Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. May 2011 

Appendix E 

Application for U.S. Fish & Wildlife Service 

Letter of Authorization 
Revised Outer Continental Shelf Lease Exploration Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. May 2011 

THIS PAGE 

INTENTIONALLY 

LEFT BLANK 

 
Polar Bear, Pacific Walrus, and Grizzly Bear 

Avoidance and Human Encounter/Interaction Plan 

 Exploration Drilling Program Chukchi Sea, Alaska 

May 2011 

Prepared by: 

Shell Gulf of Mexico Inc. 

3601 C Street, Suite 1000 

Anchorage, Alaska 99503 

Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. i May 2011 

Table of Contents 

Page 

ACRONYMS & ABBREVIATIONS ..........................................................................................................iii

1.0 INTRODUCTION ............................................................................................................................ 5

1.1 Background ......................................................................................................................... 5

1.2 Proposed Exploration Plan .................................................................................................. 6

1.3 Ice Management ................................................................................................................ 13

1.4 Oil Spill Response ............................................................................................................. 16

2.0 POLAR BEAR, GRIZZLY BEAR, AND PACIFIC WALRUS, PRESENCE DURING 

PLANNED EXPLORATION DRILLING ACTIVITIES OFFSHORE CHUKCHI SEA ......................... 18

2.1 Polar Bear .......................................................................................................................... 18

2.2 Pacific Walrus ................................................................................................................... 18

2.3 Grizzly Bear ...................................................................................................................... 19

3.0 THE PLAN – SPECIFIC OBJECTIVES AND ACTIONS ........................................................... 19

3.1 Prevent Polar and Grizzly Bear/Human Interactions ........................................................ 20

3.2 Protecting Workers and Bears ........................................................................................... 20

3.3 Protecting Workers and Walrus ........................................................................................ 21

3.4 Protecting Polar Bear and Walrus During Ice Management ............................................. 22

3.5 Protecting Polar Bears and Walrus During an Oil Spill .................................................... 24

4.0 FOOD WASTE MANAGEMENT PLAN ..................................................................................... 25

5.0 SAFETY AND COMMUNICATION ........................................................................................... 26

6.0 TRAINING .................................................................................................................................... 26

6.1 Marine Mammal Observer Training ................................................................................. 26

6.2 Bear Guard Training ......................................................................................................... 27

6.3 Other Training Materials and Meetings ............................................................................ 27

7.0 AT-RISK LOCATIONS AND SITUATIONS .............................................................................. 27

8.0 REPORTING ................................................................................................................................. 28

8.1 Polar Bear Reporting ......................................................................................................... 29

8.2 Grizzly Bear Reporting ..................................................................................................... 30

8.3 Walrus Reporting .............................................................................................................. 30

9.0 INTENTIONAL“TAKE” ACTIONS FOR BEARS ...................................................................... 31

10.0 PLAN OF COOPERATION .......................................................................................................... 32

11.0 REFERENCES ............................................................................................................................... 33

 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. ii May 2011 

Figures 

Figure 1.2-1 Planned EP Exploration Drilling Area ................................................................................ 8 

Figure 1.2-2 Schematic of ZVSP ........................................................................................................... 12 

Figure 1.3-1 Anticipated Locations of Ice Management Vessels in support of Discoverer .................. 15

Tables 

Table 1.2-1 Chukchi Sea Drill Sites - Burger Prospect .......................................................................... 7

Table 1.2-2 Chukchi Sea Exploration Drilling Program – Proposed Vessel List .................................. 9

Table 1.2-3 Chukchi Sea Exploration Drilling Program – Proposed Oil Spill Response Vessel 

List .................................................................................................................................... 10

Table 1.2-4 Chukchi Sea 2012 Exploration Drilling Program – Proposed Aircraft List ..................... 11

Table 1.2-5 Sound Source (Airgun Array) Specifications for ZVSP Surveys in the Chukchi 

Sea in 2012........................................................................................................................ 13

Attachments 

Attachment A Ice Management Plan 

Attachment B Marine Mammal Monitoring and Mitigation Plan (4MP) 

Attachment C Bear Avoidance and Encounter Procedures 

Attachment D Wildlife Notification Flow Chart 

Attachment E Polar Bear Sighting Report 

Attachment F Grizzly Bear Observation Form 

Attachment G Walrus Sighting Report 

Attachment H Plan of Cooperation Addendum 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. iii May 2011 

ACRONYMS & ABBREVIATIONS 

°C Degrees Celsius

4MP Marine Mammal Monitoring and Mitigation Plan 

ACRT Auxiliary Contract Response Team 

ACS Alaska Clean Seas 

ADF&G Alaska Department of Fish and Game 

ADEC Alaska Department of Environmental Conservation 

bbl barrels 

BOEMRE Bureau of Ocean Energy Management, Regulation, and Enforcement 

CFR Code of Federal Regulations 

cm3

 cubic centimeter(s) 

Discoverer Motor Vessel Noble Discoverer

drilling program Chukchi Sea Exploration Drilling Program

EA Environmental Assessment

EC Eurocopter 

EP Exploration Plan 

EPA 

ESA 

U.S. Environmental Protection Agency 

Endangered Species Act 

Fennica Motor Vessel Fennica

FONSI Finding of No Significant Impact 

ft foot/feet 

FR Federal Register 

IMP Ice Management Plan 

in3

 cubic inch(es) 

km kilometer(s) 

LOA Letter of Authorization 

m meter(s) 

m3

 cubic meter(s) 

mi mile(s) 

MMPA Marine Mammal Protection Act 

MMO Marine Mammal Observer 

MMS U.S. Department of the Interior Minerals Management Service 

NMFS National Marine Fisheries Service 

NSSRT North Slope Spill Response Team 

OCS Outer Continental Shelf 

ODPCP Oil Discharge Prevention and Contingency Plan 

OSR Oil Spill Response 

OST Oil Storage Tanker 

OSV offshore supply vessel 

Plan Polar Bear, Pacific Walrus, and Grizzly Bear Avoidance and Human 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. iv May 2011 

Encounter/ Interaction Plan 

POC Plan of Cooperation 

RS/FO Regional Supervisor/Field Operations 

SAR Search and Rescue 

Shell Shell Gulf of Mexico Inc. 

