Sale 97, resulted in the sale of 202 tracts totaling 449,551 ha. The mean, condition- al, unleased, economically recoverable oil estimated for Sale 97 was 650 MMbbI. The mean, conditional, leased and unleased (cumulative mean) economically recoverable oil for the Arctic Region (Beaufort Sea, Chukchi Sea and Hope Basin Planning Areas) is estimated to be 3.82 Bbbl. Capacity in the TAP should be adequate for all oil coming from the North Slope. Production of natural gas in the Beaufort Sea is considered uneconomic at this time. Most drilling from leases issued in the joint sale has been done on State tracts; the Duck Island Unit (Project 7) is located on the State tracts. On Federal tracts, two wells drilled at Beechy Point were determined to be producible and were plugged and abandoned. Two wells drilled from Tern Island were deter- mined to be producible and were temporarily abandoned in 1987. Results from a third well drilled into lease OCS-Y-197 are not yet available. In regard to Seal Island, the Amerada Hess Corporation has submitted a proposal to unitize the field as the Northstar Unit (see Project 10). Seven wells have been drilled on leases issued in Sale 71. Both Mukluk (one well drilled from a gravel island) and the Antares Prospect (two wells drilled from the Concrete Island Drilling System were determined to be nonproducible and were plugged and abandoned. Drilling from blocks leased in Sale 87 began in the summer of 1985. Including the summer of 1989, six wells have been drilled on the subject leases. The drillship then was moved to the Corona Prospect, located north of Camden Bay. The Corona Prospect was completed in the 1986 drilling season; and the drillship returned to the Hammerhead Prospect, where a second well was drilled. Drilling for each of the three prospects was supported by three ice-class vessels—two smaller vessels were used for supplies and ice management and the third vessel, the Robert Lemeur (an icebreaker-supply boat), was used to open the route to the drill site plus perform tasks similar to the smaller vessels. The Belcher Prospect, located near the Canadian border, was spudded from a drillship in September of 1988 and completed in the summer of 1989. Near Harrison Bay, Exxon has drilled a well on the Orion Prospect. The Prospect lies just north of Cape Halkett. Northwest of Oliktok Point, Tenneco used the Single Steel Drilling Caisson placed on a steel mat during the 1986 to 1987 season to begin a well that was completed in 1988. (See Roberts, 1987, for a more complete description of activities that have occurred on previously leased Federal tracts in the Beaufort Sea.) Chukchi Sea: Sale 109, the first Federal offshore oil and gas lease sale in the Chukchi Sea, was held in May 1988. Of the tracts offered, bids were accepted on 350. The mean, condition- al resource estimates for the sale were estimated at 2.68 Bbbl of oil and 15.1 Tcf of natural gas. To date, four wells have been drilled on Chukchi leases by the Shell Corporation. No report has been issued about either the producibility or existence of hydrocarbons. 15. ASRC Oil and Gas Leasing: The ASRC is a for-profit corporation created pursuant to the Alaska Native Claims Settlement Act of 1971. The Corporation has title to 4.9 million acres, both surface and subsurface estate, located in the northern part of the State. The ASRC lands are located principally to the west and to the south of the NPR-A bound- aries. The ASRC has leased approximately half its acreage to various oil companies. Several exploratory wells have been drilled on ASRC leases to date; the most notable are the wells drilled in the ANWR and Gubik, east of NPR-A. 16. Canadian Beaufort Sea: The following information concerning Canadian Beaufort Sea oil and gas activities is summarized from Campbell (1989). Eighty wells have been drilled to date in the Canadian Beaufort Sea. There have been 26 significant discoveries encompassing an estimated 1.5 Bbbl of oil and 4.5 Tcf of natural gas. The giant Amauligak oil and gas field will likely be the lead offshore oil development project, although plans are on hold at present. Current transportation concepts suggest that oil from Amauligak will be shipped by pipeline from the production islands to shore at Richards Island and then down the Mackenzie Valley to southern markets. The 9 offshore-exploration licenses that are currently in good standing are due to expire in 1990 or 1991. FUTURE LEASE SALES 17. Future State of Alaska Leasing Offshore and Onshore: Seven lease sales in the Beaufort Sea and mid-Beaufort uplands are included in the State of Alaska’s 5-year lease-sale schedule (State of Alaska, DNR, 1989). Offerings in the Beaufort Sea coastal area are considered to have moderate to high resource values. Sale 70A: This sale is scheduled for September of 1990, The sale will include lands between the Colville and Canning Rivers and will reach 532,906 acres in extent. Petroleum potential of this area is thought to be low to moderate. Sale 64: Proposed Sale 64 consists of approximately 771,840 acres of State acreage lying 30 mi from the coast between the Canning and Sagavanirktok Rivers. Most of the area was offered previously in Prudhoe Bay Uplands Lease Sale 4, held in September 1982. Some of these lands also were offered as part of previously held lease Sale 51. Additional acreage may be added to the sale, which is scheduled for May 1991, if certain active leases expire. Sale 65: This sale reoffers submerged Beaufort Sea acreage between Pitt Point and Flaxman Island. The sale is scheduled for May 1991 after leases sold in the 1979 Joint Federal/State Beaufort Sea Oil and Gas Lease Sale expire. The acreage offered in Sale 65 is approximately 340,000. Sale 61: The proposed Sale 61 area consists of about 875,000 acres southwest of the Kuparuk River oil field. The area is situated between the White Hills to the northeast and the Colville River to the northwest. Some of the acreage now included in the proposed sale has yet to be conveyed to the State; however, title to those lands is expected prior to the sale date. The sale is scheduled for January 1992. Sale 68: The proposed Sale 68 area consists of approximately 393,000 acres of State-owned tide and submerged lands offshore of NPR-A. The seaward boundary of NPR-A is the subject of a dispute between the United States and the State of Alaska. The issue is pending before the U.S. Supreme Court. Should an agreement between the parties be concluded before the sale date, an adjustment in the sale acreage and boundaries may be necessary. The sale is scheduled for May 1992. Sale 75: The proposed Sale 75 area will consist of approximate- ly 110,080 acres of lands previously leased in State Sales 13, 48, and 54. The sale will include any lands formerly part of the Kuparuk River Unit and other acreage that becomes available as leases expire on the North Slope. The sale is scheduled for September 1992. Sale 77: The proposed Sale 77 area will include North Slope lands about 70 miles south of the Kuparuk River oil field. The proposed sale area is bordered on the south by the North Slope Foothills Sale 57, on the east by the Trans-Alaskan Pipeline corridor, and on the west by the Chandler River. The proposed sale area consists of approximately 1,030,600 acres. More acreage is optional, depending on the availability of land from expiring or terminating North Slope leases. The proposed sale date is May 1993. Sale 57: About 1,500,000 acres near the foothills of the Brooks Range between Umiat and Anaktuvuk Pass are to be offered in Sale 57, to be held in September 1993. The petroleum potential in the area is considered low to moderate. Sale 80: The proposed Sale 80 area consists of approximately 500,000 acres of State-owned upland acreage on the north slope, lying between the Canning and the Sagavanirktok rivers. A major portion of the sale area consists of acreage that was offered but not leased in the previous State Lease Sales 34 and 51. Some of the acreage included in the proposed sale has yet to be conveyed to the State. Any acreage for which the State does not have at least tentative approval before the notice of sale will not be offered for sale. Petroleum potential in the proposed sale area is considered to be low to moderate. 18. Future Federal OCS Leasing Chukchi Sea: Under the proposed 5-Year OCS Oil and Gas Leasing Schedule for mid-1987 through mid-1992 (USDOI, MMS, 1987c), two lease sales are proposed for the Chukchi Sea--Chukchi Sea Lease Sales 109, held in 1988, and 126, ES presently scheduled for 1991. Initial descriptions of activities that could ensue from a lease sale in the Chukchi Sea as well the sale’s resource potential are provided in the Sale 109, Chukchi Sea FEIS (USDOI, MMS, 1987b). Beaufort Sea: The proposed 5-year leasing schedule (USDOI, MMS, 1987c) contains one lease sale for the Beaufort Sea, Sale 124, scheduled for 1991. The activities for developing the entire Beaufort Sea that are assumed in Section IIA of this EIS apply also to any future Federal leasing activity. ADDITIONAL PROJECTS CONSIDERED IN THE MIGRA- TORY SPECIES’ CUMULATIVE-EFFECTS ASSESSMENT This section describes other OCS projects and proposals and existing oil and gas infrastructures that are part of the existing environment or are reasonably foreseeable future actions. These additional projects are used in assessing effects on migratory species within the range of the respective species. 19. Dredging and Marine-Disposal Activities: Alaska Region: The Snake River, which enters Norton Sound at Nome, is dredged annually. Approximately 13,000 yd’ of sediment are removed each year and deposited about 1/2 mi east of the mouth of the river. These dredge spoils are contaminated by mercury that was released into the environ- ment during the years that mercury was used for the processing of gold. Data that have been made available recently have led the Environmental Protection Agency (EPA) to review the decision to use this offshore-disposal site. Nome harbor sediments were tested by the Army Corps of Engineers (COE) and the EPA in 1989 and were found to contain measurable levels of a number of chemical constituents. The COE and EPA are reviewing the new information regarding suitability of the material for continued ocean disposal. Pacific Region: In the Pacific Region, a variety of materials have been and are being dumped offshore: dredge spoils, low- level radioactive wastes, obsolete munitions, and industrial and municipal wastes. Ocean dumping of acceptable waste mate- rials is authorized under Title I of the Marine Protection, Research and Sanctuaries Act of 1972, as amended (33 U.S.C. 1401), and the Federal Water Pollution Control Act, as amend- ed (33 U.S.C. 1251). The EPA administers the designation and management of ocean-disposal areas and permits for dumping of all acceptable wastes except dredged materials. The COE administers the permit program for transportation of dredged materials for ocean disposal, with independent review and concurrence by EPA. 20. Commercial Fisheries: Waters off the coast of Alaska support some of the most productive fisheries in the world. In 1986, the ex-vessel value of Alaskan commercial fisheries totaled about $955 million. The salmon fishery was valued at $404 million, with a S-year (1982-1986) average value of $354 million. Fisheries for groundfish (primarily pollock, sablefish, sole, cod, and other flounders) were valued at about $268 million. Although below recent former harvest levels, the shellfish fishery, mainly for crab, has experienced increasing price levels and was valued at $182 million (NPFMC, 1989). The ex-vessel value of the 1986 herring harvest was $39 million (Smith, 1989, oral comm.). All Alaska OCS Region planning areas support commercial fishing to some degree, although the fisheries in the Beaufort and Chukchi Sea Planning Areas are of relatively minor importance. To some degree, all coastal communities in Alaska derive economic benefit from commercial fishing; however, in landings and value, Dutch Harbor, Kodiak, Naknek, Cordova, Sitka, and Petersburg rank as the major fishing ports in the Region. Alaskan commercial fisheries employ gillnets, seines, and trolling gear for harvesting salmon; longlines for halibut, sablefish, and rockfish; and trawls for other groundfish. Pots of various types are used in the crab fisheries. The limited spring and summer herring roe/bait fisheries also employ gillnets and purse seines. Commercial-fishing success varies considerably in time according to the species fished and fluctua- tions in the populations of such species. Foreign commercial fisheries also may affect Alaskan stocks and recently, concern has been directed toward open-ocean nondiscriminant gear fisheries. In addition to the commercial fisheries, there are saltwater coastal sport fisheries for salmon, halibut, and other marine fishes. Sport fishermen also harvest shellfish (crab, shrimp, and clams). While of lesser economic value than commercial fisheries, the value of the sport fishery is significant and projected to increase rapidly with the growth in population. For example, a sport-fishing economic study for southcentral Alaska, where most of the State’s population is concentrated, showed that angler expenditures associated with all sport fishing in southcentral Alaska were estimated at $127.1 million in 1986 (Jones and Stokes Associates, Inc., 1987). 21. _Anadromous Fish—Freshwater Habitat: The freshwater spawning and rearing grounds and riverine migration routes used by anadromous salmonids such as Pacific salmon are especially critical portions of their habitat because the produc- tivity of individual stocks is directly related to the amount and quality of this habitat. In southeastern Alaska, the Tongass National Forest supplies timber for mills at Ketchikan and Sitka and lesser volumes for smaller logging mills at several other locales. Some wood also is used for fuel and local construction. Logging can affect salmon streams and nearshore marine habitat through: ° Siltation that reduces gravel permeability in streams with consequent loss of salmon eggs and pre-emergent fry. This sometimes results from illegally operating logging equipment in streambeds or across streams. ° Stream blockage as a result of buffer-strip blowdowns fol- lowing cutting. ° Water warming from loss of shade after cutting, with possible adverse effects on adult spawners and rearing fry. Over 200 watersheds in the southeastern Alaska Tongass National Forest have been affected to some degree (Netboy, 1980). A number of studies have been conducted by the Alaska Department of Fish and Game, the Alaska Department of Environmental Conservation, the U.S. Forest Service, the U.S. Fish and Wildlife Service (FWS), and the National Marine Fisheries Service. In part, to prevent damage, to mitigate damages, and to perform the necessary research, the above-listed agencies, in cooperation with the timber industry and the Alaska Depart- ment of Natural Resources, have organized an interagency group. This Alaska Working Group on Cooperative Forestry and Fisheries Research, has functioned well; however, con- siderable fisheries-effects studies remain to be done before some definitive conclusions are reached. The Pacific Fisheries Management Council (PFMC) (1981) reviewed historical problems with, and the status of, freshwater habitat for anadromous salmon stocks in California, Oregon, and Washington. In particular, the PFMC cited the many serious problems associated with hydroelectric dam construction and operation. For example, construction of hydroelectric projects has flooded or blocked access to productive spawning habitat, while the operation of these facilities has resulted in reduced flows during migration and in spawning areas, increased turbidity and sedimentation of gravel, and temperature modifications. Such changes have completely eliminated many areas from salmon production and have seriously reduced salmon-production potential in other areas. The PFMC review also cited poor land- and water-use practices such as logging, road building, water diversions, streambed alterations, and pollution as factors responsible for substantially reducing or degrading the critical freshwater-habitat. Based on the freshwater habitat review presented by the PFMC (1981), substantial historical reductions in critical spawning and rearing habitat have occurred for many salmonid stocks in the central valley of California (i.e., the Sacramento and San Joaquin system) and the Columbia River drainage systems. Based on the trend existing at the time of their review (1978), the PFMC (1981) estimated that habitat availability in all major river systems and coastal streams within California, Oregon, and Washington would continue to decrease, or at best remain unchanged, over the next 10 to 20 years. Even with habitat rehabilitation efforts, the PFMC (1981) estimated relatively little improvement in habitat availability would be likely to occur over the next 10 to 20 years. Although there are no current estimates of habitat availability, many of the same activities (i.e., hydroelectric-plant operation and water diversions) that have resulted in habitat loss or degradation still continue. Efforts to mitigate or rehabilitate degraded freshwater habitat are in progress or planned in some areas (e.g., the Upper Sacramento River), and there is increas- ing recognition (California Advisory Committee on Salmon and Steelhead Trout, 1988) that substantial action is required to arrest the long-term trend of habitat loss and degradation and also of reduced salmon production. 22. Subsistence Activities: Subsistence hunting and fishing are important from both a cultural aspect and in terms of providing a major source of food for Native and rural Alaskans. The following information is summarized from the Proposed S- Year Outer Continental Shelf Oil and Gas Leasing Program Mid-1987 to Mid-1992 FEIS (USDOI, MMS, 1987), which is hereby incorporated by reference. The species used vary somewhat in different portions of the State and from com- munity to community; however, in general, marine mammals and fish are important in most coastal areas. Important subsistence resources for those communities border- ing the Gulf of Alaska, Cook Inlet, and Prince William Sound include salmon, halibut, other marine fishes, freshwater fishes, shellfishes, intertidal resources, small marine mammals, waterfowl, and upland game. Communities along the southern Bering Sea harvest salmon, halibut, shellfishes, intertidal organisms and plants, fur seals, hair seals, sea lions, birds and bird eggs, and caribou. Com- munities bordering the northern Bering Sea use salmon and other fishes; shellfishes; bearded, ringed, and spotted seals; walruses; bowhead and belukha whales; waterfowl; moose; reindeer; and caribou. Communities bordering the Chukchi and Beaufort Seas depend heavily upon marine mammals. Resources used include bearded, ringed, and spotted seals; walruses; bowhead and belukha whales; polar bears; freshwater and ocean fishes; waterfowl; birds and bird eggs; caribou; moose; Dall sheep; berries; and vegetation. 23. Municipal Wastes and Other Onshore Effluent: Histori- cally, the Nation’s rivers, estuaries, and coastal waters have received municipal-waste discharges since collection and treatment of domestic wastes were initiated. Prior to the 1970’s, ocean disposal was largely unregulated, and adverse effects on human health and the environment were observed. The major point-source discharges of waste materials into nearshore and coastal areas come from sewage-treatment facilities, industrial facilities, and electric-generating facilities. These discharges are regulated by the EPA. The effluent from the industrial and sewage-treatment facilities may contain, even after treatment, substantial quantities of synthetic organics, heavy metals, suspended solids, oxygen-consuming materials, and nutrients. Sewage effluent also may contain fecal coliform and potentially pathogenic microorganisms, and cooling-waste discharges from power plants may be elevated in temperature and have increased chlorine levels. Contaminants from marine-transportation activities enter the sea intentionally as a result of routine operational discharges and unintentionally as a result of accidental spills. With respect to ships that maintain sizable crews, the pollutants are the large amounts of domestic-waste products such as sewage, food waste, plastic debris, and trash from human activities on board. For recreational vessels, sewage disposal from marine-sanitation devices in highly populated, confined harbors and anchorages is the primary pollution concern. In contrast to the important progress made during the 1970’s in controlling industrial point-source discharges and in upgrading municipal sewage-treatment facilities, progress with nonpoint sources is negligible (CEQ, 1980). Nonpoint-source pollution is primarily the result of precipitation falling and moving over and through land and into surface waters. In some cases, nonpoint-source pollution is the result of human practices such as agriculture and irrigation. All land use activities are potential nonpoint sources of pollution. Such sources are classified as urban and nonurban runoff. Pollution discharges from nonpoint sources greatly exceed the discharge from point sources. 24. —_Coastal Development in California: California’s popula- tion is estimated to be 28 million, with a potential 50 percent increase in the State’s coastal population (within 50 miles of the coast) between 1980 and 2010. It was estimated that California had 381,000 acres of prime coastal wetlands at the turn of the century. Within 75 years, about two-thirds of this acreage had been lost to a variety of developments along the coast. These developments have caused disturbances that have ranged from large-scale, whole-ecosystem elimination to small-scale, habitat specific alterations. They include, for example, urban develop- ment, harbor construction, dredging, dike and levee develop- ment, and marina development (Speth, 1979; Zedler, 1982; Zentner, 1988). This dramatic loss of habitat is not without corresponding loss in plant and animal species. In fact, the declines of almost all of the species listed as threatened, endangered, or candidate by FWS can be traced to past overhunting or habitat loss by coastal development. 25. Federal and State Oil and Gas Activities: Postlease-Sale Activities in the Beaufort Sea and Chukchi Sea Planning Areas: See Major Project No. 14 for a summary of postlease-sale activities in the Beaufort Sea and Chukchi Sea Planning Areas. Oil and Gas Activities in Other Alaska OCS Planning Areas: The following lease sales have occurred in other planning areas of the Alaska OCS Region. Exploration activities have oc- curred within each of the sale areas except the North Aleutian Basin. Active leases remain within these sale areas, and additional exploration activities could be forthcoming. Lease Sale BF - Beaufort Sea Lease Sale 57 - Norton Sound Lease Sale 70 - St. George Basin Lease Sale 71 - Diapir Field Lease Sale 83 - Navarin Basin Lease Sale 87 - Diapir Field Lease Sale 92 - North Aleutian Basin Lease Sale 97 - Beaufort Sea Exploration activities could include exploratory drilling from a jackup rig, semisubmersible drilling unit, drillship, bottom- founded drilling unit, or artificial island; helicopter-support operations; support-vessel operations, including ice management E7 in the northern sale areas; and high-resolution shallow-hazard seismic surveys. To date, there have been no proposals for development and production within the Alaska OCS Region. Should oil and/or gas be discovered in commercially producible quantities on leases within one or more of the aforementioned sale areas, development and production activities could occur. Transporta- tion of produced product may occur by pipeline or tanker; the Pipeline or tanker routes may pass through several planning areas. State of Alaska Oil and Gas Activities: See Major Projects No’s. 13 and 17 for a summary of activities associated with past and future State of Alaska oil and gas lease sales. Northern and Central California Federal Oil and Gas Activities: From July 1964, when Exxon drilled the first well off the coast of Humboldt County, through November 1966, a total of seven exploratory wells were drilled in the Northern California Planning Area. Following the 1963 OCS lease sale, Shell drilled three wells in 1965 to 1966 in the Point Arena Basin. In the offshore Eel River Basin, four exploratory wells were drilled between 1964 and 1965. There has been no development or production in the area. Between September 1963 and September 1967, Shell Oil Company drilled 12 exploratory wells in the Central California Planning Area. Of these, 10 wells were drilled in the Bodega Basin, beginning in 1963, and 2 wells were drilled in the Ano Nuevo Basin, beginning in 1967, on leases issued in the 1963 OCS lease sale. All oil and gas leases in the area have now expired. Southern California Federal Oil and Gas Activities: While oil production in State waters off southern California commenced in 1896 with the development of the Summerland Field, the first exploratory wells in Federal waters were drilled in the Santa Maria Basin following the first Pacific oil and gas lease sale in May 1963. Chevron Oil Corporation drilled the first well in Federal waters in September 1964, off the coast of San Luis Obispo County. Twelve fields are located in the onshore portion of the basin, with one field on production in the offshore portion. One COST well was completed in 1978. As of September 1988, 296 exploratory wells had been drilled in the Southern California Planning Area. Following the discovery of the Dos Cuadros oil field by Phillips Petroleum Company in 1967, exploration activities in the Pacific OCS focused on the Southern California Planning Area. A record number of 38 exploratory wells were drilled in the Pacific OCS in 1968. This exploratory activity in 1968 led to the discovery of the Hondo, Government Point, Pescado, and Secate Fields in the Santa Ynez Unit and increased industry's interest in the oil and gas potential of the Pacific OCS Region. Exploration activities increased from 1974 through 1977, as industry further defined the oil and gas potential of the Southern California Planning Area. After a slight decline, exploration began a steady increase in the early 1980's as lease sales offered new acreage for offshore operators to explore. Since that time, the pace of exploratory drilling in the Pacific OCS has declined, as offshore operators focused their attention on development and production operations. Twenty-four offshore fields are located in five major areas of the Southern California Planning Area. Among them are: Point Arguello/Gaviota, Santa Ynez/Las Flores Canyon, Point Pedernales/Lompoc, San Miguel/South Nipomo Mesa, and Santa Clara/Ventura. Fourteen fields capable of commercial production have been discovered in Federal waters in the Santa Barbara Channel since the advent of drilling there in 1967. Further fields are currently on production. Two oil fields have been discovered offshore San Pedro in the inner-banks area of the southern California borderlands. Of the total wells in the planning area, only nine exploratory wells, commencing in 1976, have been drilled in the outer banks area. As of September 1988, 661 development wells have been drilled from 21 permanent production platforms. The cumulative production from this area, from its beginning in 1968 through 1987 has been approximately 403 MMbbI of oil and slightly less than 284 Bef of natural gas. Annual production is about 33 MMbbI of oil and 45 Bef of gas. Development and production plans have been approved or are under consideration for four additional field projects involving six new platforms. In the Santa Ynez Unit, three additional platforms are proposed for installation; i.e., Harmony/60 well slots/in 1992, Heritage/60 well slots/in 1992, and Heather/28 well slots/in 1995. Platform Julius was proposed to be installed with 70 well slots in the San Miguel Field in 1988. However, San Luis Obispo voter initiative disapproved the onshore processing and transportation facilities of Platform Julius. Platform Independence is proposed to be installed in 1992 with 60 well slots in the Point Pedernales Field but may not be needed for development. Platform Hacienda is under con- sideration for the Rocky Point Field, but no official develop- ment and production plan has been received. Shell Western Exploration and Production Inc. is considering a relocation of planned onshore facilities to Santa Barbara County. Southern California State Oil and Gas Activities: The 51 active leases on State offshore lands cover 161,000 acres. Of these leases, 29 are off Santa Barbara County, 10 are off Orange County, and 12 are off Ventura County. Nine platforms and seven production islands are presently operating on these leases. Four of the manmade islands are inside the Los Angeles/Long Beach Harbor Breakwater. The last State offshore lease sale was held in 1969. Canadian Beaufort Sea Oil and Gas Activities: See Major Project No. 16 for a summary of Canadian Beaufort Sea oil and gas activities. 26. ‘Transportation of Oil and Gas: Cook Inlet Tankering: An increase in Cook Inlet-produced oil may be shipped to markets in the Far East if allowed by Congress. Laws currently restrict the export of oil produced from Federal and State leases in Cook Inlet to 3,000 bbl per day (about two tanker trips per year), the current level of export. However, efforts are under way by Alaska’s congres- sional delegation to end these restrictions. If the restrictions are removed, it is estimated that 36 MMbbI of oil may be transported by tankers over the life of the Cook Inlet Field. This could amount to an average of about 14 tanker trips per year. It is believed that the tankers would travel the great circle route from Cook Inlet to Pacific Rim markets, which would result in tankers traveling through Unimak Pass and then westward just north of the Aleutian Islands. Alaska OCS planning areas likely to be affected would include the Gulf of Alaska/Cook Inlet, Kodiak, Shumagin, and St. George Basin. Trans-Alaska Pipeline: See Major Project No. 1 for informa- tion about the Trans-Alaska Pipeline. Trans-Alaska_Gas System: The Yukon Pacific Corporation proposes to construct the Trans-Alaska Gas System (TAGS). This system would transport natural gas from Alaska’s North Slope via a 36-inch outside-diameter pipeline to a tidewater facility at Anderson Bay, Port Valdez, Alaska. The proposed TAGS would closely parallel the existing TAP oil pipeline. Up to 2.3 Bcf of conditioned natural gas per day would be moved through TAGS. At Valdez, the natural gas would be converted to liquefied natural gas (LNG) for export by tanker to markets in the Asian Pacific Rim. Approximately 80 to 100 LNG tankers would be expected to visit the Valdez port per year. 27. _Nonenergy Minerals: Federal Offshore Mining Program-—Norton Sound Lease Sale: The following information regarding the OCS Mining Program Norton Sound Lease Sale, and offshore mining in State waters was derived from the OCS Mining Program Norton Sound Lease Sale DEIS (USDOI, MMS, 1988), which is hereby summarized and incorporated by reference. The proposed action consists of 40 blocks to be offered for lease in July 1989. The total areal extent of the proposed Norton Sound Lease Sale is about 72,148 ha (approximately 178,282 acres). The blocks that comprise the proposed action are located about 5 to 22 km offshore in water depths that range from about 20 to 30 m. The MMS has estimated that placer deposits of gold in the proposed lease-sale area for a mean case could be 530,000 troy ounces. It is projected under the mean case that one dredge would be used for mining. About 100 acres per year would be dredged for a period of 14 years, with total dredging to include about 1,300 acres. State Offshore Mining Program: Two areas along the northern shore of Norton Sound have valid mining leases--the area adjacent to the city of Nome and a small area off the coast near Bluff, about 85 km east of Nome. Permits have been applied for along much of the coast within 50 km to the east and west of Nome. These permits have been pending for several years. From 1986 through 1990 Western Gold Exploration and Mining Co., Limited Partnership (WestGold), mined from leases covering 8,802 hectares (21,750 acres) in State of Alaska waters off the southern coast of the Seward Peninsula for placer gold. WestGold used the bucket-ladder dredge Bima and recovered about 105,000 troy ounces of gold from 1986 through 1989; approximately 277 acres were mined. Mining operations with the Bima were limited to the period from late May/early June to mid-November because of weather and sea-ice conditions. No chemicals were used in the beneficiation process to recover the gold, but operations appear to have exceeded EPA NPDES limitations for two trace metals (mercury and nickel). Data from the compliance monitoring by WestGold also indicate that NPDES turbidity standards frequently were exceeded at the edge of the 500-m mixing zone. During the summer of 1989 WestGold conducte“ .e * ~‘ning operations to evaluate a bucket-wheel-type dredge and suction- type dredge operated from a submersible, remotely operated vehicle (ENSR Consulting and Engineering, 1990). Estimated full-production rates for each of the systems range from 2,700 to 3,000 m® per day. However, test-mining-excavation rates averaged only about 120 m® per day; the maximum rate was about 1,135 m? per day. In September 1990, WestGold announced that it was suspending mining operations with the Bima at the end of the 1990 season. At the Alaska Miners Convention in Anchorage in November 1990, R. Garnett, a WestGold Vice-President, reported that the Nome Offshore Placer Project was a financial failure and that the Bima had been barged to Seattle, WA, and would be offered for sale. WestGold in Alaska and the continental U.S. was being dissolved, and the leases would be available to others. WestGold noted that the ore most prospective for gold occurrred in water depths of about 3.7 m; this ore could not be mined by the Bima, which has a draft of 4.4 m and cannot operate in water shallower than 6 m in calm seas and and 7.6 m in rough seas. Also, it was noted that, in the project area, gold occurred to depths of 4.4 m in the sediments but often was concentrated in the top .5 to 1 m. WestGold estimated the potential for gold in the project area to be between 5 and 1 million ounces. APPENDIX F MMS ALASKA OCS REGION STUDIES PROGRAMS INTRODUCTION TO THE ALASKA ENVIRONMENTAL STUDIES PROGRAM Mandate: The Alaska Environmental Studies Program (ESP) was initiated by the Department of the Interior (USDOD in 1974 in response to the Federal Government’s decision to propose areas of Alaska for offshore oil and gas development. Federal management of the Outer Continental Shelf (OCS) is guided by several legislative acts. Regulations implementing the OCS Lands Act (OCSLA) of 1953, amended in 1978 (OSCLAA), designated the Bureau of Land Management (BLM) as the administrative agency responsible for leasing, and the United States Geological Survey (USGS) as responsible for supervising development and production, of mineral resources on submerged Federal lands. The offices under the BLM and USGS responsible for offshore leasing were reorganized as the Minerals Management Service (MMS) in 1982. One of the goals of OCSLA was to provide for protection of the environment concomitant with mineral-resource development. Also, the Secretary of the Interior is required to conduct environmental studies to obtain information pertinent to sound leasing decisions as well as to monitor human, marine, and coastal environ- ments (OCSLAA, 1978 [P.L. 95-372; Sec. 20]). The National Environmental Policy Act (NEPA) of 1969 requires that all Federal agencies utilize a systematic, interdisciplinary approach that will ensure the integrated use of natural and social sciences in any planning and decision making that may have effects on the environment. Federal laws such as the Coastal Zone Management Act, Federal Water Pollution Control Act Amendments, Marine Mammal Protection Act, Endangered Species Act, Alaska National Interest Lands Conservation Act, and Marine Protection, Research, and Sanctuaries Act impose additional environmental requirements on the offshore-leasing process. Purpose: The Alaska ESP is unique among the various components of the offshore leasing program. About $219 million have been spent on Alaska-related studies since 1974. It is a part of the largest single-agency, mission-oriented, marine-studies program in the Federal Government. The purpose of the studies program is to establish information needs and implement studies to assist in prediction, assessment, and management of potential effects on the human, marine, and coastal environments of the OCS and nearshore waters by proposed oil and gas leasing and development. Lease-management decisions are enhanced when current, pertinent information is available in a timely manner. To attain the program goals, data on specific environmental, social, and economic concerns arising from offshore leasing are required. The Alaska ESP then monitors selected effects during and after oil exploration and development. Organization: The Alaska ESP is in the MMS, Alaska OCS Region’s, Leasing and Environment Office located in Anchorage, Alaska. It is one of four regional environmental programs responsible for providing information in support of offshore leasing and management processes. Other offices cover the Pacific, Atlantic, and Gulf of Mexico OCS Regions. When the Alaska ESP began in 1974, BLM requested that the National Oceanic and Atmospheric Administration (NOAA) institute a marine environmental studies program to provide necessary assessment information in the biological and physical sciences. A Basic Agreement between BLM and NOAA provides a framework for administration (by NOAA) of the Outer Continental Shelf Environmental Assessment Program (OCSEAP). The current MMS-funded NOAA OCSEAP Program is located in NOAA’s National Ocean Service Office in Anchorage, Alaska. The Social and Economic Studies Program (SESP), a component of the ESP, was established in 1976 because of the unique characteristics of Alaska’s Native population and the relative isolation and nonindustrial nature of the State of Alaska. Initially, Peat, Marwick, Mitchell and Company managed the program under contract. When the Alaska OCS Region took over the management of the SESP in 1979, core studies were conducted for frontier planning areas prior to each lease sale. With the evolution of the program and the increase in our understanding of the social systems in these areas, the studies have become more focused and oriented to specific issues. As the Alaska Region’s ESP has developed, its increased capabilities in information-gathering and marine-resource assessment have led to direct contracting for certain studies. Management and contracting functions for the SESP have been performed in-house since FY 1980. Studies of endangered species and the F-1 design and implementation of additional monitoring and some pollutant-transport studies became an MMS contracting responsibility in FY 1984. Environmental Studies: The initial focus of the ESP was to obtain baseline information on the vast biological resources and physical characteristics of the Alaskan environment for prelease decision making. These studies included biological surveys of marine species, basic oceanography and meteorology, and geologic and sea-ice phenomena. As a broader base of information was established, it became possible to focus on more topical studies in smaller areas to answer specific questions and fill identified information needs. In addition, a number of generic studies were initiated on the potential effects of oil contamination on biological resources, and on the probable transport and dispersion of oil that might be spilled in the marine environment. These latter analyses are used to predict areas likely to be at greatest risk from possible pollution incidents. As more disciplinary data were collected and analyzed, the importance of taking an integrated, interdisciplinary approach by studying complete ecosystems in sensitive areas became apparent. During this time, the leasing program was maturing. As a number of sales were held and exploration activities began, the need for post-sale studies to monitor the possible effects of oil and gas activities on the environment and resources of these areas was recognized. This has been the most recent change in the focus of the Alaska ESP. The program provides information for the development of the 5-year leasing schedule, continues to provide information for presale and sale-related decisions, and develops monitoring information necessary for post-sale lease management. As studies efforts have become more complex, involving integrated, interdisciplinary efforts to study ecosystems and monitor the environment, the MMS has initiated planning workshops to gather maximum expertise, assess the status of existing information, identify indicator species and missing information, and plan the best possible approach to a study within the constraints of time and resources. As more data and information on Alaskan resources and environmental mechanisms are collected by the MMS and other Federal and State agencies, brief studies are funded to search and evaluate existing literature and data prior to initiation of a new site-specific ecosystem study. This prevents duplication of effort, and saves valuable resources by focusing study efforts only on the areas of greatest information need and highest usefulness to MMS decision needs. Such evaluations were conducted as the first phase of recent ecosystem studies. Computer-modeling techniques are now used to aid in the assessment of potential oil-spill and other pollutant risks to the environment and to key species such as fur seals, sea otters, and endangered whales. Modeling has also been used in the ecosystem studies, especially where extrapolation to other areas seemed warranted. Modeling provides a mechanism for synthesis and integration of theoretical occurrences with actual field observations. Annual Environmental Studies Planning: From ESP initiation, the Alaska Regional Studies Plan has been prepared annually. The RSP, which will become a 2-year planning document beginning in FY 1991, provides a framework for accomplishing program objectives. Information needs are reviewed by diverse organizations and committees, including the Scientific Committee of the National OCS Advisory Board; the Regional Technical Working Group; the State of Alaska; and several Federal agencies such as the EPA, FWS, NOAA, and MMS. Further critiques result from program reviews and disciplinary workshops. The RSP links the information needs of the decision maker with the environmental studies that are to be conducted. The plan identifies existing and potential offshore management decisions and specifies relevant objectives in the studies to aid in making those decisions. Principal Investigators (PI’s), contracted in accordance with the RSP, are drawn from private organizations as well as from universities and State and Federal Government agencies. A core of experienced investigators who are familiar with the task of working under arctic and subarctic conditions is available for the Alaskan program. Preparation of the RSP is the culmination of a 12-month process carried out in the Alaska OCS Region by the Environmental Studies Section. This plan describes the recommended program for Alaskan environmental and social and economic studies for a given 2-year period. The RSP provides all the information needed by the MMS Branch of Environmental Studies to develop the Alaskan portion of a F-2 National Studies List (NSL) and budget for presentation to the Director of MMS, the Secretary of the Interior, and the Office of Management and Budget. It is important to note that this FY’s 1991-1992 RSP was begun 2 years in advance, during FY 1989. Long- term planning is required because of (1) the scope and significance of the OCS oil and gas leasing process carried out by MMS for the Secretary of the Interior and (2) the time needed for budget planning and completion of studies. Proposed leasing schedules cover a 5-year period but are often adjusted to meet the concerns of affected states and the constraints of available Federal funds. Because of the need for advance planning, the program must try to anticipate all study needs based on the current and projected 5-year schedules; and it must also provide a suggested ranking of studies because the budget is not yet defined at this early stage. The OMB has established national ranking criteria used by all MMS OCS regions to establish study priorities. Primary criteria include legal mandates and timing of the information needs. The national criteria allow MMS to merge regional study needs based on the RSP’s into an NSL for funding and procurement. In addition to justifying Alaskan priorities for the national offshore studies program, the Alaskan RSP provides necessary guidance for conducting the program at the regional level. It assures an integrated framework and establishes priorities for MMS staff who plan, implement, and monitor the individual studies. Finally, at the regional as well as the national level, the RSP provides clear studies descriptions, discussion of regional needs, and ranking priorities that provide the basis for formulating regional and national budget requirements and for adjusting, as necessary, to budget limitations. The Alaskan RSP introduces the planning process; describes the environmental characteristics of the three major subregions of the Alaskan OCS; provides overviews of the proposed studies to be conducted in these areas, as well as generic studies; charts the relationship of these proposed studies to the sale process; and provides a general picture of the annual budget and suggested ranking for environmental studies. Environmental Studies Disciplines: From the initiation of the Alaska program, environmental studies have been categorized into several broadly defined subjects. Baseline information on distribution, abundance, and migratory patterns of marine species; potential disturbances to the marine environment; and oceanographic and meteorological conditions was integrated into the design of multidisciplinary studies. Major categories of study have included: Contaminant Sources and Effects; These studies were designed to determine the predevelopment distribution and concentration in the natural environment of potential contaminants commonly associated with oil and gas development. The nature and magnitude of contaminant inputs and environmental disturb- ances that may accompany exploration and development, such as spilled oil, are also studied. Endangered Species: The waters offshore Alaska provide habitat to several endangered species, notably the bowhead whale. In recent years much public and governmental attention in Alaska has been given to the potential effects of oil and gas exploration and production activities on the status and behavior of the bowhead. Studies have concentrated upon observations of bowhead-migration routes, potential feeding areas, and behavior. A unique role of bowhead study components has been to support seasonal drilling and geophysical-survey-monitoring program needs. During fall months, information on the status of the bowhead migration is transmitted from the field directly to MMS regulatory authorities. Other studies on endangered species include emphasis on surveys of distribution and abundance of endangered whales--especially to document the fall migration routes through the Chukchi Sea, feeding ecology of gray whales, experimental research on the behavioral responses of migrating bowhead and gray whales, and feeding gray and humpback whales to noise sources associated with oil and gas exploration, development, and production. Migrating bowheads have been tracked in the vicinity of offshore drilling operations. Living Resources: There are large numbers of cetaceans and pinnipeds in Alaskan offshore waters that are not endangered species. These include ringed, bearded, and fur seals; belukha whale; walrus; sea otter; and other species. The studies program has investigated life history, feeding habits, abundance, and F3 distribution of several important species, as well as aspects of their interaction with oil and gas activities. In addition to important studies on marine mammals, studies contracted by MMS or by OCSEAP for MMS have addressed commercial and subsistence fisheries and marine birds. Nearshore-fisheries studies have been conducted in the Beaufort and Chukchi Seas. Seabird studies have been conducted in areas of the Beaufort and Chukchi Seas, and shorebird research has been conducted in the Southern Chukchi. Waterfowl responses to human disturbance and, seabird and ringed seal monitoring are also being investigated. Oil-Spill Fate and Effects: A vital portion of the studies program is centered on determination of the fate and weathering of spilled oil and the effects that oil spills may have on marine habitats and biota. The MMS and NOAA participated in the Baffin Island Oil-Spill Test Program in the Canadian Arctic and investigated the weathering of spilled oil in open water and in sea ice. Weathering models for spilled oil in arctic waters have been developed and turbulent dispersion of oil droplets investigated. Pollutant Transport: The possibility of oil spills is one of the principal items evaluated as part of an environmental assessment. The studies program has continued to simulate hypothetical oil-spill transport in open and ice- covered waters by means of circulation models. These simulations are key to sale-specific-EIS preparation. Related physical oceanographic studies have investigated currents, tides, sea-ice motion, and meteorological forcing. The results of these studies are used in computing probabilities of oil-spill contact for different coastal areas. In addition, a coastal- and surf-zone-transport model for prediction of the transport of spilled oil onto and along beaches has been developed. Environmental Geology: The cold climate of Alaskan offshore waters results in extensive sea ice and permafrost. These conditions pose complications for oil and gas development, which in turn might lead to damage to the habitats of various species. The studies program has investigated shoreline erosion, sand and gravel deposits, shoreline sensitivity to oil, ice-bottom sediment interaction, bottom gouging by ice ridges, ice-ridging processes, and--to a lesser degree--marine permafrost. The information from these studies is used in defining potential areas of exploration difficulty. Ecosystems: During recent years, two ecosystem studies for areas along the Chukchi Sea coastline have been undertaken. The Peard Bay study was completed in 1986; and at present, Kasegaluk Lagoon ecosystem processes and biota usage are being observed and modeled. Several studies in the northern Bering Sea and the central and northeastern Chukchi Sea have provided pertinent, additional upstream information for the Sale 126 area. These studies are the National Science Foundation-funded Inner Shelf Transfer and Recycling program (ISHTAR), the Chukchi Sea shelf benthic habitat study, and the Bering Strait/Hope Basin habitat characterization study (including Kotzebue Sound). Environmental Monitoring: Since 1981, the MMS Alaska Region has performed monitoring studies initiated as part of aerial surveys and behavioral studies of bowhead whales. Since 1983, the Alaska Region has developed additional targeted-monitoring programs. The goal of the program is to test hypotheses regarding long-term change in sediments and lower-trophic-level organisms. This and other targeted-study efforts are expected to provide the basic framework by which the Alaska Region will meet monitoring needs under the OCSLAA. In pursuit of this goal, a long-term study was initiated to collect and curate marine mammal tissue for contaminant comparison. Social and Economic Studies: The Alaska OCS Region SESP is unique among the OCS regions administered by the MMS. This program was begun in 1976 at the urging of the State of Alaska and with recognition by the USDOI that the societies of rural Alaska are especially vulnerable to the influences of western industrial development. Social and economic studies are also mandated by Section 20 of the OCSLAA, which includes monitoring of the human environment. Social and economic studies have now been completed for nearly every coastal region of the state, and the program is turning to more specific studies of topical issues (i.e., subsistence, evaluation of arctic and subarctic offshore technologies, and specific effects of offshore oil and gas activities). The general process followed in all SESP evaluations is based on a comparative analysis of hypothetical changes likely to occur at the State, regional, or local level. As a rule, the methods used to forecast, analyze, and monitor potential changes at the local level vary from those used to evaluate regional and State-level changes. At the local level, offshore activities are most likely to have a physical presence and, therefore, a more direct effect on human activities. In light of these potential effects F-4 of offshore activities on infrastructure, community services and facilities, and social stability, the local-level analyses look at the effects on the socioeconomic characteristics of the communities and the sociocultural characteristics of the people likely to be affected. At the regional and State level--where effects are likely to be indirect--cumulative, incremental effects of all prior lease sales form the context for evaluating effects on the subject lease sale. The analyses of these effects appear in Section IV of this EIS. Social effects that may be attributed to the environmental consequences of OCS development are the subject of several sociocultural studies conducted for this lease sale and for Beaufort Sea Sale 97. Among these studies are the Chukchi Sea Sociocultural Systems Baseline Analysis, the Barrow Arch Socioeconomic and Sociocultural Description, the Description of the Socioeconomics of the North Slope Borough, the Effects of Renewable Harvest Disruption on Socioeconomic/Sociocultural Systems for Wainwright, the Nuiqsut Case Study, the Monitoring Methodology and North Slope Institutional Change Study, the Barrow Case Study, the North Slope Subsistence Study, the Social Indicators Monitoring Study, the Point Lay Case Study, and the Northern Institutional Profile Study. Past Studies in the Chukchi Sea: Prior to initiation of the ESP, the majority of research in the Chukchi Sea pertained to geodetic and hydrographic surveys. With the exception of Project Chariot, relatively little information was available on the physical and biological processes that sustained arctic habitats and ecosystems or on the biota supported by these areas. In 1959, the Atomic Energy Commission authorized environmental studies in the Cape Thompson area to assess the potential effects of using nuclear-excavation techniques to develop a harbor. Several marine studies were begun to enumerate and depict the physical- -chemical-oceanographic environment, coastal and offshore circulation, beach morphology, sedimentary regimes, lagoon biota, marine geology, marine plankton, benthic invertebrate abundance and distribution, climatology, and seabird-colony dynamics. Project Chariot was confined primarily to the southeastern Chukchi Sea (Point Hope-Cape Lisburne to the Bering Strait) and the adjacent landmass. In the late 1970’s, studies were initiated in the Chukchi Sea to collect information prior to Sale 85. Although this sale was subsequently deleted from the 5-year lease-sale schedule, considerable information was obtained. These early Chukchi Sea studies focused on distribution and abundance information on seabirds and bird colonies, marine mammals, fish, benthic organisms, and plankton. Current circulation and annual variation in ice zonations were also studied. Heavy-metal concentrations and ambient-hydrocarbon levels in the bottom sediments and water column were measured. These efforts emphasized the central and southeastern Chukchi Sea environment. Since 1979, several studies have examined the migration, habitat usage, and physiology of endangered whales and their relationship to the ice environment. Studies have been conducted of sound-transmission characteristics and used to predict the ranges at which bowheads and gray whales may react to specific sounds at specific sites. The probability of gray and bowhead whales encountering oil spills has also been studied. When the Chukchi Sea Planning Area (Sale 109) was included in the current 5-year lease-sale schedule, environmental studies that concentrated on the northeastern Alaska coastline and the northern Chukchi Sea were resumed. Major efforts began on sea-ice transport, ocean-coastal circulation, ecosystem processes centered on Peard Bay, storm-surge effects, nearshore-fish resources, development of a shoreline oil-spill-risk index, oil-spill modeling, ringed seal and seabird-colony monitoring, monitoring bowhead whale migration and habitat usage, investigating Chukchi Sea shelf benthic habitats and processes, and determining regional ocean circulation. The Alaska Region’s ESP also sponsors generic studies that produce results applicable to various planning areas, including laboratory studies on the effects of weathered hydrocarbons on various species and their life-cycle stages, oil weathering in the presence of ice and sediments, developing a coastal-zone-oil- impact/retention model, and the effects of OCS activities on marine mammal and bird behavior. Much of the work on sea-ice morphology and dynamics in the Beaufort Sea can be applied to the northeastern and central Chukchi Sea. As part of the ESP process, small workshops on various topics and Information Transfer Meetings (ITM) focusing on regional study results have been held to assist the lease-sale process and EIS authors, and to inform various government, industry, and interested citizenry on current issues. F-5 During the early years of the ESP, seismicity, volcanic activity, permafrost distribution, and bottom-sediment stability were funded to determine their potential hazard to OCS oil and gas development activities. These studies were gradually phased out due to funding constraints. Ongoing and Proposed Studies in the Chukchi Sea: The Chukchi Sea Environmental Studies List that follows this discussion shows completed, ongoing, and planned studies as of October 