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Montage of Wing Point in Bainbridge Island and the Edmonds Ferry.

Jay Inslee: Washington's 1st Congressional District

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Support Preserving Pristine Character of National Petroleum Reserve in Alaska

1 March 2005

U.S. Rep. Jay Inslee and nineteen other Members of Congress sent a letter to Secretary of the Interior Gale Norton expressing concern over an upcoming Bureau of Land Management (BLM) final decision that is anticipated to open up a large portion of the of the pristine National Petroleum Reserve, Alaska (NPR-A) to oil drilling.

Said Inslee, "The administration's plan fails to recognize that this area can both protect critical wildlife and serve as an emergency source of petroleum. The United States does not have enough oil to drill our way out of our dependence on foreign petroleum, regardless of the number of environmentally sensitive areas that the Administration would like to open to drilling. My colleagues and I will work to protect the Reserve's pristine habitat, while advocating for renewable energy technologies that promote clean energy and job growth."

Randy Moorman, Legislative Representative at Earthjustice added, "The Bush Administration says it wants to balance energy development with environmental protection. Yet along the North Slope of Alaska, they have abandoned any semblance of balance, by preparing to sell off every square inch of the western Arctic to the oil and gas industry. They have completely ignored scientists, sportsmen and Native Alaskans by recklessly opening up an area that even [Reagan Secretary of the Interior] James Watt recognized needs protection."

Maynard Axelson, President of the Washington State Brant Foundation (a waterfowl preservation group) commented, "Teshekpuk Lake is one of the last pieces of uncompromised habitat remaining on the entire Pacific Coast and is crucial for birds dispersing to all major U.S. flyways, as well as several other countries. This crown jewel is absolutely irreplaceable for a vast number of avian and animal species."

Background

On January 31st, 2005 the Bush Administration announced a plan by the BLM to drill in the pristine NPR-A. This proposal was even more controversial than a draft plan released in June 2004 because a large portion of the Reserve's Northeast Planning Area will now be offered up for leasing, including the Teshekpuk Lake Special Area, which was closed to oil drilling during the Reagan Administration. This area encompasses one of the most sensitive wetland complexes in the circumpolar Arctic.

Through an executive order enacted in 1923, the role of the NPR-A was established as an emergency oil supply for defense purposes. Through the Naval Petroleum Reserves Production Act of 1976 (NPRPA), however, Congress recognized that the unique cultural, natural, fish and wildlife, scenic and historical values of the Reserve should be protected. BLM's new plan ultimately allows oil leasing in 100 percent of the Teshekpuk Lake area and fails to offer permanent protection for a single acre. In the years since the 1998 oil leasing plan for the Northeast Planning Area, additional information has been made available that requires BLM to be more restrictive and protective in its development planning. In addition to opposition from variety of wildlife and conservation groups, a staggering 218,000 individual public comments have been submitted to BLM in opposition to the plan.

Text of the Letter

March 1, 2005

Secretary Gale A. Norton

U.S. Department of the Interior

1849 C Street, NW

Washington, DC 20240


Dear Secretary Norton:

We are writing to express our deep concern over the Bureau of Land Management's (BLM) Preferred Alternative and analysis for an amended oil and gas leasing plan in the 4.6 million-acre Northeast National Petroleum Reserve-Alaska (NPR-A) as presented in the agency's Final Amended Integrated Activity Plan/ Environmental Impact Statement (IAP/ EIS) released on January 28, 2005.

Congress has made clear that oil activities in the NPR-A need to balanced with the protection of the key biological, subsistence, and scenic resources of the NPR-A. We are especially concerned over the BLM's failure to recommend an oil and gas leasing plan that maintains protection for the areas of critical importance to waterfowl, caribou and other wildlife around Teshekpuk Lake.

Teshekpuk Lake and its many surrounding lakes and wetlands comprise one of the most important and ecologically unique wetland complexes in the entire circumpolar Arctic. This area provides habitat for molting geese from three nations and nesting birds from six continents. Under the BLM's final Preferred Alternative, however, 100 percent of the Teshekpuk Lake area will ultimately be opened to oil and gas leasing. Moreover, the new Preferred Alternative provides even less protection than the plan recommended in the draft EIS, which was released in June 2004 and spurred nearly 215,000 individual public comments, most of which opposed the draft plan's Preferred Alternative.

Oil and gas development poses numerous threats to birds, especially molting geese. The area north and east of Teshekpuk Lake provides the conditions required by molting geese, and it is no accident they gather there by the tens of thousands. Geese seek remote, secure sites for their annual molt, during which they replace old, worn feathers with new ones. Throughout their molting period, geese are flightless and highly vulnerable to predators. Predators are often attracted to oil fields and can then prey on molting geese, as well as on nesting birds and their eggs and young.

As many as 90,000 geese gather each summer to molt north and east of Teshekpuk Lake, including up to one-third of all brant in the Pacific Flyway. There is much concern about declining numbers of Pacific Flyway brant, and this population may not be able to sustain additional stress at such a critical time in its annual cycle. Brant are harvested by subsistence and sport hunters in western Alaska and down the Pacific coast to Mexico. Numbers of greater white-fronted geese molting at Teshekpuk Lake are increasing and range as high as 35,000. These geese are part of the mid-continental population, and are highly prized by sport hunters in the Midwestern and Gulf Coast states and in Mexico.