Tor Viking Motor Vessel Tor Viking

U.S. United States 

USFWS U. S. Fish and Wildlife Service 

USGS U.S. Geological Survey 

VRT Village Response Team 

VSI vertical seismic imager

VSP vertical seismic profile 

WCD Worst Case Discharge 

ZVSP zero-offset vertical seismic profile 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 5 May 2011 

1.0 INTRODUCTION 

This Polar Bear, Pacific Walrus, and Grizzly Bear Avoidance and Human Encounter/Interaction 

Plan (Plan) has been developed by Shell Gulf of Mexico Inc. (Shell) in support of its exploration 

drilling program in the Chukchi Sea beginning in the summer of 2012. 

1.1 Background 

The Plan details the policies and procedures adopted by Shell and to be implemented at its 

operations across Alaska’s North Slope and in the Chukchi Sea. The Plan is intended to support 

activities that may encounter polar bears (Ursus maritimus) and Pacific walrus (Odobenus 

rosmarus divergens), both trust species of the U.S. Fish and Wildlife Service (USFWS), as well 

as grizzly bears (Ursus arctos horribilis), which are under the jurisdiction of the Alaska 

Department of Fish and Game (ADF&G). 

Even though the chance of interactions with grizzly bears is extremely remote in this offshore 

exploration drilling program, the Plan includes discussion and guidance for avoiding them. 

The Plan ensures that workers are familiar with the issues and safety precautions associated with 

working in bear country. The goal of this document is to standardize bear interaction and 

avoidance protocol and wildlife reporting efforts for the project. With proper knowledge and 

training, workers will detect the presence of bears and walrus quickly and respond appropriately 

through monitoring, avoidance, and/or, if necessary, active deterrence by USFWS certified bear 

hazers. The awareness and prevention of human/bear and human/walrus interactions will ensure 

the safety of workers as well as wildlife. 

This Plan is intended to fulfill the requirement for a “site specific polar bear awareness and 

interaction plan,” as required by 50 Code of Federal Regulations (CFR) 18.124(c)(3), which is 

part of the requirements for a Letter of Authorization (LOA) for the incidental, non-lethal, 

unintentional take of polar bear and Pacific walrus as specified under 50 CFR 18, Subpart J. 

This Plan also applies to the intentional take of polar bears by hazing pursuant to section 

101(a)(4)(A), 109(h), and 12(e) of the Marine Mammal Protection Act (MMPA). The MMPA 

prohibits, with certain exceptions, the “taking” of marine mammals. “Take” is defined to mean, 

"to harass, hunt, capture, or kill, or attempt to harass, hunt, capture or kill any marine mammal." 

The "taking" of polar bears is allowed for Alaska Native subsistence or to protect human life. 

The MMPA and supporting regulations make provision to "take" marine mammals in the course 

of scientific research and other legitimate work in polar bear habitat. 

On May 15, 2008, the polar bear was listed as a threatened species under the Endangered Species 

Act (ESA). In June 2008, a special rule under authority of section 4(d) of the ESA was adopted 

which states that the regulatory requirements under the ESA are met by following the 

requirements of the MMPA, including obtaining a LOA. The grizzly bear is not protected in 

Alaska under the MMPA or ESA, but is protected by State game laws. 

On October 29, 2009, a federal register notice (74 Federal Register [FR] 56058) was published 

outlining proposed critical habitat for the polar bear. The USFWS published a final critical 

habitat designation December 7, 2010, which became effective January 6, 2011. 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 6 May 2011 

Like polar bears, Pacific walrus are also protected under the MMPA. Also, as of February 10, 

2011 the USFWS published it’s 12-month finding that listing the Pacific walrus as endangered 

or threatened under the ESA is warranted. Though, with publishing of the 12-month petition 

finding for the Pacific walrus, it has been added to the candidate species list. Consistent with 

section 4(b)(3)(C)(iii) of the ESA, USFWS will review the status of the Pacific walrus through 

an annual Candidate Notice of Review. 

1.2 Proposed Exploration Plan 

The locations of lease blocks where the planned exploration drill sites, and locations where 

activities in support of exploration drilling, will occur are found on Figure 1.2-1. Shell plans to 

use one drillship, the Motor Vessel Noble Discoverer (Discoverer), to drill the exploration wells. 

The Discoverer will be accompanied by ice management vessels, an oil spill response (OSR) 

fleet, and other support vessels during the exploration drilling program. 

Exploration Drilling 

Shell submitted its initial Chukchi Sea Exploration Plan (EP) to the former U.S. Department of 

the Interior Minerals Management Service (MMS) (now Bureau of Ocean Energy Management, 

Regulation and Enforcement hereinafter collectively referred to as “BOEMRE”) in May of 2009. 

The Chukchi Sea EP was deemed submitted by BOEMRE on 20 October 2009. BOEMRE 

subsequently prepared a draft Environmental Assessment (EA) wherein it analyzed the potential 

impacts of the proposed exploration drilling program, and it released that draft for public review 

and comment. On 7 December 2009, following the close of public comment, BOEMRE issued a 

final EA and Finding of No Significant Impact (FONSI), and approved Shell’s Chukchi Sea EP. 

In that initial Chukchi Sea EP, Shell identified seven blocks (Posey Area Blocks 6713, 6714, 

6763, 6764, 6912 and Karo Area Blocks 6864 and 7007) of interest in three prospects (Burger, 

Southwest Shoebill, and Crackerjack), that contained five potential drill sites (Burger C, F, J, 

Southwest Shoebill C, and Crackerjack C). The exploration activities contemplated by the initial 

Chukchi Sea EP included the drilling of an exploration well at up to three of the above-reference 

five potential drill sites using the drillship Frontier Discoverer, which is now known as the 

Motor Vessel (M/V) Noble Discoverer (Discoverer) following the acquisition of Frontier by 

Noble Corporation. Shell planned to initiate exploration activities under the Chukchi Sea EP in 

the summer of 2010, but the exploration activities were postponed when BOEMRE suspended all 

exploration activities in the Arctic following the Deepwater Horizon incident in the Gulf of 

Mexico. 

Pursuant to a revised Chukchi Sea EP submitted to BOEMRE in May 2011, which includes a 

complete Environmental Impact Analysis (EIA – Section 16 of the revised Chukchi Sea EP) of 

the revised Chukchi Sea EP, Shell plans to drill exploration wells at several of the same drill sites 

at one of the prospects identified in the initial exploration plan starting in 2012. The revised 

Chukchi Sea EP drill sites are shown in Table 1.2-1. 