1989. Studies proposed for the near future would provide further information on identified concerns related to the Chukchi Sea area. Recent study efforts from several projects have resulted in the mapping and graphing of statistical data on sea-ice behavior in the Chukchi Sea. Ice frequency, as a function of location, has been displayed for meltback and freezeup periods since the 1970's. Two studies are underway to define and model Kasegaluk Lagoon ecosystem processes with an emphasis on marine mammal and bird use. Continuing studies also include shoreline sensitivity to oil spills, tracking ocean buoys in the offshore environment, remote imagery from satellites to determine ice-related events, timing and processes, isotope studies related to marine mammal habitat usage, and bowhead whale migration and behavior (both natural and potentially OCS-induced). A present study is comparing cumulative effects of human activities activities on bowhead whale behavior in pristine and industrially active habitats. Continuing studies address the behavioral responses of whales and other marine mammals to OCS activities and the potentially negative effects of these activities on populations, habitat usage, feeding, reproduction, and subsistence harvest. Proposed studies for the Chukchi Sea will likely include a nearshore-fisheries oceanographic study, seabird- colony monitoring, importance of leads to bowhead whales and other marine mammals, revision of the oil- weathering model used in conjunction with the oil-spill-trajectory modeling, importance of benthic feeding areas for walrus in the northeastern Chukchi Sea and a study relating the potential effects of industrial activity on the subsistence hunting of bowhead whales. Technology Assessment and Research Program (TA&RP): In addition to the ESP, the MMS has funded or contributed toward approximately 140 studies being conducted under the TA&RP. Many of these studies, which focus on arcticengineering technology, are joint Federal Government/industry efforts. The information obtained by these joint projects is often proprietary, except for that portion of the research that is conducted in Government facilities. Proprietary results from many of these joint studies will be made available to the public 2 to 5 years after completion of a given TA&RP project (see the Chukchi Sea Environmental Studies List that follows this discussion). Synthesis of Information: Prior to the first lease sale in any OCS area such as the Chukchi Sea, a synthesis meeting is held to integrate multidisciplinary studies results from individual projects into a comprehensive picture of a particular planning area. Synthesis participants include scientists working under ESP contracts; MMS, NOAA, and other Federal-agency staffs; State of Alaska personnel; and representatives from the oil and gas industry, Alaska Native organizations, and other special-interest groups. During the meeting, participants discuss the most current information available and consider the potential effects of oil and gas development upon the human, biological, and physical environments associated with the planning area. Information needs that are identified during these meetings aid in future studies planning. Synthesis meetings provide EIS authors with the opportunity to directly discuss and exchange views with scientists and other participating personnel on pertinent issues and potential effects of leasing decisions. The Chukchi Sea Synthesis Meeting, held in November 1983, resulted in publication of "The Barrow Arch Environment and Possible Consequences of Planned Offshore Oil and Gas Development" (Truett, 1984). A meeting to update information on the Chukchi Sea was held on March 27, 1986. ESP contractors presented recent results of their Chukchi Sea work to MMS staff authors of the Sale 109 EIS. A collection of papers that summarize this meeting was published in 1987. F6 Chukchi Sea Environmental Studies List NOAA/OCSEAP Environmental Studies (Completed) Identification, Documentation and Delineation of Coastal Migratory Bird Habitats in Alaska, Alaska Department of Fish and Game, Arneson, P., NOAA/OCSEAP, Research Unit No. 3, 1980. Distribution, Composition, and Variability of Western Beaufort and Northern Chukchi Sea Benthos, Oregon State University, Carey, A., Research Unit No. 6, 1984. Finfish Resource Surveys, Alaska Department of Fish and Game, Jackson, P., Barton, I., and Warner, I., Research Unit No. 19, 1978, 1981. Assessment of Potential Interaction of Micro-Organisms and Pollutants Resulting from Petroleum Development on the Outer Continental Shelf of Alaska, University of Louisville, Atlas, R., Research Unit No. 29, 1982. Analysis of Marine Mammal! Remote Sensing Data, Johns Hopkins University, Ray, G., and Wartzok, D., Research Unit No. 34, 1976. Trace Hydrocarbon Analysis in Previously Studied Matrices and Methods Development for (a) Trace HC Analysis in Sea Ice and at the Sea Ice/Water Interface and (b) Analysis of Individual High Molecular Weight Aromatic HC, National Bureau of Standards, Cheslor, S., Research Unit No. 43, 1980. Environmental Assessment of Alaskan Waters - Trace Element Methodology - Inorganic Elements, National Bureau of Standards, LaFleur, P., Research Unit No. 47, 1977. Coastal Morphology, Sedimentation, and Oil Spill Vulnerability, Research Planning Institute, Inc., Hayes, M., Research Unit No. 59, 1976 to 1982. Baseline Characterization of Marine Mammals, NOAA/NMBS, Fiscus, C., and Braham, H., Research Unit No. 67, 1977, 1978. Migration, Distribution, and Abundance of Bowhead and Beluga Whales, NOAA/NMEBS, Fiscus, C., and Braham, H., Research Unit No. 69, 1981. Effects of Oiling on Marine Mammals, VIN Oregon, Inc., Kooyman, G., Research Unit No. 71, 1976, 1981. Effects of Petroleum Hydrocarbons on Alaskan Aquatic Organisms - A Comprehensive Review of All Oil-Effects Research on Alaskan Fish and Vertebrates Conducted by the Auke Bay Laboratories, Rice, S., and Karinen, J., NOAA/NMFS, Research Unit No. 72, 1983. Sublethal Effects of Petroleum Hydrocarbons and Trace Metals, Including Biotransformation, as Reflected by Morphological, Chemical, Physiological, and Behavioral Indices, NOAA/NMFS, Malins, D., Research Unit No. 73, 1982. Assessment of Available Literature: Oil Pollutants Effects on Subarctic and Arctic Biota, NOAA/NMFS, Stansby, M., Malins, D., and Piskur, F., Research Unit No. 75, 1978. Beaufort Shelf Surface Currents, United States Coast Guard, Hufford, G., Research Unit No. 81, 1977. Interaction of Oil with Sea Ice in the Beaufort Sea, University of Washington, Martin, S., Research Unit No. 87, 1982. Sea Ice Ridges and Pile-Up, U.S. Army Cold Regions Research and Engineering Laboratory (CRREL), Weeks, W., Research Unit No. 88, 1987. Current Measurements in Possible Dispersal Regions of the Chukchi and Beaufort Seas, University of Washington, Aagaard, K., Research Unit Nos. 91/151, 1981, 1984. Effects of Petroleum Exposure on the Breeding and Ecology of the Gulf of Alaska Herring Gull, Gull Group Larus argentatus and Larus glauescens, Johns Hopkins University, Bang, F., and Patten, S., Research Unit No. 96, 1979. Dynamics of Nearshore Ice, Flow Research Co., Colony, R., Research Unit No. 98, 1979. The Environmental Geology and Geomorphology of the Coastal Zone of Kotzebue Sound and the Chukchi Sea Forelands from Cape Prince of Wales to Cape Lisburne, University of Alaska, Cannon, J., Research Unit No. 99, 1979. Delineation and Engineering Characteristics of Permafrost Beneath the Arctic Seas, U.S. Army-CRREL, Sellman, P., and Chamberlain, E., Research Unit No. 105, 1976 to 1983. Seasonality and Variability of Stream Flow Important to Alaskan Nearshore Coastal Area, University of Alaska, Carlson, R., Research Unit No. 111, 1977. Low Molecular Weight Hydrocarbon Concentrations (C-1 to C-4), Alaskan Continental Shelf, 1975-1979; NOAA/Pacific Marine Environmental Laboratory, Cline, J., Research Unit No. 153, 1982. F-7 Marine Environmental Laboratory, Cline, J., Research Unit No. 153, 1982. Natural Distribution of Trace Heavy Metals on the Alaskan Shelf, University of Alaska, Burrell, D., Research Unit No. 162, 1979. Shorebird Dependence on Arctic Littoral Habitats, University of California, Risebrough, R., Research Unit No. 172, 1981, 1982, 1984. Baseline Studies of Demersal Resources of the Eastern Bering Sea, Norton Sound and Southeast Chukchi Sea, NOAA/NMEFS, Pereyra, W., and Dunn, J., Research Unit No. 175, 1976, 1979. Morbidity and Mortality of Key Marine Mammal Species, University of Alaska, Fay, F., Research Unit No. 194, 1981. Distribution, Abundance, and Feeding Ecology of Birds Associated with Sea Ice, Point Reyes Bird Observatory, West, G., and Divoky, G., Research Unit No. 196, 1982. Offshore Permafrost Studies, U.S. Geological Survey, Hopkins, D., Research Unit No. 204, 1982. Geologic Environment of the Chukchi and Beaufort Sea Shelf and Coastal Regions, U.S. Geological Survey, Barnes, P. and Reimnitz, E., Research Unit No. 205, 1978 to 1985. The Natural History and Ecology of the Bearded Seal and the Ringed Seal, Alaska Department of Fish and Game, Eley, T. and Burns J., Research Unit No. 230, 1978, 1979. Trophic Relationships Among Ice-Inhabiting Phocid Seals and Functionally Related Marine Mammals in the Arctic, Alaska Department of Fish and Game, Lowry, L., Frost, K., Kelly, B., and Burns, J., Research Unit No. 232, 1979, 1980, 1981, 1986, 1988, 1989. Study of Climatic Effects on Fast-Ice Extent and Its Seasonal Decay Along the Beaufort Sea and Chukchi Sea Coasts, University of Colorado, Barry, R., Research Unit No. 244, 1979. Relationships of Marine Mammal Distributions, Densities, and Activities to Sea Ice Conditions, Alaska Department of Fish and Game and the University of Alaska, Burns, J., Fay, F., and Shapiro, L., Research Unit No. 248, 1981. Mechanics of Origin of Pressure, Shear Ridges, and Hummock Fields in Landfast Ice, University of Alaska, Shapiro,, L., and Harrison, W., Research Unit Nos. 250/265, 1987. - Subsea Permafrost, Probing, Thermal Regime and Data Analysis, University of Alaska, Osterkamp, T., and Harrison, W., Research Unit No. 253, 1985. Morphology of Beaufort, Chukchi, and Bering Seas Nearshore Ice Conditions by Means of Satellite and Acrial Remote Sensing, University of Alaska, Stringer, W., Research Unit No. 257, 1979. Experimental Measurements of Sea-Ice Failure Stresses Near Grounded Structures, University of Alaska, Sackinger, W., and Nelson, R., Research Unit No. 259, 1979. Baseline Study of Historic Ice Conditions in Bering Strait, Chukchi Sea and Beaufort Sea, University of Alaska, Hunt, W., and Naske, C., Research Unit No. 261, 1977. Development of Hardware and Procedures For In Situ Measurements of Creep in Sea Ice, University of Alaska, Shapiro, L., Research Unit Nos. 265/250, 1987. Operations of an Alaskan Facility for Application of Remote Sensing Data to OCS Studies, University of Alaska, Stringer, W., Research Unit No. 267, 1973 through 1983. Arctic Offshore Permafrost Studies, Michigan Technical University, and the University of Alaska, Rogers, J., Research Unit Nos. 271/610, 1982. Hydrocarbons: Natural Distribution and Dynamics on the Alaskan Outer Continental Shelf, University of Alaska, Shaw, D., Research Unit No. 275, 1981. Microbial Release of Soluble Trace Metals from Oil-Impacted Sediments, University of Alaska, Barsdate, R., Research Unit No. 278, 1976. The Distribution, Abundance, Diversity and Productivity of Benthic Organisms in the Gulf of Alaska, Bering Sea and Chukchi Sea, University of Alaska, Feder, H., Research Unit No. 281, 1977, 1978. Summarization of Existing Literature and Unpublished Data on the Distribution, Abundance and Productivity of Benthic Organisms of the Gulf of Alaska and Bering and Chukchi Seas, University of Alaska, Feder, H., Research Unit No. 282, 1977. Determine the Frequency and Pathology of Marine Fish Diseases in the Bering Sea, Gulf of Alaska, and Beaufort Sea, NOAA/NMBS, McCain, B., Research Unit No. 332, 1981. Seasonal Distribution and Abundance of Marine birds, USFWS, Bartonek, J., Research Unit No. 337, 1982. Catalog of Seabird Colonies in Alaska, USFWS, Bartonek, J., and Lensink, C., Research Unit No. 338, 1977. An Annotated Bibliography of Literature on Alaska Water Birds, USFWS, Lensink, C., and Bartonek, J., Research Unit No. 339, 1981. Marine Climatology of the Gulf of Alaska (Vol. I), the Bering Sea (Vol. II) and Beaufort Sea (Vol. III), National Climatic Center/Arctic Environmental Information and Data Center, Brower, W., and Wise, J., Research Unit No. 347, 1977. Seismicity of the Beaufort Sea, Bering Sea, and Gulf of Alaska, NOAA/National Geophysical and Solar-Terrestria! Data Center, Meyers, H., Research Unit No. 352, 1977. Environmental Assessment of Selected Habitats in Arctic Littoral Systems, Western Washington State University, Broad, C., Research Unit No. 356, 1981. Beaufort Sea Plankton Studies, University of Washington, Horner, R., Research Unit No. 359, 1981. Radiometric Spectral Response of Oil Films, NOAA/APCL, Kuhn, P., Research Unit No. 399, 1977. Zooplankton: Species Composition, Distribution and Abundance, University of Washington, English T., Research Unit No. 424, 1979. Zooplankton and Micronekton Studies: Southeastern Bering Sea, Chukchi Sea and Beaufort Sea, University of Alaska, Cooney, R., Research Unit No. 426, 1977, 1978. Bering Sea Ice-Edge Ecosystem Study: Primary Productivity, Nutrient Cycling and Organic Matter Transfer, University of Alaska, Alexander, V. and Cooney, R., Research Unit No. 427, 1978, 1980. Intertidal Zone Mapping by Multispectral Analysis, Environmental Research Institute of Michigan, Wezernak, C., Research Unit No. 428, 1978. Seismic and Techtonic Hazards in the Hope Basin and Beaufort Shelf, USGS, Grantz, A., Research Unit No. 432, 1977. Modeling of Tides and Circulations, Rand Corporation, Leendertse, J., and Liu, D., Research Unit No. 435, 1987. Research to Determine the Accumulation of Organic Constituents and Heavy Metals from Petroleum-Impactec! Sediments by Marine Detritivores of the Alaska OCS, Battelle Pacific Northwest Laboratories, Anderson, J., Research Unit No. 454, 1980. Population and Trophics Studies of Seabirds in the Northern Bering and Eastern Chukchi Seas, 1981, FALCO, Inc., Roseneau, D. and Springer, A., Research Unit No. 460, 1984. The Fate and Weathering of Petroleum Spilled in the Marine Environment: A Literature Review and Synopsis, Science Applications, Inc., Payne, J., and Jordon, R., Research Unit No. 468, 1979. Shoreline History of the Chukchi and Beaufort Seas as an Aid to Predictive Offshore Permafrost Conditions, USGS, Hopkins, D., Research Unit No. 473, 1978. Characterization of Organic Matter in Sediments from the Gulf of Alaska, Bering and Beaufort Seas, University of California-Los Angeles, Kaplan, I., Research Unit No. 480, 1981. Evaluation of Earthquake Activity and Seismotechnic Studies of Northern and Western Alaska, University of Alaska, Biswas, N., and Gedney, L., Research Unit No. 483, 1979, 1983. Index of Original Surface Weather Records, NOAA/National Climatic Data Center, Research Unit No. 496, 1977. Modeling Algorithms for the Weathering of Oil in the Marine Environment, NOAA/Environmental Data Service, Mattson, J., Research Unit No. 499, 1978. Activity-Directed Fractionation of Petroleum Samples, Battelle Pacific Northwest Laboratories, Warner, J., Research Unit No. 500, 1979. Trawl Survey of the Epifaunal Invertebrates of Norton Sound, Southeastern Chukchi Sea, and Kotzebue Sound, University of Alaska, Feder, F., Research Unit No. 502, 1978. Natural Distribution and Environmental Background of Trace Heavy Metals in Alaskan Shelf and Estuarine Areas, Battelle Pacific Northwest Laboratories, Robertson, D., Research Unit No. 506, 1979. A Geographic Based Information Management System for Permafrost Predictions in the Beaufort and Chukchi Seas, Parts I and II, University of Colorado, Vigdorchik, M., Research Unit No. 516, 1978. Nearshore Meteorologic Regimes in the Arctic, Occidental College, Kozo, T., Research Unit No. 519, 1985. F-9 Characterization of the Nearshore Hydrodynamics of Arctic Barrier Island-Lagoon System, University of Alaska, Matthews, J., Research Unit No. 526, 1981. Sediment Characterization, Stability, and Origin of Barrier Island-Lagoon Complex, Alaska, University of Alaska, Naidu, A., Research Unit No. 529, 1982. Oceanographic Processes in a Beaufort Sea Barrier Island-Lagoon System and its Surroundings; Numerical Modeling and Current Measurements, Kinnetic Laboratories, Inc., Mungall, J., Research Unit No. 531, 1982. Nearshore Coastal Currents, Chukchi Sea, Summer, 1981, Kinnetic Laboratories, Inc., Research Unit No. 531, Mungall, J., 1982. Nutrient Dynamics and Trophic System Energetics in Nearshore Beaufort Sea Waters, University of Alaska, Schell, D., Research Unit No. 537, 1982. Oil Pooling Under Sea Ice, U.S. Army-CRREL, Kovacs, A., Research Unit No. 562, 1979. Transport and Behavior of Oil Spilled In and Under Sea Ice (Task I), Flow Research Co., Coon, M., and Pritchard, R., Research Unit No. 567, 1983, 1985. Transport and Behavior of Oil Spilled In and Under Sea Ice (Task II and III), ARCTEC Incorporated, Schultz, L., and DeSlauries, P., Research Unit No. 568, 1981. Oil-Weathering Computer Program User’s Manual: Multivariate Analysis of Petroleum Weathering in the Marine Environment-Subarctic, Science Application, Inc., Payne, J., Research Unit No. 597, 1984. Habitat Requirement and Expected Distribution of Alaska Coral, VIN Oregon, Inc., Cimberg, R., Research Unit No. 601, 1981. Baffin Island Oil Spill Project, Environmental Protection Service (Canada), Blackall, P., Research Unit No. 606, 1981 through 1985. Biodegradation of Aromatic Compounds by High Latitude Phytoplankton, University of Texas, Van Baalen, C., Research Unit No. 607, 1982. Beaufort and Chukchi Seacoast Permafrost Studies, Michigan Technological University and University of Alaska, Rogers, J., and Morack, J., Research Unit No. 610, 1983. Modern Populations, Migrations, Demography, Trophics and Historical Status of the Pacific Walrus in Alaska, University of Alaska, Fay, F., Research Unit No. 611, 1984. Biological Investigation of Beluga Whales in the Coastal Waters of Alaska, Alaska Department of Fish and Game, Burns, J., Research Unit No. 612, 1986. Investigations of Marine Mammals in the Coastal Zone During Summer and Autumn, Alaska Department of Fish and Game, Frost, K., Lowry, L., and Burns, J., Research Unit No. 613, 1982, 1983. Baffin Island Oil Spill Project: Hydrocarbon Bioaccumulation and Histo-Pathological and Biochemical Responses of Mollusc, Battelle Northwest Laboratories, Neff, J., Research Unit No. 615, 1984. Fish Resources of the Chukchi Sea: Status of Existing Information and Field Program Design Task I, Information Review Report, LGL Ltd., Craig, P., Research Unit No. 618, 1982. The Nature and Biological Effects of Weathered Petroleum, NOAA/NMFS, Malins, D., Research Unit No. 619, 1983. Storm Surge Modeling, University of Alaska, Kowalik, Z., Research Unit No. 627, 1984, 1985. Belukha Whale Responses to Industrial Noise in Nushagak Bay, Alaska, 1983; Hubbs-Sea World Research Institute, Evans, W., Research Unit No. 629, 1983. Fish Distribution and Use of Nearshore Waters in the Northeastern Chukchi Sea, LGL Ltd., Gallaway, B., Research Unit 635, 1984. Direct Effects of Acoustic Disturbance Sources on Ringed Seal Reproductive Behavior, Vocalization, and Communication, TRACOR, Inc., Holliday, D., and Cummings, B., Research Unit No. 636, 1984. Permafrost: 4th International Conference Proceedings, Fairbanks, Alaska, July 17-23, 1983, National Academy Press, Research Unit No. 637, 1984. Predictive Model for the Weathering of Oil in the Presence of Sea Ice (Annual Sea Ice), Science Application, Inc., Payne, J., Research Unit No. 640, 1984 Environmental Characterization and Biological Utilization of Peard Bay, Kinnetic Laboratories Inc., Kinney, P., Research Unit No. 641, 1985. F-10 Oceanographic Data: Data from the Bering, Chukchi and Beaufort Seas, Brown and Caldwell, Pitman, R., Research Unit No. 642, 1984. Chukchi Sea Coastal Studies; Coastal Geomorphology, Environmental Sensitivity, and Persistence of Spilled Oil, Woodward and Clyde Consultants, Harper, J., Research Unit No. 644, 1985. Nearshore and Coastal Circulation in the Northeast Chukchi Sea, Science Applications, Inc., Hachmeister, L., Research Unit No. 646, 1985. Primary Productivity and Nutrient Dynamics in the Chukchi Sea, University of Alaska, Schell, D., Research Unit No. 648, 1985. A Markov Model for Nearshore Sea-Ice Trajectories, University of Washington, Colony, R., Research Unit No. 654, 1985. Lethal and Sublethal Effects of Spilled Oil on Herring Reproduction, NOAA/Northwest and Alaska Fisheries Center, Rice, S., Research Unit No. 661, 1986. Lethal and Sublethal Effects of Oil on Food Organisms of the Bowhead Whale, Fishman Environmental Services, Fishman, P., Research Unit No. 662, 1985. Remote Sensing Data Acquisition, Analysis, and Archival for the Alaskan OCS, University of Alaska, Stringer, W., Research Unit No. 663, 1988. Weathering of Oil in Multiyear Sea Ice, Science Applications International, Inc., Payne, J., Research Unit No. 664, 1987. Environmental Characterization and Biological Utilization of Peard Bay, Kinnetic Laboratories, Inc., Kinney, P., Research Unit No. 665, 1986. Ringed Seal Monitoring, Alaska Department of Fish and Game, Burns, J., Research Unit No. 667, 1988. Marine Meteorology Update, NOAA/National Climatic Data Center, Brower, W. and Wise, J., Research Unit No. 672, 1988. Behavorial Responses of Gray Whales to Industrial Noise: Feeding Observations and Predictive Modeling, BBN Laboratories Inc. and Moss Landing Marine Laboratory, Wursig, B., Research Unit No. 675, 1986. Ocean Circulation and Oil Spill Trajectory Simulation, Applied Science Associates, Spaulding, M., and Reed, M., Research Unit No. 676, 1987. Oil-Sediment Interactions, Science Applications Inc., Payne, J., Research Unit No. 680, 1989. Effects of Petroleum-Contaminated Waterways on the Spawning Migration of Pacific Salmon (PHASE 1), Battelle Laboratories Northwest, Pearson, W., Research Unit No. 681, 1987. Interpolation, Analysis and Archival of Data on Sea-Ice Trajectory and Ocean Currents from Satellite-Linked Instruments, Ice Casting Inc., Pritchard, R., Research Unit No. 683, 1987. Beaufort Sea Mesoscale Circulation Study, NOAA/Pacific Marine Environmental Laboratory, Aagaard, K., and Pease, C., Research Unit No. 686, 1989. Nutrient Data in the Beaufort Sea, Woodward and Clyde Consultants, Elder, R., Research Unit No. 700, 1988. Natural Oil Seeps in the Alaskan Marine Environment, NOAA/OCSEAP, Becker, P., and Manen, C., Research Unit No. 703, 1988. The Alaskan Beaufort Sea Ecosystems and Environments, Academic Press, Orlando, Florida, Barnes, P., Schell, D. and Reimnitz, E. (eds.), 1984. Environmental Assessment of the Alaska Continental Shelf, Interim Synthesis: Beaufort/Chukchi Seas, Barrow, Alaska, February 7-11, 1977, USDOC/OCSEAP and USDOI/BLM, Weller, G., Norton, D., and Johnson, T. (eds.), 1978. The Barrow Arch Environment and Possible Consquences of Planned Offshore Oil and Gas Development (Sale 85): Proceedings of a Synthesis Meeting - Girdwood, Alaska, 30 October - 1 November, 1983, USDOC/OCSEAP and USDOI/MMS, Truett, J. (ed.), 1984. Chukchi Sea Information Update (Sale 109), Anchorage, Alaska, March 27, 1986, USDOC/OSCEAP and USDOI/MMS, Hale, D. (ed.), 1987. NOAA/OCSEAP Environmental Studies (Ongoing) Quality Assurance Program for Trace Petroleum Component Analysis, NOAA/National Analytical Facility, MacLeod, W., Research Unit No. 557, Ongoing Study. F-11 Arctic Ocean Buoy Program, University of Washington, Colony, R., Research Unit No. 674, Ongoing Study. Chukchi Shelf Benthic, University of Alaska, Naidu, S., and Feder, H., Research Unit No. 687, Ongoing Study. Archiving of Wildlife Specimens for Future Analysis, Bureau of Standards, Wise, S., Research Unit No. 692, Ongoing Study. Taxonomic Analysis of Micro-Plankton from the Beaufort and Chukchi seas, Horner Associates, Horner, R., Research Unit No. 701, Ongoing Study. Effects of Petroleum-Contaminated Waterways on the Spawning Migration of Pacific Salmon (Phase II), Dames and Moore, Martin, D., Research Unit No. 702, Ongoing Study. Performance and Compatibility Analysis of Oil Weathering and Transported-Related Models in the Environmental Assessment Process, BDM Corporation, Coon, M., Research Unit No. 706, Ongoing Study. Environmental Characterization and Biological Utilization of Kasegaluk Lagoon, Biosystems Incorporated, Kimmerer, W., Research Unit No. 707, Ongoing Study. Fisheries Oceanography in Areas of Oil and Gas Development Activities in the Arctic; Offshore Chukchi Fish, University of Alaska, Barber, W., Research Unit No. 712, Ongoing Study. Remote Sensing Data Acquisition and Analysis, University of Alaska, Stringer, W., and Dean, K., Research Unit No. 716, Ongoing Study. Minerals Management Service Environmental Studies (Completed) Aerial Survey of Endangered Whales in the Beaufort, Chukchi, and Northern Bering Seas, Naval Ocean Systems Center, Ljungblad, D., MMS Contract No. AK001, 1979 to 1988. Development of a Method for Monitoring the Productivity, Survivorship, and Recruitment of the Pacific Walrus Population, University of Alaska, Fay, F., MMS Purchase Order No. 14908, 1989. Effects of Whale Monitoring System Attachment Devices on Whale Tissue, Woods Hole Oceanographic Institution, MMS Contract No. BLM CTO-23, 1982. Historical Review of Eskimo Information - Bowhead Whale, Alaska Eskimo Whaling Commission, MMS Contract No. BLM CT8-S4. Development of Large Cetacean Tagging and Tracking Capability in OCS Lease Areas, NOAA/National Marine Mammal Laboratory, Hobbs, L., and Goebel, M., MMS Contract No. 29015, 1981. Investigations of the Potential Effects of Acoustic Stimuli Associated with Oil and Gas Exploration/Development on the Behavior of Migratory Gray Whales and Humpback Whales, Bolt Beranek and Newman, Inc., Malme, C., MMS Contract No. 29033, 1986. Development and Application of Satellite-Linked Methods of Large Cetacean Tagging and Tracking Capabilities in Offshore Lease Areas, Oregon State University, Mate, B., MMS Contract No. 29042, 1987. Tissue Structure Studies and Other Investigations on the Biology of Endangered Whales in the Beaufort Sea, University of Maryland, Albert, T., MMS Contract No. 29046, 1981. Possible Effects of Acoustic and Other Stimuli Associated With Oil and Gas Exploration/Development on the Behavior of the Bowhead Whale, LGL Ecological Research Associates, Fraker, M., and Richardson, W., MMS Contract No. 29051, 1985. The Effects of Oil on the Feeding Mechanism of the Bowhead Whale, Brigham Young University, Braithwaite, L., MMS Contract No. 29052, 1983. Observations on the Behavior of Bowhead Whales (Balaena Mysticetus) in the Presence of Operating Seismic Exploration Vessels in the Alaskan Beaufort Sea, Naval Ocean Systems Center, Ljungblad, D., MMS Contract No. 30031, 1985. Computer Simulation of the Probability of Endangered Whale Interaction with Oil Spills, Applied Science Associates, Inc., Reed, M., MMS Contract No. 30076, 1986. Coastline and Surf Zone Oil Spill Smear Model, Coastal Science and Engineering, Inc., Kana, T., MMS Contract No. 30130, 1988. Integration of Suspended Particulate Matter and Oil Transportation, Science Applications International Inc., Payne, J., MMS Contract No. 30146, 1987. Monitoring Seabird Populations in the Alaska Outer Continental Shelf Region - Proceedings of a Conference, Anchorage, Alaska, November 15-17, 1984, Lawrence Johnson and Associates, Inc., MMS Contract No. 30195, 1985. F-12 Development.of Visual Matrix Charts Which Categorize Research Literature of Endangered (Marine) Mammals, University of Maryland, Setzler-Hamilton, E., MMS Contract No. 30208, 1986. Vertical Turbulent Dispersion of Oil Droplets and Oiled Particles, Delft Hydraulics Laboratory, Delvigne, G., MMS Contract No. 30268, 1987. Prediction of Site-Specific Interaction of Acoustic Stimuli and Endangered Whales as Related to Drilling Activities During Exploration and Development of the Beaufort Sea Lease Sale Area, BBN Laboratories, Inc., and LGL Ecological Research Associates, Inc., Miles, P.. MMS Contract No. 30295, 1987. Arctic Information Transfer Meeting - Proceedings from a Meeting in Anchorage, Alaska, November 17-20, 1987, MBC Applied Environmental Services, MBC (ed.), MMS Contract No. 30297, 1988. Sea-Ice Forces and Mechanics - Conference Proceedings, Anchorage, Alaska, July 22-23, 1986, MBC Applied Environmental Sciences, Kauwling, T., and Ware, R., MMS Contract No. 30297, 1987. Mercury in the Marine Environment Workshop, November 29-30, 1988, Anchorage, Alaska, MBC Applied Environmental Sciences, Mitchell, K., MMS Contract No. 30297, 1989. Fisheries Oceanography - A Comprehensive Formulation of Technical Objectives for Offshore Application in the Arctic - Workshop Proceedings, April 5-7, 1988, Anchorage, Alaska, MBC Applied Environmental Sciences, Meyer, R., and Johnson, T. (eds.), MMS Contract No. 30297, 1988. Potential Acoustic Disturbance to Marine Mammals in Alaska, BBN Laboratories, Inc., Malme, C., MMS Contract No. 30365, 1989. Comparison of the Behavior of Bowhead Whales of the Davis Strait and Western Arctic Stocks, LGL Environmental Research Associates, Richardson, J., MMS Contract No. 30390, 1988. Monitoring Seabird Populations near Offshore Activities, USFWS, Hatch, S., MMS Contract No. 30391, 1989. Minerals Management Service Environmental Studies (Ongoing) Application of Remote Sensing Methods of Large Cetacean Tracking, Oregon State University, Mate, B., MMS Contract No. 30411, Ongoing Study. Effects of Production Activities on Bowhead Whales, LGL Ecological Research Associates, Richardson, J., MMS Contract No. 30412, Ongoing Study. Circulation and Trajectory Model, Greenhorne and O’Mara, Signiorini, S., MMS Contract No. 30413, Ongoing Study. Shoreline Segment Characteristic Handbook for Smear Model Application, E-Tech, Inc., Grunlach, E., MMS Contract No. 30420, Ongoing Study. Monitoring the Distribution of Arctic Whales - Chukchi, Science Applications International Corporation, Moore, S., MMS Contract No. 30468, Ongoing Study. Stable Isotope Analysis of 1987 and 1988 Zooplankton and Bowhead Whale Tissue, University of Alaska, Schell, D., MMS Contract No. 30472, Ongoing Study. Use of Kasegaluk Lagoon by Marine Mammals and Birds/Monitoring Beaufort Sea Waterfowl, LGL Ecological Research Associates, Johnson, S., MMS Contract No.30491, Ongoing Study. Bowhead Whale Book, Society of Marine Mammalogy, Burns, J., and Montague, J., (eds.), Ongoing Study. Bowhead Whale Aerial Survey Project (BWASP), MMS, Treacy, S., Ongoing Study. F-13 Chukchi Sea Economic and Demographic Structural Change in Alaska, University of Alaska, ISER, Technical Report 73, June 1982. Chukchi Sea Sociocultural Systems Baseline Analysis, Cultural Dynamics, Ltd., Technical Report 74, September 1983. Forecasting Enclave Development Alternatives and Their Related Impact on Alaskan Coastal Communities as a Result of OCS Development, Louis Berger and Associates, Inc., Technical Report 76, December 1982. Social Indicators for OCS Impact Monitoring, Louis Berger and Associates, Inc., Technical Report 77, Vol. I, May 1983. Social Indicators for OCS Impact Monitoring: Technical Appendices, Louis Berger and Associates, Inc., Technical Report 77, Vol. II, May 1983. Chukchi Sea Petroleum Technology Assessment, Dames and Moore, Technical Report 79, December 1982. Hope Basin Petroleum Technology Assessment, Dames and Moore, Technical Report 81, July 1983. A Description of the Socioeconomics of the North Slope Borough, University of Alaska, ISER, Technical Report 85, September 1983. A Description of the Socioeconomics of the North Slope Borough; Appendix: Transcripts of Selected Inupiat Interviews, University of Alaska, ISER, Technical Report 85A, September 1983. Effects of Renewable-Harvest Disruption on Socioeconomic and Sociocultural Systems: Chukchi Sea, John Muir Institute, Technical Report 91, January 1985. Economic and Demographic Systems Analysis, North Slope Borough, University of Alaska, ISER, Technical Report 100, October 1984. Barrow Arch Socioeconomic and Sociocultural Description, Alaska Consultants, Inc., Technical Report 101, January 1984. Barrow Arch Transportation Systems Impact Analysis, ERE Systems, Ltd., Technical Report 104, December 1984. Alaska Statewide and Regional Economic and Demographic Systems: Effects of OCS Exploration and Development, University of Alaska, ISER, Technical Report 106, April 1984. Monitoring Oil Exploration Activities in the Beaufort Sea, K. Waring Associates, Technical Report 107, January 1985. Beaufort Sea Petroleum Technology Assessment, Han-Padron Associates, Technical Report 112, March 1985. Alaska Statewide and Regional Economic and Demographic Systems: Effects of OCS Exploration and Development, 1985, ISER, Technical Report 115, June 1985. A Social Indicators System for OCS Impact Monitoring, Stephen R. Braund and Associates, Technical Report 116, December 1985. Monitoring Methodology and North Slope Institutional Change, 1979-1983, Chilkat Institute, Technical Report 117, September 1985. Economic and Demographic Systems of the North Slope Borough: Beaufort Sea Lease Sale 97 and Chukchi Sea Lease Sale 109, ISER, Technical Report 120, Vols. I and II, Technical Report 120, June 1986. Alaska Statewide and Regional Economic and Demographic Systems: Effects of OCS Exploration and Development, 1986, ISER, Technical Report 124, July 1986. Barrow: A Decade of Modernization, Chilkat Institute, Technical Report 125, November 1986. Subsistence Fisheries at Coastal Villages in the Alaskan Arctic, 1970-1986, LGL Ecological Research Associates, Inc., Technical Report 129, July 1987. Village Economics in Rural Alaska, Impact Assessment Inc., Technical Report 132, December 1988. North Slope Subsistence Study - Barrow 1987, Stephen R. Braund and Associates, Technical Report 133, December 1988. F-14 Technology Assessment and Research Program Reports Information regarding the status of the TA&RP reports may be obtained by telephone from Mr. Charles Smith, Program Manager, Technology Assessment and Research Branch, Herndon, Virginia (703) 787-1559. Many of the reports (if they are not proprietary) are available from MMS libraries. Underwater Inspection/Testing/Monitoring of Offshore Structures, Busby, Busby Associates, TA&RP No. 1. Dynamic Response of Offshore Structures, Vandiver, Massachusetts Institute of Technology, TA&RP No. 2. Incipient Crack Detection in Offshore Structures, Hochrein, Daedalean Associates, TA&RP No. 3. Cavitating Water Jet Cleaning Nozzle, Thiruvengadam, Daedalean Associates, TA&RP No. 4. Attenuation of Surface Waves in Localized Region of the Open Ocean, Hires, Stevens Institute, TA&RP No. 5. Research Program Advisory, Boller, Marine Board, TA&RP No. 6. Unmanned Untethered Inspection-Vehicle Technology, Heckman, Naval Ocean Systems Center and Cold Regions Research and Engineering Laboratory (CRREL-University of New Hampshire), TA&RP No. 7. Blowout-Prevention Procedures, Bourgoyne, Louisiana State University, TA&RP No. 8. Ultrasonic Flowmeter Evaluation, Holmes, Harry Diamond Laboratories, TA&RP No. 9. Subsea Inspection, Gehman, Harry Diamond Laboratories, TA&RP No. 10. Portable Data Recorder for USGS Inspectors, Burke, Harry Diamond Laboratories, TA&RP No. 11. Technology Assessment, Holmes, Harry Diamond Laboratories, TA&RP No. 12. Fluidic Pulser for Mud Pulse Telemetry, Holmes, Harry Diamond Laboratories, TA&RP No.13. Fluidic Sensor for Hydrocarbon and Hydrogen Sulfide Gas, Funke, Tri Tek, TA&RP No. 14. Hardhat Communicator, Shoemaker, Harry Diamond Laboratories, TA&RP No. 15. Technology Assessment for OCS Oil and Gas Operations in the Arctic Ocean, Brown, Energy Interface Associates, TA&RP No. 16. Fire-Suppression Technology, Finger, Harry Diamond Laboratories, TA&RP No. 17. Overpressured Marine Sediments, Thompson, Texas A&M University, TA&RP No. 18. Hurricane-Driven Ocean Currents, Forristall, Shell Oil Co., TA&RP No. 19. Toxic Effects of Drill Muds on Coral, Shinn, USGS, TA&RP No. 20. Underwater Acoustic Telemetry, Softley, Ocean Electronic Applications, TA&RP No. 21. Pattern Recognition Technology, Sadjian, General Sensors, TA&RP No. 22. Incipient Structural Failure by the Random Decrement Method, Yang, University of Maryland, TA&RP No. 23. Technology Assessment for Estimating Hydrocarbons Lost During a Blowout, Hawkins, Coastal Petroleum Associates, TA&RP No. 24. Overpressures Developed by Shaped Explosive Charges Used to Remove Wellheads, Phillips, Naval Surface Weapons Center, TA&RP No. 25. Detection and Suppression of Wellhead Fires, Evans, National Bureau of Standards (NBD), TA&RP No. 26. Technology Assessment for Cementing Shallow Casings, McDonald, Maurer Engineering, TA&RP No. 27. Casing-Wall Thickness Technology, Mastandrea, NDE Technology, Inc., TA&RP No. 28. Deepwater Structures Technology Assessment, Mandke, Battelle-Houston, TA&RP No. 29 (Cancelled). Acoustic Imaging Technology for Underwater Inspection, Gordon, Naval Ocean Systems Center, TA&RP No. 30. Technology Assessment for Offshore Pile Design, Sangrey, Carnegie-Mellon University, TA&RP No. 31. F-15 Recapture of Oil from Blowing Wells, Milgram, Massachusetts Institute of Technology, TA&RP No. 32. Vibration Monitoring of Offshore Structures, Rubin, Aerospace Corporation, TA&RP 33. NDE Round Robin, Dame, Mega Engineering, TA&RP No. 34. Powering the Cavitation-Erosion-Cleaning Nozzle, Dengle, Naval Surface Weapons Center and Daedalean Associates, TA&RP No. 35. Marine Riser Strumming Experiment, Vandiver, Massachusetts Institute of Technology, TA&RP No. 36. Structural Materials for Arctic Operations, McHenry, NBS, TA&RP No. 37. Statistical Risk Analysis for Determining BAST, Hill, Massachusetts Institute of Technology, TA&RP No. 38. Cryogenic Control of Blowing Wells, Powers, BDM, TA&RP No. 39. Mechanical Properties of Sea Ice, Cox, CRREL, TA&RP No. 40. Ultrasonic Inspection of Underwater Structural Joints, Rose, Drexel University, TA&RP No. 41. Arctic Underwater Structural Inspection, Busby, Busby Associates, TA&RP No. 42. Ice Forces Against Arctic Structures, Sackinger, University of Alaska, TA&RP No. 43. Environmental Effects of Wellhead Removal by Explosives, Hays, Woods Hole Oceanographic Institution, TA&RP No. 44. Field Study of the Dynamic Response of Single Piles and Pile Groups in Stiff Clay, O'Neill, University of Houston, TA&RP No. 45. Behavior of Piles and Pile Groups in Cohesionless Soils, Coyle, Texas A&M Research Foundation, TA&RP No. 46. Study of Method of Design of Piles in Clay Soils under Repeated Lateral Loads, Reese, University of Texas, TA&RP No. 47. A Study of Structural and Geotechnical Aspects of Tension-Leg Platforms, Hommert, Sandia Laboratories, TA&RP No. 48. Fitness-for-Service Criteria for Assessing the Significance of Fatigue Cracks in Offshore Structures, McHenry, National Bureau of Standards, TA&RP No. 49. Development and Testing of an Ice Sensor, Cox, CRREL, TA&RP No. 50. Engineering Properties of Subsea Permafrost, Chamberlain, CRREL, TA&RP No. 51. Dynamics and Reliability of Compliant Drilling and Production Piatforms, Simiu, National Bureau of Standards, TA&RP No. 52. Behavior of Concrete Offshore Structures in Cold Regions, Carino, TA&RP No. 53. Pile-Foundation Design for Ocean Structures, Albertsen, Naval Civil Engineering Laboratory, TA&RP No. 54. Fracture Analysis and Corrosion Fatigue in Pipelines, Erdogan, Lehigh University, TA&RP No. 5S. Assessment of Structural Icing, Minsk, CRREL, TA&RP No. 56. Static Lateral Load Tests on Instrumented Piles in Sand, Matlock, Earth Technology Corporation, TA&RP No. 57. Wave Forces on Ocean Structures, Oregon State University, Hudspeth, TA&RP No. 58. Foundation Stability of Jackup Platforms, Kvalstad, Det Norske Veritas, TA&RP No. 59. Tension Pile Test, Joint Industry Project, Chan, Conoco Oil, TA&RP No. 60. Superstructure Icing Data Collection and Analysis, Minsk, CRREL, TA&RP No. 61. Southern Bering Sea Production System Study, McGillivray, PMB Systems Engineering, TA&RP No. 62. Assessment Criteria for Environmental Cracking of High-Strength Tensioned Members, Crooker, Naval Research Laboratory, TA&RP No. 63. Caisson Monitoring Project, Luff, W. S. Atkins, Inc., TA&RP No. 64. De-Icing and Prevention of Ice Formation on Offshore Drilling Platforms, Jellinek, Clarkson College of Technology, TA&RP No. 65. Evaluation of Structural Concepts for Norton Sound, Sauve, Chevron Oil, TA&RP No. 66. Rig-Mooring Reliability, Dillon, EG&G Washington Analytical Services, TA&RP No. 67. F-16 Seafloor Seismic Data Study, Hommert, Sandia National Laboratories, TA&RP No. 68. Reliability of Gravel Mat Foundations for Arctic Gravity Structures, Yokel, TA&RP No. 69. Trace Elements for Detecting Cracking in Weldments, Jones, Colorado School of Mines, TA&RP No. 70. Assessment of Analysis Techniques for Compliant Structures, Shields, Naval Civil Engineering Laboratory, TA&RP No. 71. Torsional Evaluation of Stiffening Members in Marine Structures, Ostapenko, Lehigh University, TA&RP No. 72. Soil Flow on Pipelines, Dunlap, Texas A&M University, TA&RP No. 73. Drag and Oscillation of Marine Risers and Slack Cables, Griffin, Naval Research Laboratory, TA&RP No. 74. Remote Corrosion Monitoring of Offshore Pipelines, Howle, Tradco Chemical Corporation, TA&RP No. 75. Damage Mechanisms in the Placement and Repair of Pipelines in Deep Water, Bynum, Starfire Engineering, Inc., TA&RP No. 76. Ice Stress Measurements, Cox, CRREL, TA&RP No. 77. Structural Concepts for Lease Sale 87, Birdy, Brian Watt Associates, Inc., TA&RP No. 78. Offshore Pipeline Transportation Study for Lease Sale 87, Gillespie, R. J. Brown and Associates, TA&RP No. 79. Development of a New Philosophy for Effective Underwater Inspection, Negus, Underwater Engineering Group, TA&RP No. 80. Fatigue of Selected High-Strength Steels in Seawater, Hartt, Florida Atlantic University, TA&RP No. 81. Numerical Wave Force Simulation, Vandiver, Massachusetts Institute of Technology, TA&RP No. 82. Modeling of Ice-Structure Interaction, Sunder, Massachusetts Institute of Technology, TA&RP No. 83. Surface Oil Spill Containment and Cleanup, Stewart, Veritas Technical Services, Inc., TA&RP No. 84. Subsea Collection of Blowing Oil and Gas, Peebles, Brown and Root Development, Inc., TA&RP No. 85. ATOS (Antiturbidity Overflow System) Experiment, Cruickshank, USGS, TA&RP No. 86. Mechanical Properties of Saline Ice, Schulson, Dartmouth College, TA&RP No. 87. Inspectability of Tension Leg Platform Tendons, Halkyard, John E. Halkyard and Company, TA&RP No. 88. Wave Erosion of a Frozen Berm, Cox, Arctec, Inc., TA&RP No. 89. Evaluation of Short, Large-Diameter Piles for Arctic Applications, Matlock, The Earth Technology Corporation, TA&RP No. 90. Underwater Subsea Production System Inspection, Busby, Busby Associates, TA&RP No. 91. A Theoretical Investigation on the Behavior of Compliant Risers, Chryssostomidis, Massachusetts Institute of Technology, TA&RP No. 92. Site-Response, Liquefaction, and Soil-Pile Interaction Studies Involving the Centrifuge, Crouse, The Earth Technology Corporation, TA&RP No. 93. Dynamic Motion Study of a Large-Scale Compliant Platform, Shields, Naval Civil Engineering Laboratory, TA&RP No. 94. Structural Icing Study, Minsk, St. George Basin, CRREL, TA&RP No. 95. Probability Based Design Criteria for Ice Loads on Fixed Structures in the Beaufort Sea, Jordaan, Det Norske Veritas, TA&RP No. 96. Engineering Properties of Multi-Year Ridge Sea Ice, Masterson, GEOTECH, TA&RP No. 97. Punching Shear Resistance of Concrete Offshore Structures for the Arctic, Lew, National Bureau of Standards, TA&RP No. 98. Measurement of Ice Stress around a Cassion Retained Island in the Beaufort Sea, Croasdale, K. R., Croasdale and Associates, TA&RP No. 99. Feasibility of Production, Loading and Storage Systems for the North Aleutian Basin, Birdy, Brian Watt Associates, Inc., TA&RP No. 100. F-17 Residual Strength of Offshore Structures after Damage, Ostapenmko, Lehigh University, TA&RP No. 101. Analysis of Oil-Slick Combustion, Evans, Center for Fire Research, TA&RP No. 102. Ocean Wave Simulation Model, Borgman, University of Wyoming, TA&RP No. 103. Damage Evaluation by System Identification, Yang, Advanced Technology and Research, Inc., TA&RP No. 104. Chukchi Sea Transportation Cost Comparison Study, McKeehan, Intec Engineering, Inc., TA&RP No. 105. Development of Inspection and Repair Programs for Fixed Offshore Platforms, Bea, PMB Systems Engineering, Inc., TA&RP No. 106. Offshore Structural Systems Reliability, Cornell, Stanford University and Amoco Production Company, TA&RP No. 107. An Investigation of Non-Linear Behavior of Compliant Risers, Chryssostomidis, Massachusetts Institute of Technology, TA&RP No. 108. Oil Spill Response Equipment Performance Verification, Lichte, Mason, and Hanger-Silas, Mason Company, TA&RP No. 109. Response of Spray Ice Structures to Ice, St. Lawrence, Atmospheric and Oceangraphic Forces, Polar Alpine, Inc., TA&RP No. 110. Development of a Method to Evaluate the Tension Capacity of Drilled and Grouted Piles, Briaud, Texas A&M University, TA&RP No. 111. Platform Removal Experiment, Culver, National Bureau of Standards, TA&RP No. 112 (Cancelled). Open Ocean Boom Test, Meikle, Conservation and Protection, Canada, TA&RP No. 113. Field Evaluation of Oil Spill Chemicals Additives, Whittaker, Conservation and Protection, Canada, TA&RP No. 114. Hydrodynamic Effects on Design of Offshore Platforms, Bea, PMB Systems Engineering, Inc., TA&RP No. 115. Impact of Annual Ice with a Cable-Moored Platform, Ettema, University of lowa, TA&RP No. 116. Performance Evaluation Procedures for Underwater Ultrasonic Inspection Systems, Schmidt, Battelle, TA&RP No. 117. Blast Effects upon the Environment from the Removal of Platform Legs by Explosives, Connor, Naval Surface Weapons Center, TA&RP No. 118. Helicopter-Borne Laser Ignition of Oil Spills, Frish, Physical Sciences, Inc., TA&RP No. 119. Heavy Oil Behavior in the Ocean, Fingas, Environmental Emergencies Technology Division - Environment Canada, TA&RP No. 120. Waterjet Barrier Containment of Oil in the Presence of Broken Ice, Meikle, Environmental Emergencies Technology Division - Environment Canada, TA&RP No. 121. Earthquake Response of a Platform by the System Identification Technique, Yang, Advanced Technology and Research, Inc., TA&RP No. 122. Molikpac Ice Force Measurement Program, Gulf Canada Resources Limited, Townsend, TA&RP No. 123. Quality Control Test for Platform Weldment Fracture Toughness, McHenry, National Bureau of Standards, TA&RP No. 124. Seismic-Response Analysis of Offshore Pile-Supported Structures, Nogami, University of California, San Diego, TA&RP No. 125. Engine Exhaust Emission Control, Philip, A.D. Little, Inc., TA&RP No. 126. A Magneto-Optic-Based Flaw-Imaging Technique for Underwater Application, Fitzpatrick, Sigma Research, TA&RP No. 127. Response of Piles to Earthquake Ground Motion, O’Neill, University of Houston, TA&RP No. 128. Methodology for Comparison of Alternative Production Systems, Stahl, AMOCO Production Company, TA&RP No. 129. Interference/Clearance Problem of Risers in Floating Production Systems, Rajabi, Brown and Root Development, Inc., TA&RP No. 130. Erosional/Corrosional Velocity Criterion for Sizing Multi-Phase Flow Lines, Deffenbaugh, Southwest Research Institute, TA&RP No. 131. F-18 Resistance of TLP Tendon Steel to the Ripple Load Effects of Stress Corrosion Cracking, Pao, Naval Research Laboratory, TA&RP No. 132. Synthetic Fiber Mooring Lines for Deepwater Floating Production Facilities, Hervey, Omega Marine Services, TA&RP No. 133. Impact of Crushed Ice on the Ice-Structure Interaction for Arctic Platforms, Masterson, GEOTECH, TA&RP No. 134. Development of the Raprenox Process of NO, Control in Diesel Exhausts, Perry, Technor, TA&RP No. 135. Shipboard Navigational Radar as an Oil Spill Tracking Tool,Tennyson, MMS, TA&RP No. 136. NO, Control Workshop, Philp, Arthur D. Little, Inc., TA&RP No. 137. NO, Control Development Program, Philp, Arthur D. Little, Inc.,TA&RP No. 138. Operation RIGMOOR, Messenger, The Software Guild, TA&RP No. 139. F-19 APPENDIX G ARCHAEOLOGICAL ANALYSIS PREPARED BY MMS Prehistoric Resource Analysis Proposed Sale 126, Chukchi Sea Purpose In accordance with the Minerals Management Service (MMS) Handbook for Archaeological Resource Protection (#620.1-H, June 17, 1985), this archaeological analysis was prepared for offshore lease Sale 126 for the Chukchi Sea area. The analysis is intended to identify areas of possible prehistoric archaeological site potential and to aid the MMS in making recommendations to the Secretary on archaeological resource lease stipulation requirements and mitigation. The MMS archacological resources protection program is conducted under the authority of the OCS Lands Act, as amended (43 U.S.C. 1331 et seq.); the National Historic Preservation Act (NHPA), as amended (16 U.S.C. 470 et seq.); the National Environmental Policy Act (42 U.S.C. 4332 et seq.); Executive Order 11593; and the Department of the Interior, Solicitor’s Opinion M36928, November 24, 1980. Project Area Description The area of the proposed lease offering is off the north coast of Alaska in the Arctic Ocean. It is approximately bounded on the north by 73° N. latitude; on the south by 69° 10" N. latitude; on the west by 169° W. longitude; and on the east by 160° 30" W. longitude. The proposed Icase area is approximately 23.68 million acres and contains 4,319 blocks. All blocks are included in this archacological analysis. Method The method used to develop the archaeological analysis was established in the Handbook for Archaeological Resource Protection (MMS 620.1-H, August 11, 1986). The procedures outlined in Chapter 2, Section D.1-4 of the handbook are: Integration of the geophysical/geological and archaeological information is the focus of the prehistoric resource analysis. It includes a technical interpretation of existing geophysical/geological data in order to establish sea level changes and to identify relict landforms. This technical interpretation will provide the basis for evaluating the potential for prehistoric resource occurrence (habitability) within the proposed lease sale area. The process of integration begins at the broadest data-base level and proceed toward the specific. Preparation of the analysis is conducted in the following manner: G-1 (1) Review the baseline study. If the regional baseline study indicates that the entire proposed lease sale arca lies within an area of low probability for the occurrence of prehistoric resources, and no new data exist which contradict the regional baseline study findings, then no further prelease prehistoric resource analysis or postlease prehistoric resource reports will be required. (2) Review the sea-level data in the proposed lease sale area to establish the best estimate of paleo-sea level when blocks of medium or high probability occur in the proposed lease sale area. Blocks which a regional baseline study indicates are medium or high probability, but were not above sea level during times of potential human habitation (habitability), will require no further prelease prehistoric resource analysis or postlease prehistoric resource report. (3) Examine the geophysical/geological literature for information regarding forces or processes that might have destroyed potential prehistoric resources (survivability) or rendered them unrecoverable. Examples of such forces and processes are: (a) glacial scouring; (b) sea ice gouging; (c) subacrial exposure; (d) inlet migration; (c) transgressive scas; and (f) sedimentation. The block will require no further prelease prehistoric resource analysis or a postlease prehistoric resource report if the block exhibits any of these processes to an extent that it would be expected that prehistoric resources did not survive and/or are not recoverable. (4) Examine the USGS geology report, existing shallow hazards survey data, etc., for indications of significant landforms. If sufficient data exist to make a determination, those blocks that do not contain significant relict Pleistocene or Holocene landforms will require no further prelease prehistoric resource analysis or postlease prehistoric resource report. Those blocks that are not excluded from further consideration shall require a prehistoric resource report under the archacological lease stipulation or ROW permit requirements. Analysis Step 1 - Review of the Bascline Study Using the above method, the 4,319 blocks contained in this proposed action were reviewed. No comprehensive bascline study exists for the Alaska Region. Applicable baseline studies which cover portions of the study arca include: G-2 - Bering Land Bridge Cultural Resource Study (Dixon et al. 1976); - Alaska Outer Continental Shelf Cultural Resource Compendium, Technical Report #119 (Dixon et al. March 1986) These studies developed a general model which delineated areas likely to contain archaeological sites on the Outer Continental Shelf (Dixon et al., 1976). The criteria used for designating probability zones are: Areas of High Probability (1) Non-glacial river mouths and constricted marine approaches to these river mouths. Such areas would have concentrated anadromous fish and their predators. (2) Natural terrestrial conditions, such as passes, which funnel large mammal movements. (3) Prominent spits, points, rocky capes, headlands, and islands that may have provided habitats for seals and marine birds. Such habitat is only considered high probability of it occurs in conjunction with one or more additional habitat types or if there is a natural constriction which would tend to concentrate these species. (4) Areas of possibly enhanced marine coastal habitat diversity and availability. Areas of Medium Probability (1) Lake margins. Although the presence of fish and waterfowl resources enhances these areas as settlement locales, they are less likely to be as productive (and less likely to foster winter settlements) as those listed above. (2) North- and south-facing slopes. Guthrie (in Dixon et al., 1976) indicated that south-facing slopes tend to concentrate grazing mammals during early spring plant maturation and that many times north-facing slopes provide wind-blown, snow free winter ranges. However, neither of these habitat types concentrate grazers into specific locations where large aggregates of animals can be harvested. Although these areas are generally more productive, the mammals are scattered over a comparatively large area. Areas of Low Probability (1) Any habitat type not listed above. These previous designations of "hisk,” "medium," and "low" probability for prehistoric resource occurrence are based on paleogeo#--_* -. reconstructions using only extensions of terrestrial landforms and bathymetric data a _.. al, 1986), not on seismic data which are necessary to delineate buried features. It is the buried G-3 features that are protected from the effects of many destructive marine processes, and which, therefore, have the greatest potential for preserved archaeological sites. Recently, confusion had arisen about use of the term "high probability" to designate archacological resource potential. The utility of "high," "medium," and "low' designations has also been questioned in the past. Since the decision to be made is whether to invoke the archaeological stipulation or not invoke the stipulation, it may be more useful to refer to areas as either "having potential" for archaeological resources or "not having potential" for resources. While data exist which document the close association between the campsites of recent native populations and stream channels, the question exists as to whether this association could be projected back through time and used as a predictive model for site occurrence. A study from Banks Island in the Canadian Northwest Territory (Good and Bryant, 1985) suggests that during the last glacial epoch, large relict fluvial channels may have been infilled with acolian sands, and that only small braided streams flowed intermittently through the valley-fill deposits. If this was the case for formerly exposed areas of the Alaskan shelf as well, it could be argued that archacological sites, rather than concentrating along the outer banks of stream channels, would occur within the sometimes broad areas of channel fill. However, regardless of the potential for occurrence of preserved archaeological sites, if specific features, such as braided stream channels, cannot be delineated within the larger areas of channel fill material, there would be no further mitigation required for potential archaeological sites within the fill areas. In such instances only the immediate vicinity (100 to 150 meters) of the channel banks would have potential for the discovery of archacological sites, and then only if the channel banks appear to be well preserved. These are the areas that would require further mitigation. One core collected by USGS in the southeastern Chukchi Sea showed a sequence indicative of the Banks Island-type acolian filled relict valley with braided stream deposits. While this provides some evidence that the Banks Island data may be applicable to the Chukchi Sea, the potential braided stream deposit in the USGS core was less than 0.3 meters thick and would be undetectable with seismic instruments. In such a case, although the channel fill deposits would be seen on the seismic data, the specific braided stream deposit would not, and no avoidance of the general fill material would be required. Step 2 - Review of Sca Level Curves to Determine Habitability Published sca level curves for the Alaska Region indicate that sea level was 90 to 100 meters below present during the late Wisconsinan glacial maximum 18,000 to 20,000 years ago. Although the entire Chukchi Sea continental shelf would have been dry land at the glacial maximum, present evidence for the presence of man in the area dates to only about 12,000 B.P. Sca level curves vary considerably in the estimated position of sea level at 12,000 B.P. The curve by Morner (1969) indicates that eustatic sea level may have been as much as 65 meters below present at 12,000 B.P. A G-4 eustatic curve by Godwin, et al. (1958) indicates that sea level was approximately 55 meters below present at 12,000 B.P. A composite curve of sea level indicators from relatively stable areas (such as the Chukchi Sea is believed to be) shows a wide scatter of data points prior to about 7000 B.P., but shows sea level to be on an average about 45 meters below present at 12,000 B.P. (Shepard and Curray, 1967). Finally, a curve derived from indicators in the Kotzebue Sound area, south of the Chukchi Sea Planning Area shows sea level to have been between 32 and 30 meters below present at 12,000 B.P. (McManus, et. al, 