Through an executive order enacted in 1923, the role of the NPR-A was established as an emergency oil supply for defense purposes. However, through the Naval Petroleum Reserves Production Act of 1976 (NPRPA), Congress also recognized that the unique cultural, natural, fish and wildlife, scenic and historical values of the NPR-A should be protected. While approving oil and gas exploration, the 1976 Act expressly prohibited petroleum production or development leading to production without congressional authorization. Congress further directed the Secretary of Interior to establish the Teshekpuk Lake Special Area, located in the Northeast Planning Area of the NPR-A, and to "assure maximum protection" for its subsistence, recreational, fish, wildlife, historical and scenic values[1].

However, the BLM's final IAP/ EIS for oil and gas development in the Northeast Planning Area of the NPR-A falls dramatically short of fulfilling these conditions by failing to assure even minimal protection for the Teshekpuk Lake Special Area. The Preferred Alternative in the final IAP/ EIS would ultimately open 100 percent of the Teshekpuk Lake area to oil leasing without citing any new scientific reasons for this reversal of a 1998 plan, clearly violating the legislative mandate cited above. Moreover, the new Preferred Alternative is a dramatic contrast to the Preferred Alternative recommended in the draft EIS, which was released in June 2004 and spurred nearly 215,000 individual public comments, most of which opposed the draft plan's Preferred Alternative.

On October 18, 2004 several of us sent you a letter expressing our concerns over the Preferred Alternative in the draft EIS. We are greatly disappointed you did not respond to our letter. The final IAP/EIS not only ignores our concerns and those of the public over the weakening of protections for the Teshekpuk Lake area, but also similar concerns expressed by sportsmen and wildlife professionals in several organizations, including Ducks Unlimited, California Waterfowl Association, Wildlife Management Institute and The Wildlife Society.

The mayor of the North Slope Borough raised similar concerns in a letter to the BLM. "We are not aware of significant new wildlife or subsistence data, or industry technology that has been reported, discussed, and validated since 1998 that would justify opening areas that are now closed to leasing or surface facilities."[2] In response, the BLM has essentially disregarded these concerns and those of the nearly 215,000 individuals who commented on its plan. Nearly all of the public comments favored maintaining full protection for the area around Teshekpuk Lake. It is noteworthy that the U.S. Fish and Wildlife Service (FWS), itself an agency within the Department of Interior, submitted an August 23, 2004, memorandum on the draft EIS stating that, ".the No Action Alternative, would provide the greatest level of protection (and least risk) to wildlife, and is our preferred management approach."

Finally, 200 ornithologists and other wildlife scientists-including 43 Alaskans-submitted a letter on August 23, 2004, arguing that the 213,000-acre no-lease zone, which was part of BLM's Preferred Alternative in its draft EIS, was "too small to encompass the essential habitat used by molting geese, nesting birds, calving caribou and other wildlife." And now, in the final IAP/ EIS, the Preferred Alternative would open for leasing 100 percent of even this small core goose molting habitat.

The final IAP/ EIS also wrongly dismisses cumulative impacts that will result from prolonged oil and gas development in the NPR-A. In a June 2002 report entitled Alaska's North Slope: Requirements for Restoring Lands After Oil Production Ceases (requested by Reps. Gephardt, Rahall and Markey), the General Accounting Office (GAO) indicated that there are already significant liabilities resulting from oil industry activities conducted under federal permits on Alaska's North Slope. In addition, in March 2003, the National Research Council of the National Academies of Science released a report entitled Cumulative Environmental Effects of Oil and Gas Activities on Alaska's North Slope. The blue-ribbon panel that prepared this report specifically cited concerns about the impact of oil and gas development on molting geese and caribou around Teshekpuk Lake in NPR-A.

We urge you to reject the BLM's Preferred Alternative, which fails to provide adequate protection for the most critical parts of the Teshekpuk Lake Special Area, and direct the BLM to consider a more balanced approach to oil and gas leasing in the Northeast Planning Area of the NPR-A. Recognizing that 87 percent of Northeast NPR-A is already open to oil and gas leasing and that the BLM recently opened millions of acres of additional lands in the Northwest Planning Area of the NPR-A, a balanced approach is one that will protect core, un-fragmented blocks of critical waterfowl and caribou habitats, including those around Teshekpuk Lake.

[1] 42 U.S.C. ยงยง 6502-03

[2] Letter dated August 23, 2004, from George N. Ahmaogak, Sr., Mayor, North Slope Borough


Sincerely,

Jay Inslee

Sam Farr

Dennis Moore

Raul Grijalva

Barney Frank

George Miller

Sherrod Brown

Chris Van Hollen

Ed Markey

Jim McDermott

Robert Wexler

Rosa DeLauro

Henry Waxman

Bob Etheridge

Ed Case

Stephanie Tubbs Jones

Betty McCollum

Mike Honda

John Conyers

Barbara Lee