The Department of Interior on Tuesday issued a call for nominations and comments on potential oil and gas lease sale tracts which BLM delineated across the Arctic National Wildlife Refuge’s coastal plain. This move opens a 30-day comment period and precedes a Notice of Lease Sale.

The above map shows how the BLM Energy and Minerals Branch views the Arctic Refuge coastal plain–a blank assemblage of numbered blocks available to the highest bidder. This incredibly vast expanse of ecologically rich and life-giving land is Iizhik Gwats’an Gwandaii Goodlit to the Gwich’in Nation, or “The Sacred Place Where Life Begins” – the birthing grounds of the Porcupine caribou herd. It is critical habitat where polar bears den and migratory birds nest. It is one of the last remaining areas in Alaska’s Arctic that exists as it has since time immemorial.

Fran Mauer/USFWS

Please join us in submitting comments to the Bureau of Land Management on their Call for Nominations and Comments for the Coastal Plain Alaska Oil and Gas Lease Sale opposing lease sales on the coastal plain. The agency is only accepting hard copies, and comments must be received by December 17, 2020. Please include your name, phone number, address, and email. We will hand deliver all comments submitted to us to ensure they are counted. Please submit your comment one of these ways:

  1. Email your comments to emily@northern.org with the subject line Arctic Refuge Public Comment. We will print and hand-deliver all comments to the BLM office in Anchorage by December 17.
  2. Mail your comments to: State Director, Bureau of Land Management, Alaska State Office, 222 West 7th Avenue, Mailstop 13, Anchorage, AK 99513-7504. Again, all comments must be received by December 17. 

 

Tips for Writing Comments

Your comments should express opposition to leasing all tracts on the coastal plain. Comments will be most effective if they are substantive. Try to focus on fact-based comments rather than emotional appeals. Highlight issues of concern, like the human rights of Arctic Indigenous peoples, insufficient Environmental Impact Statements in the planning phase, climate impacts, and impacts on caribou, polar bears, and migratory birds. Here are a few ideas:

  • The Gwich’in peoples of Alaska and Canada are culturally and spiritually connected to the Porcupine caribou herd, which relies on the Coastal Plain for calving and post-calving habitat. The Gwich’in consider the coastal plain as sacred, and the place where life begins. It is vital to their human rights and food security. 

 

  • Expanding oil and gas development in the Arctic will further exacerbate climate adaptation and mitigation challenges in an Arctic that is warming at twice the rate of the rest of the country. The EIS for oil and gas leasing on the coastal plain downplays unacceptable climate impacts of extraction in the Arctic. 

 

  • An original purpose of the Arctic National Wildlife Refuge as established in ANILCA is to ensure “water quality and necessary water quantity within the refuge” to conserve fish, wildlife and habitats.  The BLM did no new analysis of how much water is actually available on the Coastal Plain in the coastal plain EIS and therefore does an insufficient job of analyzing impact to that water quantity. 

 

  • The coastal plain is habitat for millions of birds which come from every continent, including off the coast of Antarctica, to breed, forage, and molt. BLM is disregarding impacts to birds by planning oil leases in the Arctic Refuge. 

 

 

If you would like to write technical comments for individual tracts of land on the coastal plain, here are maps and resources to use.  This is the map of tracts up for comment.  You may use this worksheet or create your own list. These technical comments will take time for the agency to process and can include your specific knowledge of the coastal plain, or general talking points like the ones below:

 

  • Tract(s) #__ should be excluded from oil leasing, as the coastal plain provides critical habitat for denning polar bears. As sea ice recedes due to warming temperatures, land denning sites in the Arctic Refuge become increasingly important. According to Map 3-37, leasing this tract would have unacceptable impacts on denning polar bears and polar bear critical habitat. (Tracts: all. Map for reference: Polar bear critical habitat and denning sites ) 

 

 

  • Tract(s) #__ should be excluded from oil leasing to preserve critical fish habitat. According to FEIS Map 3-19, this tract includes essential habitat for Arctic Cod. (Tracts: 27, 7, 31, 29, 32. Map for reference: Essential fish habitat)

 

  • Tract(s) #__ should be excluded from oil leasing, as the coastal plain is habitat for millions of birds which come from every continent, including off the coast of Antarctica, to breed, forage, and molt. BLM is disregarding impacts to birds by planning oil leases in the Arctic Refuge. (Tracts: all)

 

  • Tract(s) #__ should not be considered for oil leasing, as it provides important habitat for Snow Geese, seeing more than 21 flocks of Snow Geese over 500 in number between 1982-2004 according to FEIS Map 3-26. (Tracts: 4, 5, 7, 11, 12, 18, 19, 20, 21, 28. Map for reference: Frequency of Occurrence of Snow Geese)

 

  • Tract(s) #__ should be excluded from oil leasing, as an original purpose of the Arctic National Wildlife Refuge as established in ANILCA is to ensure “water quality and necessary water quantity within the refuge” to conserve fish, wildlife and habitats.  The BLM did no new analysis of how much water is actually available on the Coastal Plain in the coastal plain EIS and therefore does an insufficient job of analyzing impact to that water quantity. (Tracts: all)

 

  • Tract(s) #__ should be excluded from oil leasing, as all tracts (over 99% of the coastal plain) are visible from high points within the federally designated Wilderness portion of the refuge. The negative visual impacts on Wilderness recreation in the Arctic Refuge negate the original wilderness and recreation purposes of the Arctic Refuge as established in ANILCA. (Tracts: all)
Northern Alaska Environmental Center

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