1983) South of the Chukchi Sea Planning Area, sea level data points should become shallower as the influence of isostatic rebound following removal of the late Wisconsinan glacial ice mass caused formerly submerged areas to be uplifted. Therefore, an organic sample giving a date of 12,000 B.P. presently found at -30 meters elevation would have originally been at a lower elevation. For this reason, the McManus, et. al., curve is probably somewhat shallow when being applied to a more stable area such as the Chukchi Sea Planning Area, which is thought to have been relatively unaffected by isostatic rebound. As more specific sca level data become available from the Chukchi Sea Planning Area, more accurate determinations of the extent of shelf exposed at 12,000 B.P. may be made. In the interim, it is recommended that a very conservative figure of -40 meters be used as an estimate for the 12,000 B.P. shoreline in the Chukchi Sea Planning Area. Step 3 - Review of the Geological/Geophysical Data to Determine Survivabilit For the Chukchi Sea Planning Area, potentially destructive processes include ice gouging, thermokarst erosion, thermal abrasion, winter storms which rework bottom sediments, and marine transgression. Of these factors which may have caused destruction of archaeological sites in the Chukchi Sea Planning Area, only the process of ice gouging has been documented and mapped (Lewbel, 1984). Though other processes are presumed to have occurred, we are not aware of data sufficient to map the areas affected by these processes. Until more data are available, and these processes clearly documented, they cannot be generically invoked as having destroyed all archaeological sites within the planning area. Phillips of the USGS previously mapped various intensities of ice gouging within the southeastern portion of the Chukchi Sea Planning Area (Lewbel, 1984). Phillip’s area of "High Ice-Gouge Intensity" is an area where recent ice gouging can be documented and is of an intensity that archacological sites occurring within the area may have been completely reworked. This depends on the depth of the ice gouging in relation to the thickness of Holocene sediments which would overlie and protect archacological sites along the late Pleistocene surface from the destructive effects of ice gouging. Data on relict shelf processes which would have affected the survival of archaeological sites progressively throughout the Holocene marine transgression are almost entirely absent. Some evidence of buried and infilled gouges has been observed in the seismic data collected in the Chukchi Sea. G-5 Step 4 - Review to Identify Significant Landforms Landforms are a useful indicator of areas where archaeological sites are likely to concentrate. This is because many landforms are areas where natural resources such as fresh water, and plant and animal resources, necessary for human survival, concentrate. Most archaeological sites cannot be directly detected through remote sensing data; however, the presence of a site can be confirmed through coring of a potential site area (landform). The MMS Handbook states that "If sufficient data exist to make a determination, those blocks that do not contain significant relict Pleistocene or Holocene landforms will require no further prelease prehistoric resource analysis or postlease prehistoric resource report." In the absence of sufficient data, which is almost always the case prior to the postlease site-specific geohazards survey, blocks cannot be eliminated from the archacological report requirement based on the lack of known landforms. Five general areas have been previously identified as possessing landforms with a high or medium probability of archaeological site occurrence. These areas include: 1. A seafloor depression east of Herald Shoal; 2. Various Chukchi Sea nearshore bathymetric depressions; 3. Areas lying offshore of Icy Cape and Point Hope; 4. The Barrow Sea Valley (outside of the sale area); and 5. The buried northwestern delta complex north of Herald Shoal. In addition to these large landforms, all areas of the Chukchi Shelf were subaerially exposed shallower than 30-32 meters at 12,000-11,800 B.P. and could contain preserved landforms (Bloom, 1983; Dixon et al., 1986; McManus et al., 1983). Sea-Floor Depression East of Herald Shoal The large, elongate, closed depression east of Herald Shoal (see Figures 5 and 6) has been proposed by Dixon as an area of high archaeological site potential. This depression can be extrapolated from bathymetry maps as a probable lake or estuary at some time before submergence, which occurred before 15,100 years ago according to the sea level rise curve of McManus et al.or much more rapidly at 12,500 years ago according to Morner’s curve (see Figures 1 and 2). Sea-floor sediments within the depression consist of sand and mud (Figure 3). Phillips reported 3 to 4 meters of sediments above folded bedrock at the site (Figure 4). Sediments within the northern part of the depression (as shown on Figure 4) are associated with the deltaic complex northwest of Herald Shoal. G-6 Nearshore Bathymetric Depressions Several other sites have been proposed by Dixon as paleolakes (see Figures 5 and 6) since today they form closed bathymetric depressions. Five such depressions were located partially or completely within the sale area. These depressions do not have significant topographic relief. The majority of them lie within sand wave fields with closures formed by the sand waves. The sand waves are Holocene features so these areas might not have been depressions during the Pleistocene. Significantly, none of these depressions appear on later, more accurate, bathymetric maps (Hill et al.). These features are probably not paleolakes. One depression, east of Cape Lisburne, was identified by later mapping. Holocene sediments appeared to form closures in this case also. Offshore Icy Cape and Point Hope Dixon has reported (Dixon to Miller, personal communication) that archaeological sites at Point Hope and Icy Cape extend virtually to the water’s edge. He feels that these areas served as "lookouts" to observe the passage of game. A series of bathymetric rises extend offshore northwest from Icy Cape. Barrow Sea Valley The southern head of Barrow Sea Valley reaches but does not impinge on the northeast portion of the sale area. This valley would have been a major region of constricting topographic relief during its subacrial exposure. Phillips reports sand waves and more than 6 meters of sediments cover the site. In this arca terrestrial Pleistocene sediments may exist on the sea floor. The down-cutting of modern channels in the sca valley has exposed Quaternary sediments and some of these may be terrestrial Pleistocene deposits. Northwestern Delta The buried northwestern delta complex identified by Phillips, et al. could be an area of high archaeological site potential. The major Late Pleistocene drainage patterns were along the ancient Chukchi Valley to the south and along the Barrow Sea Valley to the north. The location of paleochannels is poorly known at present and their individual ages may vary greatly. The large number of channels suggests that they may have been the principle agent of erosion and sedimentation on the Chukchi Plain. These channels may contain terrestrial sediments within the fluvial sequences. Summary This analysis concludes that: (1) the various Chukchi Sea nearshore bathymetric depressions do not constitute areas with a significant probability of archaeological site occurrence; and (2) no tracts within either the areas offshore Icy Cape or the Barrow Sea Valley are within the Chukchi Sea Sale 126 area. No specific G-7 tracts containing buried channels were identified from available data. Such channels are potentially present on most tracts and could be identified by the shallow hazard surveys conducted prior to drilling. Step 5 - Prehistoric Site Potential Summary and Recommendations The 40-meter bathymetric contour provides a rough approximation of where the shoreline would have been in the Chukchi Sea Planning Area at 12,000 B.P., the date at which the evidence for prehistoric man in the Americas is indisputable. More detailed sea level data from the Chukchi Sea may eventually revise this estimate downward to the 45 or 55 meter bathymetric contour, which is more in line with data on eustatic sea level change from other tectonically stable areas of the world. All blocks in the Chukchi Sea planning area shallower than 40 meters water depth would have been exposed as dry land at 12,000 B.P. Along this portion of the now-submerged shelf, relict terrestrial landforms provide indicators of areas where there is a higher potential for archaeological sites to occur. Prior to the collection of postlease marine geohazards data, insufficient data exist to determine whether landforms which may contain archacological site deposits are present. Erosional processes such as ice gouging, thermokarst erosion, thermal abrasion, winter storms, and marine transgression may scatter and destroy archaeological deposits. When sufficient data are available to map the occurrence and extent of these processes, they can be used to eliminate areas from further archaeological consideration. However, until specific data on the effect of these processes are available, only severe ice gouging is sufficiently documented to allow specific lease tracts to be eliminated from further archaeological consideration. Arcas mapped by USGS where ice gouging is intense, and extends into the sediments to a depth greater than the thickness of Holocene sediments, can be eliminated from further archacological requirements. Figure 7 shows the lease blocks within the Chukchi Sea Planning Area which fall within the 40-meter bathymetric contour and on which the lease stipulation requirement for an archaeological report should be invoked. Those tracts which fall within the area of intense ice gouging as mapped by USGS (Lewbel, 1984) are also shown. These tracts, although they fall within the 40-meter bathymetric contour, would be excluded from the archacological report requirement due to a low potential for site survivability. The blocks on which the archaeological resources stipulation are to be invoked are: OPD Blocks NR 2-4 52-55, 96-100, 140-144, 184-187, 228-231, 272-277, 316-321, 360-365, 404-409, 448-453, 492- 496, 536-540, 580-583, 624-628, 668-671, 712-715, 756-758, 800-802, 844-846, 889-891, 933- 934, 977-978 NR 2-6 17-18, 61-62 NR 3-1 287, 328, 331, 371-372, 418-419, 459-460, 462-463, 503-504, 593-595, 637-639, 681-683, 725- 727, 769-770, 947, 990-991 NR 3-2 NR 3-3 NR 3-4 NR 3-5 NR 3-6 NR 4-3 NS 3-7 NS 3-8 14-15, 58-60, 139-140, 181-184, 221-227, 265-270, 309-313, 353-356, 397, 573, 661, 726-727, 768-771, 811-815, 837-838, 855-857, 881-882, 899-900, 925-926, 928-929, 940-941, 969-973, 983-985 23-24, 67-68, 112, 156, 193-194, 200, 234-238, 244, 277-281, 320-324, 367-368, 947-948, 989- 992 1-5, 14-17, 45-49, 57-62, 89-93, 100-106, 110-111, 133-137, 144-151, 153-155, 177-181, 188- 189, 193-195, 197-199, 221-224, 231-244, 266-267, 271-284, 314-328, 361-372, 404, 407-416, 447-448, 450-455, 493-499, 537-543, 580-587, 623-631, 666-675, 709-718, 752-761, 795-803, 838-846, 881-889, 925-932, 939, 969-975, 982-983 22-26, 65-70, 108-114, 153-158, 195-202, 238-246, 282-290, 326-333, 370-377, 413-420, 456- 463, 500-506, 543-549, 586-593, 630-636 1-6, 13-15, 45-49, 56-59, 89-92, 99-103, 133-135, 142-145, 177-178, 185-188, 221, 228-232, 272- 275, 315-319, 359-362, 402-406, 445-449, 488-493, 531-537, 575-581, 618-625 47-48, 52-53, 90-97, 134-140, 178-184, 221-228 710, 813-814, 855-858, 899-902, 942-946, 986-990 460-461, 500-506, 541-550, 573-594, 618-638, 662-674, 706-715, 749-757, 793, 795-801, 837, 840-846, 881, 888-891, 925, 934-937, 969-970, 979-981 Lessees will be notified, immediately following the lease sale, of the requirements for archaeological reports for those leases which contain blocks on which the archaeological stipulation will be invoked. Analysis of the geohazards survey data collected on these tracts will provide valuable additional data to address unresolved geologic questions pertinent to archaeological resource potential discussed above. These questions include: 1) what evidence is there for the extent and severity of ice gouging in the Chukchi Sea, and is there seismic evidence of relict infilled gouges at and buried beneath the sea floor; 2) do high frequency seismic signals penetrate areas of sea floor gravels; and 3) do the seismic data provide evidence of the nature of relict fluvial systems on the Chukchi Sea shelf (i.e. is the fill primarily alluvium, or aeolian with braided stream deposits?) By analyzing the geohazards data with such questions in mind, the geohazards data can be used in future MMS Prehistoric Resource Analyses to further refine the area within which there is potential for archaeological sites to occur. G-9 YEARS B.P. 11,000 412,000 13,000 14,000 415,000 — 16,000 = 17,000 25 30m @ 12,000 B.P. \A (OPENING OF SHPANPERG ST) (-32m @ 12,000 B.P.) 30 35 40 NN _ (1-1377) pOw_ \\ E a, OCREAGER and McMANUS (1965) x= 45 a - 4 "Sh, (-46m @ 14,400 B.P.) wi SWS o ‘ (- 48m @ 14,600 BR) : Xe 50 (1-4080) D-S. \ 26a (-52m @ 15,500 B.R) 55, | x Tas ea L777 ---/-86e son L.°* (1- 4090) one a 60 N (1-3754) 65 Estimated sea level curve for the Chukchi Sea (16,500 to 12,000 B.P.). Lines of short dashes connect sample data in cores 26 (A and B), 39, and 68 (for locations see Fig. 1) and the core described by Creager and McManus (1965). Circles represent dates and depths below present sea level of samples in these cores, X represents an apparently unreliable date, The types of data used in estimating sea level positions (L, N, D, P, and the triangle) are described in the text, Cores 26A and B are replicate cores at station 26. Laboratory C-14 numbers are as follows: P = I-1377; D = I-4080; L = I-4090; N = I-3754. FIGURE 1, LATE PLEISTOCENE SEA LEVEL RISE (McManus, et al., op. cit., p. 372) G-10 —n fustatic curve (two metric sca/es) —2 5 — 30 —+40 - — 50 ‘— —6O Bea) - —70m .--"" al <C'* age in thousand years BC _ - #3 nt wt 70 9 6 7 6 5 + 3 2 ? ° 7 a= us A —L. LL 4 4 4 4 7: —L 4 4 et ————1 4. A Glacial Late Glacial [ Postgtiacial Wirm Glacial Age Flandrian Interglacial Age Te Wal Te lle ~T Te T Ile lite T Tits We Eorty (i, Middte (iI) | Late (iii) Pleistocene Epoch Holocene Epoch Eustatic curve for the last 17,000 years. The younger part is enlarged in order to show the fluctuations. The subdivision of tht Late Quaternary (three different systems) here proposed is shown below the eustatic curve. FIGURE 2. LATE PLEISTOCENE SEA LEVEL RISE (Morner, op. cit., p. 396) G-11 170° 168° 168 164 162 16h isk Arctic Ocean 18@° 74 a 72 7 70h ' ' 1 Lease sale area ----- 1 Tsobaths in meters ' J ' ¢ 6 ' 6 1 ; Mud CT] ! Q 100 kilometers ee = s — 68 17d 168 166° 16: 162 160 158 156 Distribution of surficial sediments within the Chukchi Sea. from Shumway and Beagles, 1959, Creager and McManus, 1967, Barnes, 1972, Grantz and others, 1982, and Phillips and others, 1982. AREA OF HIGH ARCHAEOLOGICAL SITE POTENTIAL FIGURE 3. SURFICIAL SEDIMENTS IN THE CHUKCHI SEA WITH BATHYMETRIC CONTOURS IN METERS (Phillips, internal memo, MMS) G-12 wre 70* 3 ii if it “3 f 2 SEDIMENT THICKNESS ABOVE FOLDED ¥ fa cade / ; BEDROCK LISBURNE —< . * Contours in meters 0 © 2% 40 60 8% 0m wo © 20 Ham oe teseements ot FOF mete (atte! NOAA Cae 4009 Bese te te 68° wivor 168" 166" 164° 12° 160" 158° 196° AREA OF HIGH ARCHAEOLOGICAL SITE POTENTIAL FIGURE 4, ISOPACH MAP OF SEDIMENT OVERLYING BEDROCK IN THE NORTHEAST CHUKCHI SEA, MULTIPLE CHANNELS, CUTTING DOWN TO AT LEAST 64 m BELOW THE SEAFLOOR, ARE FOUND IN THE NORTHWEST PART OF THE CHUKCHI SEA (Phillips, 1982) G-13 Icy Cape “4 7) ARCTIC OCEAN ot °° oe = at Chukchi/arctic coast, Standstill IT, 16,000 B.P. Compiled by G.D. Sharma from National Ocean Survey charts 1215 w-10, 171]N-17B, 1711N-18M, 1714-118, 1714-128, 1614-108 and unpublished datg of the University of Washington. Upwelling f i! Hh Ecotone Chukchi/Arctic coast, Stillstand II, 16,000 B.P. River iHouths and Nearshore { ] Riverine/Tundca-Stcppe [a] Constricting topoyraphy concen- trating large mammul movement Freshwater Lake/Tundra-Steppe Ecotone Compiled by G.D. Sharma from National Ocean Survey charts 1215N-10, 1711N-17B, 1711N-18M, 1714-118, 1714N-12B, 1814-10B and unpublished data of the University of Washington. FIGURE 5. NORTHERN BERINGIA, BATHYMETRY (m), PALEOLAKES, AND PALEORIVERS AT GLACIAL MAXIMUM (Dixon, op. cit., p. 111-53) G-14 ARCTIC OCEAN Pt. Barrow 7s, , ‘ - : ome “Pt. Franklin ' i ‘ ' ' ! ! ! ! i : 1 7 1 : ! ! SCape Lisburne Pt.Hopee §=ALASKA a eo SCWARO PENINSULA Tess J__o___ rahe Chukchi/Arctic coast, Standstill I, 22,000 8.P. Compiled by G.D. Sharma from National Ocean Survey charts 1215 N-10, 1711N-178, 1711N-10M, 1714-11B, 1714-12B, 1614-10B and unpublished data of the University of Washington. River Mouths and Neacshore (- Constricting topography concen trating large marnal movement Upwelling il Riverine/Tundra-Steppe a Freshwater Lake/Tundra-Steppe ll] Eeotone WE] Rcotone Chukchi/Arctic coast, Stillstand I, 22,000 B.P. Compiled by G.D. Sharma from National Ocean Survey charts 1215 N-10, 1711N-17B, 1711N-18M, 1714-11B, 1714N-12B, 1814-10B and unpublished data of the University of Washington. FIGURE 6. NORTHERN BERINGIA, BATHYMETRY (m), PALEOLAKES, AND PALEORIVERS AT GLACIAL MAXIMUM (Dixon, op. cit., p. 111-52) G-15 '6r_v66 1s cay CHUKCHI SEA SALE 126 ZS Point Sarrow Chukchi Sea 70 LEGEND [[) proposed SALE 126 AREA AREA OF HIGH ICE-GOUGE INTENSITY 6s oat Cape Lisburne~ 6a Q 50 Statute Miles Q 50 Kilometers Bathymetry in Meters ne eee Nautical Miles = Source: USDOI, MMS, Alaska OCS Region, 1990. Figure 7. Area of High Ice — Gouge Intensity in the Southeastern Chukchi Sea G-16 REFERENCES Bloom, A.L. 1983. "Sea level and coastal morphology of the United States through the Late Wisconsinan glacial maximum" in Late-Quaternary environments of the United States. H.E Wright, Jr. (ed), vol. 1, The Late Pleistocene, S.C. Porter, (ed.). Minneapolis, Minnesota. Dixon, E.J., G.D. Sharma, S.W. Stoker, and R.D. Guthrie. 1976. Berin, nd Brid. Itural Ri Study. Fairbanks, AK: University of Alaska Museum. Prepared for Bureau of Land Management, Outer Continental Shelf Office. Dixon, E.J., S.W. Stoker, and G.D. Sharma. 1986. Alaska Outer Continental Shelf Cultural Resource Compendium, Technical Report #119. Fairbanks, AK: University of Alaska Musem. Prepared for the MInerals Management Service. Godwin, H., R.P. Suggate, and E.H. Willis. 1958. "Radiocarbon Dating of the Eustatic Rise in Ocean Level" in Nature, Vol. 181, p. 1518-1519. Good, T.R. and I.D. Bryant. 1985. Fluvio-Aeolian Sedimentation -An Example from Banks Island, N.W.T., Canada: Geografiska Annaler, Series A, Physical Geography, Vol. 67A, No. 1-2, p.33-46. Grantz, A., T.A. Dinter, E.R. Hill, RE. Hunter, $.D. May, R.H.McMullen, and R.L. Phillips. 1982. Geologic Framework, Hydrocarbon Potential, and Environmental Conditions for Exploration and Development of Proposed Oil and Gas Lease Sale 85 in the Central and Northern Chukchi Sea. U.S.G.S. Open File Report 82-1053. Hill, E.R., A. Grantz, S.D. May, and M. Smith, 1984. "Bathymetric Map of Chukchi Sea", Miscellaneous Investigation Series, Map 1-1182-0. Lewbel, G.S., ct al., 1984. "Environmental Hazards to Petroleum Industry Development" in The Barrow Arch Environment and Possible Consequences of Planned Offshore Oil and Gas Development, J.C. Truett, (ed.), Proceedings of a Synthesis Meeting. Girdwood, AK. McManus, D.A., J.S. Creager, R.J. Echols, and M.L. Holmes. 1983. "The Holocene Transgression on the Arctic Flank of Beringia: Chukchi Valley to Chukchi Estuary to Chukchi Sea" in Quaternary Coastlines and Marine Archeology: Towards the Prehistory of Land Bridges and Continental Shelves, P.M. Masters and N.C. Flemming, (eds.). London: Academic Press. Mincrals Management Service (MMS), 1990. Memorandum from Deputy Director to Regional Director, Alaska Region, subject: Recommendations from Archaeological Resource Protection Workshop, dated September 27, 1990. Morner, N.A.. 1969. "Eustatic and Climatic Changes During the Last 15,000 Years", Geologie et Munjbouw, v.48 (4), pp. 389-399. Pearson, C.E. et al. 1986. Archaeological Investigations on the Outer Continental Shelf: A Study Within the Sabine River Valley, Offshore Louisiana and Texas. Reston, VA: Minerals Management Service. OCS Study MMS 86-0119. Phillips, R.L. 1982. "Summary of Geology, Processes, and Potential Geohazards in Northwestern Chukchi Sea" in Chukchi Sea Synthesis -Information Update, MMS-86-0097. Phillips, R.L.. 1983. Chukchi Sea Surficial Geology and Processes. Report prepared for the Minerals Managememt Service. Palo Alto, CA.: U.S. Geological Survey. Shepard, F.P. and J.R. Curray. 1967. "Carbon-14 Determinations of Sea Level Changes in Stable Areas” in Progress in Oceanography, Vol. 4, p.283-291. G-17 Shipwreck Update Analysis Proposed Sale 126, Chukchi Sea In accordance with the MMS Handbook for Archaeological Resource Protection (621. 1-H), the following report was prepared per discussions at the MMS Archaeological Workshop in Anchorage, Alaska, on July 16- 18, 1990, and Melanie J. Stright’s "Reassessment of Shipwreck Potential and Archaeological Survey Recommendations for Sale 109 Leases, Chukchi Sea, Alaska," 1989. As stated in the MMS handbook, the purpose of the shipwreck update is to provide an assessment of the potential for locating historic resources in a proposed lease-sale area. A regional baseline study or equivalent data were used in the preparation of this document. All new data that may serve to update the regional baseline study are also incorporated in this report. Known Shipwrecks within the Sale Area The majority of known shipwrecks within the Chukchi Sea are documented losses of the nineteenth-century arctic whaling fleet (see Tables 1-4). Information that was reviewed to determine the locations of known shipwrecks within the sale area includes the MMS report, "Shipwrecks of the Alaskan Shelf and Shore," (Tornfelt, In Press); "Steam Whaling in the Western Arctic" (Bockstoce, 1977); and "Whales, Ice, and Men: the History of Whaling in the Western Arctic" (Bockstoce, 1986) (Bockstoce is considered by most to be the world authority on whaling in the Arctic). Using these sources, shipwreck locations in the sale area were remapped on a base map showing the OCS lease-block grid and bathymetry at a 1:1,000,000 scale. There are 46 shipwrecks in the Chukchi Sea Planning Area. The location of the two shipwrecks (Table 1) in the proposed Sale 126 area is uncertain and cannot be assigned to blocks. Table 1. Shipwrecks That Cannot Be Assigned to Blocks. Henry Kneeland Ontario The probability that these shipwrecks may have survived ice gouging, if they are located within the 30-m isobath, is low. If located beyond the 30-m isobath, ice-gouging frequencies gradually decrease and shipwreck destruction is more speculative (see Reassessment of Shipwreck Potential and Archaeological Survey Requirements for Sale 109 Leases, Chukchi Sea, Alaska, prepared by MMS, and "Summary of Geomorphological Processes Pertaining to Survivability of Archaeological Resources in the Chukchi Sea Sale 109 Area"). The location of 23 shipwrecks (Table 2) is more precise. G-18 Table 2. Shipwrecks That Can Be Assigned to Blocks. Bowhead James D. Thompson Carlotta Jessie H. Freeman Caulaincourt John Howland Champion John Wells Concordia Navy Contest Oliver Crocker Elizabeth Swift Paiea Eugenia Seneca Gay Head Thomas Pope George Victoria II George Howland Gratitude Henry Taber The blocks where thesc shipwrecks are likely to be located are shown in Table 3. Table 3. Blocks That Have Shipwreck Potential. OPD Block NR 3-4 596, 639-640. NR 3-5 1027-1028. NR 3-7 15-17, 59-61, 103-104, 147, 148, 528-533, 538-540, 582-584, 626-627. NR 4-3 23, 24, 65-68, 107-110, 111, 150-152, 193-195, 236-238, 279-281, 322-324, 366-367, 410, 573-576, 617, 619, 620. NR 4-4 1-4, 45, 47, 48, 92. No ship in the above blocks can be assigned to a particular block since locational data is not that precise for these ships. There are enough ships in the blocks listed in Table 3 that may have survived that invoking the stipulation for these blocks is a prudent action to protect them.There are 25 other ships shown in Table 4 that are all believed to be in State waters and therefore are not within OCS jurisdiction (see Solicitor’s Opinion on Onshore Facilities, Memorandum MMS.ER.0227, received August 17, 1987). G-19 Table 4. Shipwrecks That Are in State Waters or Onshore Near the Lease-Sale Area. Awashonks Julian Comet Kohola Cyane Lettie Eagle Mabel Emily Schroeder Mary Emily Morgan Monticello Fanny Ohio Florida Orca George and Susan Reindeer Hae Hawaii Roman Helcn Johnston Thomas Dickason Hidalgo Victoria William Rotch Possible Locations of Unreported Shipwrecks within the Sale Area The most prevalent cause of shipwrecks within the sale area was shipwrecks being caught and crushed by pack ice. As the ships often followed nearshore leads through the pack, they were most often crushed or ran aground when shifting winds caused the pack ice to begin moving shoreward. Once trapped in the ice, strong ocean currents either moved the ships around Point Barrow into the Beaufort Sea or carried them northwestward from Point Barrow into the Arctic. Nincteenth-century whaling fleets sailed narrow leads up the coast of Alaska from Icy Cape and made their way to Point Barrow by late July or August. Later, particularly after the advent of steam-powered ships, they began making their way into the Beaufort Sea following a route between the coast and the pack ice to the north, In later years, whaling ships began wintering at Hershel Island in the eastern Beaufort. On leaving the Beaufort Sea at the end of the summer season, many of the ships headed westward from Point Barrow, following the southern edge of the pack ice to Herald Island, the autumn feeding grounds of the bowhead whale. There are only a few reports of ships being wrecked along this western route through the Chukchi Sea. The Henry Kneeland was abandoned somewhere in the Chukchi Sea in 1864, as was the Ontario in 1866. The Mount Wollaston and the Vigilant were caught in the ice and lost in the vicinity of Herald Island in 1879 (Herald Island lies well west of the sale area). The Helen Mar was crushed by ice in 1892 in Russian waters between 71° and 72° N. latitude and just across the U.S./U.S.S.R. border (169° W. long.). G-20 The distribution of known shipwrecks in the sale area indicates that most of the ships were trapped by ice or ran aground within very shallow coastal waters. This observed distribution is due to the fact that ships were generally forced to sail within narrow strips of open water between the pack ice and shore because of the numerous capes and shoals off the coast. Therefore, most unreported shipwrecks within the sale area probably occur close to shore in shallow water. Preservation Potential of Shipwrecks within the Sale Area The first consideration in the preservation of shipwrecks in the sale area is the human factor. According to accounts reported in Bockstoce (1986), many ships were extensively salvaged after wrecking. Following the whaling-fleet disaster of 1871, commercial salvagers organized expeditions to the Arctic to remove whatever was of value from the 31 wrecked ships. There are also several accounts of ships having been condemned due to damage from ice, then being towed to shore and auctioned off to raise money for the owners. These salvage actions had the effect of diminishing the apparent shipwreck resource from what otherwise might be expected, These actions have been taken into consideration in Tables 1 through 4. Geologic and oceanographic factors that may contribute to the preservation or destruction of shipwreck remains in the Chukchi and Beaufort Seas include bottom-sediment type and thickness, water depth, strong currents, and ice-gouge intensity. As the effects of these physical processes on the remains of sunken vessels in the Chukchi and Beaufort Seas have not been directly observed, the following discussion is hypothetical. Generally, the thicker- and finer-grained bottom sediments are, the more likely that shipwreck remains will be buried and preserved. Sediments in the Chukchi Sea range in thickness from less than 1 m to approximately 12 m, although unconsolidated sediments range only from 1 m to approximately 4.5 m. The thickest sediment cover is found off Cape Lisburne, Icy Cape, and Point Franklin (Phillips, 1986). While the average thickness of sediments in the Chukchi Sea is relatively thin, the thickest accumulations of sediments are around capes and shoals where shipwrecks are known to concentrate. This would be a positive factor for shipwreck preservation. According to Phillips and Reiss (1984) and Phillips (1986), lag gravels occur at the seafloor just outside the barrier islands between Icy Cape and Wainwright inlet and in a small patch along the coast just north of Peard Bay. Another large gravel deposit, termed the Outer Gravel Facies, lies farther offshore but comes to within a few miles of the coast between Point Belcher and Point Franklin. These coarse-grained gravels probably would not provide as good an environment for shipwreck preservation as would the finer-grained muds and sands outside the gravel deposits. Ice gouging on the Chukchi Sea shelf is most intense along topographic highs and nearshore slopes, the same areas where shipwrecks tend to concentrate. This is a negative factor for shipwreck preservation. Outside the areas of intense ice gouging, gouges are sparse and gouge depths are shallow (maximum depth of 1.3 m with an average depth of 0.3 m or less [Phillips, 1986]). Ice-gouge intensity decreases rapidly with increasing water depth and is most prevalent in water depths of less than 30 m. G-21 The Alaskan Coastal Current may rework seafloor sediments out to a distance of 70 km from shore in the eastern Chukchi Sea (Phillips, 1986). However, it is storm-generated currents that have the greater effect on bottom sediments, reworking even the seafloor gravel deposits. The periodicity of these storms is unknown. In summary, the coarse-grained gravels present at the seafloor along much of the coast of the eastern Chukchi Sea, the Alaskan Coastal Current and storm-generated currents that rework the seafloor sediments out to a distance of possibly 70 km offshore, and the intensive ice gouging that occurs in water depths of 30 m or less and concentrates on shoals and nearshore slopes, all are factors that act negatively on the preservation of shipwreck remains in the Chukchi Sea. Areas having the highest preservation potential are those areas that have the thickest accumulations of unconsolidated muds and sands. It is not known to what extent these factors have affected potential shipwreck resources in Table 3. No ships listed in Table 3 fall within the area of intensive ice gouging (Figure 7, Prehistoric Resource Analysis). Effectiveness of Remote-Sensing-Survey Instruments In arcas having only a thin sequence of unconsolidated sediments at the seafloor, the sidescan sonar should detect evidence of any shipwrecks present within a survey area. Although it was reported by Claussen and Arnold (1975) that the shipwrecks discovered at Padre Island, Texas, were completely buried in only 1.5 m of unconsolidated sediments, these ships were about 300 years older (dating from 1554) and were much smaller than the ships expected to be found in the Chukchi Sea. At 300-m linespacing, the sidescan sonar, operating at a per-channel range of 200 m, has an overlap of 100 m between survey lines and resolves objects on the order of 1 m in size. This should be sufficient to detect any historic-shipwreck remains protruding above the seafloor. Where surficial unconsolidated sediments are thick enough to have completely buried historic-shipwreck remains, the magnetometer is the primary instrument for shipwreck detection. The survey linespacing required to completely search an area depends on the amount of ferrous material associated with a shipwreck. Closer linespacing would be required to locate a wooden sailing ship having only ferrous fastenings and fittings than would be required to locate a steam whaler with iron pots in the tryworks, and with iron boiler and smokestack. For example, 1 ton of iron would cause a magnetic anomaly of only 5 gammas al a distance of 24 m from the magnetometer sensor (Breiner, 1973). This anomaly intensity is barely above the background-noise level under ideal conditions. At high northern latitudes such as the Chukchi Sea, increased interference from magnetic storms makes detection of such small intensity anomalies problematic. Although permanent magnetic base stations, such as the one operated by the USGS at Point Barrow, Alaska, can provide continuous data on magnetic storm conditions, correlating the data from these base stations to a specific survey data set in order to mathematically factor out noise would be extremely difficult because the two data sets would have to be precisely time-correlated. Of more utility might be the use of a gradiometer that involves towing two magnetometer sensors in a fixed horizontal or vertical configuration. Such a system allows two sets of magnetometer data to be collected simultaneously. The G-22 differences between the two data sets then provide real information on magnetic anomalies within the survey arca. The subbottom profiler is of very limited utility in the detection of shipwrecks because it collects only a single line of acoustic information directly under the survey vessel. It would be possible to see evidence of a shipwreck on the subbottom profiler data only if the survey vessel passed directly over the wreck. As a shipwreck may represent a relatively hard object within the seafloor sediments, it might produce a parabolic diffraction on the profiler data similar to those seen when passing over a pipeline or shell bed (Stright, 1990). In summary, the sidescan sonar is the most practical instrument for shipwreck detection when bottom conditions are such that shipwreck remains would be visible at the seafloor which is most likely the case for the Chukchi Sea. If shipwreck remains are completely buried, a magnetometer is essential for shipwreck detection. While 300-m linespacing is adequate for 100-percent coverage of the seafloor with a sidescan sonar, much closer linespacing (probably a minimum of 50 m) is necessary to ensure detection of buried shipwreck remains with a magnetometer. The effectiveness of the magnetometer at this linespacing is dependent on the amount of ferrous material present on a shipwreck. Survey Recommendations for the Chukchi Sea The archaeological report requirement of the lease stipulation will be invoked on the blocks listed in Table 3: OPD Block NR 3-4 596, 639-640. NR 3-5 1027-1028. NR 3-7 15-17, 59-61, 103-104, 147, 148, 538-540, 528-533, 582-584, 626-627. NR 4-3 23-24, 65-68, 107-110, 111, 150-152, 193-195, 236-238, 279-281, 322-324, 366-367, 410, 573-576, 617, 619, 620. NR 4-4 1-4, 45, 47, 48, 92. G-23 Bibliography Bockstoce, J.R. 1977. Steam Whaling in the Western Arctic. New Bedford Whaling Museum, New Bedford, MA. Bockstoce, J.R. 1986. Whales, Ice, and Men: The History of Whaling in the Western Arctic. University of Washington Press, Seattle, WA, 400pp. Breiner, S. 1973. Applications Manual for Portable Magnetometers. Geometrics, Sunnyvale, CA, 58 pp. Claussen, C.J. and J.B. Arnold. 1975. "Magnetic Delineation of Individual Shipwrecks--A New Control Technique" in Bulletin of the Texas Archaeological Society, Vol. 46. Phillips, R.L. and T.E. Reiss. 1984. Nearshore Marin logic Investigations, I to Wainwrighi Northeast Chukchi Sea Synthesis Information Update, OCS Study MMS 86-0097. Stright, MJ. 1990. "Archacological Sites on the North American Continental Shelf". Geological Society of America, Centennial Special Vol. 4, Chap. 25. Tornfelt, E.E. In Press. Shipwrecks of the Alaskan Shelf and Shore. Anchorage, AK: USDOI, MMS, Alaska OCS Region. USDOI, MMS, 1990a. National Shipwreck Database, [unpubl.] Alaska OCS Region, Computer File, Anchorage, AK. USDOI, MMS. 1990b. Shipwreck Database Maps, [unpubl.] Alaska OCS Region, Anchorage, AK. G-24 APPENDIX H SUPPORTING TABLES FOR THE SECTIONS ON THE ECONOMY OF THE NORTH SLOPE BOROUGH Table H—1 Direct Employment Assumptions per Unit of Work for Proposed Sale 126——by Work Type ROTA=—NUHBER OF OF -OUT= TYPE OF WORK (one unit) CREW SHIFT TION AIRCRAFT TOTAL DURATION TOTAL OF-STATE AND ASSOCIATED TASKS SIZE FACTOR FACTOR OR BOATS WORKFORCE (MONTHS) WORK-MONTHS COMMUTERS (a) (b) (c) (d) (percent) DRILLING AN EXPLORATION OR DELINEATION WELL Drilling Crew Activities 50 2 2.0 = 200 3.0 600 79.0 Helicopter Support for Drilling 3 1 2.0 1.8 15 3.0 45 47.5 Supply/Anchor Boats for Drilling Support 12 1 2.0 3.0 72 3.0 216 58.0 Longshoring Support for Drilling 6 x 2.0 a 12 3.0 36 35.0 Other Onstiore Work in Support of Drilling 4 1 2.0 = 8 3.0 24 79.0 CONSTRUCTING AN EXPLORATION SHORE BASE 67 1 2.0 = iss 12.0 1600 79.0 OPERATING AN EXPLORATION SHORE BASE (1 YEAR) 10 2 2.0 = 40 6.0 240 79.0 CONDUCTING A GEOLOGICAL-GEOPHYSICAL SURVEY 30 - 2.0 1.0 60 3.0 180 79.0 CONSTRUCTING AN EXPLORATION ISLAND Construct Ice Road 6 2 2.0 Ss 24 2.00 48 70.0 Haul Gravel in Tru 136 2 2.0 ss 544 2.16 1175 70.0 Haul Gravel in Barges 125 2 2.0 = 500 1.33 665 70.0 Construct Island from Barge Mounted Cam 44 2 2.0 = 176 1.33 234 70.0 INSTALLING A PRODUCTION PLATFORM (& EQuiP) All Work by Platform Installation Crews 150 2 2.0 = 600 10.0 6000 89.5 Helicopter Support-Platform Installation 5 1 2.0 2.0 20 10.0 200 47.5 Tugboat Support for Platform Installation 10 1 1.5 4.0 60(e) 1.0 60 58.0 Supply/Anchor Boat Support-Platform Inst. 13 1 135) 3.0 59(e) 10.0 585 58.0 Longshoring for Platform Installation 20 1 1.5 = 30(e) 10.0 300 35.0 Other Onshore Support for Platform Inst. 25 1 1.5 = 38(e) 10.0 375 89.5 INSTALLING AN OFFSHORE LOADING PLATFORM All Work by Platform Installation Crews 50 2 2.0 = 200 2.5 500 89.5 Helicopter Support-Platform Installation 5 1 2.0 2.0 20 2.5 so 47.5 Tugboat Support for Platform Installation 12 1 2.0 1.0 24 1.0 24 58.0 Supply /Anchor Boat Support-Platform Inet. 12 1 2.0 2.0 48 2.5 120 58.0 Longshoring for Platform Installation 6 1 2.0 = 12 2.5 30 35.0 Other Onshore Support for Platform Inst. 8 1 2.0 = 16 2.5 40 89.5 CONSTRUCTING A PRODUCTION SHORE BASE 50 2 2.0 = 200 12.0 2400 47.5 DRILLING A PRODUCTION OR SERVICE WELL 28 2 2.0 = 112 3.0 336 79.0 LAYING OFFSHORE OIL PIPE (100 MILES) All Work of Laying Barge Crews 175 2 2.0 1.0 700 3.3 2310 89.5 Nelicopter Support for Pipe Laying 5 1 2.0 1.0 10 3.3 22 47.5 Tugboat Support for Pipe Laying 10 1 1.5 2.0 30(e) 3.3 99 58.0 Supply /Anchor Boats for Pipe Laying 13 1 1.5 3.0 59(e) 3.3 193 58.0 Longshoring Support for Pipe Laying 20 1 1.5 - 30(e) 33 99 35.0 Other Onshore Sup ort for Pipe aying 35 a 1.5 = 53(e) 3.3 173 89.5 LAYING ONSHORE OIL PIPE (100 MILES) 250 2 2.0 = 1000 6.7 6667 79.0 CONSTRUCTING A MARINE OIL TERMINAL 300 Z 2.0 = 600 12.0 7200 47.5 CONSTRUCTING AN ONSHORE PUMP STATION 100 1 2.0 = 200 8.0 1600 47.5 CONSTRUCTING A PRODUCTION ISLAND 225 2 2.0 = 900 3.0 2700 47.5 OPERATING A PRODUCTION PLATFORM (1 YEAR) All Work of Platform Operations Crewe 40 2 2.0 = 160 12.0 1920 25.0 Helicopter euepeteer fet tore Operations 5 1 2.0 1.0 10 12.0 120 25.0 Supply/Anchor Boats-Plat form Operations 12 2 rs 1.0 36(e) 12.0 432 25.0 Longshoring for Platform Operations 6 zr 1.5 - 9e) 12.0 108 25.0 Other Onshore Work for Platform Operatns 2 1 1.5 - 3fe) 12.0 36 25.0 MAINTENANCE ON ONE MAJOR PLATFORM 10 1 2.0 = 20 4.0 80 25.0 MAINTENANCE ON ONE PRODUCTION ISLAND 28 2 2.0 = 112 3.0 336 25.0 WELL WORKOVERS FOR ONE OIL PLATFORM 10 Z 2.0 =) 20 6.0 120 25.0 OPERATING A PRODUCTION SHORE BASE (1 YEAR) 40 1 2.0 = 80 12.0 960 25.0 OPERATING A MARINE OIL TERMINAL (1 YEAR) 50 2 2.0 = 200 12.0 2400 25.0 Notes: (a) work-months (180 hours) per shift (b) shifts per rotation (c) rotations per month: "2.0"--15 days on/15 off schedule, "1.5"--20 days on/10 off schedule (d) total work-months per month (e) 240 hour work-month Source: USDOI, MMS, Alaska OCS Region, MMS Employment Model, 1985; Dames and Moore, 1982. e-H Table H—2 Sale 126 Direct Industry Employment Requirements for the Base Case 1987 198819891990 199119921993 199% 19951996 1997 19981999 2000 2001-2002 2003. 20h? NS. TOTAL DIRECT OCS MANPOMER REQUIREMENTS 2.0.2... .ceeeeee 0 0 0 0 0 37 83793667457 480 OK 1N69 2577 2260) S401 23351867 162616261656 105K 168K RE TOS VOT ars secsconsvoccensevcoosne 0 0 0 0 0 S 2 1 1k 55 & 3 Bl 1037, S17, 8B 2D sMAD_—s sMAD_— MAD_— AD_—s 2D. ‘SHORT-TERM Skilled .... 0 0 0 0 0 3 » Ui) n 38 2 2 60 Neo 3277 % 0 0 0 0 0 0 0 Unskilled .. 0 0 0 0 0 12 a 53 St 2 9 16 19060109 50 0 0 0 0 0 0 0 LONG-TERM Skilled. 0 0 0 0 0 0 0 0 0 0 0 0 0 @ 4 8 8B Unskilled 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 % * % % % *% * * TSE: AS = sericea ntensitca 0 0 0 0 0 272 T1042 50H SUZ 2K 16H 158 HDG 284k 19231475 128212321262 12621262 ‘SHORT-TERM Skilled . 0 0 0 0 0 22 T1042 50H BOZ 16H —1S8 1K SKK 18 KTS 0 0 0 0 0 Unskilled 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 ‘LONG-TERM Skilled . 0 0 0 0 0 0 0 0 0 0 0 0 0 0 O 1080 108011361136 1136 116611661166 Unskilled .. 0 0 Qo 0 0 0 0 0 0 0 0 0 0 0 0 % % % % % % % % EXPLORATION PHASE EMPLOYMENT (EXCEPT HO) 0 0 0 0 0 SW 8 7 «(67 87 80h 0 0 0 0 0 0 0 0 0 0 0 DEVELOPMENT PHASE EMPLOYMENT (EXCEPT HQ) 0 0 0 0 0 0 0 0 0 0 0 O 1289 «2617, 1980 181347 KS 0 0 0 0 0 PRODUCTION PHASE EMPLOYMENT (EXCEPT HO) 0 0 0 0 0 0 0 0 0 0 0 0 0 ri 8013881388 144K KA 1h KATA TOTAL EMPLOYMENT - EXCEPT HO 0 0 0 0 0 37 82273 627,357 280 UK 12892697 2060 32012135 16871466 1hGk = 1h 78 KK 14TH —— eS Source: USDOI, MMS, Alaska OCS Region, MMS Employment Model, 1990. &-H Table H—3 Sale 126 Direct Industry Employment Requirements for the Low Case 1987 1988 1990 19911992 19931998 19% 619971998) 11999 2000 2001, 2002s 0S AC Hs TOTAL DIRECT OCS MANPOWER REQUIREMENTS ......... teeeeee 0 0 0 o 15 0 0 0 0 0 0 0 0 0 0 0 0 0 ONSHORE JOBS -- TOT oo... cesses eee secceseccees 0 0 0 0 0 a 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 SHORT-TERM Skilled 0 0 0 0 0 7 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Unskilled . 0 0 0 0 0 iu 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 LONG-TERM Seilled ... 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 6 0 0 Unskilled 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 OFFSHORE JOBS -- TOT ..... desecesseeessecesees 0 0 0 0 0 16 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 ‘SHORT-TERM Skilled ... 0 0 0 0 0 16 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Unskilled 0 0 0 0 0 0 a 0 0 0 0 0 0 0 0 0 0 0 0 0 0 LONG-TERM Skilled ... 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Unskilled . 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 o 0 0 0 EXPLORATION PHASE EMPLOYMENT (EXCEPT HO) 0 0 0 0 o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 DEVELOPMENT PHASE EMPLOYMENT (EXCEPT HO) 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 PRODUCTION PHASE EMPLOYMENT (EXCEPT HO) 0 0 0 0 Qo 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 TOTAL EMPLOYMENT - EXCEPT HO 0 0 0 0 0 1% 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Source: USDOI, MMS, Alaska OCS Region, MMS Employment Model, 1990. v-H Table H—-4 Sale 126 Direct Industry Employment Requirements for the High Case 1987 1988 19891990 199119921993 19H 1995 19% 1997 19981999 2000 2001-202 03 Oh CSN 2H TOTAL DIRECT OCS MANPCMER REQUIREMENTS .0......cc0cc000 0 0 0 0 O S17 $37 SKIL HL 8571389 2592475267 KA BK 3825 28882 QWSHORE JOBS -- TOT. oo. .eeeeseeeeee seeeceeseee 0 0 0 0 0 % 2 1 1) B B 5s 797 0 SB ‘SHORT-TERH Skilled .... 0 0 0 0 0 23 n % % 6 6 a i 0 0 0 0 9 Q 0 Unskilled .. 0 0 0 0 0 iY a 53 ba a % 2 16 m3 SS 0 0 0 0 0 0 Q LONG-TERN Skilled . 0 0 0 0 0 0 0 0 0 0 0 0 13 % o O 1% 1% 1% 1% 1% = 1H 1% Unskilled .. 0 0 0 0 0 0 0 0 0 0 0 0 B % 0 O MWe 8 SE REE Cite) Wie crcce tree rere) 0 0 0 0 0 22 NO 2 5h 4B ABZ S92 4SZ HD SBB HDHD 7B ha HES SSE ‘SHORT-TERM Skilled .... 0 0 0 0 0 22 NO 62 5% «438 43S ZH ASZ HTD 2588 SKB SRB 0 9 9 9 Unskilled .. 0 0 0 0 0 0 0 0 0 0 0 9 0 0 0 0 0 0 0 0 0 0 9 LONG-TERM Skilled . 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2160 2160 2272, 2722272282 2S Unskilled .. 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 12 «192 192 192 192 192 IB EXPLORATION PHASE EMPLOYMENT (EXCEPT HO) 0 0 0 0 0 WW 8 738 MOSHE SHE 387 280M“ (CT 0 0 0 0 0 e a 0 OEVELOPHENT PHASE EMPLOYMENT (EXCEPT HO) 0 0 0 0 0 0 0 0 0 0 0 0 1202 45% 4387) 267588 SBSH 0 0 9 0 FRODUCTION PHASE EMPLOYMENT (EXCEPT HO) 0 0 0 0 0 0 0 0 0 0 0 0 % 38 0 CO 6% = =—6% = 2808 2008 28S TOTAL EMPLOYMENT - EXCEPT 10 0 0 0 0 0 37 822773 HSL SAN 357 150927124596 HK? S286 (32843125 2808 2808 2st _ Source: USDOI, MMS, Alaska OCS Region, MMS Employment Model, 1990. APPENDIX I ALTERNATIVE ENERGY SOURCES AS AN ALTERNATIVE TO THE OCS PROGRAM ALTERNATIVE-ENERGY SOURCES The description of energy alternatives is hereby incorporated by reference from Appendix C, Alternative-Energy Sources, of Volume 3 of the Final EIS for the Proposed 5-Year OCS Oil and Gas Leasing Program, 1987-1992. The following informa- tion is a summary of this document. Conservation: Vigorous energy conservation is an alternative that warrants serious consideration. Several studies have suggested that we could enjoy the same standard of living and yet use 30 to SO percent less energy than we do now. Aside from these savings, it is not widely recognized that wasteful consumption habits impose social costs that can no longer be afforded, as do pollution and an inequitable distribu- tion of fuel. Existing conservation programs include education, research and development, regulation, and subsidies. In the residential and commercial sectors of the economy, more efficient energy consumption could be realized by improved insulation, more efficient heating and cooling systems, better designed appliances, and more efficient lighting. Incentives such as standards for improved thermal efficiency in existing homes and offices and minimum thermal standards for new homes and offices also could result in substantial energy savings. In the industrial sector, more energy-efficient work schedules, better maintained equipment, equipment with better low-heat transfer efficiencies, and recycled heat and waste materials could result in energy savings. Transportation of people and goods accounts for approximately 25 percent of nationwide energy use. In the transportation sector, short- and mid-term conservation measures, such as consumer education, lower speed limits, and rate and service improvements on public transit and rail-freight transit, could achieve considerable energy savings. Other policies that could encourage fuel conservation in transportation include standards for more efficient new automobiles and incentives to reduce miles traveled. Significant energy savings are clearly possible through ac- celerated conservation efforts. In addition, several of the strategies mentioned above have been at least partially imple- mented by the Energy Policy and Conservation Act of 1975 (PL. 94-163). The environmental effects of a vigorous energy conservation program would be primarily beneficial. The exact nature and magnitude of these effects would depend on whether there is a net reduction in energy use or whether the reduction is accomplished through technological change and substitutions. Either case would result in the reduction of pollutants such as CO, hydrocarbons, particulates, NO,, and SO,. Conventional Oil and Gas Supplies: Reserves and undiscovered deposits of oil and gas still exist in the United States. Proven reserves are currently estimated at 31.4 billion bb! of oil and 208.0 Tef of natural gas, the lowest level since 1951. Since 1970, new oil discoveries have replaced less than one-half of produc- tion. Ultimately recoverable reserves (all deposits known or believed to exist in such forms that economic extraction is currently or potentially feasible), in addition to proven reserves, are estimated to be about 82.6 billion bbl of oil (54.6 onshore/28.0 offshore; 13 years of consumption at current rates), and 593.9 Tcf of natural gas (426.9 onshore/167.0 offshore). This estimate is rising over time, mainly because of higher prices and new discoveries in unexplored areas. Unconventional hydrocar- bons and recovery methods, especially enhanced recovery, could more than double these figures. The amount of ultimately recoverable reserves will depend on price, technology, geological information, and public policy such as price controls, access to Federal lands, and environmental standards. I-1 Petroleum production is severely constrained in the short run and greatly affected by world prices in the long run. Although the long-run demand for fuel liquids is not forecast to decline significantly (feasible solid and gaseous substitutes do not appear to exist), consumption of conventional crude oil is expected to decline significantly as synthetic liquids are pro- duced from shale, tar sands, and coal; as biomass sources are utilized; and as industry and utilities reduce oil facilities and shift to coal and possibly nuclear power. Synthetic liquid from coal is expected to be the major source of liquid fuel by 2020, supplying 50 percent of all liquid fuel and 10 percent of all consumed energy. Conventional natural gas consumption is expected to decline due to depletion, higher prices, and competition with synthetic gas from coal. Enhanced gas recovery from unconventional sources such as tight sands and Devonian shale is expected to make a significant contribution to gaseous fuel production, providing 50 percent of all gaseous fuel and 5S percent of all energy consumption by 2020. Ultimately recoverable reserves from such sources are estimated at 3,000 Tcf. A detailed description of the crude oil and natural gas systems is found in Chapters 3 and 4 of Energy Alternatives: A Com- parative Analysis (University of Oklahoma, 1975). To substitute directly for the proposed action, a combination of onshore and OCS production from other areas and continued foreign imports would be required to make up for the estimated total production of these proposed actions. This substitution would entail environmental effects such as land subsidence, soil sterilization, and disruption of existing land use patterns. Equipment failure, human error, and blowouts also may impair environmental quality. Moreover, poor well construction, particularly in older wells, and oil spills can result in ground- and surface-water pollution. The water pollutants from onshore oil production are oil and dissolved solids. The amounts of each vary over a wide range. A summary of onshore oil pollutants is available in Energy Alternatives: A Comparative Analysis (University of Oklahoma, 1975). Air pollutants (particulates, NO,, hydrocarbons, and CO) result from blowouts and subsequent evaporation and burning. These are generally insignificant, except locally. Onshore or offshore effects are basically the same. Given the fact that onshore supplies are dwindling, users of hydrocarbons from these proposed actions would have to continue their reliance on other regions and foreign imports for needed oil and gas. The decline in these supplies, even with energy conservation, could mean industrial shutdowns, increased unemployment, higher consumer prices, and changes in the standard of living. The lack of natural gas will mean additional use of “dirtier” alternative fuels (oil and coal) with consequent effects on air quality and human health. Coal: Coal is the most abundant energy resource in the United States. Proven domestic reserves of coal are estimated at 438 billion short tons. This constitutes over one-quarter of the known world supply, 80 percent of proven United States fuel reserves, and 130 times the energy consumed in 1980. UI- timately recoverable reserves are estimated at 3.9 trillion short tons. A detailed discussion of the coal resource system can be found in Chapter I of Energy Alternatives: A Comparative Analysis (University of Oklahoma, 1975). Although domestic coal reserves could easily replace the energy expected to be realized from the proposed actions, serious limitations to coal development exist. In many uses, coal is an imperfect substitute for oil or natural gas. In many other cases, coal use and production is restricted by Government con- straints, limited availability of low-sulphur deposits, inadequate mining, conversion and pollution-abatement technology, and the hazardous environmental effects associated with coal extraction and from electricity generation. Coal production also is threatened by a unique set of labor problems associated with mining and new, strict standards for coal-mine safety. Due to its relative price advantage over other fuels, competitive market structure, and large resource base, coal consumption and production are expected to increase significantly; and coal is expected to become the primary domestic energy source in the future. Synfuels from coal also will be important. Synthetic oil and gas could contribute substantially to energy supplies by the year 2000. The most important contributions would be high Btu gas from coal, synthetic crude oil from oil shales, and coal liquefaction. The success of these energy sources will depend on developing technology, the cost of the effects, and the cost of conventional oil and gas. Technology for conversion of coal into gaseous and liquid hydrocarbons has been established for several decades, and a number of relatively low-capacity commercial plants exist in various parts of the world. However, few cost-effective, advanced technologies have progressed beyond the pilot-plant stage. Coal gasification can produce gaseous fuels with low-, inter- mediate-, or high-energy content. Low and intermediate gases are produced in a two-stage process involving preparation and gasification, and the output is utilized as feedstock for electric generators. A third process, "upgrading," is required to produce high Btu gas, which produces an end-product usable by the consumer. Gasification processes have lower primary efficiency than direct coal combustion; more coal will have to be gasified to reach an equivalent Btu output. However, it is likely that coal gasification will achieve primary efficiencies of 70 percent, which is about twice that of coal to electricity end use. Liquefied coal has the potential to replace conventional crude oil as the major source of liquid fuel and to provide 10 percent of total domestic-energy consumption by 2020. The available technologies have a recovery rate of 0.53 bbl of oil per ton of coal processed. As with coal gasification, production of liquid fuels from coal requires either the addition of hydrogen or the removal of carbon from the compounds in the coal. Coal liquefaction can be accomplished by hydrogenation, pyrolysis, or catalytic conversion. Only catalytic conversion is in commercial operation. Although United States’ coal resources are very large, as with other extractable mineral fuels, there is some geographic dislocation. Most of our new low-sulphur coal is found west of the Mississippi River or in Alaska, far from industrial areas. Also, much of the western coal is in arid or semiarid areas where scarcity of water could constrain development. If an alternative to the proposed OCS sale is greater reliance on coal, it may he expected that mining would have to increase in the western states to provide the necessary fuel resources. Adverse environmental effects from heavier reliance on coal would result from its direct utilization, surface mining, under- ground mining, transportation, and conversion to liquid or gaseous fuels. Combustion of coal results in various emissions, notably SO, and particulates. If the expected production from these proposed actions is replaced by coal, there would be an increase in these pollutants, especially if coal is substituted for the natural gas presently used. Technology to control these emissions is available but has not yet been proven sufficient to be widely applied. Any large-scale shift to coal would require realization of emission regulations or improvement of tech- nologies to convert coal to gaseous or liquid fuels. The primary effect of surface mining is disruption of the land. This affects all local flora and fauna and water quality and increases landscape problems due to erosion and mine runoff. Reclamation is difficult in the western states due to the lack of water to assist in revegetation. Other problems include acid-mine-water drainage, leaching from spoil piles, processing waste, and disturbances caused by access and transportation. Noise and vibration resulting from operations also can be expected. Finally, surface mining causes conflicts with other resource uses such as agriculture, recreation, water, and wildlife habitat. The land use of strip mining ranges from 0.8 to 5.9 acres/1,012 Btu extracted, depending on seam thickness and Btu content of the coal. Underground mining primarily affects land and water quality. The land effects are those that arise from subsidence, waste disposal, access, and transportation. Very little surface is disturbed. Subsidence can destroy structures, cause landslides and earthquakes, and disrupt groundwater-circulation patterns. The amount of subsidence can be controlled by the mining method used and the amount of coal removed. The utilization of certain mining methods and the restriction of the amount of coal extracted can have detrimental effects on the economics of the operation. Water quality is affected by processing waste and the draining of acid-mine water into surrounding areas. These can be minimized through the proper methods of control both during and after operation. Waste piles can be replaced in the mine and the entrances sealed, which also would help to minimize subsidence. Other pollution problems are those associated with road and coal dust and the like, but these are minimal and easily controlled. Other disturbing aspects of mining have much less of an effect in an underground mine. Working conditions of underground mines have been improved under the Federal Coal Mining Health and Safety Act of 1969, although further efforts are needed to reduce health hazards. This program has resulted in increasing costs of underground mining when compared to surface mining, which has even more severe environmental consequences. The five major coal transportation systems (road, rail, water, conveyor, and pipeline) all have some adverse environmental effects. These include air and noise pollution, safety hazards, land-use conflicts, trash-disposal problems, and aesthetic damage. However, since spill problems are not associated with coal, most of the effects can be controlled with greater care and consideration. A slurry