As required by 30 Code of Federal Regulations (CFR) 250.212-228, details of the planned 

exploration drilling program are provided in the following sections and accompanying 

attachment material. While Shell has made this submission as a plan revision, it acknowledges 

that, pursuant to 30 CFR 250.285(c), the impacts previously identified and evaluated in Shell’s 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 7 May 2011 

initial Chukchi Sea EP and BOEMRE’s December 2009 Environmental Assessment and Finding 

of No Significant Impact are different than the impacts potentially resulting from the plan 

revision, and that this plan revision is subject to all of the procedures under 30 CFR 250.231 

through 30 CFR 250.235. 

Shell plans to conduct an exploration drilling program on BOEMRE Alaska Outer Continental 

Shelf (OCS) leases at drill sites greater than 64 miles (mi) [103 kilometers (km)] from the 

Chukchi Sea coast starting in the 2012 drilling season (Chukchi Sea Exploration Drilling 

Program, hereinafter, the” exploration drilling program”) (Figure 1.2-1). 

The leases were acquired during the Chukchi Sea Oil and Gas Lease Sales 193 held in February 

2008. During 2012,the initial year of the exploration drilling program, Shell plans to drill up to 

three exploration wells at three drill sites, and potentially a partial well at a fourth drill site in the 

Chukchi Sea at the prospect known as Burger (Table 1.2-1). All wells are planned to be 

vertical. 

Table 1.2-1 Chukchi Sea Drill Sites - Burger Prospect

Prospect Well Area Block Lease 

Number

1Coordinates (m) 

 X Y 

Latitude Longitude 

Burger A Posey 6764 OCS-Y-2280 563945.26 7912759.34 N71° 18' 30.92" W163° 12' 43.17" 

Burger F Posey 6714 OCS-Y-2267 564063.30 7915956.94 N71° 20' 13.96" W163° 12' 21.75" 

Burger J Posey 6912 OCS-Y-2321 555036.01 7897424.42 N71° 10' 24.03" W163° 28' 18.52" 

Burger R Posey 6812 OCS-Y-2294 553365.47 7907998.91 N71° 16' 06.57" W163° 30' 39.44" 

Burger S Posey 6762 OCS-Y-2278 554390.64 7914198.48 N71° 19' 25.79" W163° 28' 40.84" 

Burger V Posey 6915 OCS-Y-2324 569401.40 7898124.84 N71° 10' 33.39" W163° 04' 21.23" 

 

This plan also contemplates a situation where a well that is started must be temporarily 

suspended due to ice, weather, or other conditions, and finished at a later date. Any well on 

which exploration drilling is suspended will be secured in compliance with BOEMRE 

regulations and with the approval of the Regional Supervisor/Field Operations (RS/FO), whether 

it is permanently abandoned (30 CFR 250.1710 through 1717) or temporarily abandoned (30 

CFR 250.1721-1723). 

Shell may conduct a geophysical survey referred to as a zero-offset vertical seismic profile 

(ZVSP) at each drill site where a well is drilled. Once the objective intervals are fully evaluated, 

each exploration well will be plugged and abandoned in compliance with BOEMRE regulation. 

Drilling Vessel 

The ice strengthened drillship Discoverer will be used to drill the wells. While on location at the 

drill sites, the Discoverer will be affixed to the seafloor using eight, 7-ton Stevpris anchors 

arranged in a radial array. . 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 8 May 2011 Figure 1.2-1 Planned EP Exploration Drilling Area 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 9 May 2011 

Support Vessels 

During this exploration drilling program, the Discoverer will be attended by a minimum of ten 

vessels used for ice management, anchor handling, OSR, refueling, resupply, and servicing of the 

exploration drilling operations (Tables 1.2-2 and 1.2-3). In Table 1.2-3, the barges include an 

accompanying vessel(s) that together with the barge are counted as one vessel attending the 

Discoverer. 

The M/V Fennica (Fennica), or a similar vessel, will serve as the ice management vessel in 

support of the Discoverer. This vessel will enter and exit the Chukchi Sea with the Discoverer 

and will remain at a location approximately 25 mi (40 km) upwind and upcurrent of the drillship 

when not in use. Any ice management would be expected to occur at a distance of 3-12 mi 

(5-19 km) upwind/upcurrent of the drillship. The M/V Tor Viking (Tor Viking) or a similar 

vessel will serve as the primary anchor handling vessel in support of the Discoverer. The vessel 

will enter and exit the Chukchi Sea with the Discoverer and will remain at a location 

approximately 25 mi (40 km) upwind and upcurrent of the drillship when not in use. Any ice 

management would be expected to occur within 0.6-6.0 mi (1.0-9.6 km) upwind from the 

Discoverer. 

The planned exploration drilling operations will require two offshore supply vessels (OSVs) to 

resupply the Discoverer with drilling materials and supplies from facilities in Dutch Harbor and 

fuel. The vessels may be vessels such as the Harvey Explorer, and the C-Leader, or similar 

offshore supply boats. 

Table 1.2-2 Chukchi Sea Exploration Drilling Program – Proposed Vessel List 

Specification Ice Management Vessel 1 Anchor Handler 2 OSV 3 OSV 4

Length 380 ft 

116 m 

275 ft 

83.7 m 

280 ft 

85.3 m 

280 ft 

85.3 m 

Width 85 ft 

26 m 

59 ft 

18.0 m 

60 ft 

18.3 m 

60 ft 

18.3 m 

Draft 27 ft 

8.4 m 

20 ft 

6.0 m 

15.9 ft 

4.9 m 

19 ft 

5.8 m 

Accommodations 82 berths 23 berths 37 berths 29 berths

Maximum Speed 16 knots 

30 km/hr 

16 knots 

30 km/hr 

13 knots 

24 km/hr 

13 knots 

24 km/hr 

Fuel Storage 11,070 bbl 

1,760 m3 7,484 bbl 1,190 m3 6,233 bbl 991 m3 7,217 bbl 1,147 m3

1

 Based on Fennica, or similar vessel 2

 Based on Tor Viking, or similar vessel 3

 Based on the Harvey Spirit, or similar vessel 4

 Based on C-Leader, or similar vessel 

Oil Spill Response Vessels 

The OSR vessels supporting the exploration drilling program include a dedicated OSR barge and 

an OSR vessel, both of which have associated smaller workboats, and an oil storage tanker 

(OST). The OSR barge and the OST have not been contracted, but specifications for these 

vessels, based on the types of vessels that might be contracted, are provided below in Table 

1.2-3. An OSR barge, or similar vessel and a tug, will be staged in the vicinity of the drillship. 

