View RDC's comment letter

Overview                                                                                                                                        

The U.S Fish & Wildlife Service (USFWS) is accepting comments through Monday, April 20^th on a peer-reviewed scientific manuscript and associated model (the Wilson Model) relating to the design of a seismic survey and potential impacts to maternal polar bear dens in the 1002 Area of the Arctic National Wildlife Refuge (ANWR). The Wilson Model was developed to assess impacts of a seismic program proposed in 2018 in the 1002 area.

In reviewing a request for an authorization for this seismic program, the USFWS applied a “new approach,” different from the approach historically applied by USFWS to analyze impacts to polar bears. The proposed program never occurred, in part because of the new methodology USFWS developed. As a result, USFWS has now requested public comments on the value of this methodology and the Wilson Model, which it seeks to apply to assist in evaluating future requests for authorization to conduct activities on the North Slope and specifically, the impact of these activities on maternal polar bear dens.

There is significant scientific data that puts into question the validity of the Wilson Model. Further, use of the Wilson model as a management tool would preclude virtually all activity in the Arctic.  Beyond industry activity on the North Slope, other essential goods and services to support local communities would cease to exist if USFWS elected to use the Wilson Model as a management tool. Numerous research studies would be determined to be disastrous to denning bears, aircraft travel would be prohibited, and community development would be severely limited.

There is no basis for the USFWS to abandon its prior approach to evaluating impacts to polar bears from industry activities. Through rigorous regulatory processes and evaluations over decades, the USFWS has repeatedly found that Alaska’s oil and gas industry has, at most, a negligible impact on polar bears. Those findings have withstood challenges by environmental advocacy organizations and have been upheld on three different occasions by the Ninth Circuit Court of Appeals. 

Action Requested

RDC members are encouraged to write comments opposing the use of the Wilson Model as a management tool for industry and community activities on the North Slope. There is no basis for the USFWS to abandon its prior approach to evaluating impacts to polar bears from industry and community activities.

Comment by email to: [email protected]

Points to consider:

• The Wilson Model was designed for a specific project seismic program in a specific geographic area (ANWR 1002 area) and is not appropriate for application to different activities across the North Slope.
• Use of the Wilson Model as a management tool for industry activity would severely impact the ability of Alaskans to proceed with activities that the USFWS has repeatedly confirmed are having only a negligible impact to a small number of polar bears, denning or otherwise.
• Use of the model for all activity across the North Slope would have a significant detrimental effect on business, community development, and way of life on the North Slope.
• Application of the model as a management tool for activity on the North Slope could effectively shut down activities occurring within five miles of the coast, including near communities, airports, and established infrastructure.
• The Wilson model concludes that a number of polar bears will be seriously or fatally injured as a result of a single seismic program. There is no evidence of serious or lethal impacts to denning bears from over 40 years of oil and gas operations and data collected by both industry and the USFWS, as well as information collected by scientific researchers and Traditional Knowledge.
• In collaboration with USFWS, industry has developed robust mitigation and management tools and training which are successful in minimizing and avoiding impacts to denning bears.
• The results of the Wilson Model were never validated as the SAE/ASRC seismic program that formed the basis for the model never occurred.
• The sole reliance on an aerial Forward Looking Infrared survey as the only mitigation measure included in the model is artificially narrow and fails to include the robust mitigation toolbox industry utilizes to minimize impacts to denning bears.

 Comment deadline is April 20, 2020