pipeline also requires large supplies of water and must adequately dispose of this at the other end. Water availability is a problem in many areas of the United States, especially in the west where energy resources require- ments will have to compete with existing commercial and private users for a limited and fragile resource. The environmental effects of coal gasification are those of mining plus those resulting from the production process. Water effects of processing can be minimized by recycling and evaporation. However, large inputs of water are required for some of the technologies, thus creating the potential for conflicts in water-short areas. Air pollution could include SO,, particulates, NO,, hydrocar- bons, and CO. Land effects result from solid-waste disposal, as well as land use for the plant, coal storage, cooling sands, etc. Solid wastes include ash, sulphur, and minute quantities of some radioactive isotopes. Again, the effects of liquefaction will be those of mining and those of the processing plants. Water effluents from liquefac- tion plants could contain amounts of phenols, solids, oil, ammonia, phosphates, etc. The wastewater could be treated to remove most of these products. Air pollution could result from particulates, nitrogen, SO,, and other gases. Pollution-control facilities would be required but would lower the economic attractiveness of the plants. Solid wastes would be mostly ash. If liquefaction plants were sited near mine openings, residue could be buried in the mines with little further environmental effects. Power - : The predominant nuclear system used in the United States is the uranium dioxide-fueled, light-water moderated and cooled nuclear power plant. Research and development are being directed toward other types of reactors, notably the breeder reactor. Due to environmental concerns, the growth of nuclear energy may be slowing. At the end of 1980, there were 75 reactors in the United States, up from 19 in 1970. Although 4 reactors were licensed in 1980, 14 other planned units were canceled, and the Nuclear Regulatory Commission (NRC) closed 5 for modification to comply with revised seismic requirements and shut down 8 reactors comparable to Three Mile Island to determine the probability for a similar accident and to make required safety modifications. Nuclear energy output was down 16 percent in 1980. There are currently 102 reactors under various stages of construction, construction-permit review, or on order. Nuclear power development has encountered delays in licensing, siting, and environmental constraints as well as manufacturing and technical problems. Future capacity will be influenced by the availability of plant sites, plant-licensing considerations, environmental factors, nuclear fuel costs, rate of development of the breeder and fusion reactors, and capital costs. Domestic uranium resources are probably plentiful. Ultimately recoverable reserves are estimated to be 6.876 billion short tons, and large areas are unexplored. Twenty-one million short tons were consumed in 1980 domestic nuclear energy production. Although fuel-cycle costs of nuclear reactors have increased only slightly in recent years, present trends in reactor capitol costs are significantly narrowing the economic advantage offered by fuel-cycle costs over coal- and oil-fired plants. Although nuclear plants do not emit particulates or gaseous pollutants from combustion, the potential for serious environ- mental problems exists. Some airborne and liquid radioactive materials are released to the environment during normal operation. The amounts released are very small, and potential exposure has been shown to be less than the average level of natural radiation exposure. The plants are designed and operated in such a way that the probability of harmful radioac- tivity release from accidents is very low. Nuclear plants use essentially the same cooling process as fossil-fuel plants and thus share a similar problem of heat dissipation from cooling water. However, light-water reactors require larger amounts of cooling water and discharge greater amounts of waste heat to the water than comparably sized fossil-fuel plants. The effects of thermal discharges may be beneficial in some, though not all, cases. Adverse effects can often be mitigated by use of cooling ponds or cooling towers. Low-level radioactive waste from normal operation of a nuclear plant must be collected, placed in protective containers, and shipped to a Federally licensed storage site for burial. High- level wastes created within the fuel elements remain there until the fuel elements are d. Currently, spent fuel is stored at NRC-licensed facilities. Plans call for recovering unused fuels at reprocessing plants, solidifying the wastes, and placing them in storage at a Federal repository. There also are effects on land, water, and air quality arising from the mining of these uranium ores. Dwindling amounts of high-grade reserves will increase the amount of land mined for lower grade radioactive ores—primarily in the western states. The mining operations will be similar to coal, but the nature and distribution of the deposits mean "lesser" effects, while radioactive tailings cause unusual problems for disposal, the environment, and human health. A more complete discussion of uranium mining and processing and the economics and en ‘ironmental impacts, as well as nuclear fission and fusion, can be found in Chapters 6 and 7 of Energy Alternatives: A Comparative Analysis (University of Oklahoma, 1975). Nuclear Power - Fusion: The controlled fusing of atoms in a reactor is a long-term alternative-energy source. Scientific feasibility has yet to be proven but looks promising. Tech- nological and commercial feasibility will have to follow, how- ever. The main obstacles are obtaining a high enough tempera- ture and containing the reaction. It is unlikely that fusion will be available to any significant degree before 2025. Fusion is attractive for two reasons: abundant fuel sources and relative safety. The reaction is fueled by deuterium and tritium. Deuterium exists naturally in seawater and would be nearly cost-free; tritium can be inexpensively produced in a reactor from lithium, which is plentiful. Because of the small neutron activation involved in fusion reactions, there would be lower radioactive inventories, fewer radioactive wastes, and less serious fuel-handling problems and accident risks. A proposed hybrid fusion-fission fuel cycle would fuel fission reactors with fusion-produced isotopes and multiply the energy release of fusion tenfold, while demanding less of the fusion core and thus enhancing the safety characteristics of both reactors. A proposed pure deuterium process, while possessing a lower reaction rate, would have a neutron fuel cycle; thus, all particles and products would be electrically charged and there would, in theory, be no radioactivity. The environmental risks from fusion energy are probably less than fission, but the degree of reduction and the social accep- tability of that degree cannot be determined presently. Oil Shale: Oil shale is a fine-grained, sedimentary rock that, when heated, releases a heavy oil that can he upgraded to synthetic crude oil. The technology for exploitation currently exists. The resource base for shale is very large, perhaps as much as 360 billion bbl. Large areas of the United States are known to contain oil-shale deposits, but those in the Green River Formation in Colorado, Wyoming, and Utah have the greatest commercial potential. Oil-shale development poses serious environmental problems. With surface or conventional underground mining, it is very difficult to dispose of the huge quantities of spent shale, which occupy a larger volume than before the oil is extracted. Inducing revegetation growth in an area of oil shale develop- ment is difficult and may take more than 10 years. In-place processing avoids many of these environmental hazards. With underground mining, the spent-shale problem is much less severe. Air pollutants from the mining will come from dust and vehicular traffic. These will be predominantly particulates, followed by NO, and CO, with minimal amounts of hydrocar- bons, SO,, and aldehydes. The mining of oil shale requires little water, both for operations and for reclaiming solid wastes. Water pollutants are con- sidered negligible but may arise if saline water was encountered during the operations and had to be disposed of. However, the processing (retorting) operations of oil shale consume large quantities of water and generate large amounts of wastewater. The wastewater must be treated and can be reused in the process. Therefore, it has been assumed that water pollution would not be a problem outside the processing complex. However, the limited availability of input water in the development area could lead to resource-use conflicts. Air pollutants vary with the technology used. Solid waste comprises the greatest problem of oil-shale processing. The volume of the waste is greater than the volume of the input. Therefore, backfilling and the like would not provide a suf- ficient disposal space. Finally, there are the effects of access and of transporting the products. These are analogous to those of coal mining in the case of access and to petroleum distri- bution in the case of transporting the product. A more complete description of this energy source can be found in Chapter 2 of Energy Alternatives: A Comparative Analysis (University of Oklahoma, 1975). ‘Tar Sands: Tar sands are deposits of porous rock or sediments that contain hydrocarbon oils (tar) too viscous to be extracted by conventional petroleum-recovery methods. Large-scale production efforts have been developed in Canada, but ventures in the United States have been minor. United States’ resources are concentrated in Utah, with some potentially commercial quantities in California, Kentucky, New Mexico, and Texas. About 1.5 tons of rich tar sands yield about 1 bbl of tar, or bitumen, the equivalent of about 6.3 x 106 Btu’s. Tar can be recovered either from sands mined on the surface or under- ground or from direct underground extraction of the oil without mining. Recovery is followed by processing, upgrading to synthetic crude, and refining. Ultimately recoverable reserves may be 100 billion bbl, including other heavy oils. Surface mining produces substantial residuals, including modification of surface topography, disposal of large amounts of overburden, dust and vehicle emissions, and water pollution. Reclamation can minimize these effects. Residuals are similar to those of coal. The effects of processing tar sands are similar to those of oil shale. These include solid tailings from extraction, cooling water and blowdown streams, thermal discharges, and off-gases. Under controlled conditions, these residuals can be minimized. Underground extraction without mining can result in thermal additions, contamination of aquifers, surface spills, surface-earth movements, noise pollution, and emission of gases. Hydroelectric Power: Hyd: r is energy from falling water, which is used to drive turbines and produce electricity. Conventional hydroelectric developments convert the energy of natural stream flows falling from a height into electric power. Pumped-storage projects generate electric power by releasing water from an upper to a lower storage pool and then pumping the water back to the upper pool for repeated use. A pumped- storage project consumes more energy than it generates but converts offpeak, low-value energy to peak, high-value energy. A more detailed discussion of this energy source is found in Chapter 9 of Energy Alternatives: A Comparative Analysis (University of Oklahoma, 1975). Many of the major hydroelectric sites operating today were developed in the early 1950’s. Thirty to forty years ago, hydroelectric plants supplied as much as 30 percent of the electricity produced in the United States. Although hydroplant production has steadily increased, thermal electric-plant production has increased at a faster rate. From 1970 to 1980, hydroelectric-power production has fluc- tuated slightly between 220 and 300 billion kilowatt hours—ab- out 4 percent of total United States’ energy production. As a proportion of total United States’ electricity production and installed generating capacity, hydroelectricity has dropped from 16 percent to 12 percent, although the latter has increased from 55.1 to 76.4 million kilowatts. Much of the recent hydroelectric development has been pumped-storage capacity. It is likely that hydroelectric power will continue to represent a declining percentage of the total United States’ energy mix due to high capital costs, seasonal variations in waterflows, land-use conflicts, environmental effects, competitive water use, and flood-control constraints. Sites with the greatest production capacity and lowest development costs have already been exploited. Construction of a hydroelectric dam represents an irreversible commitment of the land resource beneath the dam and lake. Flooding eliminates wildlife habitat and prevents other uses such as agriculture, mining, and free-flowing river reaction. Hydroelectric projects do not consume fuel and do not cause air pollution. However, use of streams for power may displace recreational and other uses. Water released from reservoirs during the summer months may change ambient water tempera- tures and lower the oxygen content of the river downstream, thereby adversely affecting indigenous fish. Fluctuating reservoir releases during peak-load operation also may adversely affect fisheries and downstream recreation. Screens placed over turbines prevent the entrance of fish; small organisms may pass through or may be killed. Fish may die from nitrogen supersaturation, which results at a dam when excess water escapes from the draining reservoir. High nitrogen levels in the Columbia and Snake Rivers pose a threat to the salmon and steelhead resources of these rivers. Other adverse effects to water quality include possible saline-water intrusion into waterways and decreased ability of the waters to accom- modate moderate waste discharges. Air quality will be affected only by dust and emissions during the construction phase. Afterwards, if the impoundment is used for recreation, motor exhaust could occur. Solar Energy. Applications of solar energy must take into account the following: ° Solar energy is a diffuse, low-intensity source requiring large collection areas. Only a small portion of the potential energy is utilized. Its intensity is continuously variable with time of day, weather, and season. Its availability differs widely between geographic areas. Potential applications of solar energy show a wide range. Among them are: ° Thermal energy or water heating, space heating, space cooling, and combined systems of the buildings. Renewable, clean-fuel sources; combustion of organic matter; bioconversion of organic materials to methane; pyrolysis of organic materials to gas, liquid, and solid fuels; and chemical reduction of organic materials to oil. Electric-power generation, thermal conversion, wind-energy conversion, and ocean-thermal difference. Solar-energy-collection systems are now commercially available nationwide. Additional detail on this resource alternative is found in Chapter II of Energy Alternatives: A Comparative Analysis (United States Government Federal Policy Task Force Review Group, Solar Energy Analysis, 1978; Solar Energy Progress and Problems, EPA, USDOE, and Lawrence Berkeley Laboratories et al., 1978). Among the disadvantages of solar energy are high capital costs, expensive maintenance of solar collectors, thermal-waste disposal, and distribution for local thermal balances. The environmental effects so far identified with solar energy are relatively minimal. The primary effects of the use of this energy source on a wide scale will be land use. Due to the low density of the energy, large areas will be necessary for the collectors. However, the land use compares favorably with other forms of energy use, such as coal extraction. To date, the only other known area of concern is thermal pollution. Direct use in space heating has no thermal effects. There may be some localized thermal pollution from solar electric-power generation, which will have to be collected and transferred to the generator, but the problem is not expected to be significant. Finally, solar plants can operate only intermit- tently, thus, the energy will either have to be stored or backup fossil-fuel plants will have to be built. These will have their own sets of environmental constraints. Oil Imports: Spurred by new discoveries and competition, Middle East oil production expanded in the 1950’s and 1960's. New markets were opened and prices softened. The real price of oil fell from 1948 to 1972. Simultaneously, United States consumption of oil increased while production stayed constant; imports were relied upon to make up the difference. In 1973, the Arab-Israeli war was accompanied by an embargo imposed by OPEC against nations supporting Israel. The vulnerability of the importers to their own heavy demand became evident, and a huge price increase followed. This marked the end of the so-called era of "cheap energy,” and efforts were made to curtail imports. Another large price increase occurred in 1979. Three avenues were pursued for reducing imports: conserva- tion, or reduced net-energy demand per unit output; alternative energy; and increased domestic production. The results of these efforts for reducing imports seem to have been mostly successful. The underlying market structure for energy has been altered. World demand for oil peaked in 1977 and appears to be in an irreversible structural decline. Gross national products have been rising along with nonenergy output, alternative-energy sources, and non-OPEC production. Oil is wholly responsible for declines in energy use. The OPEC produced 32 million barrels per day (mbd) in 1977. Current projections of energy consumption until the year 2000 show rates of one-half of that projected in 1972. The USDOE is currently projecting a 0.9-percent annual growth rate (actual growth was 1.9% annually from 1970-1979) and a 3 percent annual economic growth. The dimensions of the structural change for the United States in 1981 are as follows: Total energy consumption was down 5 percent. Petroleum consumption was down (8%) for the third straight year. Oil consumption as a percentage of total energy consump- tion was down 9 percent. Imports of petroleum were down for the fourth straight year. Imports in May 1981 were 5.2 mbd, the lowest in 10 years. This was 20 percent less than in 1980 and 38 percent less than in 1979. Imported petroleum as a percentage of total petroleum consumption was down 5 percent. Imported petroleum as a percentage of total energy con- sumption was down 27 percent. Dollar value of gross national product has been steadily declining since 1970. It is reasonable to assume OPEC will affect the bulk of the world’s oil production for the remainder of the century, due mainly to the short term in elasticity of the supply of sub- stitutes, and will set prices based on factors besides price-cost relationships. Brief derivations from this leadership position may be noted in the short term due to world price adjustments. Thus, the less dependent the United States is on OPEC, the less vulnerable the United States is to large, erratic price changes. Imports from the Middle East also bring problems of IS stability of supply, balance of payments, currency exchange rates, and United States’ offloading capacity. The United States will probably remain somewhat dependent on imported energy throughout this century and, as the 1970's showed, there are situations in the Middle East that could lead to major disruptions in supply or huge price increases. However, the propensity for such anomalies is less than in the past, due primarily to the following: ° As mentioned above, the underlying market structure for energy has been altered, and demand for oil has declined drastically. Associated with this, OPEC will have con- siderable spare capacity, and price cohesiveness will be difficult to maintain. ° All OPEC nations need to produce oil to finance develop- ment. The goal of many OPEC nations is to maximize oil’s long-term contribution to the national economy rather than to maximize short-term profits. If revenue falls below a certain level where OPEC nations are not realizing an acceptable income, domestic tensions may ensue. The OPEC economies, especially Saudi Arabia’s, are more interdependent with the West than previously. The OPEC has invested interest and financial reserves in the West, im- ports a large amount of goods from the West, and has its oil Prices tied to Western currency-exchange rates. The presence of strategic stockpiles provides both a deter- rent to international disruptions in world markets and a cushion for smoothing price and supply shocks. Current stockpile inventories on most Western nations are at record levels. The OPEC's output and pricing structure also will depend on its balancing of: ° future vs. present proceeds; ° benefits vs. cost of rapid modernization; and discipline in the market vs. the political unit of OPEC. The primary hazard to the natural environment of increased oil imports is the possibility of oil spills, which can result from accidental discharge, intentional discharge, and tanker casualties. Intentional discharges would result largely from uncontrolled unballasting of tankers. The effects of chronic, low-level pollution are largely unknown. The worldwide tanker casualty analysis indicates that, overall, an insignificant amount of the total volume of transported oil is spilled due to tanker acci- dents. However, a single incident such as the breakup of the Torrey Canyon in 1967 or the Amoco Cadiz in 1978 can have disastrous results. Of more concern than tanker spills is the effect on the social and economic environment. The potential for a future embargo under this option is such that American productivity and policy could become subservient to foreign influence, having both economic and security implications for the Nation. On a more subtle level, political alignments and policies of the United States could become tied to those of foreign oil powers. This option is the least acceptable for continued American energy independence. Natural Gas Imports: Imports of natural gas via pipeline have come largely from Canada, with small amounts also coming from Mexico. In 1980, net pipeline imports from Canada were 881 billion cubic feet, about 4.4 percent of the total natural gas used in the United States. These imports were about 33 percent of Canada’s natural gas production. The natural gas-import situation continues to be highly uncer- tain. A major reason for this uncertainty is the disparity between prices for natural gas and alternative fuels in this country and the price of crude oil in world markets. The United States and Canada concluded an agreement in March 1980 that established a formula for escalating the price of Canadian imports. The formula prices Canadian gas at the Btu-equivalent price of Canadian crude oil imports, minus an adjustment that reflects savings to Canada of certain transporta- tion costs. In to escalated Canadian prices, demand in the United States for Canadian gas dropped sharply. Consequently, Canada has foregone the opportunity to raise its export price. What modifications, if any, the Canadians will make to their pricing formula and what minimum amounts of Canadian gas Americans must take under existing contracts are matters currently being examined on both sides of the border. Mexico could be a significant source of future imports because of its relatively large natural gas-resource base. Imports from Mexico were of a local nature until 1957 and have declined since 1969. In September 1979, an agreement was concluded between the United States and Mexico regarding the importa- tion and pricing of natural gas. A base price was specified to be escalated in proportion to the average price of five crude oils traded on the world market. However, the rapid increase in world oil prices between the time the agreement was concluded and the time the price escalation began brought the price of Mexican gas substantially below both oil parity and the Canadian gas price. Consequently, Mexico requested and received the same price as the Canadians. Natural gas imports are expected to be eliminated in the long tun, as domestic natural gas production will nearly satisfy decreasing demand and synthetic gas from coal can provide the balance and replace imports. The environmental effect of increasing gas imports derives mainly from the possible increased use of land for pipeline construction. A further effect is the risk of explosions and fires. Fluctuations of supply could influence quality of life, productivity, and employment. American policies also could become influenced by decisions of foreign gas producers, much as they could under the option of increasing oil imports. iquefied Natural Gas The growing shortage of domestic natural gas has encouraged projects to import liquefied natural gas (LNG) under long-term contract. Large- scale shipping of LNG is a relatively new industry. Several LNG projects are now under consideration on the Pacific, Atlantic, and Gulf Coasts. The security of foreign LNG is questionable. The complexity of the length of time involved in implementing these proposals has been increased by the need for negotiating preliminary contracts, securing the approval of the Federal Energy Regulatory Commission and the exporting country, and making adequate provision for environmental and safety concerns in the p: United States’ facilities. The authority to construct and operate facilities to implement imports and exports must be obtained separately from the Federal Energy Regulatory Commission. The cost of liquefying and transporting natural gas, other than overland by pipe, is high. The United States imported 85 billion cubic feet of LNG from Algeria in 1978. In March 1980, Algeria announced that it was demanding oil-price parity, free-on-board, for gas it exported to the United States, and it subsequently discontinued deliveries. The free-on-board price does not include transportation, terminal, and regasification costs, which are substantial. The environmental effects of LNG imports arise from tankers; terminal, transfer, and regasification facilities; and transporta- tion of gas. The primary hazard of handling LNG is the possibility of a fire or explosion during transportation, transfer, or storage. Receiving and regasification facilities will require prime shoreline locations and channel dredging. Regasification of LNG will release few pollutants to the air or water. LNG imports will influence the United States’ balance of ments. This effect will depend on the origin and purchase price of the LNG, the source of the capital, and the country (United States or foreign) in which equipment is purchased and LNG tankers are built. Geothermal - Geothermal energy is primarily heat energy from the interior of the earth. It may be generated by radioactive decay of elements such as uranium or thorium and friction due to tidal or crustal plate motions. There are four major types of geothermal systems—hot-water, vapor-dominated, geopressured reservoirs, and hot-dry-rock systems. In addition to electricity, geothermal energy can offer a potential for space heating, industrial processing, and other nonelectric uses in many areas that presently are highly dependent upon oil and gas for energy needs. However, geothermal electric-generating plants are smaller than conven- tional plants and require a greater amount of steam to generate an equal amount of energy. This is due to the fact that temperatures and pressures associated with geothermal areas are lower than those created at conventional power plants. The greatest potential for geothermal energy in the United States is found in the Rocky Mountain and Pacific regions; some potential (geopressured-geothermal) exists in the Gulf Coastal Plain of Texas and Louisiana. The geyser field in Cali- fornia, which has been producing power since 1969, is the most extensively developed source of geothermal energy in the United States. Exploration efforts also are under way in Imperial Valley, Salton Sea, Mono Lake, and Modoc County, California. Geothermal energy presently accounts for less than 1 percent of total United States’ energy production. The environmental problems associated with geothermal energy principally result from a number of gases that are associated with geothermal systems and that may pose health and pollution problems. These gases include ammonia, boric acid, carbon dioxide, carbon monoxide, hydrogen sulfide, and others. However, adverse air-quality effects are generally less than those as- sociated with fossil-fuel plants. Also associated with geothermal energy systems are saline waters that must be disposed of and isolated from contact with groundwater regimes. Land-quality problems stem from disturbance due to construc- tion of related facilities and possible ground subsidence which, in turn, can cause structural failures and loss of groundwater- storage capacity. Sources: The high cost and rapidly shrinking reserves of traditional energy fuels have encouraged research into new and different sources for potential energy. Some of these alternative sources have been known for decades, but high costs and technical problems have prevented their widespread use. These sources include tidal power, wind power, organic fuels, and ocean-thermal gradients, among others. The date of commercial availability of such alternatives will depend on the cost of the traditional energy fuels, the level of federally subsidized research through Energy Research and Development Administration assistance, and the solution of engineering and technical problems. Environmental effects of these alternatives are difficult to assess, especially since a great amount of research and develop- ment remain to be completed before operational scale systems can be developed, tested, and evaluated for production and application. Combination of Alternatives: A combination of some of the most viable energy sources available to this area, discussed above, could be used to attain an energy equivalent comparable to the estimated production within the anticipated field life of these proposed actions. However, this combination of alterna- tives, in order to attain the needed energy mix peculiar to the infrastructure of this area, would have to consist of energy sources attainable now or within the suggested timeframe that are transferable to the technology presently used. Viable substitutes would have to be available for the petroleum and natural gas required by the petrochemical industrial complex, the petroleum used for the transportation sector, and the elec- tricity and fuels used in residential and commercial sectors. Part II of the Energy Alternatives: A Comparative Analysis, particularly Chapter 16, "Comparing the Economic Costs of Energy Alternatives," discusses the factors that must be involved in developing technically and economically appropriate energy alternatives. With favorable technologies and economies, the most viable domestically available energy alternative would probably consist of the use of coal, oil shale, tar sands, and biomass to produce synthetic liquids; nuclear energy and coal to compete for the utility market; and renewables to supply a sizable portion of total energy requirements. The environmental effects of each of these alternatives have been discussed briefly in the previous paragraphs of this section. The rest will be a long-term energy-supply transition from crude oil and less dependence on oil imports. Such patterns will require new, efficient tech- nologies; major capital investments; and a high rate of growth in coal production. The future United States’ energy-source mix will depend on a multiplicity of factors—the identification of resources, research and development efforts, development of technology, rate of economic growth, the economic climate, changes in lifestyle and priorities, capital investment decisions, energy prices, world oil prices, environmental quality priorities, government policies, and availability of imports. It is unlikely that there will ever be a single definitive choice among energy sources or that development of one source will preclude development of others. Different energy sources will differ in their rates of development and the extent of their contributions to total United States’ energy supplies. Under- standing of the extent to which they may replace or complement offshore oil and gas requires reference to the total national energy picture. It is difficult to predict the extent to which the development of alternative energy supplies may be necessary since other factors are involved, such as the continuing success of energy conserva- tion by the American public, overcoming technical and econom- ic barriers that presently exist in developing other alternative- energy sources, and improving resource-recovery methods to increase the rate of recovery. For more information on these alternative approaches to our Nation’s energy needs, refer to the following: Energy Alternatives: A Comparative Analysis (University of Oklahoma, 1975), which was prepared under contract for BLM; and the Final Environmental Statements for 1982), Sales 58 (USDOI, BLM, 1979) and 70 (USDOI, MMS, APPENDIX J FATE AND EFFECTS OF EXPLORATORY-PHASE OIL AND GAS DRILLING DISCHARGES IN THE CHUKCHI SEA PLANNING AREA, OCS LEASE SALE 126 (Prepared by the USEPA) APPENDIX SERRE Fates and Effects of Exploratory Phase Oil and Gas Drilling Discharges in the Chukchi Sea Planning Area, Lease Sale 126 Prepared for: U.S. Environmental Protection Agency 1200 Sixth Avenue, WD-136 Seattle, WA 98101 Prepared by: Jones & Stokes Associates 1808 - 136th Place N.E. Bellevue, WA 98005 (206) 641-3982 April 30, 1990 TABLE OF CONTENTS INTRODUCTION seat terete claret ets oes al sreye era y one fat et estate tlegeall= PURPOSE OF EVALUATION . SCOPE OF EVALUATION . CURRENT EVALUATION 1DESGRIPTION OF ALTERNATIVES |...0.- 101+ 10 miscic monet ts ainers sma meals CLEAN WATER ACT PERMIT REQUIREMENTS . OCEAN DISCHARGE CRITERIA ............ TECHNOLOGY-BASED EFFLUENT LIMITATIONS LAND DISPOSAL ALTERNATIVES COMPOSITION AND QUANTITY OF MATERIALS DISCHARGES TYPES OF DISCHARGES... . MISCELLANEOUS DISCHARGES . COMPOSITION OF DRILLING MUD GENERAL COMPOSITION ... METAUS | 1a) er aereo Drerie ties CHROME LIGNOSULFONATES SPECIALTY ADDITIVES ..... COMPOSITION OF CUTTINGS ™ QUANTITY OF DRILLING MUDS AND CUTTINGS.................005. 17 FATE AND TRANSPORT OF MUDS AND CUTTINGS .................00. 17 THE CHUKCHI SEA PLANNING AREA ENVIRONMENTAL CONDITIONS )ia tava oe2 Bi? sisi cis liners oe mms we ml ORES asim ae om METEOROLOGY . : ‘ 5 F SEAICE germ CIRCULATION TIDES! wtsesass STRATIFICATION, SALINITY, ‘AND TEMPERATURE . SEDIMENT TRANSPORT SUMMARY... reer sou neresms mas aiaenasint 1 THE OFFSHORE OPERATORS COMMITTEE MODEL ..... DRILLING FLUID FATE FROM OPEN WATER DISPOSAL DILUTION PREDICTED BY THE OOC MODEL DILUTION, DISPERSION, AND SOLIDS ACCUMULATION .. 129 DRILLING FLUID FATE FROM ABOVE-ICE DISPOSAL 29 DRILLING FLUID FATE FROM UNDER-ICE DISPOSAL . - 30 DISCHARGE WITH SHUNTING : SUMMARY, ti: Bae'0 01> kote ole ire ty oe eben ee BIa ALE Ped se tale « ct EFFECTS ON|MARINE: BIOTAi tom stcc. at. eeietein tere ates rs eis ror ere et ars INTRODUCTION ....0.5....5 PHYSICAL CONDITIONS .. COASTAL FOODWEBS ... . VERTEBRATE FAUNA IMPORTANT PLANKTONIC SPECIES PHYTOPLANKTON oa'e scrcae caiearee EFFECTS ON PHYTOPLANKTON . ZOOPLANKTON EFFECT ON ZOOPLANKTON . CONCLUSIONS ...... BENTHIC COMMUNITIES .............- EFFECTS ON BENTHIC COMMUNITIES . CONCLUSIONS FISH RESOURCES ............ EFFECTS ON FISH RESOURCES . MARINE MAMMALS ........... EFFECTS ON MARINE MAMMAL: MARINE AND COASTAL BIRDS ............ 28 EFFECTS ON MARINE AND COASTAL BIRDS ... COMMUNITY EFFECTS COMMERCIAL, SUBSISTENCE, AND RECREATIONAL HARVESTS INTRODUCTION Fon mitts ce cre cule ier oid eee SUBSISTENCE HARVESTS HUMAN HEALTH EFFECTS ....... 0. ccc cece cc ec cee cen eee ereecees 51 EFFECTS OF LAND DISPOSAL .... 1... ccc ee cece tee c eee e ees e ee nee 51 RERERENCES) ¢aicira cars te elt ores vip cte sy Wie bee x fae vote sl sat oor en wah ets 53 EITERATUREOITED rs tr ctys sie - leurs eines eS IEG emecm stmt e 53 Table 10 LIST OF TABLES Estimated Annual Production of Drilling Muds and Cuttings During Exploration and Delineation Activities in the Chukchi Sea Planning Area, Lease Sale 126 ......----- +++ e eee eee> aes Representative Discharges from Alaskan Offshore Exploration RigS ..... 6... eee eee eee eee eens 10 Authorized Drilling Mud Types .....-. 0-2 eee e erences 13 Selected Trace Metal Concentrations Expected in Generic Drilling Muds and in Muds and Additives Discharged in Alaskan Waters ......-.+. 0s eee ees 15 Comparison of the Range of Trace Metal Concentrations in Standard Drilling Muds and Average Earth's Continental Crust ....-..-- 6 eee errr rere 16 Authorized Mud Components/Specialty Additives ..........-- 18 Summary of OOC Model Inputs .....---- 62 seer eee eee 28 Minimum Solids and Dissolved Fraction Dilutions Predicted by the OOC Model for a Point 100 Meters (330 Feet) from Discharge for Deeper Tracts .......-.-.----- 30 Comparison of Expected Dissolved Metal Concentrations at the Edge of the Mixing Zone in Sale 126 to Marine Water Quality Criteria... 6... eee eee eee 36 Summary of Special Bird Sites in the Chukchi Sea Ared) 0. Pe cits alts tery sie ot cred ies es Eade SME ... 48 et LIST OF FIGURES Page Chukchi:Sea:Lease Sale 126 oss asmemermiwmismrwrne twee 5 Winter Ice Zonation of the Chukchi Sea CORSE S75 sie sc ek SMES Sela SS AS EAS ECD Same recenerereae weer 22 Idealized Discharge Plume Behavior ....................0. 25 Solids Deposition Pattern Modeled by OOC for a Drilling Mud Discharge into Water 40 m Deep with Current Speeds of 20 cm/sec.............. 00005 31 Solids Deposition Pattern Modeled by OOC for a Drilling Mud Discharge into Water 70 m Deep with Current Speeds of 10 cm/sec................... 32 PURPOSE OF EVALUATION The U. S. Environmental Protection Agency (EPA) intends to issue a National Pollutant Discharge Elimination System (NPDES) general permit for effluent discharges associated with oil and gas exploration in the Outer Continental Shelf (OCS) Lease Sale 126, Chukchi Sea Planning Basin, Alaska. Authorized discharges from oil and gas drilling operations include drilling muds and cuttings, sanitary and domestic wastewater, desalination unit discharges, boiler blowdown, uncontaminated ballast and bilge water, blowout preventer fluid, excess cement slurry, deck drainage, non-contact cooling water, fire control system test water, and test fluids. Sections 402 and 403 of the Clean Water Act (CWA) require that NPDES permits for such ocean discharges be issued in compliance with EPA's guidelines (Ocean Discharge Criteria authorized under Section 403 of the CWA) for preventing unreasonable degradation of ocean waters. Section 301(c) of the CWA provides that the discharge of pollutants to ocean water is unlawful except in the terms of an NPDES permit. Under EPA's regulations (40 CFR 122.28[a][2]), EPA may issue a single general NPDES permit to a category of point sources located within the same geographical area if the regulated point sources: « involve the same or substantially similiar types of operations; « discharge the same types of wastes; « require the same effluent limitations or operating conditions; * require similar monitoring requirements; and « _ in the opinion of the EPA Regional Administrator, are more appropriately controlled under a general permit than under individual permits. EPA has decided that general permits are more appropriate for effluent discharges associated with oil and gas exploration than individual permits, and EPA expects to issue a general permit for exploratory drilling operations for Sale 126. However, EPA may issue individual NPDES permits for areas requiring special consideration, such as areas of sensitivity or of biological concern, and may elect to issue individual NPDES permits for future development and production operations in the Lease Sale 126 area. Before EPA can issue an NPDES permit to a new source, an environmental review must be conducted pursuant to Section 511 (c)(1) of the CWA. EPA expects to adopt the Sale 126 Final Environmental Impact Statement (FEIS) in order to satisfy this requirement. Ocean discharges must also be evaluated with respect to the Ocean Discharge Criteria developed in accordance with Section 403(c) of the CWA. EPA, e1- “T therefore, agreed to be a cooperating agency in the development of the EIS. The Minerals Management Service (MMS) of the U. S. Department of Interior (DO!) requested that EPA provide an appendix that evaluates the fate of exploration-phase ’ deliberate discharges, and the effects of these discharges on receiving water quality and biological populations. SCOPE OF EVALUATION This appendix evaluates the effects of waste discharges that would be provided for by the general NPDES permit that will be proposed for offshore oil and gas exploration in the Chukchi Sea Planning Basin under federal OCS Lease Sale 126. The appendix evaluates only deliberate wastewater discharges occurring during exploration. It does not evaluate impacts of exploration caused by noise, construction, spills, or other factors; and does not include discharges that occur during development and production. CURRENT EVALUATION MMS has presented three development scenarios which assume different numbers of exploration and delineation wells (Table 1) (DO! 1989). The average exploration and delineation well in the Chukchi Planning Area will be about 3170 meters (10,400 feet) deep, will use about 603 tonnes (660 short tons) of dry mud and will produce about 772 tonnes (850 short tons) of dry rock cuttings (DO! 1989). The first scenario is the low case. Two exploration wells are projected to be drilled in 1992 using a total of 1,206 tonnes (1,319 short tons) of drilling muds and producing a total of 1,544 tonnes (1,700 short tons) of dry rock settings. The second scenario is a base case projection which assumes that exploration will result in the discovery of approximately 910 million barrels of commercially recoverable hydrocarbons. This scenario projects 28 exploratory wells and 11 delineation wells between 1992 and 1998 with discharges of 23,517 tonnes (25,634 short tons) of dry mud and 30,108 tonnes (32,818 short tons) of dry rock cuttings. The third scenario is a high case projection which assumes that the exploration phase will result in the discovery of 1,700 million barrels of commercially recoverable hydrocarbons. Activity is assumed to continue through 2001 with 37 exploration and 16 delineation wells projected. Approximately 44,616 tonnes (34,835 short tons) of drilling muds and 40,932 tonnes (44,616 short tons) of cuttings are expected to be produced during the seven-year period. Estimated Annual Production of Drilling Muds and,cuttings During Exploration and Delineation Activities in the Chukchi Sea Planning Area, Lease Sale 126 Table 1. a2 Exploration” Mud Number of Wells Mud (Tonnes) Number of Wells Number of Rigs cuttings (Tonnes) cuttings (Tonnes) (Tonnes) Year 1544 1,206 1992 Low Case 1544 1,206 Total 3,088 2,316 2,316 772 2,416 1,809 1,809 603 toon woeenan ennenan anwnone AARAADA AAAAAAR AAA AAAS © a a 3 @ a 8,492 6,633 © 5 o a a Total won wooNneenAAA wonneenane 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 High Case 12,352 9,648 16 22,311 28,580 37 Total DoI 1989 Source: The average exploration well is assumed to use 603 tonnes (660 short tons) of dry mud and 772 tonnes (850 short Estimated number of wells and hypothetical drilling schedule. tons) of cuttings. a 2 The average delineation well is assumed to use 603 tonnes (660 short tons) of dry mud and 772 tonnes (850 short tons) of cuttings. a s-t DESCRIPTION OF ALTERNATIVES This section first notes the estimated schedule for activities in the planning area and discusses the requirements applicable to EPA in its development of NPDES permits. Finally, it describes the alternatives being considered as a part of the development of the NPDES permit for the sale area. Sale 126 (Figure 1) is currently scheduled to be held in May, 1990. Exploratory arilling in the blocks leased as a result of this sale could begin in 1992. The first delineation well could be drilled in 1993, the second drilling season. Drilling of exploration and delineation wells could continue through 1998. The amount of time to drill and test exploration wells is estimated to be about 90 days (DOI 1989). W. PI IR N’ Sections 301(b), 304, 306, 308, 401, and 403(c) of the Act provide the basis for NPDES permit conditions. The general requirements of these sections fall into two categories, ocean discharge criteria and technology-based effluent limitations. These sections are described below. OCEAN DISCHARGE CRITERIA EPA's Ocean Discharge Criteria (40 CFR Part 125, Subpart M) set forth specific determinations of unreasonable degradation that must be made prior to permit issuance. "Unreasonable degradation of the marine environment" is defined as (40 CFR 125.121 {e}): “(1) Significant adverse changes in ecosystem diversity, productivity and Stability of the biological community within the area of discharge and surrounding biological communities, (2) | Threat to human health through direct exposure to pollutants or through consumption of exposed aquatic organisms, or (3) Loss of aesthetic, recreational, scientific or economic values, which is unreasonable in relation to the benefit derived from the discharge." The determination of unreasonable degradation must be based on the following factors: quantities, composition, and potential for bioaccumulation or persistence of the pollutants discharged; potential transport of such pollutants; the composition and vulnerability of the biological communities exposed to such pollutants; the importance of the receiving-water area to the surrounding biological community; the existence of special aquatic sites; potential effects on human health; existing or potential effects on recreational and commercial fishing; applicable requirements of approved Coastal Zone Management Plans; marine water quality criteria developed pursuant to section 304(a)(1) of the CWA; and other relevant factors. aa 168° 165° 162° Map Location NORTH cw NO SCALE of LEGEND Proposed Chukchi Sea Sale 126 Area (Alternative 1) (=) Alternative 1V Point Lay Deferral Mn Leased Blocks Cape 68? Figure 1. Chukchi Sea Lease Sale 126 o-f If the EPA Regional Administrator determines that the discharge will not cause unreasonable degradation of the marine environment based upon the above criteria, an NPDES permit may be issued. If the Regional Administrator determines that the discharge will cause unreasonable degradation of the marine environment, an NPDES permit cannot be issued. If the Regional Administrator has insufficient information to determine prior to permit issuance that there will be no unreasonable degradation of the marine environment, an NPDES permit may not be issued unless the Regional Administrator, on the basis of the best available information, determines that: (1) such discharge will not cause irreparable harm (as defined in 40 CFR 125.121[a}) to the marine environment, (2) there are no reasonable alternatives to the on-site disposal of these materials, and (3) the discharge will be in compliance with certain specified permit conditions (40 CFR 125.123[d]) TECHNOLOGY-BASED EFFLUENT LIMITATIONS The CWA requires particular classes of industrial discharges, including those associated with oil and gas exploratory drillings, to meet technology-based effluent limitations established by EPA. The CWA provides for implementation of these effluent limitations in three stages. Best practicable control technology currently available (BPT) was required no later than July 1977. BPT represents the average of the best existing performances of well-known technologies for control of traditional pollutants. EPA set effluent limitation guidelines requiring BPT for the Offshore Subcategory of the Oil and Gas Extraction Point Source Category (40 CFR Part 435, subpart A) on April 13, 1979 (44 FR 22069). BPT for this subcategory limits the discharge of oil and grease in produced water to a daily maximum of 72 milligrams per liter and a 30-day average of 48 milligrams per liter; prohibits the discharge of free oil that would cause a sheen on the water surface in deck drainage, drilling fluids, drill cuttings, and well-treatment fluids; requires a minimum residual chlorine content of 1 milligram per liter in sanitary discharges; and prohibits the discharge of floating solids in sanitary and domestic wastes. Toxic pollutants are controlled by the best-available technology economically achievable (BAT) (40 CFR 401.15), while conventional pollutants, such as oil and grease, biochemical oxygen demand, pH, suspended solids, and fecal coliforms are controlled by the best conventional pollutant control technology (BCT). Controls by BAT and BCT are to be achieved as expeditiously as practicable, but in no case later than three years after the date of final promulgation of technology-based guidelines. In no case are BAT or BCT to be less stringent than the already existing BPT. Permits must impose effluent limitations which control non-conventional (i.e., neither toxic nor conventional) pollutants by means of BAT. Finally, effluent limitations based on the best-demonstrated control technology must be imposed with the development of new-source performance standards (NSPS). BAT/BCT effluent limitation guidelines and NSPS for the Offshore Subcategory were proposed by EPA in August 1985 (50 FR 34592). The guidelines are slated to be -6- proposed again in June 1990. The reproposal will address all applicable wastestreams (drilling muds and cuttings, produced water, produced sand, deck drainage, well treatment fluids, work overfluids, sanitary wastes, and domestic wastes). Promulgation of these guidelines and standards is not expected until July 1991, although proposed rules have been published (53 FR 41358). EPA Region 10 BAT requirements in permits (1) prohibit the discharge of all oil-based muds, diesel oil, and cuttings with either an oil content greater than 10 percent by weight, or cuttings which contain diesel oil, or those that cause a sheen; (2) limit the mercury and cadmium content of barite to 1 milligram per kilogram and 3 milligrams per kilogram (dry weight basis), respectively; (3) set limits for the biochemical oxygen demand of sanitary waste and require a residual chlorine content of no less than 1.0 milligram per liter in the wastes; (4) controls drilling mud and Cuttings toxicity via the drilling fluid formulation process; and (5) set other limits on miscellaneous discharges. Such requirements were incorporated in the general permits for the Bering and Beaufort Seas (49 FR 23734), for Norton Sound (50 FR 23578), for Cook Inlet, the Chukchi Sea, and Beaufort Sea (53 FR 37846). This appendix is based largely on EPA's evaluation (against these criteria) of the effects of discharge resulting from oil and gas exploratory drilling on previous leases issued by MMS for Lease Sales 87, 97, and 109. Preliminary conclusions concerning the fate and effects of drilling effluent discharges, including the results of modelling studies, have been incorporated into this document. LAND DISPOSAL ALTERNATIVES Land disposal must be considered as the alternative to ocean disposal of drilling muds if the NPDES permit conditions are not met or if there is insufficient information to determine that there will be no unreasonable degradation to the marine environment. In the event that EPA decides (on the basis of the Ocean Disposal Criteria Evaluation [ODCE)) to prohibit discharges of drilling muds from exploratory operations , several alternatives and techniques for land disposal are available. These include: storage in pits or sumps; storage in abandoned gravel pits and quarries; direct disposal over land surfaces; and subsurface injection or burial. All land disposal alternatives for offshore drilling will require transportation of drilling muds and fluids to disposal sites. This could be accomplished by barging in the open water and in some locations by truck during the ice-covered season. During freezeup and spring breakup, the muds would ‘have to be stored on site if land disposal is required. COMPOSITION AND QUANTITY OF MATERIALS DISCHARGES This section describes and quantifies the various discharges expected from oil and gas drilling rigs during exploratory and delineation activities. Attention is given to the drilling muds and the specialty additives they contain. TYPES OF DISCHARGES Exploratory oil and gas well drilling can produce a wide range of waste materials related to the drilling process, maintenance of equipment, and personnel housing. The major discharges to be expected from exploratory drilling are drilling fluids (muds), and drilling cuttings and washwater. For exploration wells drilled in 1989 in the Chukchi Sea, discharges of drilling mud did not exceed 100 barrels per hour (2,600 barrels total) and discharges of cuttings ranged up to 90 barrels per hour (1,500 barrels total). Other discharges may include sanitary and domestic wastes, desalination-unit discharge, boiler blowdown, test fluids, deck drainage, non-contact cooling water, blowout-preventer fluid, uncontaminated ballast and bilge water, and excess cement slurry. MISCELLANEOUS DISCHARGES Sanitary waste discharge is expected to be under 37,850 liters (10,000 gallons) per day per rig (Menzie 1983), which consists of chlorinated, perhaps secondary treated, effluent. Upon discharge, immediate dissolved oxygen demand is exerted, which represents the oxygen demand of organic compounds that are rapidly oxidized. Calculations described in EPA (1984a) indicate that the dissolved oxygen depression resulting from the discharge of treated sewage effluent during offshore exploratory drilling will not be significant when ambient dissolved oxygen concentrations are at least 1 milligram per liter above the dissolved oxygen standard for aquatic life. No standards exist for OCS waters; however, in Alaskan inshore waters the standards are 6 milligrams per liter at the surface, 5 milligrams at depth. Since the ambient dissolved oxygen concentration in the receiving water exceeds 8 milligrams per liter, sewage effluent discharge is not expected to significantly impact dissolved oxygen concentrations in the ocean. Domestic waste (shower and sink drainage) is not expected to produce a significant discharge flow, usually less than 30,280 liters (8,000 gallons) per day, and is sometimes reused to make drilling mud rather than discharged directly (Jones & Stokes Associates 1984), Average discharge rates from an Alaskan offshore exploration rig are presented in Table 2. Sanitary and domestic discharges from three wells drilled in 1989 ranged from 15,140 liters (4,000 gallons) per day to 49,205 liters (13,000 gallons) per day. The blowout preventer may be located on the sea floor or on the drilling platform. This device is designed to contain pressures in the well that cannot be contained by the drilling mud. Fluid may be discharged when the blowout preventer is actuated, generally on a weekly basis for testing. Some self-contained blowout preventers are now in use. The primary constituents of blowout preventer fluid are ethylene glycol and water (Jones & Stokes Associates 1984). This is not highly toxic; Price et al. Bie 1974, report the LC,, for brine shrimp to be 20,000 mg/l. Zajic and Himmelman (1978) consider the hazard of this compound to be "minor." Some proprietary formulations are also used. The volume of fluid discharged when the device is actuated needs to be monitored. A representative discharge estimate obtained from industry discharge monitoring reports is 757 liters (200 gallons) per day. This estimate may be high (Jones & Stokes Associates 1984). Blowout preventer discharges ranged from no discharge to 481 liters (127 gallons) per day from three wells drilled in the Chukchi Sea Lease Area in 1989. Cement, along with spud mud and cuttings, will be discharged from drillships. It will also be discharged on the ocean floor in the early phases of drilling before the well casing is set, and during well abandonment and plugging. Excess cement slurry will result from equipment washdown after cementing operations. The exact composition of the cement is not documented. Consequently, its composition should be either defined or an aquatic toxicity test conducted to define its hazard potential. It is generally expected to be nontoxic (Jones & Stokes Associates 1984). Discharge volumes ranged from no discharges to 56,775 (15,000 gallons) per day from wells drilled in 1989 in the Sale 109 area. Desalination-units may discharge on the order of 757,000 liters (200,000 gallons) per day per rig of water having salinity twice that of ambient seawater, although discharges from three exploration wells drilled in 1989 only discharged up to 87,000 liters (23,000 gallons) per day. Boiler blowdown may be discharged once or twice a year per rig in volumes up to 666 liters (176 gallons). Both of these discharges may contain biocides or chemicals used to combat corrosion and scaling. The volume of boiler blowdown is so small that it is unlikely to be a significant source of pollution. Desalination-unit water could result in significant mass loadings of pollutants into the immediate marine environment if the chemicals are not consumed or detoxified prior to discharge. Test fluids are discharged from the well upon completion of drilling. These may consist of formation water, oil, natural gas formation sands, any acids or chemicals added downhole, or any combination thereof. Test fluids are generally stored and treated for oil removal and pH before being discharged or flared. Approximately 1 percent of the total test fluids will have a pH of 2. During a typical 5-day well test, this may involve 8,000 liters (2,110 gallons) of water. The addition of strong acidic fluids downhole could cause significant leaching of heavy metals from the formation and residual drilling muds. The remaining test fluids will have a pH of 5 to 8.5, with about 97 percent of the volume above pH 6.5. The permit will require neutralization (pH 6.5 to 8.5) of all spent acidic fluids before discharge. Some deck drainage and fire control system test water may be produced and discharged during summer months. This would consist of rain and washwater from the deck and drilling floor, as well as water used to test the fire control system. Gutters normally carry the drainage to a sump tank where oil is separated and removed before the water is discharged. Oil is the primary pollutant in deck drainage, with a reported range of 24 to 450 milligrams per liter, but these discharges may also contain small quantities of detergents used in cleaning procedures and spilled drilling mud or chemicals (Mors et al. 1982). 