It will carry response equipment including a 47-ft (14-m) skimming vessels, three 34-ft (10-m) 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 10 May 2011 

workboats, four mini-barges, and boom and duplex skimming units for response and recovery. 

The workboats will also be used to shuttle OSR crews between a shorebase in Wainwright and 

the OSR barge for OSR training and drills and resupply as required. Together with the OSR 

vessel, this OSR barge will have sufficient containment, recovery, and storage capacity for the 

initial operational period in the event of a spill. 

The containment barge will be tended by a tug and possibly an anchor handler (Table 1.2-3). 

The tug tending the containment barge will either drift or motor under “slow-steam” movement 

with the barge. An anchor handler is included in this plan only as an additional tending option 

for the containment barge, if Shell deems it necessary in advance of the season to anchor the 

containment barge. Shell does not assume the containment barge will be anchored or that the 

anchor handler is necessary, but includes the option of anchoring the barge and it being also 

tended by an anchor handler in case that option is chosen. 

An OST such as the Mikhail Ulyanov or a vessel with similar liquid storage capacity will be 

staged in the vicinity of the Chukchi Sea drill sites so that it will arrive at a recovery site, if 

needed, within 24 hours of departure from the staging location. The purpose of the OST would 

be to provide a place to store large volumes of recovered crude oil, emulsion, and free water in 

the unlikely event of a spill and OSR operations. The OST will possess a minimum liquid 

storage capacity of 513,000 bbl. An OSR vessel such as the Nanuq will be staged in the vicinity 

of the drillship when the Discoverer is drilling in liquid hydrocarbon bearing zones to 

immediately respond to a spill and provide containment, recovery, and storage for the initial 

operational period following a spill event. In the unlikely event of a spill, the Tor Viking can 

also be used to lighter recovered oil, emulsions and free water to the Mikhail Ulyanov. The 

Nanuq or similar vessel will be paired with an OST such as the Mikhail Ulyanov and used to 

assist refueling the Discoverer and support vessels, if necessary. 

Table 1.2-3 Chukchi Sea Exploration Drilling Program – Proposed Oil Spill Response Vessel List 

Specification OSR Vessel 1,2 OSR Barge 1,3

OST 1,4 Containment Barge 1,5

Barge Tug Barge Tug Anchor Handler

Length 301 ft 

91.9 m 

205 ft 

62.5 m 

90 ft 

27.4 m 

853 ft 

260 m 

400 ft 136 ft 

36.5 m 

275 ft 

83.7 m 

Width 60 ft 

18.3 m 

90 ft 

27.4 m 

32 ft 

9.8 m 

112 ft 

34 m 

100 ft 36 ft 

11.1 m 

59 ft 

18.0 m 

Fuel Storage 6,867 bbl 

(1,092 m3

) 

390 bbl 

(62 m3) 

1,786 bbl 

(284 m3) 

221,408 bbl 

(35,200 m3) -- 

3,690 

bbl 

(587

7,484 bbl 

(1190 m3) 

Liquid Storage 12,690 bbl 

(2,017 m3

) 

76,900 bbl 

(12,226 m3) -- 

543,000 bbl 

(86,328 m3) -- -- -- 

Accommodations 

(persons) 

41 -- 6 25 -- 10 23 

Maximum Speed 16 knots -- 5 knots 16 knots -- 10 knots 16 knots (30 

km/hr) 

Workboats (3) 34 ft 

work boats 

(1) skim boat

47 ft (14 m) 

(3) work boats 34 

ft (10 m) 

(4) mini-barges 

-- -- -- -- -- 

1

 Or similar vessel 

2

 Based on the Nanuq 3

 Based on the Crowley 450 series barges 

4

 Based on the Mikhail Ulyanov, may be a similar vessel with a minimum storage capacity of > 513,000 bbl 5

 Based on a standard deck barge, Crowley Invader class ocean going tug, and a Tor Viking-style anchor handler 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 11 May 2011 

Aircraft

Offshore operations will be serviced by helicopters operated out of onshore support base 

locations. The helicopters are not yet contracted. A Sikorsky S-92 or Eurocopter EC225 capable 

of transporting 10 to 12 persons will be used to transport crews between the onshore support base 

and the drillship. It is expected that on average, 12 round trip flights per week will be necessary 

to transport supplies and rotate crews. The helicopters will also be used to haul small amounts of 

food, materials, equipment, and waste between vessels and the shorebase. The helicopter will be 

housed at facilities at the Barrow airport. Shell will have a second helicopter for Search and 

Rescue (SAR). The SAR helicopter is expected to be a Sikorsky S-61 or S-92, Eurocopter 

EC225 or similar model. This aircraft will stay grounded at the Barrow shorebase location 

except during training drills, emergencies, and other non-routine events. 

A fixed wing propeller or turboprop aircraft, such as Saab 340-B 30-seat, Beechcraft 1900, or 

deHavilland Dash8 will be used to routinely transport crews, materials, and equipment between 

the shorebase and hub airports such as Barrow or Fairbanks. A fixed wing aircraft, deHavilland 

Twin Otter (DHC-6) will be used for marine mammal observer (MMO) flights. 

Table 1.2-4 Chukchi Sea 2012 Exploration Drilling Program – Proposed Aircraft List 

Aircraft Flight Frequency 

Sikorsky S-92 or Eurocopter EC225 - crew 

rotation 

Approximately 12 round trips/week between land and offshore 

vessels throughout the 2012 drilling season 

Sikorsky S-61, S-92 or Eurocopter EC225 

helicopter – SAR 

Trips made only in emergency; one training flight/month 

Saab 340-B or Beechcraft 1900 or deHavilland 

Dash8 (Only 1) – onshore crew/supply trips 

Infrequent, onshore trips from shorebase to hub airports in Barrow 

and Fairbanks 

deHavilland Twin Otter (DHC-6) – 4MP Twice weekly during drilling season 

The ice strengthened drillship Discoverer will move through the Bering Strait and into the 

Chukchi Sea on or after 1 July, and then onto the Burger Prospect as soon as ice and weather 

conditions allow. Exploration drilling activities may continue through 31 October. The 

drillship and support vessels will exit the Chukchi Sea at the end of the drilling season. 

