The U.S. Fish and Wildlife Service on December 8, 2020, published a proposed Marine Mammal Protection Act Incidental Harassment Authorization (IHA), opening a 30-day public review and comment period. If finalized, the IHA would allow the incidental harassment, meaning unintentional displacement or other non-lethal disturbance, of up to three polar bears in the Coastal Plain of the Arctic National Wildlife Refuge, during seismic and post-seismic work between January 21 and September 30, 2021. 

This authorization is a requirement for proposed seismic testing on the coastal plain because it provides habitat for the threatened Southern Beaufort Sea polar bear population. Kaktovik Inupiat Corporation applied for a seismic testing permit in October, to be carried out by SAExploration. Obtaining an IHA from the Fish and Wildlife Service would be a critical step forward for this process. 

If you can, please join us in submitting comments regarding the incidental take of polar bears to the Fish and Wildlife Service here. The comment deadline is January 7, the day after the scheduled lease sale in the coastal plain. 

This process has been rushed and confusing, and we’re so grateful for those who have made the time to put together comments at different stages of this haphazard and destructive process. Robust public input on the IHA is an important opportunity to draw attention to the flawed science in this authorization.

Here are some talking points to include in your comments: 


The Southern Beaufort Sea polar bear population is the world’s most imperiled polar bear population, with as few as 900 individuals. The Arctic Refuge’s coastal plain is vital to the survival of this imperiled population. Oil and gas development in the coastal plain could eradicate polar bears from this region.

  • The draft IHA contains serious gaps in its analysis of the likely harm to polar bears. The Trump Administration’s rushed process has once again resulted in a flawed and scientifically-deficient process.
  • Approximately 77 percent of the coastal plain is designated as critical habitat for polar bears under the Endangered Species Act. The coastal plain on-shore denning habitat is becoming increasingly vital for the Southern Beaufort Sea polar bear population as sea ice diminishes due to climate change. 
  • The draft IHA concedes there is about a 1 out of 5 probability (21%) of the seismic survey having an encounter with maternal dens that results in death/serious injury, and most of the time that will mean the death or serious injury of two cubs, not just one. With as few as 900 Southern Beaufort Sea polar bears left, we can’t afford the death of a single bear to fossil fuel development. 
  • The draft IHA assumes that completing three FLIR (forward-looking infrared radar) surveys will ensure that 98% of dens that are identified prior to KIC driving across the access route or beginning exploration activities will be protected by a buffer. No explanation is provided for how FWS concludes that 98% of dens will be detected after three FLIR surveys in light of the acknowledged 45% detection success rate per FLIR survey.


  • Seismic exploration is highly destructive to lands and wildlife. The coastal plain still bears scars of 2-D seismic testing conducted more than 30 years ago. Modern seismic methods cut an even denser grid of trails. In 1984-85, trails on the coastal plain were approximately four miles apart. 
  • Industrial activities including oil and gas exploration, drilling, infrastructure construction, facilities operation, traffic and even the mere presence of humans could cause mother polar bears to abandon their maternity dens, leaving their cubs to perish and sending the species into further decline.
  • Convoys of 90,000 lb. thumper trucks, tractors and bulldozers would roll over extensive areas of fragile tundra 24 hours a day, 7 days a week, for months, and two 160-person worker “camps” with extensive amenities would be dragged across the landscape. This application is for a single winter, but these intrusive activities typically go on for years throughout the life of an oil field and would cause severe and long-lasting damage to the Arctic Refuge.


Submit your comments online here.

Northern Alaska Environmental Center

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