10/01-10/12 137 2,165 139° 15,294 12,150 145,800 2,068 6,892 39 4,679 1,956 2177 78,950 25,080 752,400 2,124 7,080 9/01-9/30 8/32? No? ND ND 21,600 2,280 7,600 21,600 BPH = barrels per hour; BBL = barrels; GPD = ed representative Alaskan offshore exploration a 09 172° 58,698 8/01-8/31 ale2 1,679 13,940 418,200 2,075 6,917 8-r 7/01-7/31 10 2,845 389 236° 79,213 13,006 403,200 2,427 8,084 6/10-6/30 30 4,406 4 257 35,1384 13,630 282,000 2,225 7,419 3 GAL = gallons. Rig relocated to new exploration block. No discharge. -submersible rig at two wells in the Navarin Basin, 1985 erage BPH Total Maximum BSL Discharge, Units ‘Average BPH Total Maximum BBL Average BPH Total Maximum BBL Average GPD Total Maximum GAL Average GPD Average GPD Includes cuttings. Maximum mud, cuttings and washwater reported as 532 BPH. seni gallons per Maximum mud, cuttings and washwater reported as 875 BPH. Maximum mud, cuttings and washwater reported as 438 BPH. Maximum mud, cuttings and washwater reported as 575 BPH. Table 2. Representative Discharges from Alaskan Offshore Exploration Rigs? 3 § & : = 5 3 & 5 $ g ; £ b 5 8 z ; i s 2 E 3 § Hl S 2 5 § § iz Z g < é E E 3 a aI 8 8 Drilling Mud Deck Drainage Sanitary Waste Domestic waste Washvater cuttings 2 3 4 5 6 iz 8 1 » ° ' Generally, except for an elevated temperature, the composition of non-contact cooling water will not significantly differ from ambient seawater (Jones & Stokes Associates 1984). Oil-water separators are used to treat bilge waters for removal of petroleum hydrocarbons prior to discharge. While ballasts waters are untreated, the permit prohibits discharges that will produce an oil sheen. The volume of non-contact cooling water can vary depending on the system used. Closed-system, air-cooled designs require no cooling water, whereas other systems may discharge up to 7 million liters (1.87 million gallons) per day. Reported temperatures range from 18 to 2&C (62 to 84°F), much higher than ambient seawater. Biocides may be used to control fouling in the heat exchange units (Zimmerman and de Nagy 1984). The volumes of cooling-water discharge could result in significant mass loadings of pollutants into the immediate marine environment if the chemicals are not consumed or significantly detoxified prior to discharge. Bilge waters are treated for removal of oil prior to discharge. Ballast waters are not treated; however, the permit will prohibit discharges that produce an oil sheen. In summary, discharges other than drilling mud and cuttings are expected to represent only small pollutant loadings from offshore exploratory drilling operations using properly designed and functioning equipment. Potential pollutant loadings could result from deck drainage, biocides, corrosion inhibitors, and scale preventors and the following precautions appear warranted: . cooling-water and desalination-unit discharges (and any other high volume discharge) should be monitored for volume of discharge and the chemical composition and concentration of biocides, corrosion inhibitors, or other chemical additives; . heavy metal concentrations in spent test fluids should be determined; . oil separators or sump tanks should be used for deck drainage, and the oil disposed of safely; and . no solid waste should be thrown into the sea. COMPOSITION OF DRILLING MUD GENERAL COMPOSITION Drilling muds are complex mixtures of clays, barite, and specialty additives used primarily to remove rock particles from the hole created by the drill bit. The composition of drilling mud can vary over a wide range from one hole to the next, as well as during the drilling of a specific hole. Drilling muds serve several other functions in addition to removing solids. These include creating pressure to counteract pressure encountered in the formation at depth and controlling the flow of fluids between the formation and the hole. As the hole -11- 6-7 becomes deeper and encounters different formations, the type of mud may need to be changed or the composition altered. Six generic water-based mud (WBM) types have been evaluated and approved by the EPA during previous permit development. Table 3 lists the basic components of each mud and the maximum allowable concentration of each base component (53 FR 37846). Maximum values represent the present authorized maximum concentrations. Each mud differs in its basic components, and a single mud type can vary substantially in composition. Specialty additives may also be incorporated. Oil-based drilling muds may be used but are not allowed to be discharged because they violate the effluent limitation of no discharge of free oil. “Oil-based" means that the mud or fluid contains oil as the continuous phase, with water as the dispersed phase. Additionally, the discharge of drilling muds and associated cuttings which have been contaminated by diesel oil is prohibited. METALS The presence of potentially toxic trace elements in drilling muds and cuttings is a concern. Metals, including lead, zinc, mercury, arsenic, vanadium, and cadmium, can be present as impurities in barite; chromium is present in chrome lignosulfonates and chrome treated lignite (Crippen et al. 1980; Menzie 1982). According to Ayers et al. (1980), drill pipe dope (15 percent copper, 7 percent lead) and drill collar dope (35 percent zinc, 20 percent lead, 7 percent copper) also contribute trace metals to the muds and cuttings discharge. Trace metal concentrations expected in drilling muds used in oil and gas exploratory drilling are given in Table 4. Two values are given. The metals content of the generic muds prior to use was analyzed by CENTEC (1984) and these values are reported in Column 1. The metals content of the discharges, which consist of both generic muds and additives, is reported in DMRs, and maximum metal concentration values from the reported data are given in Column 2. The difference in concentrations is substantial for barium, cadmium, chromium, lead, mercury, nickel, and zinc. Arsenic and copper change very little. This difference can be attributed to authorized specialty additives, incidental contamination from pipe dope, and differences in laboratory analyses and sample sources. The range of metal concentrations in the drilling discharge is compared to average concentrations of the metals observed in the Earth’s continental crust and in Alaskan OCS sediments (Table 5). With the exception of copper, all the listed metals can occur at concentrations greater than average continental crust or Alaskan OCS sediments. Barium in drilling muds is present at two orders of magnitude or greater concentration than any other trace metal. =12%- Table 3. Authorized Drilling Mud Types Maximum Allowable Maximum Allowable Components Concentration (tb/bbl) Components: Concentration (ib/bdi) lt Ps i 4. Mon:Dispersed mud KCl 50 Bentonite 50 Starch 12 Acrylic Polymer 2 Cellulose Polymer 5 Lime 2 Xanthum Gum Polymer Drilled Solids Caustic Barite er/Freshwater Scawater/tignosul fete Mud Bentonite!” Lignosul fate, Chrome, or Ferrochrome Lignite, Untreated or Chrome-treated Coustic Lime Barite Drilled Solids Soda Ash/Sodium Bicarbonate Cellulose Polymer Seawater/Freshwater kime Mud Lime Bentonite!” Lignosulfate, Chrome, or Ferrochrome Lignite, Untreated or Chrome-treated Caustic Borite Drilled Solids Soda Ash/Sodium Bicarbonate Seawater/Freshwater Source: 53 £R 37846 100 575 As Needed 50 1S 10 575 100 ‘AS Needed 15 10 S75 100 As Needed Barite Orilled Solids Seawater/Freshwater Spud Hud Lime Bentonite!’ Caustic Barite Soda Ash/Sodium Bicarbonate Seowater Seawater/Freshwater Gel Mud Lime Bentonite!’ Caustic Barite Drilled Solids Soda Ash/Sodium Bicarbonate Cellulose Polymer Seawater/Freshwater Attapulgite, sepiolite, or montmorillonite may be subsituted for bentonite. 180 70 As Needed 50 50 As Needed $0 50 100 As Needed E49= o.-r CHROME LIGNOSULFONATES Chrome lignosulfonates are present in two of the six generic muds approved for offshore drilling. When added to drilling fluids, chrome lignosulfonates adsorb to the clay component, inhibiting flocculation and loss of viscosity during use. However, chrome lignosulfonates are readily soluble in water (approximately 500 grams per liter (Knox 1978]), and the extent to which they may be displaced from drilling muds during use, or by seawater ions after discharge, has not been determined. Chrome lignosulfonates resist decomposition and persist in the marine environment for long periods of time. They are a major source of chromium, and their impacts on the biota will be addressed in a later section. The proportion of total chromium in the discharge that is actually combined with used lignosulfonates is unknown (Liss et al. 1980). Marine sediments are the likely repository for discharged chrome lignosulfonates. The fate of these compounds in marine sediments is unclear. Because they are water soluble, the potential exists for slow release into sedimentary pore waters and/or reintroduction into bottom waters by resuspension or bioturbation, increasing their availability to marine organisms. All evidence points to minimal degradation by either abiotic (strictly chemical) degradation (Sarkanen and Ludwig 1971) or microbial breakdown (Crawford 1981). This evidence is supported by published studies of lignin distributions in marine sediments that indicate minimal in sity degradation periods in excess of 10,000 years (Hedges and Van Green 1982). This indicates that chrome lignosulfonates will persist in the sediments for long periods of time. SPECIALTY ADDITIVES In addition to the substances listed in Table 3 that make up the six generic mud types approved for use by EPA, a group of downhole additives are used for specific problems that may be encountered in the course of drilling. These additives can range from simple inorganic salts to complex organic polymers. Table 6 lists the more common additives in water-based drilling muds. Among the additives used in large enough quantities to result in significant mass loadings to the environment are: spotting materials, lubricants, zinc compounds, biocides, and materials added to prevent loss of circulation. Spotting materials are used to help free stuck drill strings. Some of these (e.9., vegetable oil or fatty acid glycerol) are easily broken down in the environment. The most effective and consequently most frequently used spotting compounds are oil based. Previous oil and exploration NPDES permits have authorized, with restrictions, the use of mineral oil as a spotting agent (53 FR 37846). The discharge of muds and Cuttings contaminated by diesel oil, spots, or oil-based muds is prohibited. In normal situations, 8,000 to 32,000 liters (50 to 220 barrels). of spotting material are sent downhole in a concentrated pill (not diluted throughout the mud system) (EPA 1984b). -14- Table 4. Selected Trace Metal Concentrations Expected in Generic Drilling Muds and in Muds and Additives Discharged in Alaskan Waters Maximum Concentration (mg/kq) Muds Discharged Metal Generic Muds' in Alaskan Waters* Arsenic 17.2 11.8 Barium 1,240 298,800 Cadmium 0.7 5.5 Chromium 908 1,820 Copper 77.3 47.7 Lead 52.2 1,270° Mercury 0.7 194 Nickel 9.8 88° Vanadium n/a’ 235° Zine 90.4 3,420 CENTEC (1984). The muds were hot-rolled prior to analysis to simulate chemical changes induced by downhold conditions. EPA (1988b). Reported in mg/kg solids. Only one operator, using Generic Mud #8, discharged muds with this high concentration of lead. The average of 100 records is 33.1 mg/kg with a standard deviation of 127.8 mg/kg. Only one operator, using Generic Mud #7, discharged muds with this high concentration of mercury. The average of 100 records is 0.36 mg/kg with a standard deviation of 1.86 mg/kg. Northern Technical Service, 1981, p. 91. Reported in ppm drilling fluid. Not available. = 15x tir Table 5. Comparison of the Range of Trace Metal Concentrations in Standard Drilling Muds and Average Earth's Continental Crust Drilling Muds' Continental (mg/kg dry weight Crust Metal of whole mud) (mg/kg)? Arsenic 11.8 1.8 Barium 298,800 425 Cadmium 5.5 0.15 Chromium 1,820 120 Copper 47.7 60 Lead 1,270 14 Mercury 19 0.08 Nickel 88 84 Vanadium 235 120 Zinc 3,420 70 ' From Table 3. Maximum metals concentration of muds and additives discharged to Alaskan waters. Ronov and Yaroshevsky 1972, pp. 252-254. Concentrations within the pill may approach 100 percent oil. When the drill string is unstuck, the spotting material can sometimes be brought out as a plug to a separate holding tank and residual oil content in the mud will remain at approximately 2 percent. However, if the drill string remains stuck, the pill of spotting material is left downhole with the abandoned drill string. If the oil is left to mix with the drilling muds, average concentrations of up to 10 percent oil can be reached in the drilling muds. Lubricants are added to the drilling mud when high torque conditions are encountered on the drill string. These lubricants can be vegetable or mineral oil or asphalt-based compounds such as Soltex. When needed, these lubricants are used to treat the entire mud system (roughly 320,000 liters [2,000 barrels}) with concentrations Of 5.5 to 140 kilograms per cubic meter (2.5 to 63 pounds per barrel). Zinc compounds (@.g., zinc carbonate) are used as sulfide scavengers when formations with hydrogen sulfide are encountered. The entire mud system is treated with zinc compounds as needed. Typically, concentrations of 1.5 to 5.5 kilograms zinc compounds per cubic meter of mud (0.6 to 2.5 pounds per barrel) are used, resulting in 450 to 1,800 kilograms (990 to 4,000 pounds) of zinc carbonate (240 to 940 kilograms (530 to 2,070 pounds] of zinc) in the drilling mud. The zinc sulfide and unreacted zinc compounds are discharged with the drilling mud into the environment. In cases of lost circulation to the mud system, combinations of cellophane, mica, and walnut hulls are added to the mud in one of two methods. The entire system can be treated with typically 0.2 to 2.0 kilograms (0.5 to 5 pounds) per barrel, which results in 220 to 2,200 kilograms (484 to 4,840 pounds) of the additives to the system. -16- Alternately, a pill of 100 to 200 barrels with a concentration of 9 to 27 kilograms (20 to 60 pounds) per barrel can be sent downhole (EPA 1984b). When drilling is resumed, the additives are separated out from the drilling mud and discharged with the cuttings COMPOSITION OF CUTTINGS The trace metal concentrations listed for the earth's continental crust are an indicator of the concentrations to be expected in the cuttings. It should be noted, however, that the trace metal concentrations in mud and the natural rock could vary well beyond the range noted in Table 5. Most of the trace metals in the cuttings are likely to be located in the mineral structure of the rock formation. Cuttings typically occur as granular material similar to coarse sand. QUANTITY OF DRILLING MUDS AND CUTTINGS The estimated quantities of drilling muds and cuttings to be disposed of under each scenario are described on page 2 of this appendix and are given in Table 1. A total of 19,680 tonnes (21,648 short tons) of drilling mud and 31,652 tonnes (34,817 short tons) of cuttings are projected under the high case scenario. The rate of discharge during a well drilling operation is quite variable. There are periods of no discharge when drill bits are changed or casing is placed. During the actual drilling and circulation of the drilling mud, cuttings are brought up from the hole, removed by solids control equipment (approximately 90 to 95 percent efficient), and discharged relatively continuously. Drilling mud is discharged in bulk when mud type is changed, during cementing operations, or at the end of drilling. Bulk discharge rates have been reported to range from 4,800 to 190,000 liters per hour (30 to 1,200 barrels per hour) with the total volumes discharged over 1.5 to 3.5 hours and ranging from 15,900 to over 320,000 liters (100 to 2,000 barrels). TI N: AN. This assessment relies extensively on the results of computer simulation modeling of dispersion and dilution of drilling muds. Oceanographic conditions are briefly described, then the model and verification studies are presented, and the results of the modeling runs are discussed. Factors influencing the transport and persistence of discharged drilling muds and Cuttings include oceanographic characteristics of the receiving water, depth of discharge, discharge rate, and method of disposal. Because ice covers the'lease sale area during most of the year, three disposal methods are discussed in this section: on- ice disposal, open-water disposal, and below-ice discharge. Oceanographic influences include tide, wind, freshwater overflow, ice movement, stratification, and current regime. “47> eu-r Table 6. Authorized Mud Components/Specialty Additives Product Name Generic Description’ Maximum Allowable Concentration (1b/bbl unless, otherwise noted)? Aktflo-s Aluminum stearate Ammonium nitrate Aqua-Spot Bara Brine Defoam Ben-Ex Bit Lube II Calcium carbide Cellophane flakes Chemtrol-x Con Det D-D DMS Desco CF Duovis Durenex Flakes of silicate Aqueous solution of non- ionic modified phenol (equivalent of DMS) Sulfonated vegetable ester formulation Dimethyl polysiloxane in an aqueous emulsion vinyl acetate/maleic anhydride copolymer Fatty acid esters and alkyl phenolic sulfides in a solvent base Polymer treated humate Water solution of anionic surfactants Blend of surfactants Aqueous solution of nonionic modified phenol Chrome-free organic mud thinner containing sulfomethylated tannin Xanthan gum Lignite/resin blend -18- 32 0.2 200 mg/L nitrate or 0.05 lb/bbl 1% by vol. As needed As needed 45 Product Name Maximum Allowable Concentration (1b/bbl unless, otherwise Generic Description’ noted) mineral mica Gelex Glass beads LD-8 Lube-106 Lubri-Sal MD (IMCO) Milchem MD Mil-Gard Nut hulls, crushed granular Phosphoric acid esters and triethanolamine Plastic spheres Poly RX Resinex Selec-Floc Sodium chloride Sodium nitrate Sodium polyacrylate and polyacrylamide Aluminum stearate in propoxylated oleylalcohol Oleates in mixed alcohols Vegetable ester formulation Fatty acid ester Ethoxylated alcohol formulation Basic zinc carbonate Polymer treated humate Reacted phenol-formaldhyde- urea resin containing no free phenol, urea, or formaldehyde High molecular weight poly- acrylamide polymer packaging in light mineral oil -19- 2 10 gal/1500 bbl 2 2.0% (by vol) 0.25? 0.04 gal/bbl or 0.3 lb/bbl? As needed As needed 0.25 50,000 mg/L chloride 200 mg/L nitrate or 0.05 lb/bbl €_-r Product Name Generic Description’ Maximum Allowable Concentration (1b/bbl unless, otherwise noted) */ Sodium polyphosphate Soltex Sulf-x ES Therma Check Therma Thin Torg-Trim II Vegetable plus polymer fibers, flakes, and granules VG-69 XC Polymer XO, Zinc carbonate and lime Source: 53 FR 37846 1 Sulfonated asphalt residuum Zinc oxide Sulfono-acrylamide copolymer Polycarboxylic acid salt Liquid triglycerides in vegetable oil Organophilic clay Xanthan gum polymer Ammonium bisulfite As needed 1 50 12 2 0.5 As needed Any proprietary formulation that contains a substance which is an intentional component of the formulation, other than those specifically described, must be authorized by the Director. 2 If a listed product will be used in combination with other functionally equivalent products, the maximum allowable concentration (MAC) for the sum of all of the products is the lowest MAC for any of the individual products. Four examples of functionally equivalent products are: (1) Aktaflo-S and DMS, MAC lb/bb1; (2) Ben-Ex and Gelex, MAC = 1 lb/bbl; (3) Chemtrol-x, Durenex, Poly RX, and Resinex, MAC = 4 lb/bbl, and (4) Con Det, D- D, MD (IMCO), and Milchem MD, MAC = 0.25 lb/bbl. For these examples, the MAC for any combination of the products is given in parentheses. For guidance on whether other products are considered to be functional equivalents, contact the regional office of EPA. a THE CHUKCHI SEA PLANNING AREA ENVIRONMENTAL CONDITIONS The lease area encompasses continental shelf and ocean basin waters. The proposed Sale 126 encompasses about 12 million hectares (29 million acres) located offshore along the Alaskan coast north from Cape Lisburne to Peard Bay and extending offshore to 1692 W. Longitude and northwards to 73 N. Latitude. All of the water depths in the lease sale area are less than 60 meters. The majority (75 percent) of Sale 126 lies in water depths between 40 meters (130 feet) and 60 meters (200 feet). METEOROLOGY The lease sale area is in the Arctic climate zone. The mean annual temperature is -12C. Low levels of solar energy during the winter (roughly October to May) produce low temperatures and a harsh environment. The sun remains below the horizon for 49 consecutive days during midwinter. SEA ICE The lease sale area is essentially ice covered for all but four months of the year. Breakup typically begins as early as May. Open water conditions typically persist though September, when the refreezing process begins. Open water leads frequently occur early in the melt season along the coastal zone. Sea ice in the nearshore region is more mobile during the breakup and freezeup periods than it is during winter. The ice is primarily driven by winds and by ocean current forces. Displacement of the ice may be up to several miles per day during these periods. As a first approximation, wind-driven sea ice moves at a rate of about 2.5 percent of the velocity of the wind (Pritchard and Stringer 1981). During the spring the sea ice is relatively weaker than it is in the winter, and in the fall it is relatively thinner. Based on observation of the dynamic behavior and the location of the structural types of sea ice, the winter ice regime of the coastal Chuckchi Sea may be divided into the landfast ice zone, shear or stamukhi zone, and the pack ice zone (Figure 2). The lease area is within the pack ice zone. The location of these zones varies spatially and temporally and is strongly influenced by bathymetry and the position of offshore island sand shoals. The boundaries between these zones are, for the most part, gradational. -21- vi-r w Zz S 8 Py S ¥ S é STAMUKHI ZONE LAND FAST ICE ZONE GROUNDED RIDGE ZONE FLOATING FAST ICE BO FAST ICE] MULTI-YEAR RIDGE GOUGED ICE tt ACTIVE TIDAL CRACKS (C TRACES OF FORMER ACTIVE TIDAL CRACKS Figure 2. Winter Ice Zonation of the Chukchi Sea Coast CIRCULATION A warm current, originating in the Bering Strait flows northeastward through the Chuckchi Sea. This water converges toward the coast near Pt. Barrow where it enters the Beaufort Gyre. Nearshore currents have the same general northeasterly drift of the offshore flow, however they may be locally disrupted by topography and storms.CURRENTS Currents measured in the Chukchi Sea during the summer months range from less than two to greater than 50 centimeters per second, the latter being measured at the onset of a storm in mid-August. Details of these measurements for the lease sale area are given in the Sale 109 ODCE (EPA 1988b). TIDES Tides in the lease sale area are semi-diurnal and of low amplitude, with a range between 2 to 20 centimeters (1 to 10 inches). Semidiurnal tides in Ledyard Bay have an amplitude of 3 centimeters (1.1 inch). Meteorological tides (storm surges) are much more important than astronomical tides in coastal waters. Variations in water level of +3 meters to -0.9 meters (+10 feet to -3 feet) may result from a storm surge. STRATIFICATION, SALINITY, AND TEMPERATURE Nearshore salinity measurements have identified a two-layer system. The upper layer, consisting of fresher water from riverine input, rests on top of a layer containing more saline oceanic water. The surface layer shows a marked decrease in salinity in proximity to major rivers such as the Kukpowruk River. Freshwater input also causes a marked division between nearshore and offshore waters, often occurring near the 6 meter (20 foot) isobath. Details of the relevant studies may be found in the Sale 109 ODCE (EPA 1988b). In general, the summer surface salinity over the shelf ranges from less than 5 to 30 parts per thousand. At 10 meters (33 feet) salinities range from 25 to 30 parts per thousand and at 30 meters (100 feet) salinities vary from 31 to 32.5 parts per thousand (EPA 1984b). Surface and 10 meter (33 foot) temperatures range from -1 to @C. At 30 meters (100 feet), they vary from -1 to 7C (EPA 1984b). In the winter, the lack of freshwater supply to the coast and salt leaching from sea ice both contribute to a weak winter stratification. At these cold temperatures, water densities are determined by salinities and not temperatures. SEDIMENT TRANSPORT Several factors influence the rate and quantity of sediment transport in the Chukchi Sea, including ice gouging, entrainment in sea ice, wave action, currents, and bioturbation. Sediments on the inner shelf landward of the 20 meter (66 foot) isobath are influenced strongly by waves and currents. The bulk of sediment on the Alaskan shelf is transported northwards on the inner shelf because this is the prominent current -23- si-r direction. However, there are a number of embayments along the coast within which Currents are weak. Erosion and transport of sediments to and from these regions is infrequent. The Sales 87, 97, and 109 ODCE (EPA 1984b, 1988a, 1988b) also noted that sediments experience intensive reworking by currents in areas landward of the 15 meter (50 foot) isobath. Such processes are also active in the Chukchi Sea coastal waters. Catastrophic transport associated with severe storms is an important transport mode and is particularly effective in the fall months when such storms are associated with fresh ice which enhances the erosion and often entraps sediments in new ice. In the spring, the breakup of this dirty ice may result in sediment being deposited large distances from the point of entrapment. Sediment transport is variable and extremely limited over most of the lease area. Discharged material is anticipated to remain at its initial settling location. SUMMARY The Lease Sale 126 oceanographic conditions can be summarized as follows: = The area is ice covered much of the year, except for open water during a four month summer. » Current speeds are between 2 to 4 centimeters per second (0.04 to 0.08 knots) with speeds of 10 to 15 centimeters per second (0.2 to 0.3 knots) over the continental shelf and in some eddies. Current speed and water exchange are increased with wind stress. «= The water column is stratified in summer and relatively homogeneous in winter. « Sediment transport occurs primarily during the summer and transition seasons. = Sediment is transported by intense storms and, in shallower waters, ice; otherwise, natural sediment transport rates are low. THE OFFSHORE OPERATORS COMMITTEE MODEL The prediction of the fate of discharged muds and tailings relies on a computer model developed by a consortium effort of offshore operators. The Offshore Operators Committee (OOC) model was developed to describe the fate of offshore drilling mud discharges and has been used in all Ocean Discharged Criteria Evaluations prepared for Alaskan waters. The model simulates the amount of material settling on the bottom. It is discussed in detail in Brandsma et al. (1983), Tetra Tech (1984), and EPA (1984b, 1988a). Field and laboratory experiments provide a qualified understanding of discharge Plume behavior (Figure 3). The studies indicate that discharge of drilling mud and Cuttings separate into an upper and lower plume (EPA 1984b, 1988a). The upper -24- CROSS SECTION CLOUD CROSS SECTION JAMIC COLLAPSE PASSIVE DIFFUSION DIFFUSIVE SPREADING GREATER THAN DYNAMIC SPREADING NOTE: CROSS-SECTIONS ARE SHOWN AT THREE STAGES OF THE PLUME. A HEAVY CLASS OF PARTICLES IS DEPICTED SETTLING OUT OF THE PLUME AT AN EARLY STAGE. LIGHTER PARTICLES ARE SHOWN SETTLING DURING THE DYNAMIC COLLAPSE PHASE. VERY FINE PARTICLES ARE SHOWN LEAVING THE PLUME SHORTLY AFTER DISCHARGE AND REMAINING NEAR THE SURFACE TO FORM THE VISIBLE PLUME. SOURCE: ADAPTED FROM BRANDSMA ETAL. 1980. Figure 3. Idealized Discharge Plume Behavior. -25- oir plume is subject to physical transport processes very different from those influencing the lower plume. The lower plume contains the bulk of the solids (over 90 percent) and descends rapidly (faster than the rate predicted by Stokes’ law for individual particles). The lower plume usually has not-been studied. The lower plume initially forms a circular jet with negative buoyancy and momentum. As the jet descends, ambient fluids are entrained and the plume grows larger and less dense. The jet remains in a convective descent phase until it reaches the level of neutral buoyancy or hits the seafloor where it spreads radially outward. At the level of neutral buoyancy, the material in the jet travels at mean velocity similar to “the ambient fluid (EPA 1984b, 1988a, 1988b). Most field experiments indicate that discharged drilling materials settle mainly near the discharge point. Advection of discharged solids strongly influences solids accumulation patterns, especially in shallow water. Increased currents can resuspend or laterally transport effluent flows away from the discharge point (EPA 1984b, 1988a). Several studies have been conducted to determine the magnitude of initial dilution of drilling discharges, including several studies from the Beaufort Sea area. Details of these studies may be found in the Sale 87 ODCE and the Sale 97 ODCE. Due to difficulty of obtaining measurements for the lower plume, dilution data refer only to the upper plume. Overall, solids dilutions from 1,000:1 to greater than 10,000:1 have been measured in the upper plume at the edge of the mixing zone (100 meters [330 feet]) during OCS studies. Due to the presence of sea ice, which is a dominant feature of the lease sale area, dilution may be much less than observed elsewhere because under-ice currents are weaker. Dilutions on the order of 200:1 -- several orders of magnitude lower than dilutions typical of open water -- were observed by Northern Technical Services (1983) from a discharge from Tern Island, a gravel island in the nearshore Beaufort Sea. Virtually all solids and some soluble components present in drilling mud discharges are eventually deposited in seafloor sediments downcurrent from the discharge point. Deposition characteristics and patterns are extremely variable and are strongly influenced by several factors, including type and quality of mud discharged, hydrographic conditions at the time of discharge, and height above the bottom at which discharges are made (EPA 1984b, 1988a, 1988b). According to the Sale 87 ODCE and the Sale 97 ODCE (EPA 1984b, 1988a), studies have shown that accumulation of drilling materials on the seafloor is inversely related to the energy dynamics of the ambient environment. A low energy environment does not possess currents capable of removing or vertically mixing deposited material Metals associated with the drilling muds have been shown to accumulate in surficial bottom sediments, but the distribution is extremely uneven. Of the drilling mud components, barium is present in the highest concentrations in sediments downcurrent of the discharge point. This is due to its high concentration in the drilling mud, insolubility, and high density. Generally, there is a gradient of decreasing concentration of deposited materials with distance from the discharge point. The greatest deposition usually occurs directly under or a short distance away from the -26- discharge point. Major deposition usually occurs within 100 meters (330 feet) of the discharge point, and background level concentrations of heavy metals are usually achieved within 1,000 meters (3,300 feet) downcurrent (EPA 1984b, 1988a) The OOC model uses LaGrangian calculations to track material settling out of a fixed pipe. A Gaussian formulation is used to sum the three components and to track the distribution of solids to the bottom. Although there are limitations to this model (it does not account for mud flocculation, and it does not simulate produced water), it is considered one of the best available for modeling discharge plume behavior in water depths greater than 5 meters (16 feet) and when surface waves induce variations in water depth of less than 10 percent (Tarnay, undated). The model simulates the effluent plume through three phases: the jet-phase (convective) descent; the dynamic collapse of the plume; and a later passive diffusion phase. In addition, the model simulates an upper cloud of material which appears as particles of mud separate from the main plume during its convective descent phase. The spread of muds and cuttings on the bottom increases with water depth; in-water dilutions also are greater with increasing depths. Inputs to the model include data from three parametric categories; drilling mud characteristics, discharge conditions, and ambient conditions (Table 7). Drilling mud characteristics consist of bulk density, discrete particle classes, and concentration, density, and settling velocity for each particle class. Discharge conditions include rate, duration, orientation, and position of discharge, and rig type. Ambient conditions include water depth, density profile, current velocity, and wave conditions. For the model simulations, it was assumed that 10 percent of the mud separated in a linear fashion during the convective descent phase of the main plume. Initial concentrations of suspended solids in the discharge are assumed to be 1,441,000 milligrams per liter. Ocean currents are assigned a constant magnitude and direction for each model run, although in reality they vary with depth and time. A consequence of this assumption is overestimation of solids accumulations on the bottom and underestimation of dilutions. Typical drilling rig and discharge characteristics are assumed for a rig of 60 by 70 meters (200 by 230 feet), a discharge nozzle radius of 10 centimeters (4 inches), and a vertical angle of discharge. The model assumes the discharge occurs 0.3 meters (1 foot) below the sea surface, although in reality the depths are greater than this to ensure the discharge is below the wave action at the surface. It is assumed that 1,000 barrels per hour are discharged, which is at the upper limit of discharge rates (Tarnay, undated). The model has been calibrated using field measurements taken at several continental shelf drilling sites including the Gulf of Alaska. The field studies and modeling effort suggest the following conclusions: . Drilling muds tend to be rapidly diluted over space and time. Concentrations can be reduced three to four orders of magnitude within 100 meters (330 feet) of the discharge, and five to six orders of magnitude within 800 meters (2,600 feet). a27= 4i-f Table 7. Summary of O0C Model Inputs Category Variable Typical Value’ Discharge Conditions Rate 100-1,000 bbt/n Duration 30-60 min Angle (from horizontal) 90° Depth Below Surface 0.3 m (1.0 ft) Nozzle Radius 0.1 m (0.33 ft) Rig Length 70.1 m (230 ft) Rig width 61.0 m (200 ft) Forced Separation of Fine Particles yes Drilling Mud Characteristics Bulk Density 2.09 g/cm? (17.4 tb/gal) Initial Solids Concentration 1,461,000 mg/ Tracer Concentration 100 mg/t Receiving Water Characteristics Current Velocity 2-30 cm/sec Wave Height 0.61 m (2 ft) Wave Period 12 sec Density Gradient «0.10 Source: Tetra Tech 1984 " Typical values used for all model runs unless otherwise specified. * Greatest deposition occurs beneath or slightly downcurrent of the discharge point. In shallower waters, a majority of sedimentation occurs within 100 meters (330 feet) of the discharge point, and background concentrations of trace metals and suspended solids are reached within 1,000 meters (3,300 feet). Deeper waters result in greater dilution, wider dispersion, and lower depth of accumulation. . Metal distribution in bottom sediments is uneven, generally with a gradient of decreasing concentration associated with distance from the outfall. DRILLING FLUID FATE FROM OPEN WATER DISPOSAL Dilution of muds and cuttings discharge during the open water season should be aided by dynamic oceanographic processes. Other OCS studies indicate that dilutions on the order of 2,000 to 1 can occur 100 meters (330 feet) from the discharge point (EPA 1984b). These dilutions occurred in areas with currents ranging from 10 to 80 centimeters per second. Average currents are expected to be less than 15 centimeters per second in the lease area. DILUTION PREDICTED BY THE OQC MODEL A computer model was developed to describe the initial dilution of drilling mud discharges to the marine environment and has been adopted by the Offshore Operators Committee (OOC). A description of the OOC Model parameters, assumptions, limitations, and model results for Sale 109 may be found in the Sale 109 ODCE. = 28's Model results do not include cuttings. These are expected to be of coarser grain size than muds and will, therefore, settle more quickly. Cuttings will affect a smaller area than muds, but will accumulate to greater depths. DILUTION, DISPERSION, AND SOLIDS ACCUMULATION Over 99.6 percent of the Sale 126 area lies in depths of 20 meters (65 feet) or greater. The OOC model has previously been used to predict initial dilution and solids deposition of drilling mud discharges for other Alaskan OCS areas. The results of representative model runs which bracket Sale 126 depths are shown in Table 8. Minimum dilution is defined as the inverse of the largest concentration found at any depth at a given distance from the source. A dilution of 1000:1 means that a tracer with an initial concentration of 100 mg/I would have a concentration of 0.1 mg/l at 100 meters from the discharge. Normal operating procedure requires several discharges of drilling mud in the course of drilling one well. It is unlikely that there will be repeated deposition in one area except directly beneath the outlet, given the changing currents and a narrow deposition footprint. Thus, examples modeled by Tetra Tech (1984) assume the total solids discharged were 114,634 kilograms (52,000 pounds). The deposition pattern along the axis of the current is given for depths of 40 meters (130 feet) (Figure 4) and for 70 meters (230 feet) (Figure 5). (Peaks in the histogram are artifacts of the model corresponding to different settling patterns for different particle size classes.) The total amount of discharge is accounted for if it is assumed that the material settles to a uniform depth over an 8 degree arc of a circle. Approximately 86 percent of discharged solids will be deposited on the seafloor within 914 meters (3,000 feet) down-current of the discharge point for depths of 70 meters (230 feet). DRILLING FLUID FATE FROM ABOVE-ICE DISPOSAL The nearshore Chukchi Sea is generally ice covered from October through May and the majority of the Sale 126 area lies far enough offshore that pack ice may persist throughout the year. In these offshore areas, disposal above the ice may be the only available method. Disposal above ice is usually accomplished by deposition on the ice in large frozen chunks with no layering attempted. It may also be spread in thin layers on the ice within berms to keep the disposal site intact as long as possible. Dilution and dispersion of the effluent occur at ice breakup, when greater wind and water si-r Table 8. Minimum Solids and Dissolved Fraction Dilutions Predicted by the OOC Model for a Point 100 Meters (330 Feet) from Discharge for Deeper Tracts Water Depth Minimum Dilution (m) (ft) Particulate Dissolved 20 66 1,092 1,082 70 231 1,803 2,702 Source: Tetra Tech 1984 Model Conditions: Total discharge rate = 1,000 barrels per hour Current speed = 10 centimeters per second movement are present. Mud discarded as large chunks may not be dispersed to the same extent as the layered discharges. The presence of muds on the ice affects the solar heat intake of ice. Consequently, melting of dirty ice will be faster than surrounding clean ice; the effects would be confined to the local area. A detailed discussion of dilution and dispersion of drilling effluent using above-ice disposal techniques is presented in the Sale 109 ODCE. This discussion applies equally well to the Sale 126 area. DRILLING FLUID FATE FROM UNDER-ICE DISPOSAL The nearshore Chukchi Sea is covered by ice for approximately eight months of the year, from early October through late May. Oceanographic conditions during ice cover are very different from those of open water season. This in turh affects effluent dispersion. In an NPDES permit issued for the Lease Sale 126 area, under-ice disposal would likely require special authorization from the Regional Administrator. CURRENTS. Current velocities are much lower under the ice pack than during the open water season. Under-ice currents are typically 5 centimeters per second, which is fast enough to enhance dilution, but significantly lower than the approximately 20 centimeters per second required to resuspend bottom sediments (EPA 1984b; Houghton et al. 1980). A more detailed discussion of under-ice currents may be found in the Sale 109 ODCE. 8 So 0.6 am o 2 o °o (¥) Hida -31- 1200 1000 400 DISTANCE (ft) 100 Pattern Modeled by OCC fora ischarge into Water 40 m Deep th Current Speed of 20 cm/sec. § 33 oe AQ oo a = Soe ARE + e = 3 Py <> 6.-¢ INCHES 0.31 0.23 0.16 0.08 0.00 1.000 0.750 g 0.250 0.000 (W2) NOLISOd30 GNW ONITNYG 40 Hid3G -32- (METERS) (FEET) 600 800 1000 1200 2000 400 200 3000 1000 DISTANCE FROM DISCHARGE POINT Figure 5 Solids Deposition Pattern Modeled by OOC for a Drilling Mud Discharge into Water 70 m Deep with Current Speeds of 10 cm/sec STRATIFICATION, SALINITY, AND TEMPERATURE. The degree to which mixing and dispersion of drilling discharges will occur is influenced by the degree to which the water column is stratified. Greater vertical differences in temperature and salinity increases the degree of density stratification, which reduces dilution and dispersion of discharges (National Research Council 1983). Marked seasonal fluctuations in salinity and temperature distribution occur in the lease sale area. Nearshore temperatures and salinity characteristics are strongly affected by seasonal ice formation. During freezing, only 15 to 20 percent of the solutes are incorporated into the ice, and waters below tend to have increased salinities and densities. SEDIMENT TRANSPORT. Of the factors influencing sediment transport, ice gouging and sediment entrainment in sea ice predominate during the winter months. The effect of ice in intensifying currents in shallow water and mitigating wind stress on the water are also significant factors. A detailed discussion of these factors appears in the Sale 87 ODCE and Sale 97 ODCE. These procedures would be relevant only in the shallowest (<20 meters deep) lease acreage. DILUTION, DISPERSION, AND SOLIDS ACCUMULATION. Of all the disposal methods described, below-ice discharge introduces the largest peak concentration of muds to the environment. A stratified, low energy environment exists throughout the winter months, restricting dilution and increasing solids accumulation. Current velocities are generally less than 5 centimeters per second during ice cover, depending on location. DISCHARGE WITH SHUNTING Shunting increases the depth at which the discharge enters the water, i.e., reduces the functional water depth. For example, a 30 meter (100 foot) shunt pipe discharging in water depth of 70 meters (230 feet) is equivalent to a surface discharge with 40 meters (130 feet) water depth. SUMMARY The Sales 87, 97, and 109. ODCE all summarize the results presented in this section which may be applied to Sale 126. The results of field studies and computer modeling of discharges in the nearshore Beaufort Sea and other OCS areas support the following conclusions for Sale 126: « Drilling muds tend to be diluted rapidly over both space and time. Dilutions of 1,000 to 2,000:1 are generally achieved within 100 meters (330 feet) of the discharge. » — Aminimum dilution of 1000:1 at the edge of the mixing zone for any given well may be considered as a conservative estimate for the Sale 126 area. oz-r « Of the three disposal methods available -- open-water, above-ice, and below- ice disposal -- below-ice disposal is the least desirable due to the lesser dilution and dispersion of discharges. . Based on OOC model results, the total area within Sale 126 receiving drilling mud and cuttings to a depth greater than 1 millimeter during open water is estimated to be 49 to 90 hectares (121 to 222 acres) for the 39 wells expected. WATER QUALITY WATER-QUALITY CRITERIA The 403(c) regulations allow a 100-meter (330-foot) radius mixing zone for initial dilution of drilling effluent. At the edge of the mixing zone, EPA marine water-quality criteria must be met. Compliance with water-quality criteria is assessed in this section. Marine water-quality criteria (45 FR 79318, 50 FR 30784, 51 FR 43665, and 52 FR 6213) are stated as acute (or one-hour average concentration) and chronic (or four- day average) values. The chronic criteria are applicable to a relatively constant flux of pollutants. Acute criteria values are applicable to instantaneous releases or short-term discharges of pollutants. As drilling mud discharges are periodic with durations of only a few hours, the acute criteria are applicable to drilling-mud discharges (Petrazzuolo 1981). The water quality criteria have been developed using several different operationally defined concentrations for the metals, including “dissolved,” “active” (a term no longer in use), “total recoverable,” and “total” concentrations. These classifications refer to the types of filtration and degree of acid-digestion a sample receives and are a first- estimate of the form of the metal in the sample (e.g., bound, unbound). In the past EPA has considered the estimated dissolved metal concentrations to be sufficiently similar to the operationally defined “active” and “total recoverable” concentrations to permit comparison with the criteria. The discharges from exploratory phase oil and gas drilling are to open waters and occur intermittently for a few hours at a time. Dissolved metals concentrations are of most concern under these conditions since these are immediately available and are bioavailable (O'Donnel et al. 1985). Due to a lack of total recoverable metals data, estimated dissolved metals concentrations are also utilized here. However, the Region will consider requiring permittees under future oil and gas general permits to report total recoverable metals data instead of total metals. Hence in the future it would be possible to conduct direct comparisons with the water quality criteria using total recoverable metals data. The dilution achieved within 100 meters (330 feet) of the discharge has been predicted in the section entitled "Fate and Transport of Muds and Cuttings.” The worst case predicted by the computer model was a discharge of 1,000 barrels per hour into 40 meters (130 feet) of water and a current speed of 10 centimeters per second. The -34- dilution achieved at the edge of the mixing zone was approximately 1000:1. This dilution value can be applied to the expected concentration of dissolved metals in the drilling mud to determine metal concentrations at the edge of the mixing zone. Dissolved metals concentrations are considered closer to “active” or "total recoverable" concentrations than "total" values. Concentrations of metals in the whole mud will be used to estimate dissolved metals concentrations (Table 9). Table 9 also presents the maximum allowable water quality criteria for the metals considered. A comparison of these values shows that all dissolved metal concentrations at the edge of the mixing zone are well below the acute criteria. Over a period of months or years, leaching or diffusion of dissolved metals from deposited muds is also expected to be insignificant. Only a small fraction (about 0.1 percent) of the metal concentrations in whole mud is expected to be in the dissolved state; the remaining metals are bound to the solid phase. The dissolved portion is probably lost to the water column during plume descent. After deposition on the seabed, some additional metals can be expected to dissolve into the interstitial water under certain sediment conditions. However, after equilibrium is established, the concentrations of metals in the interstitial water will not be any higher than the estimated dissolved concentrations. These dissolved metals would be dispersed throughout the water column during a sediment resuspension event or slowly diffused upward from an undisturbed mud deposit. Metals released to the water column will likely readily adsorb onto naturally occurring suspended sediments. The dissolved phase of metals and other chemicals tends to be more bioavailable than the particulate phase (Lockhart et al. 1982; O’Donnel et al. 1985). Particulate-bound chemicals have variable bioavailability that depends on the chemical and biological species and environmental conditions considered (Anderson et al. 1977). EFFECTS ON MARINE BIOTA INTRODUCTION The Lease Sale 126 area includes waters to depths of 60 meters and encompasses two major marine environments: cold offshore and bottom waters representing outer shelf waters; and warmer, nearshore waters dominated by inshore portions of the Alaskan Coastal Current (Aagaard, 1984; Hachmeister and Vinelli, 1985). Studies of Chukchi Sea biology have only recently intensified, and many features of this ecosystem are still poorly understood. The Chukchi Sea and Beaufort Sea coastal ecosystems were compared by Truett (1984). Major points of this comparison that are germane to the current evaluation are summarized below. l2-r Table 9. Comparison of Expected Dissolved Metals Concentrations at the Edge of the Mixing Zone in Sale 126 to Marine Water Quality Criteria Dissolved Concentrations! Marine Criteria’ pom pom In 100 m from Discharge” Discharge” t-he. Avg. 96-hr. Avo. Arsenic 0.026 0.000026 0.069 0.036 (trivalent) (trivalent) Barium 298 3.0 No Criterion No Criterion Cadmium 0.006 0.000004 0.063 0.0093 Chromium as 0.0013 1 0.05 (hexavalent) (hexavalent) Copper 0.088 0.000088 0.0029 No Criterion Lead 0.820 0.00082 0.16 0.0056 Mercury 0.00036 9.00000036 0.0021 0.000025 Nickel 0.088 0.000088 0.075* 0.0083 Vanadium 0.235 0.000235 Mo Criterion No Criterion Zine 1,350 0.00135 0.095* 0.086" Based on whole mud concentrations as reported in EPA 1985. Dissolved concentrations in ppm (mg/L), representing 0.1 percent of total concentration in muds. Assumed dilution 1000:1. Corresponding to discharge of 1,000 bbi/m into water depth of 40 m and current speed of 10 caysec. From 50 FR 30784. One hour average concentration (ppm) not to be exceeded more than once every three years on the average (acute exposure levels) and 96 hour average concentration not to be exceeded more than once every three years on the average (chronic exposure levels). Both are based on the total recoverable method which is operationally defined as the concentration of metal in an unfiltered sample following treatment with hot strong mineral acid (EPA 1979). * From 51 FR 43666. Final criteria, based on total recoverable method. * From 52 FR 6213. Criteria based on total recoverable method. PHYSICAL CONDITIONS The coastal Chukchi Sea: « has more open water both spatially and temporally than does the Beaufort Sea; « is more influenced by Bering Sea water than by Arctic Ocean water: « is pervaded to a greater extent by cold, salty marine water; « has a large polyna or lead system that persists each spring in or just + — offshore of the deep nearshore environment; -96- = has fewer natal stream sources of anadromous fish; and « has large cliffs suitable for seabird nesting. COASTAL FOODWEBS Chukchi Sea coastal foodwebs have: * agreater annual primary productivity than those of the Beaufort Sea, with more of the water column primary production settling to the bottom; = agreater diversity and higher biomass per unit area of benthic feeders; = asmaller percentage (biomass) of epibenthic mysids in diets of nearshore vertebrate consumers; = a greater diversity of marine prey fish species; and «= agreater diversity and biomass of planktivorous fish-eating predators. VERTEBRATE FAUNA The coastal Chukchi Sea vertebrate fauna has: « more species and greater biomass of marine mammals per unit area than the Beaufort Sea; = more species and greater unit area biomass of marine fishes; = fewer species and a lesser biomass per unit area of non-salmonid anadromous fishes; « a lower density of feeding and moulting oldsquaw ducks; and * agreater abundance of cliff-nesting seabirds (the Beaufort Sea has essentially none). The detritus-based benthic infauna and epifauna form the basis of food trophic levels in the Chukchi Sea. These benthic communities are expected to be more vuinerable than other marine communities to drilling mud and cutting discharges during oil and gas exploration, and are therefore, of primary concern to activities associated with Lease Sale 126. Most of the important species (as defined by Truett 1984) in the Chukchi Sea are associated with the nearshore area (20 meters and shallower). Exceptions include walrus and bearded seal, (which utilize the pack ice edge and are, therefore, often in the deeper water areas of the Barrow Arch during summer) and marine fishes. Most of the Sale 126 area is located in waters between 30 and 50 meters deep; the biology -37- ce-r of these deeper environments is less studied than the nearshore environments. Exploratory drilling in the nearshore area would have potentially greater primary and secondary impacts on important marine biota than drilling in the offshore area. IMPORTANT PLANKTONIC SPECIES PHYTOPLANKTON Phytoplankton productivity in the Chukchi Sea is greatest during the approximately five week-long summer period. However, production in open water leads can begin as early as late March. Epontic (attached under-ice) algae, primarily diatoms, probably contribute significantly to production in these waters. Maximum phytoplankton production is controlled by available nutrients, which are influenced by water column stratification during summer (Morris 1981). EFFECTS ON PHYTOPLANKTON No sensitive or unique marine sites of critical importance to phytoplankton productivity have been identified. The possible impacts of drilling mud discharges on marine phytoplankton include: . Decreased primary production due to light reduction from increased turbidity; . Decreased primary production and/or increased mortality due to direct acute or sublethal toxic effects of trace metals; and . Stimulation of primary production by trace nutrients in the discharge (Jones & Stokes Associates 1984). ZOOPLANKTON The few existing studies of zooplankton in the nearshore and offshore Chukchi Sea were summarized by Truett (1984). One implication of a hypothesized zooplankton community composed of inefficient phytoplankton grazers suggests that much of the phytoplankton production would sink to the bottom and be consumed by benthic communities. This hypothesis is supported by the character of the Chukchi Sea benthic community discussed later in this chapter. EFFECTS ON ZOOPLANKTON Possible impacts to zooplankton include: . Decreased growth, altered behavior, and/or increased mortality due to the direct acute or chronic effects of toxic materials in drilling muds; . Interference with feeding or respiratory activity due to increased suspended solids concentrations; and . Indirect enhancement or inhabitation of zooplankton population resulting from impacts on phytoplankton (Jones & Stokes Associates 1984). Both cadmium and mercury affect plankton. Exposure to 100 micrograms cadmium per liter seawater for 10 days reduced dinoflagellate population growth by 20 percent (Prevot and Soyer-Gobillard 1986). Five micrograms cadmium per liter seawater for 10 days reduced diatom spore formation by 35 percent and 15 micrograms cadmium reduced spore formation by 81 percent (Sanders and Cibik 1985). Low levels of cadmium (2.0 ug) and mercury (0.2 ug) reduced fatty acid content and therefore the nutritional quality of marine diatoms (Jones et al. 1987). ‘However, these concentrations of metals are not expected to be reached. The suspended particulate phase of a reference drilling mud and a used production mud significantly increased hydranth shedding in the coelenterate Tubularia crocea after 48 hours exposure to 100,000 parts per million (Michel et al. 1986). The liquid phase was more toxic, with concentrations of 10,000 parts per million increasing coelenterate shedding. The effects of drilling muds on the marine algae Skeletonema costatum were investigated (EG&G Bionomics 1976a, 1976b). The ECS5O (concentrations at which a designated effect is displayed by 50 percent of the test organisms) with barite was 385 ppm and with freshwater lignosulfonate was 430 ppm without agitation. With agitation, the EC50s increased to 1,650 ppm and 16,000 ppm respectively. Various lignosulfonate formulations were tested in agitated mixes (EG&G Bionomics 1976a, 1976b); the lowest EC50 was 1,325 ppm with IMCO RD-123+spot. The effects of two drilling muds and eight mud additives on the primary production of natural assemblages of Californian marine phytoplankton were assessed by Alldredge et al. (1986). Short-term (4-hour) exposure to barium sulfate, lignosulfonate, and a reference drilling mud concentrations over seven orders of magnitude did not affect primary production, and the used drilling mud significantly enhanced production. Long-term exposure (120 hours) to 10 micrograms of X-Pel-G or Soltex or to 100 milligrams iron lignosulfonate per liter significantly reduced production. In no case was the species composition altered. Plankton are unlikely to be exposed to drilling mud discharges for this length of time. CONCLUSIONS Several factors suggest that the discharge of drilling muds will have a limited effect on plankton: « tis assumed that most toxic metals will be bound to muds and ligands and will not be available in the water column. « Expected dissolved concentrations of metals in the drilling-mud discharges at the edge of the mixing zone are within the EPA water quality criteria, which were established to protect marine life. ee-r « The dilution of muds is rapid. At the edge of the mixing zone, dilutions of greater than 1,000:1 fold are expected for particulates. Concentrations of over 1,000 ppm will probably be present for only 100 meters (330 feet) down-current of the discharge. = The residence time of the drilling muds will be much shorter than the 9€- hour