Barrow and/or Wainwright have been selected as the temporary shorebase locations for the 

Chukchi Sea exploration drilling program. However, no exploration drilling program activities 

are planned to occur onshore. Nearshore or onshore incursions by exploration drilling program 

support activities (e.g., OSR training exercises) will occur at the shorebase in Wainwright, on a 

limited basis. A Barrow shorebase will be used as the primary airbase for crew changes and 

SAR between land and the drillship and for temporary housing for these crewmembers. It is 

estimated that there will be up to 12 round trips per week with OSR work boats between the 

Wainwright shorebase and offshore OSR vessels for training and drills. This interaction plan 

therefore includes interaction and awareness guidance for Program workers regarding grizzly 

bears, and polar bears that may be present in the nearshore or land. Interactions with grizzly 

bears are highly unlikely offshore, and at the shorebases as well. Pacific walrus are present in 

offshore and nearshore waters of the Chukchi Sea including the area of Shell’s prospects, and 

observations of walrus are likely to occur during the exploration drilling program. All three 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 12 May 2011 

species are addressed in this plan, although interactions and encounters grizzly bears are 

considered unlikely for this project. 

Vertical Seismic Profile 

Shell may conduct a geophysical survey 

referred to as a vertical seismic profile 

or VSP at each drill site where a well is 

drilled in 2012. During VSP surveys, an 

airgun array is deployed at a location 

near or adjacent to the drillship, while 

receivers are placed (temporarily 

anchored) in the wellbore. The sound 

source (airgun array) is fired repeatedly, 

and the reflected sonic waves are 

recorded by receivers (geophones) 

located in the wellbore. The geophones, 

typically a string, are then raised up to 

the next interval in the wellbore and the 

process is repeated until the entire 

wellbore has been surveyed. The purpose of the VSP is to gather geophysical information at 

various depths, which can then be used to tie-in or ground-truth geophysical information from 

the previous seismic surveys with geological data collected within the wellbore.

Shell will be conducting a particular form of VSP referred to as a ZVSP, in which the sound 

source is maintained at a constant location near the wellbore (Figure 1.2-2). A typical sound 

source that likely would be used by Shell in 2012 is the ITAGA eight-airgun array, which 

consists of four 150 cubic inches (in.3) (2,458 cubic centimeters [cm3]) airguns and four 40 in.3

(655 cm3) airguns. These airguns can be activated in any 

combination and Shell would utilize the minimum airgun 

volume required to obtain an acceptable signal. Current 

specifications of the array are provided in Table 1.2-5. The 

airgun array is depicted within its frame or sled, which is 

approximately 6 ft x 5 ft x 10 ft (see photograph below). 

Typical receivers would consist of a Schlumberger wireline 

four level vertical seismic imager (VSI) tool, which has four 

receivers 50-ft (15.2-m) apart. 

Photograph of the ITAGA 8-airgun Array in Sled

Figure 1.2-2 Schematic of ZVSP
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 13 May 2011 

Table 1.2-5 Sound Source (Airgun Array) Specifications for ZVSP Surveys in the Chukchi Sea in 2012 

Source 

Type No. 

Sources 

Maximum 

Total 

Chamber 

Size 

Pressure Source Depth Calibrated PeakPeak Vertical 

Amplitude 

Zero-Peak Sound 

Pressure Level 

SLB, 

ITAGA 

Sleeve 

Array 

8 airguns 

4 X 150 in.3

4 X 40 in.3

760 in.3

12,454 cm3 2,000 psi 140 bar 

3.0 m / 9.8 ft 

5.0 m / 16.4 ft 

16 bar @1 m 

23 bar @1 m 

238 dB re1μPa @1 m 

241 dB re1μPa @1 m 

A ZVSP survey is normally conducted at each well after total depth is reached but may be 

conducted at a shallower depth. For each survey, Shell would deploy the sound source (airgun 

array) over the side of the Discoverer with a crane (sound source will be 50-200 ft (15-60 m) 

from the wellhead depending on crane location), to a depth of approximately 10-23 ft (3-7 m) 

below the water surface. The VSI with its four receivers will be temporarily anchored in the 

wellbore at depth. The sound source will be pressured up to 2,000 psi, and activated 5-7 times at 

approximately 20-second intervals. The VSI will then be moved to the next interval of the 

wellbore and re-anchored, after which the airgun array will again be activated 5 to 7 times. This 

process will be repeated until the entire wellbore is surveyed in this manner. The interval

between anchor points for the VSI usually is between 200-300 ft (60-91 m). A normal ZVSP 

survey is conducted over a period of about 10-14 hours depending on the depth of the well and 

the number of anchoring points. 

1.3 Ice Management 

Polar bears and walrus are strongly associated with sea ice so that ice management has the 

potential to affect individuals of these species. Some ice management may be required for 

Shell’s 2012 exploration drilling program. Shell has included two ice management vessels in the 

fleet supporting the drillship and has prepared and will implement an Ice Management Plan 

(IMP) (see Attachment A) for this contingency. The IMP includes ice detection and monitoring, 

identifies ice alert levels and actions, defines and assigns personnel and responsibilities, and 

describes well suspension and re-entry procedures. 

Shell’s IMP relies heavily on the observations and experience of its Ice Specialists and Ice 

Advisors, a group of arctic-seasoned mariners whose sole duty is to provide critical information 

and advise drilling vessel supervisors and the drilling vessel master about any and all ice-related 

threats. These observers and advisors will be stationed on the drillship, the ice management 

vessel and the anchor handler. Marine mammal monitoring by MMOs is also ongoing while ice 

management vessel movements and actions are underway with regard to ice-related threats. 