time period of bioassay tests. « The area affected by detectable discharge plumes is very small relative to the area of the total lease sale area (Jones & Stokes Associates 1989). BENTHIC COMMUNITIES Benthic communities of the Chukchi Sea outer shelf region in the Lease Sale 126 have not been intensively studied. The most comprehensive investigation of the infaunal benthos of the eastern Chukchi Sea was conducted by Stoker (1978), who studied the distribution, biomass, trophic relationships, and productivity of the fauna based on data collected during 1970-74. The faunal composition of the eastern Chukchi Sea was noted as being similar to that found in the eastern Bering Sea. Two major faunal assemblages were identified from the Barrow Arch samples: one group was dominated by the polychaete Maldane sarsi, the echinoderm Ophiura sarsi, the sipunculoid Golfingia margaritacea, and the bivalve Astarte borealis; the second group was dominated by the bivalves Macoma calcerea, Nucula tenuis and Yoldia hyperborea and the amphipod Pontoporeia femorata. These findings indicated that Chukchi Sea infauna is dominated by detritus feeders. Evidence from marine mammal feeding studies indicates that burrowing bivalve molluscs are an important component of benthic infaunal communities (Truett 1984). The epifauna of the Chukchi Sea outer shelf seems to be dominated by echinoderms (Frost et al. 1983; Truett 1984); however, little is known about the Lease Sale 126 area. The benthic communities of the nearshore Chukchi Sea appear similar to those studies in the nearshore western Beaufort Sea. The general composition, biomass and diversity of these communities are lower than that of communities south of Point Hope (Truett 1984). EFFECTS ON BENTHIC COMMUNITIES The National Research Council (NRC) (1983), Ferbrache (1983) and Jones & Stokes Associates (1984) have summarized the work of Petrazzuolo (1981), Neff (1981) and Brandsma et al. (1983), identifying the potential detrimental benthic impacts of discharged drilling fluids and cuttings in low-energy environments as: . physical smothering of bottom-dwelling organisms; . changes community structure and benthic habitat (i.e., sediment chemistry and texture), making it unsuitable for certain species, @.g., interference with burrow construction and feeding or interference with settlement of benthic larvae; and . introduction of substances which may have negative effects upon metabolism, health, behavior, or reproductive capability of benthic species (i.e., toxicologic effects). SMOTHERING. Research and data collection efforts indicate that if a depositional mound or Cuttings pile remains on the seabed following discharge, population depressions and/or changes in the benthic community will occur. The suspended solids content of these discharged fluids consists mainly of barite and bentonite. Cuttings are generally sand grain sized and settle out at relatively short distances from the point of discharge. A localized reduction of individuals and numbers of species due to smothering effects will be most likely in areas where deposition of cuttings on the benthos exceeds 1 centimeter and persists for more than a few days (Jones & Stokes Associates 1984) More subtle community changes may result from alteration of substrate characteristics Species will be favored which are more tolerant of the deposition of increased silt/clay components derived from drilling fluids. Increased requirements for feeding, respiration and reproductive energy may cause adverse impacts, and decreased larval recruitment may occur (Menzie et al. 1980). Menzie noted reduced abundances in polychaetes, molluscs, and crustaceans up to 370 meters from a well site in low energy mid-Atlantic OCS drill site in 120 meters of water. However, hake (Urophycis spp.) and crabs (primarily Cancer borealis) were apparently attracted to the drill site. Abundance of sand stars (Astropectin americanus) appeared unaffected. Species attracted to the harder substrates of intact mounds may colonize this newly formed area in response to a “reef effect” (Northern Technical Services 1981; Menzie et al. 1980). Increased predation resulting from the attraction of predator species may result in a net reduction of prey species as an indirect impact (Menzie et al. 1980). Such an indirect impact could reduce localized nearshore reproductive success and recruitment of important motile epifaunal species (i.e., gammarid amphipods), with attendant impacts to higher trophic levels. TOXICITY. Houghton et al. (1980) identified ligno-sulfonates and caustic soda (sodium hydroxide), through an effect on pH, as the most acutely toxic components of water-based drilling fluids. The NRC (1983) identified diesel fuel (No. 2 fuel oil) and biocides as two of the most toxic constituents which may be present in some drilling muds. In light of this, EPA Region 10 permits for offshore drilling operations have prohibited the discharge of diesel oil and limited the toxicity of drilling muds. The toxicity of new drilling-mud additives must pass a toxicity-based criterion prior to their discharge. Generally, the animals tested in laboratory bioassay studies have a remarkably high tolerance to whole drilling muds (EPA 1984b). Dock shrimp larvae had the lowest LCS5O (lethal concentration for 50 percent of the test organisms) of any Alaskan organisms tested in an unmixed whole mud (LC50 of 600 ppm) (Carls and Rice 1984). However, it is possible the mud used was formulated with a component containing «41s be-r hexavalent chromium, which is highly toxic to marine life and is not be permitted by EPA Region 10. Other low ECSOs for a high molecular weight polymer are 10,000 ppm for Mya arenaria and 14,000 ppm for the amphipod Orchestia traskiana (KCL-XC- polymer) (EPA 1984b). The toxicity of drilling muds and barite to the primitive vertebrate lancelets (Branchiostoma carbaeum) was tested in flow-through aquaria (Clark and Patrick 1987). Lancelets were kept in 1:1 clean sand:test sediment, with additional treatments of daily additions of barite or lime to the depth of 0.15-0.23 centimeter (0.06-0.09 inch). Although burrowing was reduced, making the animals more susceptible to predation, ‘neither barite sediment nor barite additions were toxic to lancets. Seawater/ lignosulfate mud (Mud #2, Table 3) and lime mud (Mud Type #3, Table 3) were toxic to buried animals after 7 days, and to animals on the surface within 24 hours. Lightly treated lignosulfate was toxic to both buried and surface lancets within 24 hours. Drilling muds are one to two orders of magnitude more toxic to mysids (Mysidopsis bahia) than they are to lancets (Gaetz et al. 1986). Although few studies have been conducted, it is possible that other benthic organisms emerge from drilling mud deposits. This would not only make the animals more susceptible to predation, but would attract predators to selectively feed in the area of drilling mud deposits, increasing the chance of heavy metal accumulation through the food web. BIOACCUMULATION. Heavy metals can be highly persistent in the environment and have the potential to bioaccumulate in marine organisms and to biomagnify through food webs, possibly leading to man. Benthic organisms are particularly susceptible since they live on and in drilling-mud deposits. Mercury, cadmium, and barium are of most concern due to toxicity. Mercury and arsenic are of concern because of their propensity to bioaccumulate. Anderson et al. (1987) report that marine species have demonstrated little bioaccumulation from exposure to sediments contaminated with heavy metals, with the exception of mercury, cadmium, and copper Mercury, one of the few metals to biomagnify (increase in concentration up trophic levels) may be in excess of 10 parts per million in some drilling muds. Concentrations of mercury in ocean sediments range from <10 to 2,000 parts per billion with a mean of 100 parts per billion (D'Itri 1972). Although mercury discharged in drilling muds is largely inorganic and not bioavailable, virtually any mercury compound may become a bioaccumulation hazard for organisms since bacteria common to most natural waters are capable of biomethylating the metal (Callahan et al. 1979). Several studies have reported sediment and organism mercury concentrations to be correlated, with bioconcentrate factors of 0.01 to 0.57 (O'Conner and Rachlin 1982), although some organisms, such as polychaetes, probably absorb mercury from the water through their epidermis (Jensen and Baatrup 1988). The polychaete Neris virens exposed to 9 parts per billion mercury as mercuric chloride in aquaria water had a bioconcentration factor of 930 with a constant rate of uptake. Constant rates of mercury uptake have been observed for over 72 days in marine polychaetes (Kendall 1978). -42- Cadmium can accumulate to high levels in marine organisms without causing apparent ill-effects, due perhaps to proteins such as metallothionein that detoxify non- essential metals (Hamer 1986; Langston and Zhou 1987). Several studies have reported sediment and organism cadmium concentrations to be correlated. Cadmium bioconcentration factors for oysters range from 0.008 (Atwood et al. 1979) to 40 (Neff et al. 1978) times that of sediment. The soft shell clam, Macoma accumulates cadmium primarily from water (Langston and Zhou 1987). Macoma exposed to 100 micrograms cadmium per liter of seawater had a linear uptake of cadmium. The elimination rate from the soft tissue was very slow (1 percent of the accumulated cadmium was eliminated daily) while the elimination rate was faster from the shell (46 percent in 7 days). Barium is considered a chemical of concern due to its high concentration in drilling muds and propensity to settle on the substrate, although it has low toxicity. Bioaccumulation has been described in non-Alaskan species. Mariani et al. (1980) found barium in benthic organisms to be about 10 times that of sediment concentrations. Expected barium concentrations in the drilling muds are 298,800 parts per million (Table 4). ALTERATION OF SEDIMENT CHEMISTRY AND TEXTURE. Alteration of sediment characteristics is expected to affect the benthos more subtly than smothering and over larger areas. Menzie et al. (1980) noted reduced abundances of polychaetes, echinoderms, molluscs, and crustaceans up to 370 meters (1,200 feet) from a well site in a low-energy mid-Atlantic OCS site in 120 meters (390 feet) of water. The authors could not attribute the population depressions to any one factor, but instead suggested four possible mechanisms: fish and large epibenthic invertebrates attracted to the drilling area reduced benthic populations through predation; mobile crustaceans emigrated from the discharge area; altered sediment composition adversely affected feeding and survival of some benthic species; and altered sediment composition inhibited larval recruitment. The initial impact zone was recolonized and commenced recovery within a year of cessation of drilling-mud discharge. It has been suggested that low levels of metals in seawater significantly reduce larval settlement. The settling of larvae have been tested in known heavy metal constituents of all drilling muds, in proprietary drilling mud additives, and in samples of drilling mud standards (Morse 1984). Of the heavy metals, larvae were most sensitive to mercury which significantly interfered with settling at minimum concentrations of 2 parts per billion. The additives (Soltex, lignosulfonate, and Drispac) reduced settling at dilutions of 1:100, and drilling mud reduced settling at dilutions of 0.1 milligram mud in 1 liter of water (1:10,000). An 8-week recolonization study conducted by Tagatz et al. (1985) consisted of boxes containing clean sand (control), 1:10 or 1:3 barite:sand mix, and 1:10 or 1:3 drilling-mud:sand mix placed in 3 meters (10 feet) of water in Santa Rosa Sound, Florida. A total of 1,081 individuals representing 63 species recolonized the boxes. There were 43 species in the control substrate compared with 38 species in the barite:sand mixes, 32 in the 1:10 mud:sand, and 24 species in the 1:3 mud:sand mix. The apparent toxicity of the lime drilling mud was attributed to diesel oil, a component banned from use in EPA Region 10. Although there were significantly fewer individuals #432 s¢-r in the 1:3 barite:sand mix compared with the control (220 vs 296), species diversity, species dominance, and dissimilarity indices were not markedly affected. RECOVERY. After cessation of drilling activity, benthic communities will recolonize the area although pioneer species may not be the same as those lost. With time, the pre-existing community will probably recover. Menzie et al. (1980) suggest that benthic communities within the initial impact zone are recolonized and commence recovery within a year following cessation of discharge. The potential for bioaccumulation of metals remains (Crippen et al. 1980), although the discharge of toxic pollutants can be regulated through the NPDES permit. Crippen et al. (1980) analyzed sediment and benthos for mercury, arsenic, cadmium, lead, and zinc near a drilling site in the Beaufort Sea one year after discharge had ceased. There were suggestions of elevated mercury levels in benthic organisms very near the original discharge site, but no indications of significant bioaccumulation for any of the other metals. The mud discharged had mercury levels far in excess of those which EPA Region 10 would approve for discharge under current NPDES permits. A field survey was conducted at the Murchison oil-field in the North Sea 16 months after the major cuttings discharges had ceased (Mair et al. 1987). The benthic community was sampled to 2,000 meters (6,600 feet) from the discharge point. Species abundance, diversity, and evenness were significantly lower at the 100-meter (330-foot) station as compared to the reference station, although these community Parameters were not significantly different from the reference point 1,000 meters (3,300 feet) from the discharge point. The community recovery was strongly affected by the oil residues from the oil-based drilling muds. Oil-based drilling muds are not permitted under EPA Region 10 permits. CONCLUSIONS No geographic areas in the lease sale area of specific importance for benthos potentially affected by the discharges have been identified. The following factors should result in limited benthic community effects from drilling fluids discharges: « the potential for resuspension and further dispersion and dilution of contaminated sediments by periodic high current velocities and storm events; «the relatively low numbers and diversity of infaunal organisms in areas of intensive ice-gouging; « the mobility of many of the’trophically important epibenthic organisms (mysids and amphipods); and « the control of toxic pollutants effected through the BAT and NSPS effluent limitations. Therefore, it is anticipated that transitory and localized impacts from exploratory drilling may occur on the benthos of the sale area. Due to the limited quantity of materials which would be discharged and the small area affected by those discharges, the impacts would be insignificant. FISH RESOURCES Fish resources of the Lease Sale 126 area, like other taxonomic groups, have been the focus of only a few studies. The dominant marine and anadromous fish species found during a recent study were Arctic cod (Boreogadus siada), Arctic staghorn sculpin (Gymnocanthus tricuspis), fourhorn sculpin (Myoxocephalus quadricornis), capelin (Mallotus villosus), shorthorn sculpin (Myoxodephalus scorpius), hamecon (Arteciellus scaber), Arctic flounder (Liopsetta glacialis), and saffron cod (Eleginus gracilis). Pink salmon (Onchorhynchus gorbuscha) and boreal smelt (Osmerus ‘mordax) were the primary anadromous species found in the Chukchi Sea, while ciscoes and whitefish (Coregonus spp.), Arctic char (Salvelinus alpinus), and chum salmon (Q. keta) were represented by very few captured specimens (Fechhelm et al. 1984). Arctic cod are very abundant and widely distributed in the Chukchi Sea; they are also known to congregate near the underside of ice, and around open water fissures in winter. Saffron cod, fourhorn sculpin, sandlance (Ammodytes hexapterus), Pacific herring (Clupea harengus pallasi), and capelin all spawn in shallow, coastal waters where they deposit adhesive eggs on various substrates, including vegetation. Pink salmon and boreal smelt use larger river systems and estuaries in the area, such as the Koklik, Utukok, Kukpowruk, and Kuk, as spawning and rearing areas (Fechhelm et al. 1984). These rivers all flow into the Chukchi Sea between Wainwright and Point Lay. EFFECTS ON FISH RESOURCES Fish and most mobile pelagic species can avoid discharge plumes and areas of high turbidity resulting from exploratory drilling operations. Jones & Stokes Associates (1984) suggests that although some studies have indicated that fish may be attracted to a discharge plume, it is likely that stresses induced by particulates in the main body of the plume would restrict fish to the plume edges. These factors also mean that fish may not experience significant exposures to toxic concentrations of pollutants in the discharge. Following cessation of discharge, fish will return to a discharge area, particularly if the settlement of discharged cuttings and drilling fluids provides significant microrelief (i.e., creation of new habitats). While little is known regarding the threshold at which effects from smothering or toxic effects on demersal fish eggs could occur, the wider dispersion of discharged drilling fluids in deeper areas could result in a large area being covered with more than 1mm of muds and cuttings. This could result in the smothering of fish eggs of cottids, Arctic cod and other demersal fish (Jones & Stokes Associates 1984). However, under actual field conditions, the area affected is relatively small, but still could exceed the 100 m mixing zone established by EPA. -45- 9e-r Finally, the limited effects that the discharges could exert on benthic communities, phytoplankton, and zooplankton suggest negligible reductions in food supplies of fish (Jones & Stokes Associates 1984). Thus, only minor impacts on fish are anticipated from exploratory phase discharges. MARINE MAMMALS The seasonal distribution of marine mammals in the northeast Chukchi Sea was summarized by Morris (1981): Pack Ice . polar bear Flaw Zone bowhead whale, beluga whale, bearded seal, polar bear Fast Ice tinged seal, polar bear Packice ringed seal Pack Edge walrus, polar bear, bearded seal, beluga whale Open Water (migration routes) walrus, seals gray, bowhead, and beluga whales Coastal Lagoons beluga whale, spotted seal The coastal zone of the Chukchi Sea is inhabited by marine mammals only during summer and autumn. Frost et al. (1983) summarized all available data for marine mammal sightings which included: spotted seal, walrus, beluga whale, harbor porpoise, killer whale, minke whale, and gray whale. In the coastal waters, Frost et al. (1983) found that the greatest concentration of marine mammals occurs in and near Kasegaluk Lagoon, which is used by 2,000 to 3,000 beluga whales and at least 2,000 to 3,000 spotted seals. Spotted seals are less Numerous, but still abundant, near the mouths of the Kuk and Kugrua Rivers. Some walrus have been seen hauled out of Cape Lisburne every summer since 1975. Killer whales have been seen off Point Lay and Wainwright during most years; minke whales have been sighted at Cape Lisburne. Harbor porpoises have been observed near Wainwright, in Peard Bay, and near Barrow, and likely pass along the entire coast. Gray wales feed along the entire Chukchi Sea coast but are most common between Icy Cape and Barrow (Frost et al. 1983). The feeding habits of marine mammals in the lease sale area were summarized by Morris (1981): Plankton eaters: bowhead whale Benthos eaters: gray whale, ringed seal, bearded seal, walrus, spotted seal Fish eaters: beluga whale, ringed seal, spotted seal, bearded seal Mammal eaters: polar bear, killer whale The gray whale and the Bering Sea or western Arctic stock of the bowhead whale are considered endangered species. EFFECTS ON MARINE MAMMALS Effects on marine mammals resulting from exposure to discharges, acute and chronic toxicity, and bioaccumulation and food supply effects are unlikely (Jones & Stokes Associates 1984). The high mobility of marine mammals combined with the intermittent and brief duration of drilling effluent discharges and the dilution of discharge plumes are all factors that contribute to the unlikelihood of impacts to marine mammals. It should be noted that the greatest potential for impacts, although highly unlikely, is from effects to benthic food supplies of certain mammalian species. Walrus, bearded seals, and gray whales are primarily benthic feeders. Walrus and bearded seals feed on infauna, particularly bivalve molluscs. There are indications that large populations of walrus in recent years may be drastically reducing supplies of bivalves in the coastal Chukchi Sea, with resulting pressure on walrus populations (Truett 1984). Gray whales feed on ampeliscid amphipods by plowing and straining benthic sediments. Carrying capacity of the Chukchi Sea for gray whales is determined by the numbers and locations of dense patches of prey (Truett 1984). Gray whales are dependent on areas rich in benthic amphipods during the summer feeding period; they fast while on their wintering grounds (Morris 1981). The addition of impacts to benthic communities from drilling discharges, although deemed minor to negligible when considered separately, need to be considered in light of carrying capacity limitations for walrus and gray whale populations in the coastal Chukchi. Cumulative impacts in localized areas may become important if these areas support important food resources for these species. MARIN: ‘AL BI The marine and coastal bird fauna of the Lease Sale 126 area includes loons, procellarids (fulmars and shearwaters), cormorants, waterfowl (including brant, eiders, and oldsquaws), shorebirds, larids, (jaegers, gulls, and terns), and alcids (auks and their relatives). Few birds are present in the area during the winter, but several million individuals may use the area during the spring, summer, and fall (Truett 1984). Landforms in the area that provide important bird habitat include: coastal cliffs (nesting), barrier islands and spits (nesting), lagoons and semi-enclosed bays (feeding and moulting), and wetlands and gravel beaches (feeding). Marine environments are used extensively by certain bird species for feeding, while open water leads associated with the Chukchi Sea polynya are important migratory pathways and feeding areas in spring (Truett 1984). Table 10 summarizes a number of special areas used by marine and coastal birds. PATE Le-r Table 10. summary of Special Bird Sites in the Chukchi sea Area site Importance Coastal Environment: Cape Lisburne Kasegaluk Lagoon Point Hope Peard Bay Marine Environments: Ledyard Bay Water off Cape Lisburne Open Leads and Polynyas The Northernmost seabird colony in western North America. Provides essential cliff-nesting habitat for about 80 percent of all nesting alcids and larids in Barrow Arch. The most important coastal lowland habitat for non-cliff-nesting birds in NE Chukchi Sea and Barrow Arch. Mud flats, salt marshes, beaches, and protected waters provide essential summer and fall feeding, molting and staging habitat for waterfowl, shorebirds, gulls, and terns. Salt marshes are only known major resting and feeding stop for Alaskan and Canadian Arctic Slope populations of black brant between Beaufort Sea and SE Bering Sea. The split and associated wetlands are a noteworthy are for non-cliff-nesting birds in Barrow Arch. Provides important molting and staging habitat for oldsquaws, and feeding and staging habitat for red phalaropes. Rich feeding habitat for many bird species; perhaps the most important such habitat in the Barrow Arch. Important staging and molting area for common and king eiders. Significant lat summer and fall feeding habitat for majority of alcids and larids nesting at Capes Lisburne and Lewis. vital winter resting and feeding habitat for black guillemots and possibly other species. Site Importance Offshore Spring Part of a major spring migration route Lead for birds antering eastern Chukchi and western Beaufort Seas from Bering Sea. Provides essential fall feeding habitat for migrating Ross' and ivory gulls. Resting and feeding habitat for a variety of nonbreeding and post breeding species. Seasonal Ice Edge Source: Truett 1984 EFFECTS ON MARINE AND COASTAL BIRDS Impacts to bird populations from drilling mud and cuttings discharges are unlikely; however, some secondary impacts at special aquatic sites are possible. Most coastal and marine birds occur in the Chukchi from spring to fall. Concentrations of cliff-nesting and other species in certain areas are dependent on marine fauna, including benthic infauna and epifauna, as food. Several bird habitats in the Sale 126 area were identified by Truett (1984) as being particularly vulnerable to impacts from oil and gas activities due to large concentrations of birds utilizing nesting and feeding resources. These locations include the marine environments of Ledyard Bay, and waters off Cape Lisburne where benthic infauna and epifauna are heavily utilized by foraging birds. Effects on marine and coastal birds resulting from toxicity, bioaccumulation, or food supply effects are not expected to occur (Jones & Stokes Associates 1984). COMMUNITY EFFECTS Overall, larvae and planktonic organisms are most sensitive to constituents in the water column, and effects on the biota will primarily be a function of dilution and dispersion of the discharge plume and duration of discharge. Since dilution is rapid and metals concentrations are within EPA water quality criteria (set to protect marine life) within 100 meters (330 feet), effects to the plankton biomass are expected to be transient and localized. The benthic community is the most likely to be affected physically and toxicologically because of potential exposure to large amounts of drilling mud solids. Effects on the benthos will be primarily a function of the depth and areal extent of solids deposition. Since the area affected is small, population depressions in the benthic community are not expected to have serious impacts on marine species higher up on the trophic web. -49- se-r Benthic community structure is changed in the immediate vicinity of the discharges due to smothering, in particular by cutting piles which may be a few meters high and 100 to 200 meters (330 to 660 feet) in diameter in a non-dispersive environment (Battelle Ocean Sciences 1987). However, the fresh habitat is rapidly recolonized, and field studies show little change in benthic communities one year following cessation of drilling activity, providing oil-based drilling muds are not used. Mercury and cadmium bioaccumulation through the trophic links is of some concern. Plankton in the discharge plume are exposed to these metals and have the potential to ingest them. The benthic polychaete, Capitella capitata, feeding on phytoplankton-zooplankton debris contaminated with mercury and cadmium show a significant metal accumulation (Windom et al. 1982). It is also possible that pioneer species reinvading the areas smothered during mud deposition are selected prey for fish and mammals. Although minimal bioaccumulation of metals during exploratory drilling is expected because of the limited volumes of drilling muds and cuttings discharged, tissue analyses of benthic species pioneering the mud deposits should be conducted. Based on an assessment of the sensitivities and susceptibilities of Alaskan marine organisms to drilling mud and drilling mud components, the biological communities in Sale 126 do not appear to be at unreasonable risk from toxicity caused by limited offshore exploratory phase discharges of drilling mud. However, the potential for significant effects on all communities increases when large-scale production is considered. iM. 1 ECREATI HARVEST: INTRODUCTION In light of the information presented in the ODCE 109, it appears there are no commercial fisheries in the Lease 126 Sale Area (EPA 1988b). Trawl survey results for the Chukchi Sea do not indicate any potential for commercial harvests. In addition, EPA (1988b) reported that there are no recreational harvests of marine species in the Barrow Arch area. SUBSISTENCE HARVESTS Morris (1981) reported a great variety of fish, bird, mammal, and perhaps some invertebrate species are harvested by local villagers under subsistence regulations. Several species including bearded seal, spotted seal, ringed seal, walrus, cods and flounders are benthic feeders and therefore must be considered in an evaluation of effects of exploratory drilling discharges. Impacts to the benthos are expected to be insignificant because of the small quantities of mud to be discharged and the small areas to be impacted. The maximum subsistence areas for fish, seals and walrus are located near Point Hope, between Point Lay and Wainwright and in the Barrow Arch. These areas should -50- be considered special aquatic sites when evaluating the potential impacts of discharges from drilling activities along the nearshore three-mile limit. More detailed information concerning subsistence use of marine resources by the Chukchi Sea communities of Point Hope, Point Lay and Wainwright can be found in Truett (1984). MA\ T! Ingestion of organisms that have accumulated significant concentrations of heavy metals or petroleum hydrocarbons from drilling mud is the principal potential source of adverse human health effects caused by discharge of drilling muds and cuttings into the marine environment. Human health affects are most likely to result from chronic ingestion of marine organisms that have accumulated high levels of metals, primarily barium, lead, mercury, and cadmium. Barium, which is present in large concentrations in drilling muds, could be accumulated marine organisms by human ingestion of enough contaminated seafood in a short enough time period of time to pose a human health threat is unlikely. Petrazzuolo (1981) assessed human health risk based on reported barium concentrations in biota and concluded that a human would have to eat 5 to 15 kilograms (11 to 33 pounds) of contaminated seafood in a short period of time (biological half-life of barium is less than 24 hours) in order to be at risk. Organic mercury is readily taken up by marine biota and accumulates in the liver and kidney (Hamer 1986). Mercury accumulation by pilot whales can be high enough to pose a health risk to human inhabitants of the Faroe Islands (Andersen et al. 1987), and seal meat has been found to contain high levels of mercury (Botta et al. 1983). The potential for chromosome mutagenicity was high in Greenlandic Eskimos having a high proportion of seal meat in their diet, and seal meat consumption was positively correlated with human blood concentrations of mercury and cadmium (Wulf et al 1986). The body burden of metals in birds and animals from areas remote from major human activity (the Antarctic and the Canadian Arctic) are relatively high (Steinhagan- Schneider 1986; Eaton and Farant 1982). The increases in metal body burdens of animals consumed by humans attributable to drilling mud discharges are expected to be minor, since drilling mud discharges are periodic and of small volume. However, incrementally small additions of heavy metals from diverse sources do increase the potential for bioaccumulation of metals through the food chain. Metal content of drilling muds should therefore be minimized. EFFECTS OF LAND DISPOSAL Land disposal of drilling muds and cuttings is generally unattractive as sites fill and new disposal locations must be found. Although land disposal has been considered for operations off the Canadian coast (Lamm 1982) and in the Beaufort (Dranjnich 1983; Cooper Consultants, Inc. 1986a) and Chukchi Seas (Cooper Consultants, Inc. 1986b). However, if the drilling mud composition is such that ocean disposal would -51- 62-6 violate the conditions of the NPDES permit, or if there is insufficient information to determine that there will be no unreasonable environmental degradation to the discharge site, on-land disposal is the only option. On-shore disposal options include placing the mud in existing quarries, building pits or sumps, of direct land disposal. For each of these options, shipping traffic, docking facilities, and haul roads are required. ~ The construction of pits or sumps removes land from other uses. The magnitude of land loss is dependent on the volume of waste to be disposed and the amount of time that would be required to reclaim the lands with vegetative cover. Snow can accumulate in the pits over winter, and flooding is a danger during spring break-up. Furthermore, drilling muds and fluids that could not be safely disposed of at sea probably contain toxic materials such as oil and grease, heavy metals, synthetic and natural organic compounds, high concentrations of salt, and have a high biochemical oxygen demand. Accumulated pit water must be disposed of to avoid a lagoon forming which may attract waterfowl and other wildlife and pose potential hazards to them. Land disposal Of pit water can stress the vegetation; for example, willows are particularly sensitive to salt concentrations over 4,000 milligrams per liter (Cooper Consultants, Inc. 1986a). French and Rossiter (1985) monitored the impacts of placing waste drilling fluids upon tundra. It was found that (1) no significant deleterious changes in water quality occurred in adjacent Hoodoo River as a result of overland seepage of waste effluent, (2) leaching of heavy metals appeared to be slow and soluble components were quickly diluted to background levels, and (3) terrain disturbance was considerably less than that which might have occurred if a sump had been constructed. These short- term results suggest that direct surface disposal of waste fluids may be an acceptable procedure in those polar semi-desert environments where the potential for permafrost terrain disturbance is high. 5525 LITERATURE CITED Aagaard, Knut. 1984. Current, CTD, and pressure measurements in possible dispersal regions of the Chukchi Sea, University of Washington. Alldredge, A. L., M. Elias, and C. C. Gotschalk. 1986. Effects of drilling muds and mud additives on the primary production of natural assemblages of marine phytoplankton. Mar. Environ. Res. 19:157-176. Andersen, A., K. Julshamm, O. Ringdal, and J. Moerkoere. 1987. Trace element intake in the Faroe Islands. 2.. Intake of mercury and other elements by consumption of pilot whales (Globicephalus meleanus). Sci. Total Environ. 65:63-68. Anderson, J., W. Birge, J. Gentile, J. Lake, J. Rodgers, Jr., and R. Swartz. 1987. Biological effects, bioaccumulation, and ecotoxicology of sediment-associated chemicals. Pp. 268-296 in K. L. Dickson, A. W. Maki, and W. A. Brungs, eds., Fate and effects of sediment-bound chemicals in aquatic systems. Proceedings Sixth Pellston Workshop, Florissant, Colorado. SETAC Special Publication Service. Pergammon Press, New York. Anderson, J. W., L. J. 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Zhou. 1987. Cadmium accumulation, distribution and elimination in the bivalve Macoma balthica: Neither metallothionein nor metallothionein-like proteins are involved. Mar. Environ. Res. 21:225-237 Liss, R. G., F. Knox, D. Wayne, and T. R. Gilbert. 1980. Availability of trace elements in drilling fluids to the marine environment. Pp. 691-722 in 1980 Symposium research on environmental fate and effects of drilling fluids and cuttings. Lake Buena Vista, FL. Lockhart, W. L., D. A. Metner, A. P. Blouw, and D. C. G. Muir. 1982. Prediction of biological availability of organic chemical pollutants to aquatic animals and plants. Pages 259-272. In J. G. Pearson, R. B. Foster, and W. E. Bishop (eds.) Aquatic Toxicology and Hazard Assessment: Fifth Conference. ASTM STP 766. American Society for Testing and Materials, Philadelphia, PN. Mair, J. McD., |. Matheson, and J. F. Appelbee. 1987. Offshore macrobenthic recovery in the Murchison Field following the termination of drill-cuttings discharges. Mar. Poll. Bull. 18:628-634. - 56 - Mariani, G. M., L. V. Sick, and C. C. Johnson. 1980. An environmental monitoring study to assess the impact of drilling discharges in the mid-Atlantic. lil: Chemical and physical alterations in the benthic environment. Pp. 438-498 in 1980 Symposium - research on environmental fate and effects of drilling fluids and cuttings. Lake Buena Vista, FL. Menzie, C. A. 1982. The environmental implications of offshore oil and gas activities. Environmental Science and Technology 16:454-472. Menzie, C. A., D. Maurer, and W. A. Leathem. 1980. An environmental monitoring study to assess the impact of drilling discharges in the mid-Atlantic. IV: The effects of drilling discharges on the benthic community. Pp. 499-540 in 1980 Symposium - research on environmental fate and effects of drilling fluids and cuttings. Lake Buena Vista, FL. Menzie, C.A. 1983. Environmental concerns about offshore drilling - Muddy issues. Oceanus 26(3):32-39. Michel, W. C., K. 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National Academy Press. Washington, DC. 180 pp. Neff, J. M. 1981. Fate and biological effects of oil well drilling fluids in the marine environment: A literature review. Report 15077. U. S. Environmental Protection Agency. Gulf Breeze, FL. 151 pp. Neff, J. W., R. S. Foster, and J. F. Slowey. 1978. Availability of sediment-adsorbed heavy metals to benthos with particular emphasis on deposit-feeding infauna. poCee Contract No. TR D-78-42. U. S. Army Corps of Engineers, Washington, . 286 pp. as ce-r Northern Technical Services (NORTEC). 1985. Environmental effects of below-ice drilling effluent discharges, Mukluk Island, Well No 1, Beaufort Sea, Alaska. Prep. for SOHIO Alaska Petroleum Company. 57 pp. Northern Technical Services (NORTEC). 1984. Renaissance study, drilling mud and cuttings disposal site, Seal Island, Beaufort Sea, Alaska. Final Report prepared for Shell Western Exploration & Production Inc. Anchorage, AK. 27 pp. Northern Technical Services (NORTEC). 1983. 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Highly hazardous material spills and emergency planning. Marcel Dekker, Inc. NY. 225 pp. Zimmerman, E. and S. de Nagy. 1984. Biocides in use on offshore oil and gas Platforms and rigs. Prep. for U. S. Environmental Protection Agency. Unpubl. draft. 27 pp. APPENDIX K THE U.S. DEPARTMENT OF THE INTERIOR’S AUTHORITIES, RESPONSIBILITIES, AND RESPONSE ACTIONS WITH THE T/V EXXON VALDEZ OIL SPILL THE U.S. DEPARTMENT OF THE INTERIOR’S AUTHORITIES, RESPONSIBILITIES, AND RESPONSE ACTIONS ASSOCIATED WITH THE T/V EXXON VALDEZ OIL SPILL Shortly after midnight on March 24, 1989, the 987-foot vessel T/V Exxon Valdez struck Bligh Reef in Prince William Sound, Alaska. What followed was the largest oil spill in U.S. history. The resultant oil slick contacted coastlines in Prince William Sound, along the Kenai Peninsula, Cook Inlet, and the Shelikof Strait. Experts are assessing the environmental and economic implications of the T/V Exxon Valdez oil spill. The job of cleaning up the spill is a continuing process; and, although the initial response proceeded slowly, major steps have been taken. The very large spill size, the remote location, and the character of the oil all tested spill-preparedness and -1 capabili- ties. Government and industry plans, individually and collec- tively, proved to be wholly insufficient to control an oil spill of the magnitude of the T/V Exxon Valdez. Initial industry efforts to get equipment onscene were slow. And, once deployed, the equipment could not cope with the spill. Authoritics and Responsibilities: The U.S. Department of the Interior (USDOI) has four areas of responsibility for oil spills or releases of hazardous substances. Two entail response activities, and two are associated with USDOI’s role as a trustee for natural resources. The authorities for these activities are the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act, and the Clean Water Act (CWA) (amendments to the Federal Water Pollution Control Act) Section 311. Executive Order (EO) 12580 names the members of and delegates certain responsibilities to the National Response Team, of which USDOI is a member. Following oil spills or releases of hazardous substances, the USDOI--as a member of the National Response Team and Regional Response Teams--provides response assistance along with other Federal agencies in support of the U.S. Coast Guard (USCG) or the Environmental Protection Agency (EPA) in the manner described in the National Contingency Plan and the Regional Contingency Plans. The USDOI’s focus in response assistance is based on the full range of the Department’s jurisdiction and expertise. (The USDOI also responds to oil spills or hazardous-substance releases on its own lands, in compliance with Superfund provisions for Federal facilities.) As a trustee for natural resources, the USDOI is authorized to seek compensation for—or restoration of—natural resources under its trusteeship that may have been injured by releases of oil or hazardous substances. Federal trust responsibilities encompass those natural resources belonging to, managed by, held in trust by, appertaining to, or otherwise controlled by the United States. Under CERCLA/CWA and EO 12580, the USDOI is a trustee for migratory birds and certain marine mammals (e.g., walruses, polar bears, and sea otters) and for its park, refuge, and Native-allotment lands. Trustee activities may include participating in negotiations with potential responsible parties along with any other natural resource-trustee agency, EPA, USCG, and the Department of Justice to agree upon either compensation for injured natural resources or measures to be taken for the restoration or rehabilitation of injured resources. Where injury to natural resources has resulted from the release of oil or hazardous substances, the USDOI is responsible for developing regulations that may be used by Federal or State natural resource trustees in assessing damages. Use of these regulations is not required, but trustee claims based on these regulations have the force and effect of a "rebuttable presump- tion" in court. Within the USDOI, notification of the T/V Exxon Valdez oil spill was first received by the Alaska K-1 Bureau of Land Management (BLM) and immediately there- after by the USDOI’s Regional Environmental Officer (REO) in the Alaska Office of Environmental Project Review, the USDOI member on the Alaska Regional Response Team (ARRT). The REO’s office became the central point for coordination of ARRT members in Anchorage and coordination for USDOI support to the response efforts led by the USCG. The Regional Environmental Assistant’s (REA) office at the headquarters of the USCG’s Federal On-Scene Coordinator (OSC) in Valdez became a key coordination point for natural resource-related activities and for USDOI logistical support throughout the first few weeks of the spill. In addition to the Office of Environmental Project Review, USDOI’s response involved five bureaus and the Office of Aircraft Services (OAS) on the basis of: (1) land, natural, and cultural resource jurisdiction (Fish and Wildlife Service [FWS], National Park Service [NPS], and Bureau of Indian Affairs [BIA]); and (2) expertise and logistical support (BLM, Minerals Management Service [MMS], and OAS). ° Fish and Wildlife Service: The FWS concentrated its short-term efforts on documenting the numbers, species, and locations of migratory birds and sea otters in areas affected or potentially affected by the spill and on docu- menting effects on sea otters and migratory birds and their habitats. The FWS provided resource information throughout the planning of cleanup operations, par- ticipated in aerial reconnaissance of proposed cleanup sites, and monitored onsite-cleanup operations. The FWS also monitored Exxon-funded rescue and rehabilitation opera- tions for birds and sea otters and provided personnel and logistic support for capture of eagles and sea otters. ° National Park Service: The NPS, with the assistance of the **ragency Incident Command Team (ICT), organized and supervis<4 documentation of prespill conditions at Kenai Fjords, Katmai, and Lake Clark National Parks and Aniakchak National Monument. Activities included water- quality sampling, shoreline-vegetation surveys, cultural resource surveys, and wildlife counts. The NPS docu- mented wildlife effects and provided technical assistance in beach-cleanup operations. The NPS personnel worked closely with the USCG to establish priorities for placing oil-containment booms and monitoring onsite-cleanup operations. Bureau of Indian Affairs: The BIA provided information to Exxon to ensure that cultural resources were identified and protected during shoreline-cleanup operations. Bureau_of Land Management: The BLM provided personnel and equipment to the REO’s office in Anchor- age and the REA’s office in Valdez and mobilized ICT personnel and equipment to support response activities in the Seward, Kodiak, and Homer zones. In addition, BLM provided and deployed remote weather-tracking stations for the National Oceanographic and Atmospheric Administra- tion (NOAA) and fuel bladders to support remote aerial and boat operations in Prince William Sound. ° — Office of Aircraft Services: The OAS provided air support to USDOI bureaus and other Federal and State agencies. Minerals Management Service: The MMS initiated the following actions after the T/V Exxon Valdez oil spill: (1) assisted other bureaus and agencies during the oil spill, (2) funded studies (including data collection) associated with the spill, and (3) worked to improve oil-spill planning and response. The Alaska OCS Region of MMS provided personnel assistance to meet other bureau needs during the Exxon Valdez oil spill. For example, they provided staff support to the REO during the first 3 weeks of the spill; and regional staff worked on otter capture and surveillance, assisted in bird identification and census at the bird-mortality centers, and participated on the Resource Assessment Team. On April 18, 1989, Secretary of the Interior Lujan directed MMS to immediately review current oil-spill-planning and response requirements for OCS oil and gas operations. In response to this directive, the MMS Director organized a task force to evaluate spill planning, training, drill and inspection requirements, and procedures for each MMS OCS Region. The MMS task force undertook an intensive review of MMS regulations and policies to define needed changes in cleanup and oil-spill-containment provisions. The Alaska OCS Region initiated two task forces to review current oil-spill-contingency plans (OSCP’s) in relation to MMS regulations. The Shell Western Exploration and Production, Inc.’s, Chukchi Sea OSCP and the Amoco Production Com- pany’s Belcher OSCP were reviewed. Both plans met MMS requirements. K-2 The Alaska OCS Region implemented a "tabletop" oil-spill- response drill. This drill is a test for a major spill simulating a blowout with a 5,000-barrel-per-day flow. The objective is to walk through the and to exercise the knowledge of the OSC. The MMS completed an exercise with Shell Western at the Burger Prospect in the Chukchi Sea. The Alaska OCS Region also made a physical inventory of the oil-spill-response equipment at the oil-spill-response coopera- tives. This inventory included a physical count to make sure equipment was onsite and to verify the usable condition of the equipment. These inventories were conducted at Alaska Clean Seas, at the Cook Inlet Response Organization, and in Canada. On April 18, 1989, Secretary of the Interior Lujan announced that the USDOI would expand its current research program for improving oil-spill-response technology. The funding planned for the program, $6 million over a 3-year period, will be evenly shared by the American Petroleum Institute. The money will fund research in oil-spill detection, containment, and cleanup technology. These activities will be coordinated with other executive branch agencies including the Department of Trans- portation, EPA, and NOAA, as well as other countries, including Canada. APPENDIX L OIL-~SPILL RESPONSE OIL-SPILL RESPONSE I. FATE AND BEHAVIOR OF SPILLED OIL The spilled-oil fate and behavior description, in general, and in specific regard to surface spills, subsurface spills, summer broken-ice spills, and winter broken-ice or under-ice spills as contained in Sale 100 FEIS, Section IV.A.1.a (USDOI, MMS, 1985), is incorporated by reference; a summary of this description, as augmented by additional material, as cited, follows. This section addresses additional oil-spill concerns for proposed Sale 126 related to the Chukchi Sea Planning Area ice conditions. In this section, oil-weathering rates are calculated from the weathering model described in Payne (1984) and Kirstein and Redding (1988). In this spill-behavior discussion, oil-spill cleanup is not considered or assumed. It is likely that cleanup would be attempted but, historically, at-sea cleanup has not been very effective. Success depends too greatly on local ice, oceanographic, and weather conditions; type and oil quantity; logistics; and shoreline character. Readers are referred to Appendix L, Section III, for a discussion of oil-spill-cleanup technology and effectiveness. Spills 1,000-bbl or greater from pipelines and platforms pose the greatest spill risk to the study area. In the Chukchi Sea, 53 percent of spill risk is derived from pipelines and 47 percent from platforms. A pipeline spill would almost always be a subsurface spill. Most platform spills--because platform spills are much more likely to occur during production than during exploration--would occur as surface spills. Pipeline and platform spills are more likely to be crude oil but could be fuel oil. In the Outer Continental Shelf (OCS), 7 of 12 1,000-bbl-or-greater platform spills were of stored oil, either stored crude or fuel oil. Stored-oil spills could be as large as blowout spills. For example, Endicott Reservoir preliminary development plans called for storage of 50,000 bbl of diesel for potential shutdown (crude oil could congeal in the pipeline). A winter spill that resulted from the proposed action most likely would be into moving pack ice. Most proposed sale areas contains pack ice, the previously unoffered Chukchi Sea portion of the proposed sale area has little landfast ice, and most undiscovered resources are thought to be in deeper waters. A. Surface Spills: Oil spills spread less in cold water than in temperate water due to the increased oil viscosity. In the Sale 126 area, an oil spill would spread less, remaining 100-fold thicker than a slick in a more temperate climate. In the Chukchi Sea, a 22,000 bbl open-water spill (average size 1,000-bbl-or- greater pipeline or platform spill) may physically cover 2 to 5 km’, and a 100,000 bbl spill may cover 5 to 14 km? (Table L-1). The oil spill, however, would not remain as one continuous slick over such a small area. Winds 4.4 m per second or greater would cause a slick to break into windrows. Waves, slick movement, and changes in winds and ocean currents all tend to spread the slick discontinuously over the ocean surface. In open water in the Chukchi Sea, within 30 days, the slick could spread discontinuously over an area 200-fold greater than the actual oiled surface area. As weathering and spreading forces continued, the oil would separate further into individual tarballs or pancakes. The oil composition affects how an oil slick would weather. North Slope and the crude that may be found in the Chukchi Sea and resulting characteristics may vary considerably, but generalizations could be made. Volatile component evaporation accounts for the largest loss from most crude-oil spills, on the order of 25 percent within the first 24 hours. Over the oil-slick life, evaporation accounts for about one-sixth to two-thirds of slick mass. For Prudhoe Bay-like crude, with a high residual content, approximately 9 percent of a spill would evaporate in 1 day at 2°C and a 6-m-per-second (11-kn) wind (calculated from Payne 1984), Higher wind speeds or warmer temperatures would increase the initial evaporation rate but would not Table L-1 Spill-Size Examples for Spills in the Open-Water Season in the Chukchi Sea Planning Area Summer Spill” Meltout Spill” Time After Spill: 3 Days 10 Days 30 Days 3 Days 10 Days 30 Days 22,000-bbl Spill Oil Remaining (%) 83 72 58 84 65 44 Thickness (mm) 16 08 0.4 2, 1.0 0.5 Thick-Slick Area (km?)*/ 18 3.1 48 1.2 2.0 3.0 Discontinuous- Slick Area (km?) 57 260 1,100 1,400 1,600 2,200 100,000-bbl Spill Oil Remaining (%) 85 76 63 88 70 48 Thickness (mm) 2.6 13 0.7 a8 17 0.9 Thick-Slick Area (km?) SL 8.8 14 3.4 5.7 8.5 Discontinuous- Slick Area (km?) 120 570 2,300 3,000 3,500 4,800 Source: Vv 2/ 3 4/ Calculations are based on the oil-weathering model of Kirstein and Redding (1988). These examples are of a Prudhoe-Bay type crude, which is considered the best analog for undiscovered crude in the Chukchi Sea Planning Area. September spill, 11 kn windspeed, 2°C, 0.7-m waves; average weather based on Brower et al, (1988). Time after meltout. Spill assumed to occur in May into first-year pack ice, pools 2 cm thick on ice surface for 10 days at 0°C prior to meltout into 50-percent ice cover, 0°C, 11 kn windspeed, negligible waves. This is the area of oiled surface. Calculated from Equation 6 of Table 2 in Ford (1985); the discontinuous area of a continuing spill or the area swept by an instantaneous spill of the given volume. Note that ice dispersion occurs for about 60 days prior to Meltout Day 0. appreciably increase the slick mass percentage that eventually escapes into the atmosphere. Volatile components total only 18 percent of Prudhoe Bay crude. A diesel fuel spill would behave similarly, but diesel is missing both the most volatile and least volatile components found in crude oil. Under the conditions assumed above for a Prudhoe Bay crude, a light diesel would initially evaporate more slowly than the crude, on the order of 3.2 percent over the first day, but overall, a larger percentage of diesel would evaporate. Competing with evaporation is dissolution, which chiefly involves the volatile aromatic fraction. Compared to evaporation, dissolution is very slow; usually most volatiles evaporate rather than dissolve. Dissolved hydrocarbon concentrations underneath a slick, therefore, tend to remain low (see Sec. IV.B.1 of this Environmental Impact Statement [EIS]). Over time, about 5 percent of a slick would dissolve. Winds, waves, and currents break off oil droplets from a slick and mix them into the underlying water. The greater the turbulence, such as in a storm, the more rapidly oil is lost from the slick. Oil droplet dispersion into the water, not dissolution, is the major mechanism for getting oil into the water column. Mousse formation (water-in-oil emulsion) slows but does not stop dispersion from a slick. For Prudhoe Bay-like crude, with a relatively small volatile component, dispersion could be important in removing oil from a slick. A 22,000-bbl Prudhoe Bay crude spill would initially have a 9.7 grams per m? per hour dispersion rate (Table L-2). Dispersion would initially remove about 2.4 percent of the oil slick per day, about 13 percent over 10 days, and about 18 percent over 30 days. Storm winds and waves could greatly increase dispersion rates. The slick character changes through time. Many crudes, including Prudhoe Bay crude, form mousse. Most Canadian Beaufort Sea crudes, however, do not (Bobra and Fingas, 1986). After initial weathering, roughly 40 percent of the Prudhoe Bay-like crude may remain as tarballs, pancakes, or mats. For arctic open waters, tarballs could form within days to months, depending on weather, mixing energy, oil type, and nucleation sites availability to initiate tarball formation (Payne, 1982, 1984; MacGregor and McLean, 1977). B. Subsurface Spills: Subsurface spills could occur from leaks through the seafloor pipelines or from subsea well blowouts. Blowouts or pipeline spills would disperse small oil droplets and entrained gas into the water column. A trunk pipeline--with gas removed--would emit only oil droplets. Most oil would rise rapidly to the water surface to form a slick. Droplets less than 50 microns in size, a category including about 1 percent of total spill volume, could be carried several kilometers down-current before reaching the water surface. Buist, Pistruzak, and Dickins (1981) found that 90 percent of the oil reached the surface within 50 m of the discharge point in a simulated subsurface gas-and-oil blowout at a 20-m-water depth in the Canadian Beaufort Sea. Oil droplet release allows some increase in the oil dissolution, but the rapid oil rise to the surface suggests that this increase in dissolution must be fairly small. Oil that reached the surface would weather and behave similarly to a surface spill. C. Summer Broken-Ice Spills: The Sale 126 area is mostly covered by pack ice in summer. Therefore, a summer spill would most likely be into first-year or multiyear broken ice. An oil spill in broken ice would spread between ice floes into any gaps greater than about 8 to 15 cm (Free, Cox, and Schultz, 1982). A large, instantaneous spill would push loosely packed ice floes away from the spill, creating a larger gap at the spill site. In more closely packed ice--because fresh crude oil is less dense than sea ice--crude oil would have a tendency to overflow rather than underflow ice (Thomas, 1983). Any waves within the ice pack also would tend to pump oil onto the ice. Approximately 25 percent of the oil spilled in pancake ice would be present on the pancake top due to pumping (Stringer and Weller, 1980). More viscous L2 Table L-2 Total Hydrocarbon Concentration Examples for Spills in the Open-Water Season in the Chukchi Sea Planning Area Summer Spill” Meltout Spill?’ Time After Spill: 3 Days 10 Days 30 Days 3 Days 10 Days 30 Days 22,000-bbl Spill Concentration (ppm') 16 .09 .04 03 05S 04 100,000-bbl Spill Concentration (ppm) aad Ag 07 04 09 .08 Source: USDOI, MMS, 1989. i Concentration is based on the discontinuous area calculated from Equation 6 of Table 2 in Ford (1985) and a 10-m water depth. Time after meltout. Spill assumed to occur in May into first-year pack ice, pools 2 cm thick on ice surface for 10 days at 0°C prior to meltout into 50-percent ice cover, 0°C, 11 kn windspeed, negligible waves. 2/ and/or weathered crudes may adhere to porous ice floes, essentially concentrating oil within the floe field and limiting the oil dispersion. Such concentration was observed in the Ethel H. (Deslauriers, 1979) and Kurdistan (Reimer, 1980) spills. Initial spillage could entrain some oil on the ice floe underside; however, due to oil’s buoyancy, most oil would remain in the water between floes. Oil would move from underneath first-year ice when differences in ice and underlying water velocities are approximately 15 to 25 cm per second (Cox and Schultz, 1981). Velocities would have to be greater than 20 cm per second to move oil underneath the rougher multiyear ice relief. In the Chukchi Sea Planning Area, strong currents and 15 to 25 cm per second differential velocities are possible. In broken, first-year ice, brine channels allow relatively rapid oil movement from underneath the ice to the ice surface. Thomas (1983) calculates a maximum 0.4 mm per hour oil-flow rate through decaying first-year ice. Any ice--wave action oscillation, slight floe uplifting from collisions, overturning, or tilting that results from uneven melting--also tends to remove oil from underneath the ice. Multiyear ice does not contain continuous brine channels. Entrapped oil release from multiyear ice would be slower than from first-year ice but would still occur. Oil between or on ice floes is subject to normal evaporation. Some additional oil dispersion occurs in dense, broken ice through floe grinding action (Reimer, 1980). This floe grinding action also promotes mousse formation. With floe grinding, Prudhoe Bay crude forms a mousse within a few hours, an order of magnitude more rapidly than in open water (Payne, 1984). D. Winter Under-Ice Spills: A winter spill under unbroken, landfast ice or pack ice would most likely be a pipeline spill. The oil would rise to the ice underside as described for a summer pipeline spill rising to the water surface. Oil spreading along the ice underside is controlled by several factors. Separate oil droplets or small pools of approximately 0.2-mm thickness would not coalesce or flow into hollows underneath the ice (see Buist, Pistruzak, and Dickins, 1981). Approximately 2 mm of additional oil could be accommodated in the skeleton ice crystals beneath the solid-ice layer. Thicker oil layers coalesce or spread under the ice until an equilibrium 0.8 cm thickness is reached (Rosenneger, 1975). If a sufficient oil volume is instantaneously spilled, oil would spread into hollows underneath thinner ice. In first-year late winter ice, such hollows could store 150,000 to 300,000 bbl per km? (Stringer and Weller, 1980). Multiyear ice, which is rougher, could store 1.8 MMbbI per km? in under-ice relief (Kovacs, 1977). More than 90 percent of the proposed sale area lies in the pack-ice rather than the landfast-ice zone (Roberts, 1987). A spill into winter ice would, therefore, more likely be into multiyear pack ice than landfast ice. The greater multiyear ice storage capacity would not be well-used in a real spill situation due to ice movement over the spill. A 1,000-to-25,000-bbl-per-day-pipeline spill may spread as a ribbon, approximately 100 m wide and 0.3 to 8 mm thick, on the moving pack ice underside. Greater than 25,000-bbI spills would pool within the ribbon into hollows on the ice underside. Only a spill rate greater than 75,000 to 150,000 bbl per day would fill the ice underside storage capacity and result in a wider ribbon. The ribbon length depends on spill duration; and the ribbon would grow at the ice drift speed, approximately 5 km per day in the Chukchi Sea Planning Area (see Sec. III.A.3.a of this EIS). Faster ice movement may occur in a storm, resulting in a longer, but thinner, oiled ice ribbon. Differential velocities between ice and underlying water greater than 15 to 25 cm per second would move oil out of ice underside hollows. Fifteen to 25 cm per second velocities are possible in the Chukchi Sea Planning Area. Even with 15 to 25 cm per second velocities, oil may not move more than a few kilometers from its original ice underside location. New ice would form beneath the under-ice oil within 5 to 10 days, isolating it L-3 from currents and further weathering. Grease ice and also slush ice beneath the ice cover should retain spilled oil and limit its spread and movement (Martin, 1981; Truett, 1985). Because of these and other factors, a winter spill (or whatever part of a winter spill that is not cleaned up) is a fresh, unweathered spill when the ice melts. To get into a lead or a polynya earlier than breakup, oil would have to be spilled in a polynya or a polynya would have to form through the ice-entrapped spill; that is, it would have to break the ice in the middle of the frozen spill. If such breakage occurred in the latter case, appreciable quantities of oil could not be released unless breakage occurred through a relatively rare, thicker oil pool. Such pools would be isolated and small; therefore, only minimal quantities of oil would be released into the forming polynya. Oil released into the polynya would be blown to its downwind edge, where it would accumulate in a band. The oil would then be either frozen into the ice or contained behind accumulating brash ice (floating ice fragments not more than 2 m across). It is possible that the cold, saline water formed as the polynya freezes could incorporate relatively high dissolved hydrocarbon concentrations into a sinking denser water plume. This plume would then spread out at some equilibrium depth in deeper water as a relatively stable and distinct layer (see Sec. IV.C.1 of this EIS). In the Chukchi Sea Planning Area, oil would start melting out of first-year ice in June; oil spilled earlier in winter would melt out earlier. Oil in multiyear ice would be released more slowly, perhaps 1 to 3 months later, with 10 percent of the oil taking more than 1 year for release. E. Winter Broken-Ice Spills: The most likely winter spills from platforms in the proposed Sale 126 area would be spills into broken pack ice. Spills from platform-stored oil would collect in open water or broken ice in the lee of bottom-founded production platforms. Blowouts provide a mixed spill mode. A subsea blowout would place oil into the broken ice in lee of the platform. The subsequent winter spilled oil fate would be similar to a subsea-pipeline leak under ice. Rather than underneath the ice, a surface blowout would place oil into broken ice and on top of the ice. Such surface release would likely result in appreciable, but incomplete, volatile hydrocarbon evaporation prior to breakup. Thus, a surface blowout--or any other spill on top of the ice--would be partially weathered during winter. Most oil spilled into winter broken ice would be rapidly frozen into the pack ice. Because the oil would be frozen into new ice, brine channels would be present and would allow most oil to be released during breakup. II. EXTENT AND PERSISTENCE OF OILED SHORELINE If an oil spill occurs and contacts shore, two important but nonbiological questions arise: (1) how much shoreline would be contaminated and (2) how long would the contamination persist? In winter, Chukchi Sea landfast ice may keep spills offshore, away from the shoreline, and any oil that did reach shore would not penetrate into the frozen beach until it thaws in spring. For these shorelines, spills during the open-water season are a greater hazard than spills during the winter. A. Extent of a Shoreline Spill: An offshore spill that reaches shore is not likely to reach the shoreline in its entirety; contact could occur with the shoreline in several locations, or the spill could be "smeared" along a single location, depending on the winds and longshore current. How long a stretch of coastline could be coated by an oil spill is difficult to quantify but could be estimated on the basis of a study by Ford (1985). L4 Ford used multiple regression and 39 spill case histories in which coastline was oiled to develop empirical equations predicting how much coastline would be oiled if oiling occurred. (Note that not all spills reach shore.) Ford found the volume spilled accounted for 59 percent of the variance in the historical record. Volume and latitude was a slightly more precise estimator, accounting for an additional 6 percent of the variance. Wind speed, water temperature, and wave height did not significantly correlate to the amount of shoreline oiling. The Equation 13 (Table 4 in Ford, 1985) relating shoreline oiling to volume alone is a more appropriate predictor than the equation relating oiling to both spill volume and latitude. The correlation to latitude is caused by a an increase in shoreline complexity as latitude increases. However, the historical spill record Ford uses encompasses a narrow latitude range. Based on Equation 13, if a 22,000 bbl spill occurred and contacted land, about 50 km of coastline would be oiled. For a 100,000 bbl spill, oiling would be on the order of 90 km. However, it would be possible for a spill to contact severalfold longer or shorter stretches of coastline than these averages or, alternatively, not contact any shoreline at all. A 100,000-bbl-or-greater spill and, in particular, long-duration spills are depicted less precisely in the oil-spill-risk analysis than are instantaneous spills. The oil-spill-risk analysis could still be used to represent the risk from such spills. For 100,000 bbl-or-greater spills, the spill center of mass is represented accurately. However, the oil spreading over different trajectories through time and space results in more frequent oil contacts to land but with each contact involving only a total spill fraction. For such spills, the conditional contact probabilities from an individual hypothetical spill site represent the total spill fraction that would contact that environmental-resource area or land segment, disregarding weathering and cleanup. Such spill/model- trajectory behavior is demonstrated by both the Santa Barbara spill of 1969 (Amstutz and Samuels, 1984) and the Exxon Valdez spill of 1989 (Jayko and Spaulding, 1989). (The conditional probability would normally represent the likelihood that the environmental-resource area or land segment was contacted by the entire spill.) Note, however, that there are additional constraints on specific shoreline stretch oiling potential. These constraints are discussed in the Sale 87 FEIS, Section IV.A.1.d (USDOI, MMS, 1984). This discussion is incorporated by reference; a summary follows. The Chukchi Sea tidal range is low (10-30-cm average), and marsh or delta tidal flat habitats would have to be inundated by seawater during a storm surge to allow appreciable inland oil stranding. These dual restraints on oil stranding reduce the oiling likelihood and degree to marsh and delta tidal flats to less than that implied by probabilities from the oil-spill-risk analysis. B. Persistence of Stranded Oil: The shoreline oil-retention characteristics along the U.S. Chukchi Sea coast are described in the Sale 109 FEIS, Section IV.A.1.d (USDOI, MMS, 1987). This description is incorporated by reference; a summary follows. An oil-persistence discussion relates to that oil remaining after cleanup or to situations where cleanup could cause more damage than if the spill is left in place. Marshes; low tundra shores; and low, vegetated barriers, may be areas where most cleanup operations--contaminated soil and vegetation removal or even heavy foot traffic--could cause permanent scars in the landscape and ecosystem. Newer techniques, such as low-pressure hosing coupled with clipping of oiled vegetation, provide both ecologically and technologically sound means of cleaning some of these areas. Thus, cleanup is a viable option to mitigate shoreline oiling and oil persistence. Oil persistence on various shoreline types has been investigated both experimentally through small, deliberate test-plot spills and by monitoring oil persistence following accidental spills. In these studies, oil persistence is highly correlated with shoreline type, largely due to the physical processes in both oil weathering and natural oil dispersion (Hayes, Gundlach, and Getter, 1980; Michel et al., 1990). Based on these empirical data, several studies have rated the Chukchi Sea coastline oil-retention potential. Most Chukchi Sea coastline has moderate to high retention potential, with less than half of the coast in the L-5 high category (EIS Fig. IV-A-11; Hayes and Ruby, 1979; Woodward-Clyde Consultants, 1981; Robilliard et al., 1985). Stranded oil, if not cleaned up and if in a zone of high oil-retention capacity, could persist for decades along at least some oiled shoreline (Gundlach, Domeracki, and Thebeau, 1982). In many locations, persistence would be less due to the rapid Chukchi Sea coastline retreat rate; stranded oil would erode along with the shoreline. Ill. OIL-SPILL-CONTINGENCY MEASUR: A. Federal Laws: Environmental protection from oil spills is regulated under the National Oil and Hazardous Substances Pollution Contingency Plan (40 CFR part 300) required by section 105 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) (42 U.S.C. 9605) and by Section 311 (c) (2) of the Clean Water Act as amended (33 U.S.C. 1321 (c) (2)). Section 311 of the Clean Water Act provides the overall framework for oil spills and designated hazardous substances, including national policy and responsibilities. It is the policy of the United States that the spiller assumes complete financial responsibility for removal actions. If the predesignated On-Scene Coordinator (OSC) determines that timely and/or adequate removal actions are not being carried out, then the Federal Government would initiate cleanup. The Government may then bring action against the responsible party to recover all cleanup costs up to the liabilities set by Federal Law. The CERCLA significantly broadens the scope of spill reporting and response. Specifically, the act requires that the National Response Center be notifies of any release of a reportable quantity of a hazardous substance to the environment. The Resource Conservation and Recovery Act (RCRA) addresses problems related to the generation, disposal, and management of waste materials in the United States. These regulations require that generators, transporters, and disposers of hazardous wastes must obtain EPA identification numbers. During spill situations where hazardous waste is recovered and transported to a disposal sites, the shipment must be accompanied by a manifest which includes the EPA generator and transporter identification number. The Oil Pollution Act of 1990, Public Law 101-380, has a direct effect on some provisions of the OCS program. The Oil Pollution Act of 1990 establishes an Interagency Coordinating Committe on Oil Pollution Research. Membership of the Committe includes representatives of NOAA, DOE, DOI (includes MMS and FWS), DOT, DOD, EPA, NASA, and the U. S. Fire Administration in the Federeal Emergency Management Agency, and other Federal Agencies that may be designated by the Presedent. The Oil Pollution Act of 1990 also requires a study of potential spills in the Arctic Ocean. The Secretary of the Interior, in consultation with the Governer of Alaska, is to conduct a study of the issues of recovery of damages, contingency plans, and coordinated actions in the event of an oil spill in the Arctic Ocean, The Secretary is to submit a report to Congress by January 31, 1991. B. National and Regional Oil and Hazardous Substances Pollution Contingency Plans: The National and Regional Oil and Hazardous Substances Pollution Contingency Plans have been developed in compliance with the Clean Water Act, Section 311 (c)(2) and CERCLA, Section 105. These plans provide for a coordinated and integrated response by departments and agencies of the Federal and State Governments to protect the public health and environment and to minimize adverse effects due to oil and hazardous substances discharge, including containment, dispersal, and removal. The OSC is the Federal official predesignated by the EPA or USCG to provide on-scene coordination and direction of all aspects of a spill and subsequent removal actions. The OSC is predesignated as part of the planning and preparation for response to pollution incidents. The OSC maintains a responsibility to ensure that the proper initiation, containment countermeasures, cleanup, and disposal actions take place. An official from any agency with responsibility under the Regional Contingency Plan may assume the role of the OSC until the predesignated OSC arrives. L-6 The Regional Response Team (RRT) provides the appropriate regional mechanism for planning and preparedness activities before a response action is taken and for coordination and advice during such response action. The two principal components of the RRT mechanism are a standing team, which consists of designated representatives from each participating Federal agency, State and local governments, and incident-specific teams where participation would relate to the technical nature of the incident and its geographic location. Both the national and regional plans contain the responsibilities and the functions of the OSC and the RRT and are available for review at the EPA and USCG offices. The standing RRT would serve to recommend changes in the regional response organization as needed, to revise the regional plan as needed, and to evaluate the preparedness of the agencies and the effectiveness of local plans for the Federal response to discharges and releases. In Alaska, the entire coastal area is a geographic zone of responsibility covered by the Alaska Region Oil and Hazardous Substances Pollution Contingency Plan. The purpose of the regional plan is to provide for a coordinated and integrated Federal and State agency response posture in Alaska at the RRT level. At the same time, this provides the predesignated OSC with guidance and assistance for preparing local contingency plans and responding effectively to pollution incidents. Members of the Alaska Coastal RRT are designated representatives from the USCG, EPA, State of Alaska, Federal Emergency Management Agency, and the following Federal departments: Agriculture, Commerce, Defense, Energy, Health and Human Services, Interior, Justice, Labor, and State. The following are available to assist the RRT, OSC, and SSC in performing their duties: national special forces on call, such as the USCG’s Pacific Strike Team and the Environmental Response Team established by the EPA; a computerized national inventory of pollution-response and -support equipment for locating specialized equipment tailored to the characteristics of the spill; memoranda of agreement and interagency agreements to explicitly define areas of responsibility in cases where overlapping jurisdiction may exist; and specialized functional groups within the RRT to provide expertise and leadership in areas such as public information, pollution-control techniques, damage assessment, and protection of living marine resources. C. Joint Contingency Plan Against Pollution in the Bering and Chukchi Seas: This plan, including the operational appendix, was established under the agreement between the Government of the U.S.A. and the Government of the U.S.S.R. concerning cooperation in combatting pollution in the Bering and Chukchi Seas in emergency situations. The plan primarily addresses international matters and is meant to augment pertinent existing plans. The implementation of the plan is the joint responsibility of the U.S. Coast Guard (Department of Transportation) and the U.S.S.R. Marine Pollution Control and Salvage Administration, attached to the U.S.S.R. Ministry and Merchant Marine. D. MMS Pollution Prevention and Response Regulations: The general and permanent rules for oil, gas, and sulphur operations in the OCS are regulated by 30 CFR part 250. Subpart C regulates pollution prevention and control. Pollution prevention is the top priority. The lessee is directed to prevent unauthorized discharges of pollutants into the offshore waters. Inspections are an integrated part of pollution prevention. Inspections on a daily basis could be required to prevent discharges of pollution. Pollution-response equipment shall be inspected at least monthly. In addition, spills are to be reported immediately if greater than one barrel and within 12 hours if less than one barrel. The oil industry lessee is regulated by 30 CFR 250.42 to submit an oil-spill- contingency plan for approval by the Regional Supervisor with or prior to submitting an Exploration or Development and Production Plan. The MMS, Alaska OCS Region, provides guidelines developed in compliment with the USGS/USCG Memorandum of Understanding (MOU) dated December 18, 1980. An oil-spill- contingency plan (OSCP) shall be reviewed and updated annually. Stated in 30 CFR 250.42 and other legal requirements, the OSCP shall contain information on the following: (1) oil-spill-risk analyses, (2) recovery equipment, (3) equipment availability (4) response time, (5) drills, (6) support vessels, (7) dispersant equipment, (8) authority, (9) disposal, (10) detection and monitoring, and (11) any provision of the regulations dealing with contingency L7 planning, the provision’s use, and maintenance of pollution-control equipment, or related training also shall apply in the preparation of contingency plans. E. Petroleum-Ind R ganizations: Alaska Clean Seas (ACS) was organized by the petroleum industry to support industry oil-spill-response activities in both State and OCS waters off the Alaskan coast. The ACS organization is divided into Cost Participation Areas (CPA’s). The current areas are the ABSORB CPA and the West Coast CPA (Norton Sound, St. George Basin, Navarin Basin, and Chukchi Sea). This cleanup organization and others (such as CIRO) operate through a voluntary private-industry agreement to jointly acquire oil-spill-containment and -cleanup equipment, to train personnel in its use, and to provide a pooled capability of response equipment greater than any one company could provide. On April 7, 1989, Richard M. Morrow, Chairman of the Board, American Petroleum Institute, and Chairman of Amoco Corporation, announced that the Board of Directors of the American Petroleum Institute had established a top-level task force to review industry operations in the areas of oil-spill prevention and response. On June 14, 1989, the task force approved the following conclusions and recommendations. The Task Force proposes that an industry funded Petroleum Industry Response Organization (PIRO) be established to consist of a Headquarters Group and five Regional Response Centers. Although none of these response centers are in Alaska, Richard M. Morrow has written to Governor Steve Cowper and the Alaskan Congressional delegation saying: "The industry had not at all disregarded Alaska, but is treating it explicitly as a unique, and very important, region which is developing a special contingency plan. The Alaska plan specifically establishes at Valdez a response capability roughly equivalent to that proposed for each of the five regional response centers. In addition API should review local capability in the period before PIRO is established." Vice Admiral John Costello, president of PIRO Implementation, Inc., recently reported that each PIRO response center will be manned and equipped to handle up to 216,000-bbl spills (Oil Spill Intelligence Report, 1990). On September, 8, 1990, PIRO announced the formation of the Marine Spill Response Corporation (MSRC). The MSRC will be funded by oil companies and others involved in the shipment or receipt of oil by tanker through another newly created organization, the Marine Preservation Association (MPA). The MSRC will consist of a Washington, D.C., headquarters and five response regions with regional centers located in the New York-New Jersey Metropolitan area (Northeast region), Port Everglades in South Florida (Southeast region), Lakes Charles, Louisiana (Gulf region), Port Hueneme, California (Southwest region), and Seattle, Washington (Northwest region). Alaska is considered one of the six prestaging areas for the Northwest region. According to the API task force report, MSRC should play an appropriate response and cleanup role in Alaska. The definition of this role is not yet resolved. Primary response capabilities already in existence must be evaluated before it can be determined what else might be required. Discussions with industry and the state have not yet proceeded to the point where MSRC’s role can be completely described for Alaska (MSRC press release, 1990). F. Petroleum In Oil-Spill-Contingency Planning: The oil industry lesee is regulated by 30 CFR 250.42 to submit an OSCP for approval by the Regional Supervisor with or prior to submitting an Exploration or Development and Production Plan. Information on oil-spill-contingency planning for the Chukchi Sea is referenced from the only existing public OSCP’s for Sale 109 leases in the Chukchi Sea at this time (Spiltec, 1989; 1990). The Shell Western and Exploration Inc. (SWEPI) and Texaco OSCP’s are used as examples only; other oil companies may choose to handle spill response in their OSCP’s in a different manner. (1) Oil-Spill-Risk-Analyses: Predicting oil-slick movement is desirable because it gives some idea of where a slick would migrate and where potential shoreline contamination may occur due to oiling. Knowing slick movement could aid in preplacement of oil-spill-response equipment, and in the event of a spill, aid in effective oil-spill-response actions (including containment, protection of sensitive areas, and spill cleanup). Spiltec (1989, 1990) used the data from the MMS oil-spill-risk analysis with the Rand three- L-8 dimensional model. Each OSCP used the MMS spill-point data closest to its operation area, ranging from 5 to 45 km. (2) Recovery Equipment: Responses to spills from OCS activities are approached by arranging and ranking lines of defense to prevent spilled oil from affecting identified vulnerable environment. The first line of defense is always offshore mechanical containment. The collection of spilled oil (without containment) is usually not successful (see below). The type of recovery equipment and its deployment method rest entirely with the operator. However, subject to the prevalent conditions identified in the risk analysis, the equipment should be "state-of-the-art." Based on previous research and development studies, observations, and experiences, currently available "state-of-the-art" equipment is capable of operating in 8- to 10-ft seas and 20-kn winds (46 FR 2911). However, a recent reevaluation of the effectiveness of response equipment by the USDOI (USDOI, MMS, OCS Spill Task Force, 1989) following the Exxon Valdez oil spill was more pessimistic, concluding that most response equipment available in the U.S. does not satisfy the MMS/USCG cleanup and recovery requirements in 8- to 10-ft seas. This relatively poor rating of response equipment by the MMS task force was attributed in part to the lack of MMS standard protocols for evaluating and comparing equipment performance. That is, MMS has no formal protocol or quantitative procedures for evaluating whether response equipment proposed by lessees is "state-of-the-art" as required by MMS guidelines for OSCP’s. Based on the MMS task force analysis, offshore-response equipment in U.S. waters does not meet the level of performance required by MMS, Alaska OCS Region guidelines for Approval of Oil-Spill-Contingency Plans. The MMS task force has recommended that MMS establish a standard test protocol for offshore booms and adopt an existing protocol for oil skimmers to define "state-of-the-art" and minimum performance requirements. These recommendations were presented to the Secretary of the Interior and MMS has implemented modifications and alternative procedures that might improve response and readiness. (3) lly Available Spill-Cleanup Equipment: The MMS, Alaska OCS Region, requires a lessee who wishes to drill to have an initial spillresponse capability of 1,000 bbl per day. The Alaska OCS Region used a response capability of 5,000 bbl per day to evaluate SWEPI’s and Texaco’s OSCP in the Chukchi Sea. During SWEPI’s 1990 exploration-well drilling in the Chukchi Sea, oil-spill-cleanup equipment was kept on the drillship, the icebreaking supply boat, and an oil-spill response barge. Table L-3 lists the equipment on the drillship; Table L-4 lists the equipment on the supply boat; and Table L-5 lists the equipment on the dedicated oil-spill-response barge. Beginning in 1991, Texaco and SWEPI will share the oil-spill-response barge Responder, placing the barge at the operation site with the higher risk. Texaco will store oil-spill-response equipment aboard the Kulluk, the supply boats, and the oil-spill response barge. Table L-S5a lists the onsite spill-response equipment aboard the Kulluk and supply boats. Texaco and SWEPI are members of ACS/ABSORB and have access to equipment at the ABSORB Deadhorse warehouse. Table L-6 lists the ACS/ABSORB detection and recovery equipment at Deadhorse. Additional equipment is maintained by additional U.S. companies in the Beaufort Sea, Canadian companies, and the Canadian Beaufort Sea Oil Spill Cooperative at Tuktoyaktuk, NWT (Tables L-7 and L-8). If commercial oil quantities are discovered in the Sale 126 area, additional spill equipment may be stockpiled, either by Alaska Clean Seas or by the field owners. (4) Response Time: The MMS, Alaska OCS Region, requires initial response equipment mobilization and deployment within 6 to 12 hours of a spill, geography permitting. However, the spiller must be prepared to respond before the spill reaches shore (in less than 6 hours, if necessary). This initial timeframe is for relatively small spills, although MMS has not specifically defined size. The SWEPI considers the equipment listed in Table L-7 to be capable of handling small operational spills. The SWEPI considers the equipment listed in Tables L-3 through L-5 to be capable of handling larger spills. b=? Table L-3 Chukchi Sea-Based Equipment for Oil-Spill Response on the Explorer Ii Summer 1989 Item Quantity Kepner Reel Pak (2 @ 500’ each) 1,000 feet SPC sorbent pads 25 bales 3" MTM transfer pump with weir skimmer and hose 1 Source: Spiltec, 1989. Table L-4 Chukchi Sea-Based Equipment on the M/V Robert Lemeur Summer 1989 Item Quantity 26’ Munson aluminum workboats, 2 each with two 140-hp motors Kepner Reel Pak (500’/Pak) w/tow bridle 2 assemblies, "T" connectors, and repair kit Fire-resistant boom 1,000 ft SLURP weir skimmer (57 Ib) w/accessories 1 CSI rope mop skimmer w/200’ mop, swivel Al base, and 3 tail pulleys 3M sorbent sheets (200 sheets/bale) 10 bales 3M sorbent rolls (38-Ib/roll) 20 rolls Barite-Bentonite -- Lost circulation materials -- 10,000 gal storage container 1 2" trash pumps 2 2" diaphragm pump 1 60’ lengths 2" suction hose (B.F. Goodrich) 10 30’ lengths 2" suction hose (B.F. Goodrich) 5 Multiquip 5-kw generator 2 36’ x 9 x 8’ spill response building 1 Heavy Duty Electrical Extension cord 200 ft Barrels, anchors, line, chain, buoys Hand tools, shovels, etc. Plastic liners and bags Polyethylene sheeting Plastic bags Handtools Source: Spiltec, 1989. Table L-5 Chukchi Sea-Based Equipment on the Responder barge for Oil-Spill Response Summer 1989” ITEM QUANTITY 34- x 12-ft tow boats with diesel inboard engines 2 26- x 8-ft aluminum workboats with two 140-hp outboard engines 4 18-ft Avon Searider rigid-hull inflatable boats 2 Kepner Reel Paks, 1,000 ft each with compactible 18- x 23-in boom 2 Kepner Reel Paks, 500 ft each with compactible 8- x 12-in boom 5 3M Fire Boom, 12- to 18-in diameters with 18- to 24-in skirts 3,600 ft Rope mop skimmers 4 Halliburton Skimmering Barrier with boom, pump floats, reels, separators, etc. in SOCK (over-the-side skimmer with power pack, storage tanks, etc.) 1 Transrec Skimmer System (Framo/NOFO Type 250) with reel and power pack, 1,000 ft of NOAS (800 series) Ocean Boom on reel, and an Oil Trawl Collection System (over the side V-shaped barrier with net). 1 10-in Hyde-Vac Suction System (August 1989 delivery) 1 Walosep (WI Model) centripetal/weir skimmer with power pack 1 Komara Disc Skimmers with power pack 2 SLURP Skimmer (portable weir skimmer) 2) Hoses, various 4,150 ft Pumps, various 4 200-bbl oil/water separators 2) 100-bbl oil/water separators 2 Firestone Fabritanks (25,000 gal each) 2 Dracone Barges (2,500 gal each) 2) Bladders (2,500 gal each) 6 Bladders (10,000 gal each) 3 Simplex Helitorches 2 Dispersant spray bucket 1 Drums of Corexit 9527 dispersant 30 3M-type 100 sorbent sheets 40 rolls 3M-type 520 sorbent boom 120 bales 3M sorbent pads 100 bales Bird scare-away cannons 10 7.5-kw generator al 13.5-kw generator 1 Life-support boxes 2) Response boxes 2 90-hp Johnson Outboard i. High-pressure washer 1 Batch mixer 1 Sure-Fire gelling mix 700 Ibs Source: Spiltec, 1989. ' Below-deck storage tanks (9) on oil-spill-response barge will hold up to 67,000 bbl of recovered oil/water. This list is not a complete inventory. Table L-Sa Onsite Spill-Response Equipment on Kulluk and Supply Boats July 1, 1991 ITEM QUANTITY 26-ft Munson aluminum workboats, each with two 140-hp motors a Kepner Reel Pack (500’/Pak)w/tow bridle assemblies, "T" connectors, and repair kits Zz Fire-resistant boom 1,000 ft SLURP weir skimmer (57 Ib) w/accessories 1 CSI rope mop skimmer w/200-ft mop, swivel base, and three tail pulleys 1 3M Sorbent sheets (200 sheets/bale) 10 bales 3M Sorbent rolls (38 Ib/roll) 20 rolls Barite -- Bentonite - Lost circulation materials -- 10,000-gal storage container 1 2-in trash pumps 2 2-in diaphragm pump 1 60-ft lengths 2-in suction hose (B.F. Goodrich) 10 30-ft lengths 2-in suction hose (B.F. Goodrich) 5 Multiquip 5 kw generator 2 36-ft x 9-ft x 8-ft spill-response buildiung 1 Heavy duty electrical extension cord 200 ft Barrels, anchors, line, chain, buoys Hand tools, shovels, etc. Plastic liners and bags Polyethylene sheeting Handtools Source: Spiltec, 1990. Table L-6 Response Equipment Maintained by Alaska Clean Seas in Deadhorse (July 1989)” ITEM QUANTITY DETECTION Gas/Oxygen Detector Gas Analyzer Current Meters Ice Auger Orion Tracking System Marker Stake CONTAINMENT Goodyear Sea Sentry Heavy Duty Boom Kepner Compactible 11x15 EPI Mini Boom American Marine Simplex Boom Kepner Reel Pak Boom Expandi Boom Fire Containment Boom RECOVERY ARCAT II with 12-man liferaft 3M Sorbent Boom Type 280 3M Sorbent Roll 100 3M Sorbent Pad Type 151 3M Sorbent Pad Type 157 3M Sorbent Type 356C MI-30 Disc Skimmer Weir Skimmer 214-E Rope Mop Skimmer Barracuda Rope Mop Skimmer MW 62 Rope Mop Skimmer Trans-Vac with Manta Ray Skimmer Destroil Skimming System (pump and float) Arctic Skimmer System (for North Star vessel) Shallow Water Access Mop System (Swamp) DISPERSANTS EXXON Corexit 9527 ARCO Chem D-609 Ship Spray Unit (for ARCAT II) DISPOSAL Ignitors Helitorch Aerial Ignition System STORAGE Firestone Fabritank (2,250 gal) Firestone Fabritank (4,400 gal) Trellecon Bladder Dracone Barge (2,400 gal) Kepner Towable Bladder (1,200 gal) ERI Air Berm (1,000 gal) ERI Air Berm (2,000 gal) ERI Air Berm (3,000 gal) Fast Tank (rapide, 400 gal with liner) Fast Tank (1,500 gal with liner) Fast Tank (2,000 gal with liner) LOGISTICS - VESSELS 32-ft North Star Workboat 21-ft Munson Workboat 16-ft Grumman (with trailer and 25-hp outboard) 15-ft Gregor (with trailer and 15-hp outboard) Source: The McCloskey Group, 1989. This is not a complete inventory. 1,00 2,035 5,400 2,000 3,000 4,000 4,500 2,500 ON@NHHR ft ft ft ft ft ft ft 1 250 bales 507 rolls 290 bales 400 bales 85 boxes 1 10 10 rPReEN Pe 10 drums 10 drums 1,700 NNENNHPYSE SS Orne Table L-7 Spill-Response Equipment Onboard the Drilling Barge Kulluk during 1989 Drilling of the Belcher Prospect in the Beaufort Sea ITEM QUANTITY Kepner 48-in Inflatable Offshore Boom mounted on two Kepner Boom Reels 1,000 ft Zoom 30-in Boom 600 ft 3M Fire-Resistant Boom 1,500 ft Morris MI-30 Skimmer 2 Storage Bladder (12,000 U.S. gal) 1 Porta-Tanks Water Separator Box (1,200 gal) 2 Pumps 2} 8 ft - 10 ft Sorbent boom 25 bales 18 in x 18 in x 3/8 in Sorbent pads 15 bales 36 in x 150 ft x 3/8 in Absorbent 12 rolls Corexit 9527 dispersant 1 drum Back pack dispersant spray unit 1 Hose 75 ft Air-deployable ignitors 20 30-in Sea anchors 2 Orion Tracking Buoys 4 Source: The McCloskey Group, 1989. This is not a complete inventory. Pp ry. Table L-8 Response Equipment Maintained by the Canadian Beaufort Sea Oil Spill Cooperative at Tuktoyaktuk, NWT, July 1989” ITEM QUANTITY DETECTION Orion Tracker Buoys 1 Orion Receiver Orion Antenna Argos Buoys Scott Comb. Gas/Oxy Tester OrPNna CONTAINMENT Fireproof Boom c/w ISO Container 250 ft Arctic Boom Mod/ 772,200 ft 36-in Containment Boom 5,100 ft Bennett Inshore Boom 2,000 ft RECOVERY Morris M130 Skimmer 6-in Oil Mop Skimmer Rope Mop Skimmer Slurp Skimmer Lockheed Skimmer Pepe S DISPOSAL 100-bbl/day Saacke Burners 2 Dispersant spray system a Air-deployable ignitors 2,000 Simplex Heli-Torch a TRANSFER Oil Separator Pumps, various 9 w STORAGE Porta Tanks (1,200 U.S. gal) 8 10,000-gal Uniroyal Bladders 3 1,000-gal Canflex Bladders 15 1,000-gal Open-top Canflex Bladder 1 LOGISTICS--VESSELS Carrier II Sea Truck (Twin 70 Merc) 90-hp Outboard Zodiac with 20-hp outboard 39-ft Deployment outboard vessel (Carrier 5) Hiab Model Crane on Carrier 5 14-ft Deployment vessel 16-ft Deployment vessel 27-ft Jet boat PREP RPRENR LOGISTICS--COMMUNICATIONS Marconi DT 39 Radios Raytheon FM Radios Marconi Radios Chargers for above radios Lorad VHF Portable Radios SMR VHF 78 CB Radio WUUBAYw LOGISTICS--ANTI-POLLUTION BARGE II Barge, 216 ft x 49.5 ft x 9.6 ft, complete with but not limited to the following equipment: Free-water knockout system L VEP Skimmer Watson Heater Treater/Upgrading 1 5000-bbl/day burner with boom 1000-gal fuel tanks 2 Oil and water pumping system w e Source: The McCloskey Group, 1989. ‘ This is not a complete inventory. Only onsite equipment and that which could be transported from Deadhorse by helicopter could meet this guideline for deployment for most of the sale area. The limited geographic and temporal presence of open water and slow vessel speeds in broken ice would preclude timely transport of spill equipment by sea. For larger spills--those that could exceed the local cleanup-response capability--MMS, Alaska OCS Region, requires that additional equipment be available onsite within 48 hours. Additional response equipment to handle a large spill in the Chukchi Sea--those that exceed the local cleanup-response capability--would be available from a multitude of sources. Many of these sources and their equipment lists have been inventoried for potential use in the Chukchi Sea, in Alaska Clean Seas (1984), and in the individual oil-spill-contingency plans of lessees. Estimated response times for mobilization and transport of equipment to Prudhoe Bay from these additional sources are given in Table L-9 for air transport and in Table L-10 for sea transport. Equipment stored in Anchorage also could be trucked to Prudhoe Bay within 32 to 40 hours, not including mobilization and loading/unloading times. Mobilization and air-transport times needed to airlift spill-cleanup equipment to Deadhorse would range from 3.3 to 13 hours from sources in Alaska and on the Pacific Coast, assuming available C-130 transport and good weather. Sea transport from Alaskan and other U.S. ports to Prudhoe Bay would not be possible without icebreaker support except during a brief period of relatively open water in late summer. Equipment could reach a summer-spill site by vessel in the Sale 126 area within 1.3 to 3 days from Canadian Beaufort Sea and Chukchi Sea equipment sites. The estimate for the Chukchi Sea assumes an airlift between Kotzebue and Deadhorse. Thus, additional equipment would be most rapidly and readily available from the Canadian Beaufort Sea area. Flight time for a C-130 between Deadhorse and Tuktoyaktuk would be about 1 hour. Equipment could be shipped from the Canadian Beaufort Sea over a period of 2 to 3 months. U.S. Customs regulations would not interfere. Spill equipment to be used in the proposed sale area would require only a courtesy call to U.S. Customs, who should be notified before equipment is brought within the 3-mi limit, unless true emergency conditions exist. In the latter case, U.S. Customs wov'd accept after-the-fact notification (Union Oil Company of California, 1985). Equipment stored at Deadhorse or airlifted to Deadhorse would be capable of meeting the criteria of the 48-hour-response time set by MMS. Additional, slower-arriving equipment would still be useful in case of a major spill; but MMS would not consider such equipment in judging whether oil-spill-contingency plans met the MMS 48-hour-response criteria. Once spill-cleanup equipment reaches Deadhorse or Prudhoe Bay, it could be transported relatively quickly to the spill site within the Chukchi Sea only if it could be carried by helicopter and then only if weather permitted. A helicopter could reach any point in the Sale 126 Area within 3 hours, weather permitting. Pack ice would prohibit ship transport other than by icebreaker over most of the Sale 126 area for most of the year, including summer. Land-vehicle transport of spill equipment would not be safe across appreciable distances on pack ice. (5) Drills: A drill for familiarization with pollution-control equipment and operational procedures must be held at least once every 12 months. Drill conditions must simulate conditions in the area of operations. In the summer 1989 drilling season, two drills were held by SWEPI. On July 11 and 12, 1989, two days after drilling started at the Klondike Prospect, the first Oil Spill Response Drill (OSRD) occurred in open waters west of Kotzebue Sound. At that time, response equipment, as listed in SWEPI’s OSCP, was inspected to ensure all response equipment listed was in place. Table L-11 lists the equipment deployed during the OSRD. In 1990, SWEPI conducted an OSRD in Port Clarence to the satisfaction of MMS. A Table-Top and Communications Oil-Spill Response Exercise occurred on September 27, 1989, 87 days into a 109-day drilling season. The purpose of the table-top exercise was to evaluate SWEPI’s familiarization with the OSCP and communications, and to ensure that the designated spill coordinator was prepared to coordinate a major spill response. This is the first table-top exercise in the Alaska OCS Region. The table- L-10 Table L-9 Estimated Response Times for Mobilizing and Transporting Equipment to Deadhorse by Air-Cargo Transport Estimated Transportation Mobilization Time to Total Response Time” Deadhorse” — Time to Deadhorse” Equipment Storage Hours (Hours) (Hours) Owner Location (Min.) (Max.) (Min.) (Max.) Alaska Clean Seas Anchorage 2 s 19 3.9 6.9 Beaufort Sea Oil Spill © Tuktoyaktuk 2 4 1.0 3.0 5.0 Alyeska Pipeline Valdez 2 s 2.4 4.4 14 Service Company Cook Inlet Response Kenai 2 5 2.0 4.0 7.0 Organization Anchorage Zz a 9) 3.9 6.9 U.S. Coast Guard Kodiak Zz 5 2.6 4.6 76 Anchorage 2 5 19 39 6.9 VRCA Environmental Prudhoe Bay 2 5 0 2.0 5.0 Service Fairbanks a 5 13 3.3 63 Anchorage 2 a 19 a” 6.9 Kenai az 5 2.0 4.0 7.0 Clean Sound Seattle 2 5 6.1 8.1 ea Clean Bay Concord 2 5 ot 9.1 12.1 Clean Seas Santa Barbara 2 SD) 19 99 129 Clean Coastal Waters Long Beach 2 5 79, 99 12.9 USS. Navy Stockton 2 a el 91 12.1 Source: The McCloskey Group, 1989; Spiltec, 1989. ” Estimated mobilization times were supplied by equipment owners and are overall ranges that are nonspecific to the type or quantity of equipment required. ?/ Estimated transportation times based on C-130 flight characteristics (300-kn flight speed). %/ Total response times are the sum of estimated mobilization time and travel times by C-130. They do not include the amount of time required to load the equipment or variations in travel time arising from adverse climatic factors that might be encountered enroute. Table L-10 Estimated Response Times for Mobilizing and Transporting Equipment to the ABSORB Area by Surface Vessel’ Estimated Estimated Travel Mobilization Time to Prudhoe Bay Total Response Time” Equipment Storage Time” (10 Knots)” Minimum Maximum Owner Location (Hours) (Days) (Hours) (Days) (Hours) (Days) (Hours) Alaska Clean Seas Anchorage 2-5 8 19 8 21 9 0 Cook Inlet Kenai 2-5 8 1 8 3 8 6 Response Organization U.S. Coast Guard Kodiak 2-5 8 1 8 3 8 6 Anchorage 2-5 8 19 8 21 9 0 Beaufort Sea Oil Tuktoyaktuk 2-4 a 6 a 8 “5 10 Spill Cooperative EE EEEEEEEEEEEEEee? Source: The McCloskey Group, 1989; Spiltec, 1989. ah Surface-vessel transportation is available only during the open-water season around Point Barrow. This season is of limited duration--typically 6 to 8 weeks per year. 2/ Estimated mobilization times were supplied by the equipment owners and are overall ranges that are nonspecific to the type or quantity required; vessel availability is assumed. %/ Travel times to site are from ports near the storage sites to a hypothetical spill site in the ABSORB CPA. These estimates do not include the amount of time required to unload the equipment at the site or variations in travel time arising from adverse climatic factors. ‘/ Total response times indicated are the sum of estimated mobilization times and travel times to the spill site. Table L-11 Spill-Response Equipment Deployed During SWEPI Oil-Spill-Response Drill for 1989 ITEM QUANTITY 26? Munson aluminum workboats 2 34 aluminum workboats 2 18’ Avon Searider rigid-hull inflatable boat 1 Transrec Skimmer/Oil Trawl Collection System 1 18" X 23" Kepner Reel Pak compactible boom 1,000 ft SOCK skimmer 1 Halliburton Skimming Barrier 1 Source: USDOI, MMS, 1989. top exercise demonstrates communication capabilities and the spill-response coordinators’ familiarity with the equipment, strategies, and responses listed in the OSCP. However, as designed, it would be difficult for this type of exercise to demonstrate or assess the capability of a company to actually mobilize a major response effort. In 1990, SWEPI conducted a second Table-Top and Communications Oil-Spill-Response Exercise to the satisfaction of the MMS. (6) Dispersant Equipment: It is SWEPI’s position that physical containment and removal techniques and the possible burning of oil would normally be used in lieu of any chemical dispersants for response to an oil spill in the Chukchi Sea. If relatively fresh oil could move into a region where surface contac: with birds, bears, or whales were highly likely, dispersant use might provide a significant backup- response option. Because dispersant use involves sophisticated equipment and skilled personnel and because it is subject to stringent regulatory control, SWEPI will use trained personnel within its own organization, from ACS, from CIRO, and from contract application firms for any treatment operation. Table L-5 lists dispersant and application equipment availability (Spiltec, 1989). Texaco would evaluate physical-containment and removal techniques and the possible burning of oil, as well as the use of dispersants for response to a spill in the Chukchi Sea. The 30 drums of Corexit 9527 and the helicopter spray bucket aboard the spill- response barge would allow for the immediate treatment of a small operational spill or for the the partial treatment of a major spill (Spiltec, 1990). Should the experimental treatment of a larger spill look promising, backup chemicals and additional application systems could be called for from Deadhorse, Anchorage, Arizona, or British Columbia (Spiltec, 1990). (7) Disposal: SWEPI’S planned storage/disposal methods include: in-situ burning, incineration, flaring at Marathon’s flaring system in Cook Inlet, flaring from a barge offshore, and/or burial/landfills at the North Slope Borough facility at Deadhorse and North Star Borough near Fairbanks (Spiltec, 1989). Texaco’s planned storage-disposal methods include Marathons’s in-place flaring system in Cook Inlet, flaring from a barge offshore, systems currently available through ABSORB and the Canadian Beaufort Sea Oil Spill Cooperative, burning; and, as necessary, barges and/or tankers could be used to transport recovered oil/water to refineries/incinerators outside Alaska. Regardless of the disposal method, Federal and State government approval is required. (8) Early Detection, Monitoring and Predicting Spill Movement: Daily pollution inspections are required under 30 CFR 250.41, and inspection records are required to be documented. Orion tracking buoys, radar reflectors (floats), and ice-marking dye were added to the list of equipment to be on the Oil- Spill-Response Barge after MMS assigned a task force to review SWEPI’s OSCP. In addition, three Orion tracking systems are located at Deadhorse. These radio-outfitted buoys move with an oil slick. A receiver with a directional antennae can locate the buoy position. Depending on the weather, this system could be available within 12 hours. Texaco would have the same spill tracking equipment available as SWEPI. IV. EFFECTIVE OF OIL-SPILL CL P AT SEA The 6-to-12-hour and 48-hour response times required of drilling lessees by MMS, Alaska OCS Region, are mobilization and deployment requirements. Cleanup would continue as long as necessary, without any timeframe or deadline. For example, a winter spill in pack ice might require initial onsite response followed by further cleanup of oil melting out and pooling on top of the ice in late spring or summer. Mechanical cleanup at sea usually is much more effective on low- or mediumviscosity oils than on high-viscosity oils. A low-viscosity oil could be a diesel or fresh, light crude. A medium-viscosity oil could be a lubricating oil or a light, flowing emulsion. A high-viscosity oil would be a weathered crude, bunker oil, or thick emulsion. An oil such as Prudhoe Bay crude initially would have low viscosity but would quickly weather and form an emulsion. In the presence of broken sea ice, this transformation may take as little as 4 hours (Payne, 1984); in the absence of sea ice, it may take perhaps 2 days (Payne et al., 1984). For the summer, 22,000-bbl example in Table L-1, based on the weathering model of Kirstein, Redding (1988), L-11 Prudhoe Bay crude would weather into a high-viscosity oil within 4 hours of spillage. The effectiveness of most forms of mechanical recovery of the crude would decrease twofold over this 4-hour period. Oleophilic-rope recovery systems are a relevant exception to this twofold decrease in oil-recovery rate with increasing oil viscosity. The Alaska Clean Seas has emphasized such devices in its arctic contingency strategy, including development and deployment of the oleophilic-rope skimmer, the ARCAT II. Oleophilic-rope systems at medium international sea states, between Sea State 1 and Sea State 3, could recover high-viscosity oil more readily than lesser viscosity oils. At a lower sea state (Sea State O), highly viscous oils could be recovered at 69 percent of the rate for low-viscosity oils (S.L. Ross Environmental Research Ltd., 1983a). Chemical dispersion--the use of dispersants to mix the oil into the water rather than attempt to recover the spilled oil--is an alternative technique to mitigate spill damage. Dispersants lose effectiveness even more rapidly than mechanical recovery as oil weathers and becomes more viscous. Oils with in situ viscosities greater than 2,000 centistokes usually cannot be dispersed (The International Tanker Owners Pollution Federation, Ltd., 1982a,b). Based on the weathering model of Kirstein and Redding (1988), under the conditions in Table L-1 for a summer spill of 22,000 bbl, such viscosities would be reached by Prudhoe Bay crude about 8 hours after spillage. In the presence of sea ice, the rapid formation of mousse could preclude effective use of dispersants in even a shorter period of time. Best use of dispersants obviously occurs when they could be applied immediately after the spill has occurred (or near the point of spillage for a continuing spill). Use of dispersants to treat an oil spill, however, requires the OSC to have the concurrence of the EPA representative to the Government Regional Response Team (RRT) and also the concurrence of the State’s representatives. Historically, such permission has been difficult if not impossible to obtain. The reason for this difficulty lies in the perceived toxicity of oil-dispersant mixtures, in questions as to the effectiveness of the dispersant, and in the fact that dispersants remove oil only from the surface of the water and not from the water environment. Detailed information on the effectiveness of a specific dispersant on a specific spilled oil as a function of air and water temperature, dispersant concentration, and age or weathered state of the slick--as well as detailed information on the proposed dispersant-application system--are necessary for an informed RRT decision on dispersant use. Such parameters would be known when any spill-contingency plans were written for production, and approval for dispersant use would be, in theory, more likely during production than has been the case during exploration. In practice, dispersant use may be unlikely even for production oil spills. The RRT had released guidelines for dispersant use in Cook Inlet and Prince William Sound. Inability to demonstrate and evaluate dispersant effectiveness on the Exxon Valdez spill in Prince William Sound in a timely fashion and slowness in mobilizing both dispersants and delivery systems, however, negated potential effectiveness. The USCG OSC decided that no significant proportion of oil was chem- ically dispersed from the Exxon Valdez spill. The post-Exxon Valdez report to the Secretary of the Interior by MMS (USDOI, MMS, OCS Oil Spill Task Force, 1989) concluded that "Dispersants have been found to be routinely ineffective in open-ocean application." The National Research Council (NRC) was requested to "review the state of knowledge in toxicity, effectiveness of application techniques, and effectiveness of commercially available dispersants." In response, the Commission on Engineering and Technical Systems of the NRC convened the Committee of Effectiveness of Oil Spill Dispersants. The committee report, "Using Oil Spill Dispersants on the Sea," reflects a broad database. Dispersant toxicity depends on concentration, duration of exposure and type of organism. The primary components of dispersants are crucial for evaluating toxicity. All surfactants are toxic at high concentrations. Among the factors controlling toxicity of surfactants to aquatic organisms are ethoxylate chain lengths, presence to esthers versus ethers, and hydrophillic-lipophillic balance (Wells, 1984). The toxicity of dispersant formulations has been studied; a wide range of values is reported (NRC, 1989: Table 3-5). The L-12 toxicity of dispersant formulations is influencd by physiochemical and biological factors. These factors are important because toxicity estimates are relative; they depend on the environmental conditions and biological populations being exposed (NRC, 1989). Because of natural dispersion, oil slicks of less than 10,000 bbl in the open ocean are seldom tracked for more than about 10 days before the oil becomes too dispersed to locate or identify as a slick. Out of necessity or otherwise, natural dispersion has frequently been the chosen response technique in Alaskan waters. The F/V Ryuyo Maru No. 2 grounded off St. Paul Island in 1979. Fuel oil on board could not be safely removed, and the vessel was deliberately blown up at a time when weather would maximize natural dispersion (Reiter, 1981). In Kuskokwim Bay in the summer of 1982, the Cornell Barge No. 8 sunk, spilling some but not all of its load of fuel oil, The remaining fuel oil was deliberately released and allowed to disperse by the Coast Guard. Accidental and deliberate release totaled 2,190 bbl over 3 weeks (Oil Spill Intelligence Report, 1982). The observed slick extended no more than 1 km from the barge, indicating a slick life of no more than a few hours. The tanker Cepheus grounded in Anchorage Harbor and spilled 5,000 bbl of fuel in January 1984. Because of the presence of broken ice in surrounding waters, the spill could not be tracked and no cleanup occurred away from the tanker, but no slick was ever found. Oil spills do not always disperse this rapidly or completely. Generally, the more asphaltic the oil, the larger the spill, the calmer the water, and the more restricted the water body, the longer a spill would persist. Oil on the water from the Exxon Valdez closed several State salmon fisheries 5 months after the 260,000-bbl spill. Uncontained burning also is a possible spill remedy. Experiments suggest that burn efficiencies on the order of 50 to 60 percent may be possible if the spill could be immediately set on fire (Laperriere, 1984). However, any delay in ignition would decrease combustion efficiency. In the Exxon Valdez spill, spilled oil was still burnable on day 3, but not after the storm that occurred at the end of day 3. Thus, the effectiveness of both mechanical recovery and in situ burning of spilled oil at sea decreases rapidly with increasing sea state (roughness of the sea). However, in such worsening sea state, the effectiveness of dispersants and natural dispersion increases. According to S.L. Ross Environmental Research Ltd. (1983a), mechanical cleanup becomes nonfunctional between International Sea States 3 and 4. However, a recent reevaluation of the effectiveness of response equipment by USDOI (USDOI, MMS, OCS Oil Spill Task Force, 1989) following the Exxon Valdez spill concluded that most response equipment available in the U.S. can operate in Sea State 2 or less (waves less than 2-4 ft and winds less than 19-15 kn), although some equipment operates in higher sea states. Based on this MMS evaluation, sea states would exceed the capabilities of response equipment from 9 to 24 percent of the time in summer months--the range in occurrences of Sea States of 3 or greater--in the Chukchi Sea Planning Area. Ice cover the remainder of the year would eliminate both high sea states and standard uses of most mechanical-response equipment. This relatively poor rating of response equipment by the MMS task force was attributed in part by the task force to lack of MMS standard protocols for evaluating and comparing equipment performance. That is, MMS has no formal protocol or quantitative procedures for evaluating whether response equipment proposed by lessees is "state-of-the-art" as required by MMS guidelines for oil-spill-contingency plans or something less. Based on the MMS task force analysis, offshore-response equipment in U.S. waters does not meet the level of performance required by MMS Alaska OCS Region Planning Guidelines for Approval of Oilspill Contingency Plans, "state-of-the-art" equipment capable of operating in 8- to 10-ft. seas and 20-kn winds, which are sea conditions equivalent to International Sea State 5. The MMS task force has recommended that MMS establish a standard test protocol for offshore booms and adopt an existing protocol for oil skimmers to define "state-of-the-art" and