MMOs, operating under the guidance of the marine mammal monitoring and mitigation plan 

(4MP) (see Attachment B) for this exploration drilling program will advise ice management 

specialists and advisors on the necessary mitigation measures designed by the agencies to assist 

avoidance of incidental take of marine mammals, notably polar bears and Pacific walrus, while 

ice is being managed by vessels. Ice and weather forecasting is provided by Shell’s Ice and 

Weather Advisory Center. This center is continuously manned by experienced personnel who 

rely on number of data sources for ice forecasting and tracking including: 

• Radarsat and Envisat data – satellites with Synthetic Aperture Radar providing allweather imagery of ice conditions with very high resolution; 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. 14 May 2011 

• Moderate Resolution Imaging Spectroradiometer – a satellite providing lower resolution 

visual and near infrared imagery; 

• Aerial reconnaissance – provided by specially deployed fixed wing or rotary wing aircraft 

for confirmation of ice conditions and position; 

• Reports from Ice Specialists on the ice management vessel and anchor handler and from 

the Ice Observer on the drillship; 

• Incidental ice data provided by commercial ships transiting the area; and 

• Information from the National Oceanographic and Atmospheric Administration ice 

centers and the University of Colorado 

General ice management practices are summarized below. Salient aspects include: 

• Ice management around the Discoverer will involve redirecting, rather than breaking, ice 

floes while the floes are well away from the drill sites; and 

• To minimize impacts on marine mammals, vessels that can safely travel outside of the 

polynya zone will do so, unless it is necessary to break ice (as opposed to managing ice 

by pushing it out of the way), or if sea state conditions require an alternative route 

Shell’s ice management fleet will consist of two vessels: an ice management vessel (the Fennica 

or similar) and an anchor handler/icebreaker (the Tor Viking or similar). This fleet will manage 

the ice by deflecting any ice floes that could affect the Discoverer when it is drilling and would 

also handle the Discoverer’s anchors during connection to, and separation from the seafloor. 

Drift ice will be actively managed by ice management vessels, consisting of an ice management 

vessel and an anchor handling vessel. Ice management for safe operation of Shell’s planned 

exploration drilling program will occur far out in the OCS, remote from the vicinities of any 

routine marine vessel traffic in the Chukchi Sea thereby resulting in no threat to public safety or 

services that occurs near to shore. Shell vessels will also communicate movements and activities 

through Communications and Call Centers on the North Slope. Management of ice by ice 

management vessels will occur during a drilling season predominated by open water and thus 

will not contribute to ice hazards, such as ridging, override, or pileup in an offshore or nearshore 

environment. 

The ice management/anchor handling vessels would manage any ice floes upwind of the 

Discoverer by deflecting those that could affect the Discoverer when it is on location conducting 

exploration drilling operations. The ice management/anchor handling vessels would also 

manage the Discoverer’s anchors during connection to and separation from the seafloor. The ice 

floe frequency and intensity are unpredictable and could range from no ice to ice densities that 

exceed ice management capabilities, in which case exploration drilling operations would be 

stopped, the well secured properly and the Discoverer disconnected from its anchors and moved 

off site. Ice management activities may be necessary in early July and towards the end of 

operations in late October, but data regarding historic ice patterns in the Burger area indicate that 

it will not be required throughout the planned exploration drilling seasons. When ice is present 

at the drill site, ice disturbance will be limited to the minimum needed to allow drilling to 

continue. First-year ice will be the type most likely to be encountered. The ice management 
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Shell Gulf of Mexico Inc. 15 May 2011 

vessels will be tasked with managing the ice so that it will flow easily around and past the 

Discoverer without building up in front of it. This type of ice is managed by the ice management 

vessel continually moving back and forth across the drift line, directly updrift of the Discoverer 

and making turns at both ends. During ice management, the vessel’s propeller is rotating at 

approximately 15-20 percent of the vessel’s propeller rotation capacity. Ice management occurs 

with slow movements of the vessel using lower power and therefore slower propeller rotation 

speed (i.e., lower cavitation), allowing for fewer repositions of the vessel, thereby reducing 

cavitation effects in the water. Occasionally, there may be multi-year ice ridges that would be 

managed at a much slower speed than that used to manage first-year ice. Shell does not intend to 

break ice with the ice management vessels but, rather push it out of the area as described here. 

Ice breaking could be conducted if the ice poses an immediate safety hazard at the drill sites, but 

is far from preferred as indicated in the IMP (see Attachment A). 

The primary driver of the ice floe is the wind, so the ice management vessels will be typically 

upwind of the Discoverer when managing ice. The ice management vessels will generally 

remain outside the immediate drill site area, the Fennica and Tor Viking will generally occupy a 

40o

 arc up to 3.1 mi (5 km) upwind originating at the Discoverer (Figure 1.3-1). It is anticipated 

that the ice management vessels will be managing ice for up to 38 percent of the time when 

within 25 mi (40 km) of the Discoverer. The actual distances (distances between vessels, and 

width of the swath in which ice management occurs) will be determined by the ice floe speed, 

size, thickness, and character, and wind forecast. 

Figure 1.3-1 Anticipated Locations of Ice Management Vessels in support of Discoverer
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Shell Gulf of Mexico Inc. 16 May 2011 

Ice may also build up at the bow of the Discoverer. In these situations the Tor Viking would 

periodically pass close to the Discoverer bow and dislodge the ice with its propeller wash. 

During these “bow washing” events, which are expected to last no more than one hour, the Tor

Viking would operate at low power, and operate from either side of the bow (rather than in front 

of the bow). 

Occasionally, there may be multi-year ice ridges that would be managed at a much slower speed 

than that used to manage first-year ice. Shell doesn’t plan on breaking ice with the ice 

management vessels but, rather, intends to push it out of the area. Ice breaking would be 

conducted; however, if the ice poses an immediate safety hazard at the drill sites. Shell will stop 

operations and move off site if ice were to become so prevalent in the drilling area that it is 

difficult to safely continue operations. 

1.4 Oil Spill Response 

Shell is committed to conducting safe and environmentally responsible operations in the Chukchi 

Sea. To achieve this goal, oil spill prevention is a primary priority in all aspects of operations. 

Shell’s Chukchi Sea Regional Exploration Program Oil Discharge Prevention and Contingency 

Plan (ODPCP) emphasizes the prevention of oil pollution by employing the best control 

mechanisms for blowout prevention, fuel transfer operations, as well as implementing mandatory 

prevention training programs for field operating personnel. Prevention training will include 

strict procedures and management practices to eliminate spills in all aspects of operations. All 

project personnel, including employees and contractors, involved in oil spill contingency 

prevention and response would receive prevention and response training as described in the 

ODPCP. Training drills also would be conducted periodically to familiarize personnel with onsite equipment, proper deployment techniques, and maintenance procedures. 