minimum performance requirements. These recommendations have been presented to the Secretary of the Interior. L-13 In real spill situations, optimum efficiency of cleanup equipment is seldom reached. To some extent, bad weather, equipment failures, and personnel problems could be factored into estimates of cleanup efficiency in oil-spill-contingency plans. In practice, such estimates are usually found to be overly optimistic. Spill cleanup generally requires unexpected modification of procedures and equipment. Equipment or people often do not work as well as hypothesized. This was demonstrated in both the 1987 Glacier Bay and 1989 Exxon Valdez spills of TAP crude in Alaskan coastal waters. The MMS, Gulf of Mexico (GOM) OCS Region (USDOI, MMS, GOM, 1983), reviewed the historical record of oil-spill cleanup at sea and concluded that such cleanup is usually not very efficient: Offshore containment/cleanup operations are generally a major task requiring significant coordination and cooperation, transportation of large equipment, vessel support, aircraft support, set-up and maintenance of a command/coordination post in the field, and properly staged and available equipment. Often, the weather/sea conditions and crew fatigue become the critical factors during offshore operations. The effectiveness of containment/cleanup operations offshore are, in general, marginally effective. It is possible to contain a platform spill if environmental and logistical conditions are right; however, it has been found through experience that conditions are rarely ideal and full containment of a platform spill is not likely. The effectiveness of this type of containment and cleanup operation is estimated to be approximately 5 percent to 15 percent recovery. Inshore containment/cleanup operations could be either large-scale or moderately sized operations, depending on any particular spill situation. Again, if the task becomes large it requires the same level of coordination and support as an offshore operation. The effectiveness of a containment/cleanup operation in an inshore area largely depends on the unique physical characteristics of the environment and the area of the operation. Beach cleanup is normally effective utilizing hand labor, organic sorbents, and a wide variety of tools from rakes to bulldozers. Utilizing booms and skimmers, containment of a spill moving into an inlet is marginally successful, depending almost entirely on the physical characteristics of the inlet. Containment and cleanup in marshes is very controversial. Modern opinions often lean towards the "NO ACTION" strategy for fear of cleanup operations causing even more damage. The effectiveness of inshore containment cleanup operations could often be much greater than offshore operations. Effectiveness is estimated to be 20 percent to 50 percent containment and cleanup of material moving into the area. V. EFFECTIVENESS OF OIL-SPILL CLEANUP IN ICE When a spill is dispersed far from its source or when ice is moving, containment and cleanup are more difficult. Planning an effective surface response with mechanical equipment to spills in pack ice would require that an icebreaker (or icebreaking-supply ship) be locally stationed in both winter and summer as a dedicated oil-recovery vessel (Tebeau, 1987). Icebreakers are expected to be present in the Sale 126 Area during both exploration and production. An appropriate example of such operations would be the exploration drilling conducted by a drillship on Sale 109 leases in the summer of 1989. The drillship was accompanied by three icebreaker/supply vessels that "managed" the ice at the drill site. In situ burning of spilled oil during heavy ice periods may be a more promising approach. Buoys or other markers would be placed on the ice to track under-ice spills. Exposed oil would be ignited whenever possible. Existing response capabilities are more effective on landfast ice than on broken or pack ice. Spills on top of landfast ice could be cleaned up fairly easily as long as oil is not pooled to sufficient depth (on the order of several centimeters) to crack the ice and allow some of the oil to flow underneath the ice (Shell Western E&P, Inc. et al., 1984). Cleanup effectiveness for oil under landfast ice has been measured by Buist, Pistruzak, and Dickins (1981). L-14 Buist, Pistruzak, and Dickins conducted three simulated undersea blowouts totaling 119 bbl under landfast ice in the Canadian Beaufort Sea. The following spring, as the oil rose to the surfaceand pooled on the ice, as much oil as possible was burned or manually recovered. Cleanup efforts ceased only when breakup occurred and the remaining oil naturally dispersed. A total of 125 burns were conducted, more than one burn for each barrel of oil spilled. Overall burn efficiency averaged 51 percent, with average burn efficiencies ranging from 18 to 77 percent in the three spill experiments. An additional 28 percent of the oil (range of 14-51%) was manually recovered. The manual cleanup was labor-intensive, requiring 0.7 man-days per barrel or 350 man-days per square kilometer. Overall, 79 percent (range of 67-88%) of the weathered oil was burned or manually recovered. Spills in broken or moving ice would be more difficult to handle. The greatest success would be expected when the spill is contained within a small area close to the source of the spill. The ice itself may be useful in restricting the spreading of the oil, keeping the oil thicker and more amenable to burning. Oil melting out of pack ice would be much more difficult to burn than oil in the Buist, Pistruzak, and Dickins (1981) study. Oil would melt out of pack ice much more slowly than from landfast, first-year ice; some oilwould even take a second summer to reach the top of the ice (see Sec. I of this appendix). In addition, a stationary but continuing spill could spread a ribbon of oil underneath many or even hundreds of kilometers of pack ice (see Sec. IV.N). The manufacture, shipment, temporary storage, and deployment of igniters, helitorches, or gelled gasoline necessary to ignite thousands of oiled melt pools from a major spill is a logistical nightmare. Burning experiments in broken ice have given promising results with fresh oil, but results have been variable and less promising with weathered oil and emulsions. Field tests in a mud pit at Prudhoe Bay were able to burn 55 to 85 percent of fresh Prudhoe Bay crude, but crude with a flash point of over 30°F could not be ignited (Shell Oil Company et al., 1983). Tests at OHMSETT for fresh crude had burn efficiencies of 85 to 95 percent at 22- to 34-percent ice cover and burn efficiencies of 58 to 79 percent at 78- to 85-percent ice cover. Burn efficiencies of two tests for oil-in-water emulsions were only 10 to 52 percent at 78- to 84-percent ice cover (Smith, unpublished). Some oil burned against retaining barriers in both the field and OHMSETT tests; and the efficiencies are somewhat higher than could be expected for a true, uncontained burn in broken ice. Payne (1984) found that emulsification is accelerated in broken ice (occurring within 4 hours), indicating that a slick would have to be set on fire very soon after spillage in order to obtain a high burn efficiency. It may be more difficult to burn spilled oil during freezeup than at any other time of year. Martin (1981) has shown that wave action mixes the oil downward into the grease ice. Oil and ice would have to be recovered and the oil separated from ice before burning; there would be only a limited capability for in situ burning. Partly because of oil-spill risks during broken ice, the State of Alaska has applied two sets of seasonal drilling restrictions in State waters of the Beaufort Sea. Tier-I regulations prohibit drilling during periods of broken ice, during some periods of open water for locations outside the barrier islands, and during the fall bowhead whale migration and freezeup for locations outside the barrier islands. Tier-II regulations allow unrestricted drilling in State waters, with the exception of locations outside the barrier islands during the fall bowhead migration and freezeup. The Tier-II level applies only to "lessees who demonstrate compliance with applicable laws and regulations, including the theoretical and physical capability to detect, contain, and clean up and dispose of spilled oil in broken ice conditions" (see Shell Oil Company et al., 1983). In 1983, several oil companies participated in a review of applicability of current cleanup techniques to broken-ice conditions (Industry Task Group, 1983) and field demonstrations of capabilities during breakup of landfast ice (Shell Oil Company et al., 1983). A third report (Shell Western E&P, Inc. et al., 1984) provided additional technical documentation of review and demonstrations and constitutes a state-of-the-art manual for cleanup during breakup of landfast ice in the Beaufort Sea. L-15 The cooperative review, the field demonstrations, and resulting reports considered only breakup conditions. Freezeup conditions were deemphasized because of the existence of a seasonal drilling restriction in State waters during the fall bowhead migration. The State of Alaska had an independent consultant evaluate this demonstration of industry's capabilities (S.L. Ross Environmental Research Ltd., 1983b) and, based on that and its own analysis, granted Tier-II status to the participating oil companies. The conclusion of S.L. Ross Environmental Research Limited provides a concise summary of oil-spill-countermeasure capabilities of industry in broken-ice conditions: The industry’s technological capability is judged to be very good for removing oil discharged from a large oil well blowout occurring on a gravel island in the Alaskan Beaufort Sea during broken ice conditions (as well as during periods of landfast ice and open water); this is only the case if the blowout is ignited and/or combustion and skimming techniques take place in close proximity to the island. ... Although industry’s overall response capability for gravel-island oilwell blowouts is very good (by virtue of oil burning procedures at or near the well-head) the fact remains that the capability to clean up large oil spills floating amongst moving ice is generally not good, particularly if the oil is thin and weathered.In other words, industry couldeffectively clean up an oil spill in moving ice only if the spill is a platform blowout that could be set on fire without endangering platform integrity. If this is the case, the platform could still be used as a base for cleanup and well-control operations. L-16 Bibliography Alaska Clean Seas. 1984. Contingency Planning Manual. (Revised June 1985.) Anchorage, AK. Allen, G.H., D.A. Hale, and R-T. Prentki. 1984. Framework for Oil-Spill Response on the Alaskan OCS. OCS Report, MMS 84- 0021. Anchorage, AK: USDOI, MMS, Alaska OCS Region. Amstutz, D.E. and W.B. Samuels. 1984. Offshore Oil Spills: Analysis of Risks. Marine Environmental Research 13:303-319. Brower, W.A., Jr., R.G. Baldwin, C.N. Williams, Jr., J.L. Wise, and L.D. Leslie. 1988. Climatic Atlas of the Outer Continental Shelf Waters and Coastal Regions of Alaska, Vol. III - Chukchi-Beaufort Sea. OCS Report, MMS 87-0013. Anchorage, AK: University of Alaska, AEIDC, 527 pp. Buist, I.A., W.M. Pistruzak, and D.F. Dickins. 1981. Dome Petroleum’s Oil and Gas Undersea Ice Study. Spill Technology Newsletter 6:120-146. Deslauriers, P.C. 1979. Observations of Oil Behavior in Ice Floes and the 1977 Ethel H. Spill. In: Proceedings of a Workshop on Oil, Ice, and Gas, University of Toronto, Toronto, Canada, pp. 87-94. Free, A.P., J.C. Cox, and L.A. Schultz. 1982. Laboratory Studies of Oil Spill Behavior in Broken Ice Fields. In: Proceedings of the Fifth Arctic Marine Oil Spill Program Technical Seminar. Ottawa, Ontario, Canada: Environment Canada, pp. 3-14. Ford, R.G. 1985. Oil Slick Sizes and Length of Coastline Affected: A Literature Survey and Statistical Analysis. Contract No. 14- 12-0001-30224. Los Angeles, CA: USDOI, MMS, Pacific OCS Region. Gundlach, E.R., J. Sadd, G.I. Scott, L.C. Thebeau, and D.G. Maiero. 1981. Oil Spill Sensitivity of Coastal Environments and Wildlife of Norton Sound and Pribilof Islands, Alaska. Final Report of Principal Investigators, RU 59. USDOC, NOAA, OCSEAP. Columbia, SC: Research Planning Institute, 170 pp. Hayes, M.O., E.R. Gundlach, and C.D. Getter. 1980. Sensitivity Ranking of Energy Port Shorelines. In: Proceedings of the Specialty Conference on Ports, May 19-20, 1980. ASCE, Norfolk, VA. Hayes, M.O. and C. Ruby. 1979. Oil-Spill Vulnerability, Coastal Morphology, and Sedimentation of Kotzebue Sound. Environmental Assessment of the Alaskan Continental Shelf. Annual Reports of Principal Investigators, RU 59. USDOC, NOAA, OCSEAP. Columbia, SC: University of South Carolina, Dept. of Geology. Industry Task Group. 1983. 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Sea-Ice Thickness Profiling and Under-Ice Oil Entrapment. In: Proceedings of the 1977 Offshore Technology Conference, Vol. III. Houston, Texas. Laperriere, F. 1984. In-Situ Burning of Uncontained Oil Slicks. Spill Technology Newslette 9(3-6):72-73. MacGregor, C. and A.Y. McLean. 1977. Fate of Crude Oil in a Simulated Arctic Environment. In: Proceedings of the 1977 Oil Spill Conference. Washington, DC: American Petroleum Institute, pp.461-463. Marine Spill Response Corporation. 1990. Marine Spill Response Corporation, The World’s Largest Oil Spill Response Organization, Press Release, 1220 L Street Northwest, Washington, D.C. Marine Spill Response Corporation. 1990. Marine Spill Response Corporation, Its Relation to New Oil Spill Legislation. Press Release, 1220 L Street Northwest, Washington, D.C. Marine Spill Response Corporation. 1990. Marine Spill Response Corporation, A New Weapon for Cleaning Up Oil Spills. Press Release, 1220 L Street Northwest, Washington, D.C. Martin, S. 1981. Anticipated Oil-Ice Interactions in the Bering Sea. In: The Eastern Bering Sea Shelf: Oceanography and Resources, D.W. Hood and J.A. Calder, eds. Seattle, WA: Distributed by the University of Washington Press, USDOC, NOAA, Office of Marine Pollution Assessment, pp. 223-243. Michel, J., C. Henry, W.J. Sexton, and M.O. Hayes. 1990. The Exxon Valdez Winter Monitoring Program results, In: Proceedings of Conference on Oil Spills: Management and Legislative Implications: May 15-18, 1990, Newport, Rhode Island. National Research Council, Commission on Engineering and Technical Systems, Marine Board, Committee on Effectiveness of Oil Spill Dispersants. 1989. Using Oil Spill Dispersants on the Sea. Washington, D.C.: National Academy Press, pp. 81-214. Oil Spill Intelligence Report. 1982. Light Fuel and Gasoline Spill from Sunken Barge Off Alaska. Oil Spill Intelligence Report SG3):1. Payne, J.R. 1984. Development of a Predictive Model for the Weathering of Oil in the Presence of Sea Ice. First Final Report, RU 640. La Jolla, CA: Science Applications. Prepared for USDOC, NOAA, OCSEAP. Payne, J.R., B.E. Kirstein, G.D. McNabb, Jr., J.L. Lambech, R. Redding, R-E. Jordan, W. Horn, C. deOliveira, G.S. Smith, D.M. Baxter, and R. Gaegel. 1984. Multivariate Analysis of Petroleum Weathering in the Marine Environment - Sub-Arctic, Vol. I, Technical Results. Environmental Assessment of the Alaskan Continental Shelf, Final Reports of Principal Investigators, Vol. 21(i):9-10. Juneau, AK: USDOC, NOAA, OCSEAP. Payne, J.R. 1982. The Chemistry and Formation of Water-in-Oil Emulsions and Tar Balls from the Release of Petroleum in the Marine Environment. RU 597. Working Paper. Washington, DC: National Academy of Sciences. Reimer, E.M. 1980. Oil in Pack Ice: The Kurdistan Spill. In: Proceedings of the Third Arctic Marine Oil Spill Program Technical Seminar. Ottawa, Ontario, Canada: Environment Canada, pp. 529-544. Reiter, G.A. 1981. Cold Weather Response F/V Ryoyo Maru, No. 2, St. Paul, Pribilof Islands, Alaska. In: Oil Spill Conference. Washington, DC: American Petroleum Institute, pp. 227-231. Robilliard, G.A., J.R. Harper, J. Isaacs, and C. Foget. 1985. Chukchi Sea Coastal Studies, Coastal Morphology, Environmental Sensitivities, and Persistence of Spilled Oil, Final Report to NOAA/MMS, 3 Vols., RU 44. Walnut Creek, CA: Woodward-Clyde Consultants. Rosenneger, L.W. 1975. Movement of Oil Under Sea Ice. Beaufort Sea Technical Report No. 28. Victoria, B.C., Canada: Department of the Environment. L-18 Shell Oil Company, Sohio Alaska Petroleum Co., Exxon Company, USA, Amoco Production Company, ARCO Alaska, Inc., Chevron USA, Mobil Oil Corporation, Phillips Petroleum Company, and Texaco, Inc. 1983. Oil Spill Response in the Arctic, Part 2: Field Demonstrations in Broken Ice. Anchorage, AK. Shell Western E&P, Inc., Sohio Alaska Petroleum Company, Exxon Company, Amoco Production Company, ARCO Alaska, Inc., Chevron, USA, Inc., Gulf Oil Corporation, Mobil Oil Corporation, Phillips Petroleum Company, and Texaco, Inc. 1984. Oil Spill Response in the Arctic, Part 3: Technical Documentation. Anchorage, AK. S.L. Ross Environmental Research Limited. 1983a. The Efficiency of Mechanical Oil Skimmers. Ottawa, Ontario, Canada. S.L. Ross Environmental Research Limited. 1983b. Evaluation of Industry’s Oil Spill Countermeasures Capability in Broken Ice Conditions in the Alaskan Beaufort Sea. Ottawa, Ontario, Canada: Prepared for State of Alaska, Dept. of Environmental Conservation. Spiltec. 1989. Oil Spill Contingency Plan, OCS Lease Sale Area 109, Chukchi Sea, Alaska. Prepared for Shell Western E&P Inc. Spiltec. 1990. Oil Spill Contingency Plan, OCS Lease Sale Area 109, Chukchi Sea, Alaska. Prepared for Texaco Producing Inc. Stringer, W.J. and G. Weller. 1980. Studies of the Behavior of Oil in Ice. Environmental Assessment of the Alaskan Continental Shelf. Fairbanks, AK: University of Alaska, Geophysical Institute. Tebeau, P.A. 1987. Oil Spill Response Systems for the Beaufort Sea. In: Proceedings of a Synthesis Meeting, the Diapir Field Environment and Possible Consequences of Planned Offshore Oil and Gas Development, P.R. Becker, ed. Chena Hot Springs, AK, January 25-28, 1983. Anchorage, AK: USDOC, NOAA, OCSEAP, and USDOI, MMS, Alaska OCS Region, pp. 227-236. The McCloskey Group. 1989. Beaufort Sea OCS Lease Sale 97 Oil Spill Contingency Plan. Revision No. 3/June 1989. Santa Barbara, CA: Prepared for Amoco Production Company (USA). Thomas, D.R. 1983. Potential Oiled Ice Trajectories in the Beaufort Sea. Report No. 252. Kent, WA: Flow Industries, Inc. Truett, J.C. ed. 1985. Physical Environment and Pollutant Behavior. In: Proceedings of a Synthesis Meeting: The Norton Basin Environment and Possible Consequences of Planned Offshore Oil and Gas Development. Denali National Park, AK, June 5-7, 1984. Anchorage, AK: USDOC, NOAA, OCSEAP, and USDOI, MMS, pp. 11-37. Union Oil Company of California. 1985. Oil Spill Contingency Plan for OCS Lease Sale 87, Beaufort Sea, Alaska. USDOI, MMS. 1984. Proposed Diapir Field Lease Offering (1984) (Sale 87). Final Environmental Impact Statement. OCS EIS/MMS 84-0009, 2 Vols. Anchorage, AK: USDOI, MMS, Alaska OCS Region. USDOI, MMS. 1985. Norton Basin Sale 100. Final Environmental Impact Statement. OCS EIS/EA MMS 85-0085, 2 Vols. Anchorage, AK: USDOI, MMS, Alaska OCS Region. USDOI, MMS. 1987. Chukchi Sea Sale 109 Final Environmental Impact Statement. MMS OCS, EIS/EA 87-0110. Anchorage, AK: USDOI, MMS, Alaska OCS Region. USDOI, MMS, Oil Spill Task Force. 1989. Oil Spill Planning, Response Requirements, and Practices for the Outer Continental Shelf Oil and Gas Operations. Report to the Secretary of the Interior. USDOI, MMS, Gulf of Mexico Region. 1983. Final Environmental Impact Statement, Vol. 1. Metairie, LA: USDOI, MMS, Gulf of Mexico Region. L-19 Wells, P.G, 1984. The Toxicity of Oil Spill Dispersants to Marine Organisms: A current perspective. In: Oil Spill Chemical Dispersants: Research, Experience, and Recommendations, E.W. Alled, ed. STP 840. Philadelphia: ASTM, pp. 177-202. Woodward-Clyde Consultants. 1981. Coastal Analysis of Alaska and the Northwest Passage. Prepared for Dome Petroleum Ltd., Victoria, B.C., Canada. L-20 GLOSSARIES SAlayssu i GLOSSARY OF ACRONYMS AND INITIALISMS (Includes Common Abbreviations and Symbols) AAC Alaska Administrative Code ABSORB Alaska Beaufort Sea Oilspill Response Body ACI Alaska Consultants, Inc. ACMA Alaska Coastal Management Act ACMP Alaska Coastal Management Program ACORP Alaska Cooperative Oilspill Response Planning Committee ACS Alaska Clean Seas ADEC Alaska Department of Environmental Conversation ADF&G Alaska Department of Fish and Game AEIDC Arctic Environmental Information and Data Center AEWC Alaska Eskimo Whaling Commission AHF Allan Hancock Foundation AINA Arctic Institute of North America AMOP Arctic and Marine Oilspill Program AMSA Area Meriting Special Attention ANCSA Alaska Native Claims Settlement Act ANHB Alaska Native Health Board ANILCA Alaska National Interest Lands Conservation Act ANWR Arctic National Wildlife Refuge AOGA Alaska Oil and Gas Association APD Application for Permit to Drill APFRT Arctic Peregrine Falcon Recovery Team API American Petroleum Institute ARBO Arctic Region Biological Opinion AS Alaska Statute ASRC Arctic Slope Regional Corporation BACT best available control technology BAST best available and safest technology bbl barrel, barrels Bbbl billion barrels BEM Branch of Environmental Modeling (MMS, Reston, Va.) BIA Bureau of Indian Affairs BIOS Baffin Island Oil Spill Project BLM Bureau of Land Management BOP blowout preventor B.P. Before the present [time] bpd barrels per day BTF Biological Task Force ic carbon sc degrees Centigrade or Celsius CAH Central Arctic herd Call Call for Information and Nominations CASPPR Canadian Arctic Shipping Pollution Prevention Regulations CDU Conical Drilling Unit CDF&G California Department of Fish and Game CEQ Council on Environmental Quality CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 CETA Comprehensive Employment and Training Act cf cubic feet CFR Code of Federal Regulations CIDS Concrete Island Drilling System COE COST CPA CPC CRSA CZM CZMA DEC DEIS DGC DNR DPP DST DWT E&D EEZ EIS EP EPA ESP EWC FAA FEIS FERC FWS GIS HRD HUD GLOSSARY OF ACRONYMS AND INITIALISMS (Continued) Capital Improvements Program (North Slope and Northwest Cook Inlet Response Organization centimeter square centimeter cubic centimeter centimeters per second Coastal Management Program Corps of Engineers (U.S. Army) Continental Offshore Stratigraphic Test Cost Participation Area Coastal Policy Council (State of Alaska) Coastal Resource Service Area coastal zone management Coastal Zone Management Act decibels Department of Environmental Conservation (State of Alaska) draft environmental impact statement Division of Governmental Coordination (State of Alaska) Department of Natural Resources (State of Alaska) Development Production Plan deep-stratigraphic test deadweight tonnage Environmental Assessment Exploration and Development (Report) Exclusive Economic Zone environmental impact statement exploration plan Environmental Protection Agency Endangered Species Act Environmental Studies Program Eskimo Whaling Commission degrees Fahrenheit Federal Aviation Administration final environmental impact statement Federal Energy Regulatory Commission Federal Register foot Fish and Wildlife Service (U.S.) fiscal year grams Geographic Information System High-resolution seismic-reflection data Department of Housing and Urban Development Arctic Boroughs) ICAS IPP ISER ISHTAR TUM TIwc JRT MMbbl MMPA MMS MRSC m/sec NANA NAQS NAS NEPA NMFS nmi NO, NOAA NOI NOS GLOSSARY OF ACRONYMS AND INITIALISMS (Continued) Inupiat Community of the Arctic Slope inch Intergovernmental Planning Program Indian Reorganization Act Institute of Social and Economic Research (UAA) Inner Shelf Transfer and Recycling Program Information to Lessees Information Transfer Meeting Integrated Terrain Units Information Update Meeting International Whaling Commission Joint Response Team kilogram kilometer square kilometer kilowatt lethal concentrations at which half the organisms die Land Management Regulations liquefied natural gas meter square meter cubic meter United Nations Marine Pollution Convention, Annex V thousand barrels mile, miles minute milliliter memorandum of understanding millimeter million barrels Marine Mammal Protection Act Minerals Management Service Marine Spill Response Corporation meters per second Northwest Alaska Native Association National Air Quality Standards National Academy of Sciences National Environmental Policy Act National Marine Fisheries Service nautical mile nitrogen dioxide National Oceanic and Atmospheric Administration Notice of Intent Notice of Sale NPDES NPR-A NPS NRC NSB NSBCMP NTL NWAB NWAFC OCD OCRM Ocs OCSEAP OCSLA OCSLAA OGJ OMB OOC OPEC OSC OSCP OSRA OSRD OTA PAH PBU PIRO ppb ppm ppt PSD RD RRT RS RSFO RTWG RU sID SMA SESP SHPO so, SOA SRA SSDC SWEPI GLOSSARY OF ACRONYMS AND INITIALISMS (Continued) National Pollution Discharge Elimination System National Petroleum Reserve-Alaska National Park Service National Research Council North Slope Borough North Slope Borough Coastal Management Program Notice to Lessees Northwest Arctic Borough Northwest and Alaska Fisheries Center Offshore and Coastal Dispersion (Model) (Office of) Ocean and Coastal Resource Management outer continental shelf Outer Continental Shelf Environmental Assessment Program Outer Continental Shelf Lands Act of 1953 Outer Continental Shelf Lands Act and Amendments Oil and Gas Journal Office of Management and Budget (State of Alaska) Offshore Operators Committee Organization of Petroleum Exporting Countries on-scene coordinator Oil-Spill-Contingency Plan oil-spill-risk analysis oil-spill-response drill Office of Technology Assessment (U.S. Congress) polycyclic aromatic hydrocarbons Prudhoe Bay Unit Petroleum Industry Response Organization parts per billion parts per million parts per thousand Prevention of Significant Deterioration Regional Director Regional Response Team Regional Supervisor Regional Supervisor, Field Operations Regional Technical Working Group Research Unit Secretarial Issue Document spring migration area Socioeconomic Studies Program State Historical Preservation Office/Officer sulfur dioxide State of Alaska Subsistence Resource Area Single Steel Drilling Caisson Shell Western Exploration and Production, Inc. GLOSSARY OF ACRONYMS AND INITIALISMS (Continued) TAP Trans-Alaska Pipeline TAPS Trans-Alaska Pipeline System TA&RP Technology Assessment and Research Program TSP total suspended particulates UAA University of Alaska USCG United States Coast Guard USDOC US. Department of Commerce USDOD US. Department of Defense USDOE U.S. Department of Energy USDOI USS. Department of the Interior USGS United States Geological Survey VLCC very large crude carrier VOC volatile organic compound WSF water-soluble fraction Symbols ° degrees (Fahrenheit or Centigrade) an parts per thousand (salinity) > greater than > greater than or equal to < less than < less than or equal to Bu Greek "mu" = "micro" ug microgram t plus/minus INDEX XACNI Accident rates pipelines IV-A-3 platforms IV-A-3 tankers IV-A-3 Acid precipitation IV-B-1 Admiralty Bay II-36 Air quality I-11; III-9 effects Alternative I low case II-3; IV-B-1-2 base case II-12; IV-C-14 high case II-22; IV-D-1-2 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-31; IV-G-1-2 cumulative effects IV-H-2-3 natural gas production and development IV-I-1-2 unavoidable adverse effects IV-K-1 very large oil spill IV-J-2 operations emissions IV-B-1-2, C-2-4, D-1-2 other emissions IV-B-2, C-1-2, D-2 Akoviknak Lagoon III-43 Akunik Pass III-40 Alaska Coastal Current III-1, 19 Alaska Coastal Management Act of 1977 (ACMA) III-54 Alaska Coastal Management Program (ACMP) II-47; IlI-54; IV-B-21-22, C-73, D-32 Alaska Coastal Policy Council 1-54 Alaska Eskimo Whaling Commission (AEWC) II-41; III-35; V-AEWC-1-2 Alaska Maritime National Wildlife Refuge 1-6; IlI-20 Alaska National Interest Lands Conservation Act (ANILCA) 16 Alaska Native Claims Settlement Act of 1971 (ANCSA) I-6; III-58 Alaska Native Health Board III-51 Alternative I - The Proposal II-1-28 low case II-2-6; IV-B-1-22 base case II-6-20; IV-C-1-82 high case II-20-28; IV-D-1-33 Alternative II - No Sale II-1, 28; IV-E-1 Alternative III - Delay the Sale II-1, 28; 1V-F-1 Alternative IV - Point Lay Deferral Alternative I-14; II-1, 28-36; IV-A-1, G-1-14; V-UNO-1, NOAA-1 Alternatives, comparative analysis Tables II-G- 1, S-1 ANILCA See Alaska National Interest Lands Conservation Act (ANILCA) Archaeological resources I-10; III-51-53 Bering Land Bridge National Preserve 1-6; III- 53; IV-B-21, C-72 Cape Krusenstern National Monument I-6; IlI-52; IV-B-21, C-72 defined I-51 effects Alternative I low case II-6; IV-B-20-21 base case II-19; IV-C-70-72 high case II-27; IV-D-31-32 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-35; IV-G-13 cumulative effects IV-H-14-15 natural gas production and development IV-I-5 unavoidable adverse effects IV-K-3 very large oil spill IV-J-10-11 offshore III-51-52; IV-B-20-21, C-70-71 onshore III-52-53; IV-B-21, C-71-72 protection of II-36-37 shipwrecks III-52; IV-B-20-21, C-71, D-32 ARCO Alaska V-ARCO-1 Arctic National Wildlife Refuge (ANWR) III-53 Arctic Ocean III-3 Arctic Peregrine Falcon See Falcon, arctic peregrine Arctic Slope Regional Corporation (ASRC) III- 50, 53 Areas of Special Biological and Cultural Sensitivity I-13; II-45-46 Areas Meriting Special Attention See Land use plans and coastal management programs Artificial Islands See Islands Atqasuk effects Alternative I low case IV-B-19 base case II-18; IV-C-51-52, 55, 65, 66-70 high case II-26-27; IV- D-26-27 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV IV-G-11-12 cumulative effects IV-H-10-14 natural gas production and development IV-I-4-6 unavoidable adverse effects IV-K-2-3 very large oil spill IV-J-9-10 population III-44 sociocultural system III-48; IV-B-19-20, C- 66-70, D-29-31, H-13-14 subsistence-harvest patterns III-44-45; IV-B- 19, C-51-52, 55, 65, D-26-27, H-10-13 Ayugatak Lagoon III-43 Barrow V-3 effects Alternative I low case IV-B-17-18 base case II-18; IV-C-61-62 high case II-26-27; IV-D-22-23 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV IV-G-10-14 cumulative effects IV-H-10-14 natural gas production and development IV-I4-6 unavoidable adverse effects [V-K-2-3 very large oil spill IV-J-9-10 population III-35 sociocultural system III-47-48; IV-B-19-20, C-66-70, D-29-31, H-13-14 subsistence-harvest patterns I-18; III-35-37; IV-B-17-18, C-51-54, 60-62, D-22-23, H- 10-13 Bathymetry III-1; IV-A-14-16 Bear, polar I-9; [II-22, 24; V-MMC-1 effects Alternative I low case II-4; IV-B-5-6 base case II-15-16; IV-C-29-35 high case II-24; IV-D-8-10 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-33; IV-G-8 cumulative effects IV-H-39-44 natural gas production and development IV-1-3 unavoidable adverse effects IV-K-1-2 very large oil spill IV-J-5-6 subsistence-harvest patterns III-37, 40, 41- 42, 44; IV-C-60 Beaufort Sea I1I-4 Canadian petroleum development IV-H-15 Belukha whales See Whales Benthic organisms See Lower-trophic-level organisms Bering Land Bridge National Preserve III-53; IV- B-26, C-72 Bering Sea III-3-5 Bering Sea Fishermen's Association V-BSFA-1 Biological resources II-37-38; III-10-27 effects Alternative I low case II-4-5; IV-B-4-17 base case II-13-17; IV-C-8-50 high case II-22-26; IV-D-5-16 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-31-34; IV-G-5-10 cumulative effects IV-H-6-9, 21-53 irreversible effects IV-M-1 natural gas production and development IV-I-24 unavoidable adverse effects IV-K-1-2 very large oil spill IV-J-3-8 Biological Task Force (Chukchi Sea Biological Task Force) I-46-47 Birds, marine and coastal I-9; II-43-45, 46; III- 20-22 effects Alternative I low case II-4; IV-B-4-5 Birds, marine and coastal (continued) base case II-14-15; IV-C-23-29 high case II-24; IV-D-7-8 Alternative II IV-E-1 Alternative II] IV-F-1 Alternative IV II-32-33; IV-G-7-8 cumulative effects IV-H-22-39 natural gas production and development IV-I-2-3 subsistence-harvest patterns III-37, 39-40, 41, 43, 44-45;IV-C-59-60 unavoidable adverse effects IV-K-1 very large oil spill IV-J-4-5 endangered (arctic peregrine falcon) II-5, 16, 25; III-26; IV-B-16, C-44-45, D-13-14, E- 1, F-1, G-9, H-51 protection of II-46 Block deletions See Mitigating measures Blossom Shoals III-1 Bowhead whales See Whales Bullen Point III-53 Bureau of Indian Affairs V-BIA-1 Bureau of Mines V-BOM-1 Call for Information I-1-2, 6-8 Canning River Delta III-53 Cape Beaufort III-40 Cape Dyer III-42 Cape Krusenstern National Monument I-6; III- 52; IV-B-21, C-72 Cape Lewis I-15; III-26; IV-C-23 Cape Lisburne I-15; II-45; III-23; IV-C-23 Cape Sabine I-23 Cape Thompson II-45; III-42; IV-C-23 Caribou I-9-10; [I-27 effects Alternative I low case II-5; IV-B-17 base case II-17; IV-C-46-49 high case II-25-30; IV-D-15-16 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-34; IV-G-10 Central Arctic herd III-27; IV-C-46 cumulative effects IV-H-44-46 habitat alteration IV-C-48 natural gas production and development IV-I-4 subsistence-harvest patterns III-36, 38, 40, 42, 44, 45; IV-C-57-58; V-BSFA- 1 unavoidable adverse effects IV-K-2 very large oil spill IV-J-8 Western Arctic herd II-27; IV-C-46-50; V-GP-4 Cetaceans See Whales; Endangered and threatened species Chipp River III-37 Chukchi Platform III-1 Chukchi Sea III-1-10 Biological Task Force II-46-47 seaice III-4-9; IV-A-12-14 Circulation III-3-5 Clean Water Act of 1977 II-3 Climate See Geology, environmental; Fog; Meteorology; Storm surges; Temperature; Winds Coastal erosion IV-A-14-15 Coastal management programs I-11; I-47; III-55 coastal habitats III-54-55; IV-C-77-78 coastal resources III-55 effects Alternative I low case II-6; IV-B-21-22 base case II-19; IV-C-72-80 high case II-27-28; IV-D-32-33 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV IV-G-13-14 cumulative effects IV-H-15-17 irreversible effects IV-M-1 natural gas production and development IV-I-5-6 unavoidable adverse effects IV-K-3 very large oil spill IV-J-11 North Slope Borough III-55-56 policies III-55; IV-C-72-73 state III-54-55 Coastal management programs (continued) See also Land use plans and coastal management programs Coastal Policy Council (CPC) See Alaska Coastal Policy Council (CPC) Coastal Zone Management Act of 1972 (CZMA) 14; 1-54 Colville River Delta III-56; IV-A-6 onshore effects birds IV-C-44 caribou IV-C-47 fish IV-C-20 Concrete Island Drilling System (CIDS) II-8; IV-A-12 Conical Drilling Unit (CDU) II-7; IV-A-12 Constraints and technology I-10; IV-A-12-16 Cumulative effects air quality [V-H-2-3 archaeological resources IV-H-14-15 belukha whales IV-H-51-53 birds IV-H-22-39 bowhead whales IV-H-46-48 caribou IV-H-44-46 coastal management programs IV-H-15-17 economy IV-H-10 endangered and threatened species IV-H-46-51 falcon, arctic peregrine [V-H-51 fishes IV-H-7-8, 21-22 gray whales IV-H-48-49 land use plans IV-H-15-17 lower-trophic-level organisms IV-H-6-7 migratory species IV-H-21-53 birds IV-H-22-39 harbor seal/sea otter IV-H-9 Pacific salmon IV-H-21-22 northern fur seal IV-H-42-44 pinnipeds IV-H-39-44 polar bear IV-H-39-44 sociocultural systems IV-H-13-14 Steller (northern) sea lion IV-H-49-51 subsistence-harvest patterns IV-H-10-13 water quality IV-H-3-5 wetlands IV-H-17-20 Currents III-3-5; I1V-A-14-15 Dalton Highway See North Slope Haul Road Dease Inlet [I-37 Deferral area See Alternative IV Delay the Sale Alternative II-1; IV-F-1 Dissolved oxygen concentrations ITI-10 Draft environmental impact statement (DEIS) preparation of I-2-3 Dredging effects IV-C-15 Drill sites See Islands Drilling discharges effects IV-B-2-4, C-4-5, 13-15, 20-21, D-2-3, G-2-3, 5, 6 muds II-8 Drilling units I-10; II-7-8; IV-A-12 See Concrete Island Drilling System; Conical Drilling Unit; Drillships; Islands; Single Steel Drilling Caisson Drillships II-7; [V-A-12; V-GP-2 Earthquakes I-11; [II-2; IV-A-15 See Geologic hazards Economy of the North Slope Borough I-11; III-27-33; V-ARCO-1 effects Alternative I low case II-5; IV-B-17 base case II-17-18; IV-C-50-56 high case II-26; IV-D-16-22 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-34; IV-G-10-11 cumulative effects IV-H-10 natural gas production and development IV-I-4 unavoidable adverse effects IV-K-2 very large oil spill IV-J-8-9 See North Slope Borough Effects, comparative analysis See Alternatives, comparative analysis Effects, potential Alternative I II-1-22 low case II-2-6; IV-B-1-29 base case II-6-20; IV-C-1-82 high case II-20-28; IV-D-1-33 Alternative II IV-E-1 Alternative III IV-F-1 Effects, potential (continued) Alternative IV IV-G-1-14 cumulative effects IV-H-1-53 Elson Lagoon III-37 Emissions See Air quality Employment See North Slope Borough Endangered and threatened species 1-9; III-24-26 defined I-24 effects Alternative I low case II-4-5; IV-B-6-16 base case II-16; IV-C-35-45 high case II-24-25; IV-D-10-14 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV I-43; IV-G-8-9 cumulative effects IV-H-46-51 irreversible effects IV-M-1 natural gas production and development IV-I-34 unavoidable adverse effects IV-K-2 very large oil spill IV-J-6-7 See also Falcon, arctic peregrine; Seals, northern fur; Sea lion, Steller; Whales, bowhead, gray Endangered Species Act of 1973, as amended (ESA) I-3; I-44; I-24 Endicott project III-53; IV-C-74 Energy objectives I-1 Environmental Protection Agency I-7; V-EPA- 1-4 Epontic organisms See Lower-trophic-level organisms Erosion See Coastal erosion Eskimo curlew I-12 Falcon, arctic peregrine III-26 effects Alternative I low case II-5; IV-B-16 base case II-16; IV-C-44-45 high case II-25; IV-D-13-14 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-33; IV-G-9 cumulative effects IV-H-51 natural gas production and development IV-I-3-4 unavoidable adverse effects IV-K-2 very large oil spill IV-J-7 protection of II-46 Fishes 1-9; III-16-20 anadromous species III-16-18 effects IV-C-17-19 habitat alteration IV-C-21-23 spawning III-16 species arctic char (Dolly Varden) III-16-18; IV-C-18-19 arctic lamprey III-16 ciscoes III-16; IV-C-18-19 Bering III-17 cod V-NOAA-7 arctic II-18-20 saffron III-18-20 flounder III-18-20 rainbow smelts III-16-17; IV-C-18-19 salmon III-16; [V-C-17-19 chum III-16 coho III-16; IV-C-17-18 king I-16 pacific III-16 pink III-16 sockeye III-16 sculpins III-18-20 whitefish III-16; IV-C-18-19 annual catch III-17-18 effects Alternative I I-11 low case II-4; IV-B-4 base case II-13-14; IV-C-16-23 high case II-23-24; IV-D-6-7 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-32; IV-G-6-7 natural gas production and development IV-I-2 unavoidable adverse effects IV-K-1 very large oil spill IV-J-4 freshwater species III-16-18; IV-C-17-19 marine species III-18-20 effects TV-C-19 natural gas production and development IV-I-2 unavoidable adverse effects IV-K-1 very large oil spill IV-J-4 species Canadian eelpout III-18-20 capelins II-19; IV-C-19 Fishes (continued) cod V-NOAA-7 arctic III-18-20; IV-C-19 saffron III-18-20; IV-C-19 flounder III-18-20; IV-C-19 arctic III-18-20 hamecon I-18 Pacific herring III-19 Pacific sand lance III-19 sculpins III-18-20; IV-C-19 arctic staghorn III-18-20 fourhorn III-18-20 shorthorn III-18-20 twohorn III-18-20 yellowfin soles III-20 overwintering area IV-C-19 subsistence-harvest patterns III-36-37, 39, 41, 42-43, 44, 45-46; IV-C-58 Fog I-12; III-3 Food web/trophic structure III- 15-16; IV-C-12-13 Formation-water discharge IV-C-4-5, D-3 Geologic hazards III-1-2, 5-9; IV-A-12-15, C-74 See also Coastal erosion; Earthquakes; Ice gouging; Ice hazards; Mass movement; Mudslides; Natural gas hydrates; Sediments; Shallow gas; Slumping Geology III-1-2 constraints and technology IV-A-12-16 continental rises III-1 continental shelves III-1; IV-A-14 Chukchi III-1 environmental III-1-5 petroleum III-1 Geophysical hazards See Geologic hazards Gravel deposits I-1 Gravel roads pipeline-support road I-10; IV-C-28 Gray whales See Whales Greenpeace USA V-GP-1-8 Haul road See North Slope Haul Road (Dalton Highway) High-resource case II-20-28; IV-D-1-33 Hydrocarbons II-39-40; I-10; IV-C-4, 9-13 transportation II-39-40; IV-A-3 Ice gouging III-6; IV-A-12, C-71 Ice hazards III-5-9; IV-C-74 Ice islands See Islands Icebreakers II-3, 7; IV-A-13 Icy Cape II-28; III-1, 39; IV-A-8, C-25, 33 Inaru River III-37 Indian Reorganization Act (IRA) III-50 Industry activity constraints IV-A-12-16 development II-2-3, 6, 9-11, 21-22, 29-30; IV-C-5-6, 15-16, 22, 27-29, 42-43, 43-44 existing II-3,9 exploration II-2-3, 7-9, 20-21, 29; IV-A-12- 13, C-42, 43 production II-2-3, 9-11, 21-22, 29-30; IV-A- 12-13, C-42-43, 43-44 proposed IV-A-12-14, C-5-6 transportation II-2-3, 11-12, 22, 30; IV-A- 12-13 Information to Lessees I-12-13;II-43-50 See Mitigating measures International Agreement on the Conservation of Polar Bears of 1976 III-24 International Whaling Commission (IWC) III-34; IV-C-56 Inupiat I-6 population III-31-33, 46; IV-C-66 sociocultural systems III-59-65; IV-C-66-70, D-27-31 subsistence-harvest patterns I-10; III-41-59; IV-B-17, 17-19, C-51-56, D-17-22, 22-27, G-11-12 Invertebrates See Lower-trophic-level organisms Islands artificial IV-A-12 barrier IV-C-19 bottom-founded II-7; [V-A-12 Concrete Island Drilling System (CIDS) II-8; [V-A-12 Single-Steel Drilling Caisson (SSDC) II- 8; IV-A-12 Caisson-retained island IV-A-12 floating II-7-8; IV-A-12 Conical Drilling Unit (CDU) II-7; IV-A- 12 ice-strengthened drillships II-7; IV-A-12 ice II-8; IV-A-12 Kaktovik III-46 Kasegaluk Lagoon I-7, 15; II-45; III-16, 56; IV- C-17, 33 Kelp beds See Lower-trophic-level organisms Kilkralik Point III-43 Kokolik River Delta III-17, 40 Kugrua Bay III-15 Kugrua River III-17, 39 Kuk Inlet III-39 Kuk Lagoon III-39 Kuk River III-17, 39 Kukpowruk Pass III-40 Kukpowruk River III-17 Kukpuk River III-17, 43 Land status and use See North Slope Borough Land Management Regulations III-53-54; IV-B- 21, C-72-73 Land use plans and coastal management programs I-11; II-53-56 Areas Meriting Special Attention III-56; IV- C-78 Automated Geographic Information System (GIS) I-54 effects Alternative I low case II-6; IV-B-21-22 base case II-19; IV-C-72-80 high case II-27-28; IV-D-32-33 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-45; IV-G-13-14 cumulative effects IV-H-15-17 natural gas production and development IV-I-5-6 unavoidable adverse effects IV-K-3 very large oil spill IV-J-11 irreversible commitment IV-M-1 Leasing program goals I-1 history 1-5-6 legal mandates and authorities I-6 litigation 1-5-6 Notice of Availability I-4 Process I-1-4 public hearings I-3; V-3-4, PH-1-6 regulatory enforcement I-6 schedule I-1 scoping I-2, 6-15 Ledyard Bay I-15; II-45; II-21; IV-C-23, 49 Lisburne project IV-C-74 Low-resource case II-2-6; IV-B-1-22 Lower-trophic-level organisms I-9; I-38; III-10- 16 benthic organisms III-13-15 invertebrates/communities III-13-15 effects II-38; IV-C-10-12 epifauna III-14-15; IV-C-10-11- infauna III-14-15; IV-C-10-11 macroscopic algae III-13; IV-C-9-10 meroplankton III-13 kelp-bed communities I-38; III-13; IV-C- 9-10 effects Alternative I low case II-4; IV-B-4 base case II-13; IV-C-8-16 high case II-22; IV-D-5-6 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-31-32; IV-G-5-6 cumulative effects IV-H-6-7 natural gas production and development Iv-I-2 unavoidable adverse effects IV-K-1 very large oil spill IV-J-3-4 epontic organisms, communities III-12-13; IV-C-9-10, 12 ice-algal cells III-12-13 planktonic organisms (pelagic) communities Lower-trophic-level organisms (continued) Ill-10-12; IV-C-11-12 effects IV-C-11-12 meroplankton III-11 phytoplankton III-10-12; IV-C-9-10 zooplankton III-10-12; [V-C-10-11 Marine and coastal birds See Birds, marine and coastal Marine Mammal Commission V-MMC-1-8 Marine Mammal Protection Act of 1972 1-5; II- 44; 11-24 Marine mammals See specific species Mass movement IV-A-15 Meade River III-37, 56; IV-C-58 Meteorology III-2-3 See also Temperature; Storm surges; Winds Migratory species See Cumulative effects Millikktagvik III-39 Mining and mineral processing IV-C-76 Mitigating measures I-12-13; II-36-50; V-EPA- 1-2 Information to Lessees I-13; [1-43-50 Information on Bird and Marine Mammal Protection (No. 1) I-13; II-44-45 effectiveness [I-45 purpose II-45 Information on Areas of Special Biological and Cultural Sensitivity (No. 2) 1-13; 1145-46 effectiveness II-45-46 purpose II-45 Information on Arctic Peregrine Falcon (No. 3) I-13; II-46 effectiveness I-46 purpose II-46 Information on Chukchi Sea Biological Task Force (No. 4) I-13; 1-46-47 effectiveness II-47 purpose II-47 Information on Coastal Zone Management (No.5) I-13; 1-61-62 effectiveness II-47 purpose II-47 Information on Endangered Whales and MMS Monitoring Program (No.6) I-13; 11-47-48 effectiveness I-48 purpose II-48 Information on Development and Production Phase Consultation with NMFS to Avoid Jeopardy to Bowhead Whales (No. 7) I-13; II-48-49 effectiveness II-49 purpose II-49 Information on Oil-Spill-Cleanup Capability (No.8) I-13; II-49-50 effectiveness II-49-50 purpose II-49 Stipulations I-12-13; II-36-43 Protection of Archaeological Resources (No. 1) I-12; 1-36-37 effectiveness II-37 purpose II-37 Orientation Program (No.2) I-12; II-38-39 effectiveness [I-39 purpose II-39 Protection of Biological Resources (No.3) 1-37-38 effectiveness II-38 purpose II-38 Transportation of Hydrocarbons (No. 4) I- 12-13; II-39-40 effectiveness I-40 purpose II-40 Industry Site-Specific Bowhead Whale- Monitoring Program (No. 5) I-13; II- 40-41 effectiveness II-41 purpose II-41 Subsistence Whaling and Other Subsistence Activities (No. 6) I-13; II- 41-42 effectiveness I-42 purpose II-41-42 Oil-Spill-Response Preparedness (No. 7) 1-13; 1-42-43 effectiveness II-42-43 purpose II-42 Mohr, J.L. V-JLM-1-2 Mudslides III-2 Muds See Drilling discharges NANA Regional Corporation V-NANA-1-2 Naokok Pass III-40 National Energy Plan I-1 National Environmental Policy Act of 1969 (NEPA) I-2 National Marine Fisheries Service (NMFS) I-3; 11-48 National Oceanic and Atmospheric Administration I-6; V-NOAA-1-8 National Park Service I-2, 6; V-NPS-1-2 National Petroleum Reserve - Alaska (NPR-A) II-11; II-53; I1V-C-47, 72 Natural gas development and production IV-I-1-6 Natural gas hydrates III-2 Noatak River III-27 Noise and disturbance airborne IV-B-12-13, C-26-27 bird populations II-14-15, 24, 32-33; IV-C- 26-27 leasing activities IV-B-7-16, C-5-7, 27-29, 46-48 marine mammals II-15-17, 24-25, 33-34; IV- C-32-34, 35-37, 35-37, 45-46, D-10-11; V-NSB-2, EPA-2 waterborne IV-C-26-27 whale II-16-17, 24-25, 33-34; IV-B-7-16, C- 35-37, 45-46 bowheads II-16, 24-25, 33; IV-C-35-37, D-10-11 long-term noise effects IV-C-35-37; V-GP-7 spring lead system IV-C-35; V- NOAA-S, 7, BIA-1 gray II-16, 24-25, 33; IV-C-35-37 North Chukchi Basin III-1 North Slope Borough I-2; III-27-51; V-NSB-1-3 Automated Geographic Information System TH-54 Capital Improvements Program (CIP) III-50- 51, 53; IV-C-50 Coastal Management Program II-47; III-53, 55-56; IV-C-73-80 Areas Meriting Special Attention III-56; IV-C-78 boundary III-55; IV-C-72 policies III-55-56; IV-C-72, 73, 80 Comprehensive Plan III-53; [V-C-72-73 economy III-27-33; IV-B-17, C-50-56, D-16- 22, E-1, F-1, G-10-11, H-10; V-ARCO-1 employment III-30-31; IV-B-17, C-50-51, D- 16-17, E-1, F-1, G-10-11 household income III-50-51 irreversible commitment M-1 Land Management Regulations III-53-54; IV- B-21, C-72-73 land status and use I-11; III-53; IV-B-21-22, C-72-80, H-15-17 population III-31-33, 46 revenues III-29-30; IV-B-17, C-50, D-16 sociocultural system II-52-53; III-46-51; IV- B-19-20, C-66-70, D-27-31, E-1, F-1, G- 12-13, H-13-14, 1-4-5, M-1 subsistence-harvest patterns II-52-53; III-41- 59; IV-B-17, 17-19, C-51-56, 56-66, D- 17-22, 22-27, E-1, F-1, G-11-12, H-10- 13, I-4-5; V-ARCO-1 transportation systems II-10-11 unavoidable adverse effects IV-K-2-3 See also Atqasuk; Barrow; Kaktovik; Nuiqsut; Point Hope; Point Lay; Wainwright North Slope Haul Road (Dalton Highway) IV-C- 47, 80 Northern Alaska Environmental Center V-NAEC-1-3 Nuigsut IV-I-4-6, J-8-11, K-2-3; population III-45 sociocultural system III-48; IV-B-19-20, C- 66-70, D-29-31, H-13-14 subsistence-harvest patterns I-18, 26-27; III- 45-46; IV-B-19, C-751-52, 55-56, D-27, H-10-13 Nunagiaq III-39 Oceanography See Bathymetry; Circulation; Currents; River discharge; Sea ice; Tides; Waves and swells Offshore-storage and loading facilities IV-A-13- 14 Oil and gas resource estimates Alternative I II-1 low case II-1, 2; IV-A-1 base case II-1, 6; IV-A-1, high case II-1, 20; IV-A-1 Alternative IV II-29 irretrievable commitment IV-M-1 Oil-spill-cleanup capability I-10; [V-A-9-11 ice IV-A-10, 11 Oil-spill-risk analysis I-10; IV-A-2-7; Oil spills Alaskan record IV-A-5-6 Oil spills (continued) cleanup I-10; II-42-43, 49-50; IV-A-9-11; V- TFA-2-3, JUM-1, NPS-2 sea IV-A-10-11 ice IV-A-10, 11 contingency measures II-42-43, 49-50; IV-A- 9-11 discharges IV-B-2-4, C4-5, 13-15, 20-21, D- 2-3, G-2-3, 5,6 effects IV-B-6-8, C-9-13, 17-20, 24-26, 29- 32, 37-45, 45-46, 48-50, 81-82, D-3-4, 11-13, G-4-5 extent and persistence IV-A-8-9 fate and behavior I-10; IV-A-7 frequency estimates IV-A4 historical rates IV-A-3 ice-trapped IV-A-10, 11 onshore IV-A-8 probability IV-A-3, 5-7, 7-8 response I-7; IV-A-9-11; V-JLM-2 size ranges IV-A-6 toxicity IV-A-11-12 trajectory simulations IV-A-3-4, 7 very large oil spill IV-J-1-11 Orientation program II-38-39 Otter, Sea IV-H-9 Outer Continental Shelf Lands Act of 1953 (OCSLA) Amendments of 1978 I-5; II-36; V-TFA-3 Peard Bay I-7, 15; II-45; III-15, 20; IV-C-17, 23, 33 Peard Bay Lagoon III-15 Permafrost III-1-2; IV-A-14 Petroleum provinces III-1 Phytoplankton See Lower-trophic-level organisms Pinnipeds See Seals; Walrus Pipelines IV-A-13-14 construction II-11-12 design requirements IV-A-13-14; V-EPA-2 offshore IV-A-13-14, C-15 sea-ice hazards IV-A-14 oil spills TV-A-3-12 onshore II-11-12; IV-C-15; V-BSFA-1, NOAA-5 support road IV-C-47, 71 10 permafrost IV-A-14 TAP (see Trans-Alaska Pipeline) transportation II-11-12; IV-A-3, 13-14, C-15 Pitmegea River [I-17 Plankton See Lower-trophic-level organisms Plants, marine IV-C-9-10 Point Barrow II-41; I-35 Point Belcher II-10; IV-C-17, 80 offshore-pipeline landfall site I-10; IV-A-3, C-15; V-NOAA-2 shorebase II-10; IV-C-15, 70 Point Franklin II-45; III-1, 24, 35 Point Hope IV-H-10-14, I-4-6, J-8-11, K-2-3 population III-42 sociocultural system III-48;IV-B-19-20, C- 66-70, D-29-31, H-13-14 subsistence-harvest patterns II-18, 26-27; III- 42-44; IV-B-19, C-64-65, D-26, H-10-13 Point Hope Lagoon IV-C-23 Point Lay IV-H-10-14, I-4-6, J-8-11, K-2-3 population III-40 sociocultural system III-48; IV-B-19-20, C- 66-70, D-29-31, H-13-14 subsistence-harvest patterns II-18, 26-27, 34; III-40-42; IV-B-19, C-51-52, 55, 63-64, D-25-26, H-10-13; V-3, NOAA-4 Point Lay Deferral (Alternative IV) I-14; II-1, 28-36; IV-A-1, G-14; V-NOAA-3 Polar bears See Bear Population III-31-33, 46 See North Slope Borough Production platforms I-10; II-9-10; IV-A-13 Protection of Biological Resources I-12; II-37- 38 Prudhoe Bay - Kuparuk industrial complex III-53 Qilamittagvik III-39 Qipuglaich III-39 Refuges See Alaska National Maritime National Wildlife Refuge; Arctic National Wildlife Refuge (ANWR) Resource estimates See Oil and gas resource estimates, high case, low case, mean case Scoping process I-2, 6-15 results I-6-15 Sea ice III-5-9; IV-A-12-14, C-7-8 anchor III-6-7 constraints [V-A-12-14 decay III-8-9 floebergs III-8; IV-A-12 floes III-6; IV-A-12 forecasting IV-A-12-13 islands III-8; [V-A-12-13 landfast-ice zone III-5 leads and open-water areas III-6 pack-ice zone III-7-8; IV-A-12, C-7-8 polynyas III-7; V-NOAA-2 rideups III-5; IV-A-12 ridges III-6, 8; IV-A-13 seafloor gouging III-6; IV-A-12 stamukhi zone III-5-7; [V-A-13 summer conditions III-8-9 superstructure icing IV-A-15-16 winter conditions III-5-8 Sea lion, Steller (northern) IV-H-49-51; V- MMC-1 SEACO V-SEA-1 Seals 1-9; III-22-24 bearded III-22-23; IV-H-39-42 effects 1-9 Alternative I low case II-4; IV-B-5-6 base case II-15-16; IV-C-29-35 high case II-24; IV-D-8-10 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-33; IV-G-8 cumulative effects IV-H-9, 39-44 natural gas production and development IV-I-3 unavoidable adverse effects IV-K-1-2 very large oil spill IV-J-5-6 harbor IV-H-9 northern fur IV-H-42-44 ringed I1I-22; IV-H-39-42 spotted III-23; IV-H-39-42 subsistence-harvest patterns III-36, 39, 40- 41, 43; IV-C-58-59 11 Sea Otter See Otter, Sea Seasonal Drilling Restriction I-5; V-MMC-1-2 Secretarial Issue Document (SID) I-4 Sediments marine III-1 surficial III-1 unstable IV-A-15 Seismic activity II-7, 9, 21, 29-30; IV-G-S, 6 Seismic disturbance effects IV-C-13, 21-22 Shallow gas III-2 Ships sea-ice hazards IV-A-12-13 Shipwrecks III-52; IV-B-20-21, C-72, D-323 Shoals II-1 Short-term effects and uses IV-L-1-2 defined IV-L-1 Single Steel Drilling Caisson (SSDC) II-8; IV- A-12 Sinuk III-43 Skull Cliff I-7, 15; I-35; IV-C-9 Slumping III-2 Social Systems See North Slope Borough Sociocultural systems--North Slope III-46-51 effects 1-9 Alternative I low case II-7; IV-B-19-20 base case II-24-25; IV-C-66-70 high case II-35-36; IV-D-27-31 Alternative II [V-E-1 Alternative III [V-F-1 Alternative IV II-35; 1V-G-12-13 cultural values III-49-50; IV-C-68-69, D- 30 cumulative effects IV-H-13-14 industrial activities IV-C-67, D-28 irreversible commitment IV-M-1 natural gas production and development IV-I-5 population and employment IV-C-67, D- Sociocultural systems--North Slope (continued) 28-29 social organization III-48-49; IV-C-68-69, D-29-30 social problems III-51; [V-C-69-70, D- 30-31 stress IV-C-69-70, D-31 subsistence-harvest patterns IV-C-67-68, D-29 unavoidable adverse effects IV-K-2 very large oil spill IV-J-10 Spring lead system effects on endangered whales IV-C-35 State of Alaska V-AK-1-5 Stipulations I-12-13; II-36-43 Storm surges III-4; IV-A-14-15 Studies (Chukchi Sea) Table II-D-1; Appendix F Subsistence-harvest patterns I-8-9; II-18, 26-27, 34; III-33-46; V-ARCO-1, AEWC-1-2 defined I-33 effects Alternative I low case II-5; IV-B-17, 17-19 base case II-18; IV-C-51-56, 56-66 high case II-26-27; IV-D-17-22, 22-27 Alternative II IV-E-1 Alternative II IV-F-1 Alternative IV I-34; IV-G-11-12 communities IV-B-17, 17-19, C-51-56, 60-66, D-22, 22-27 cumulative effects IV-H-11-12 irreversible commitment IV-M-1 natural gas production and development IV-I-4-5 resources III-44-59; IV-C-56-60 unavoidable adverse effects IV-K-2 very large oil spill IV-J-9-10 harvest II-18, 26-27, 34; I1I-3346; IV-C-56- 60 Support and logistics activities II-8-9, 10-11, 20-21, 21-22, 29, 30 Tankers IV-A-3; V-GP-8 accident rates IV-A-3 oil spills IV-A-3 Temperature III-2-3 Tides Il-4 Topogoruk River III-37 12 Toxicity studies IV-A-11-12 Trace metals III-10; IV-C-20-21; V-JLM-1, NOAA-7 Trans-Alaska Pipeline (TAP) II-11; IV-A-3, C- 47 Pump Station No. 2 II-11; IV-A-3, C-47, D- 32 Transportation systems II-11-12; IV-A-3, 13-14 air II-10-11 effects IV-C-15, 27, 33-34 hydrocarbons II-11-12; IV-A-3 marine IV-A-3, 13 surface IV-A-3, 13-14, C-15-16, 33-34 See also Pipelines and Tankers Trophic structure See Food web/trophic structure; Lower- trophic-level organisms Trustees for Alaska V-TFA-1-5 Tundra IV-C-23; V-TFA4 Turbidity III-10; IV-C-5 Undiscovered recoverable resources See Oil and gas resource estimates United States Coast Guard I-2; IV-A-9 United States Fish and Wildlife Service (USFWS) 1-6; II-45; IV-C-44; V-FWS-1-4 UNOCAL Corporation V-UNO-1 Utukok River III-17, 39 Wainwright IV-H-10-14, I-4-6, J-8-11, K-2-3; V-2 population III-38 sociocultural system III-48; IV-B-19-20, C- 66-70, D-29-31, H-13-14 subsistence-harvest patterns II-18, 26-27; III- 38-40; IV-B-18-19, C-51-52, 54-55, 62- 63, D-23-25, H-10-13 Wainwright Inlet [I-18 Walrus 1-9; III-22, 23-24; V-FWS-1 effects Alternative I low case II-4; IV-B-5-6 base case II-15-16; IV-C-29-35 high case II-24; IV-D-8-10 Alternative IV II-33; IV-G-8 Walrus (continued) cumulative effects IV-H-39-42 natural gas production and development IV-1-3 unavoidable adverse effects IV-K-1-2 very large oil spill IV-J-5-6 annual catch III-37, 38, 41, 44 subsistence harvest patterns III-37, 41, 44; IV-C-59 Waterfowl See Birds, marine and coastal Water quality I-10; III-9-10 effects Alternative I low case II-3-4; IV-B-24 base case II-12-13; IV-C4-8 high case II-22; IV-D-2-5 Alternative II IV-E-1 Alternative III IV-F-1 Alternative IV II-31; IV-G-2-5 cumulative effects IV-H-3-5 natural gas production and development IV-I-2 unavoidable adverse effects IV-K-1 very large oil spill IV-J-2-3 See also Dissolved oxygen; Hydrocarbons; Trace metals;Turbidity Waves and swells III-4; IV-A-14- 15 Weather See Meteorology Wells exploration and delineation Alternative I II-7-10 Alternative IV II-29 production and service Alternative I II-9-10 Alternative IV I-29 Wetlands effects Alternative I low case II-6; IV-B-22 base case II-19-20; IV-C-78, 80-82 high case II-28; IV-D-33 Alternative IV II-35-36; IV-G-14 cumulative effects [V-H-17-20 natural gas production and development IV-I-6 unavoidable adverse effects IV-K-3 very large oil spill IV-J-11 a3 Whales I-19, 13 belukha III-24, 26-27 effects Alternative I low case II-5; IV-B-16-17 base case II-16-17; IV-C-45-46 high case II-25; IV-D-14-15 Alternative II IV-E-1 Alternative III I[V-F-1 Alternative IV II-33-34; IV-G-9-10 cumulative effects IV-H-51-53 natural gas production and development IV-I-3 unavoidable adverse effects IV-K-2 very large oil spill IV-J-7-8 subsistence harvest III-36, 38, 40, 42 bowhead I-13; II-40-41, 47-49; III-24-25; V- SEA-1 effects Alternative I low case II-4-5; IV-B-6-16 base case II-16; IV-C-35-44 high case II-24-25; IV-D-10-13 Alternative IV II-33; IV-G-8-9 cumulative effects IV-H-46-48 natural gas production and development IV-1-3-4 unavoidable adverse effects IV-K-2 very large oil spill IV-J-6-7 food habits III-25; V-SEA-1 Mitigating measures Information on Endangered Whales and MMS Monitoring Program (No.6) II- 47-48 effectiveness [I-48 purpose II-48 Information on Development and Production Phase Consultation with NMEFS to Avoid Jeopardy to Bowhead Whales (No. 7) II-48-49 effectiveness II-49 purpose II-49 Industry Site-Specific Bowhead Whale- Monitoring Program (No. 5) II-40-41 effectiveness [I-41 purpose II-41 noise and disturbance V-TFA-4 long-term effects IV-C-35-37; V-GP-7 spring lead system IV-C-35; V- NOAA-S, 7, BIA-1 reproduction III-25 stocks III-25 subsistence harvest III-35-36, 38, 42; IV- C-5S6-57 unavoidable adverse effects IV-K-2 gray I1-47-48; III-24, 25-26 effects Alternative I Whales (continued) low case II-4-5; IV-B-6-16 base case II-161; IV-C-35-44 high case II-24-25; IV-D-10-13 Alternative IV I-33; IV-G-8-9 cumulative effects IV-H-48-49 natural gas production and development IV-I-34 unavoidable adverse effects IV-K-2 very large oil spill IV-J-6-7 See also Endangered and threatened species Winds III-2 Wrangel Island III-23; IV-A-8,C-17 Zooplankton See Lower-trophic-level organisms 14 4 U.S. GOVERNMENT PRINTING OFFICE: 1991-791-199/21802