The likelihood of a large oil spill event is very low. Shell has designed a response program 

based upon a regional capability of responding to a range of spill volumes, from small 

operational spills up to and including the Worst Case Discharge (WCD) from an exploration well 

blowout. Shell’s program is developed to fully satisfy the response planning requirements of the 

State of Alaska and federal oil spill planning regulations. The ODPCP presents specific 

information on the response program that includes a description of personnel and equipment 

mobilization, the incident management team organization, and the strategies and tactics used to 

implement effective and sustained spill containment and recovery operations. 

A dedicated OSR vessel possessing sufficient onboard storage capacity to provide containment, 

recovery, and storage for the initial 24-hour operational period will be staged in the vicinity of 

the drillship when drilling into potential liquid hydrocarbon bearing zones. An Arctic OST also 

will be staged so that it will arrive at the recovery site within 24 hours of departure from its 

staging location. The OST will possess a minimum liquid storage capacity of 513,000 bbl 

(81,560 m3

), sufficient capacity to store all recovered liquids (oil and emulsified oil/water) from 

a 30-day blowout. 

An OSR barge with skimming capability, and an associated tug, will be located in the nearshore 

zone and will possess capacity to mobilize prior to earliest projected time oil could arrive in the 

Chukchi nearshore zone. The OSR barge possess storage capacity of 76,900 bbl (212,226 m3

) 
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Shell Gulf of Mexico Inc. 17 May 2011 

for recovered liquids. It will also carry response equipment, including a 47-ft (14-m) skimming 

vessel, 34-ft (10-m) workboats, mini-barges, boom and duplex skimming units for nearshore 

recovery and possibly support nearshore protection. The OSR barge will carry designated 

response personnel and will mobilize to recovery areas, deploy equipment and begin operations. 

Alaska Clean Seas (ACS) is Shell’s primary response action contractor for the Chukchi Sea spill 

response program. ACS would lead the containment, control, and recovery efforts in the 

offshore, nearshore, and shoreline environments. ACS’s response personnel and oil spill 

response equipment would be available while critical exploration drilling operations into 

hydrocarbon bearing zones are underway providing spill containment and response capability in 

the unlikely event of an actual oil spill incident. Additionally, ACS provides program oversight, 

spill management team support, response training, and additional responders through Auxiliary 

Contract Response Teams (ACRT), North Slope Spill Response Team (NSSRT) and Village 

Response Teams (VRTs). 

Shell provides dedicated response vessels and equipment for the onshore, nearshore and offshore 

operations. Response activities will be conducted using Shell or ACS tactics as defined in 

Shell’s Beaufort and Chukchi Seas Regional Tactics Manual and/or ACS’s Technical Manual, or 

otherwise as defined in the ODPCP. The protection of wildlife, including polar bears and 

walrus, is addressed in Section 1.6.11 and Appendix E of the ODPCP, and in Tactics W-1 

through W-6 in Volume 1 of the ACS Technical Manual. The primary objective is to protect 

wildlife by preventing birds and mammals from entering spill or containment areas. 

Containment areas will be monitored until USFWS and/or ADF&G determine that monitoring is 

no longer required. In general, wildlife protection strategies include, but are not limited to: 

• Containment and controls to limit the spread of oil, and the area influenced by the spill 

and response options 

• The drillship has marine mammal observers (MMOs) aboard at all times 

• Hazing of birds and mammals 

• Capture and relocation of wildlife in direct threat 

• Aircraft monitoring 

Refer to the following documents (not attached) for additional information: 

• Chukchi Sea Regional ODPCP Appendix E - Wildlife Capture, Treatment and Release 

Programs, Chukchi Sea Oil Spill Response Planning 

• ACS Tactics Manual – Sections W1 through W6 

• DRAFT “Oil Spill Response Plan for Polar Bears in Alaska”, USFWS Marine Mammals 

Management, June 2010 

In the event of an accidental release that may impact shoreline resources additional certified bear 

guards and security staff would be deployed to protect workers and polar bears. Hazing 

equipment will be stored at the Deadhorse warehouse and office building. USFWS staff may 

also be deployed to provide additional oversight and consultation in the event of a major 
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response. Section 3.5 of this plan outlines an adaptive management approach between Shell and 

the USFWS to protect polar bears and walrus in the unlikely event of an oil spill. 

2.0 POLAR BEAR, GRIZZLY BEAR, AND PACIFIC WALRUS, 

PRESENCE DURING PLANNED EXPLORATION 

DRILLING ACTIVITIES OFFSHORE CHUKCHI SEA 

2.1 Polar Bear 

Polar bears are widely distributed at low densities throughout the Arctic. About 2,000 polar 

bears can be found in the Chukchi-Bering Sea stock which inhabits an area as far west as the 

extreme eastern portion of the Eastern Siberian Sea, as far east as Point Barrow, and as far south 

as the Bering Sea. A small portion of the Southern Beaufort Sea stock of polar bears also utilizes 

the Chukchi Sea, primarily during the ice-covered season. 

Polar bears spend most of their time during summer on the drifting pack ice (ADF&G 2008a). 

Polar bears typically remain widely distributed in their range, as they are predominantly solitary 

animals. Polar bears in the Chukchi Sea spend most of their time near pack and annual ice over 

shallow, productive waters where their predominant prey of ice seals exist. Predominant polar 

bear distribution in the Chukchi Sea retreats north in the spring/summer with the retreating ice 

pack, then returns south in the fall as the ice pack again extends south. In the area of Shell’s 

planned exploration drilling activities of the Chukchi Sea, polar bears are more abundant in May 

and June, then again in late October and November, but may be found in the area of Shell’s 

prospects at any time throughout the drilling season. Polar bears were encountered near Shell’s 

prospects during previous drilling efforts in 1989-1991, and a small number were observed 

during recent Shell baseline surveys conducted in the prospects in August and September of 

2008. 

Shell’s exploration drilling program activities will begin approximately 4 July and will end on or 

before 31 October. There will likely be some sightings of polar bears during the exploration 

drilling program, with the number of bears depending on the amount of ice in the area. 

Nearshore sightings or encounters only are envisioned if Shell’s marine vessels traveling to a 

shorebase observed such a bear. Bears have been known to venture inland, but this is not 

common. When polar bears emerge from dens with their cubs in the spring they start traveling 

on drifting sea ice and forage for food. Extra care is necessary at these times to properly store 

and dispose of food waste to prevent polar bear attraction and their entry into work areas. Polar 

bears will generally avoid human activities if they are not attracted by food and food wastes. 

U.S. Geologic Service (USGS) data document polar bear sightings and den locations (Fischbach 

et al. 2007). Polar bears typically exit their dens in March or April; therefore there would be no 

active dens during the exploration drilling program. 

2.2 Pacific Walrus 

A single stock of Pacific walrus inhabits the shallow continental shelf waters of the Bering and 

Chukchi seas. The distribution of walrus varies seasonally from the winter concentrations in the 

Bering Sea, to open leads, polynyas, on pack ice, and island or shoreline haul outs. Most Pacific 
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Shell Gulf of Mexico Inc. 19 May 2011 

walrus migrate northward following the retreating ice pack during spring and return south during 

the fall. Migrations are directly related to the seasonal advance and retreat of the sea ice 

(ADF&G 2008b). During the summer months, Pacific walrus are widely distributed across the 

shallow continental shelf of the Chukchi Sea with the most significant concentrations in the ice 

pack within 62 mi (100 km) of the leading edge of the ice pack. If pack ice is not suitable, 

walrus haul out on land, but usually remain near their prey base. There are haul-outs along the 

eastern Chukchi shoreline at Cape Thompson, Cape Lisburne, and Icy Cape. Pacific walrus can 

also be expected in shallow waters near the coast or on ice closer to land. 

USFWS surveys have estimated up to 101,213 walrus on the Chukchi Sea pack ice in September. 

Walrus distributions in the Chukchi Sea are highly dependent on the distribution and extent of 

seasonal pack ice. Walrus were observed in the area of the drillship and support vessels in 

previous exploration drilling efforts in 1989-1991, and some were observed in the vicinity of 

Shell’s prospects during baseline surveys conducted July-October of 2008 and 2009. When 

Shell’s exploration drilling program could be expected to be on location in the Chukchi, most 

walrus are assumed to be within the pack ice north of the prospects. The number of walrus that 

will be encountered during the planned exploration drilling program will depend on the amount 

of ice in the area. 

2.3 Grizzly Bear 

Grizzly bears are present on the North Slope during the summer months and may be present 

along the shoreline where they forage for food, taking advantage of whale or seal carcasses or 

eating human refuse. Given that the vast majority of the exploration drilling program activities 

are over 64 mi (103 km) offshore, and the habitat of grizzly bear is onshore, it is extremely 

unlikely that interactions with grizzly bears will happen during drilling activities with the 

possible exceptions at the shorebase(s). 

3.0 THE PLAN – SPECIFIC OBJECTIVES AND ACTIONS 

Because exploration drilling activities and/or support activities will be occurring in polar bear 

habitat and in areas where Pacific walrus and grizzly bear may occasionally be found, complete 

avoidance of these animals cannot be ensured. However, precautions detailed in this document 

can reduce the chances of human encounters and problems with bears and walrus. 

Objectives of the Plan are to: 

• prevent (avoid) bear/human and walrus/human encounters and interactions; 

• educate workers about the controls used to prevent encounters and interactions; 

• protect workers, bears and walrus during drilling activities, ice management and in the 

unlikely event of an oil spill; and 

• implement reporting and observation procedures. 

During the duration of the exploration drilling activities, Shell will be aware of, or have 

established, a 24 hour direct connection (duty line) to personnel from the USFWS.
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Shell Gulf of Mexico Inc. 20 May 2011 

3.1 Prevent Polar and Grizzly Bear/Human Interactions 

There is always the potential for bear encounters during field activities even when all precautions 

are taken to avoid and eliminate attractants. Early detection of bears in the vicinity of operations 

is an essential element to prevent bear/human encounters. Bear avoidance and encounter 

procedures are presented in Attachment C. Workers will regularly and frequently observe their 

surroundings to detect bears in project areas. MMOs are the most likely personnel to notice 

bears or walrus because their job description requires them to look for and identify marine 

mammals (Attachment B) near project activities. They will be the primary support for project 

activities with the potential to encounter bears. 

In contact situations, the main concern is to maintain the safety of personnel. The goal is to 

avoid and minimize potential conflict and bear/human interactions. 

Actions to take if bears are in the area: 

• If a bear is observed, alert all on-site personnel so work activities can be altered or 

stopped to avoid interactions. Bear sightings will be reported to the designated 

representative. 

• Depending on the distance between the bear and the activities, retreating to the safety of 

vessels, emergency shelter, or buildings or vehicles if an encounter occurs in developed 

onshore areas may be necessary. 

• Personnel should give bears plenty of room and should not approach or crowd bears. 

Every bear has “personal space” – the distance in which they feel threatened. The greater 

the distance between the worker and the bear, the better for conflict avoidance. 

• Personnel are forbidden from feeding bears or any other wildlife. 

3.2 Protecting Workers and Bears 

Worker safety is a priority. The following procedures will be implemented to ensure worker 

awareness and knowledge about their own safety concerning bears. A copy of the Bear 

Avoidance and Encounter Procedures are provided as Attachment C. 

• To avoid surprise encounters, personnel exiting a vessel or other facility will check 

behind doors, blind spots, and access areas prior to exiting to avoid a surprise encounter. 

• Polar bears traverse along the barrier island corridor throughout the year. During summer 

months, increased numbers are anticipated in this area, particularly during the months of 

August and September. 

• Personnel will be made aware that bears will hide behind structures, and to be conscience 

of this. 

• Areas will be illuminated during hours of darkness, when workers are present. 

• Periodic safety sessions will be conducted to address and elevate awareness of bear 

avoidance techniques and activities. 
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• Outdoor work crews will survey the surrounding area, to ensure bears cannot enter 

without being detected. 

• Workers will become familiar with the local environment. 

• A “buddy system” will be employed, to ensure fellow workers are informed about the 

whereabouts and activities that may bring workers in contact with bears. 

• Workers and facility occupants will be alerted if a bear is observed. 

• A Bear Guard will be designated, if necessary, to monitor for the presence of bears. The 

Bear Guard may also hold another work position that would allow him or her to monitor 

for the presence of bears, such as equipment operator. 

• Bear hazing will be approved by the designated representative (e.g., site manager). Only 

a designated properly trained and authorized bear hazer will be permitted to haze bears. 

Personnel other than the designated bear Hazer will not attempt to haze a bear. 

• Aircraft and vessels will not operate within 0.5-mi (800 m) exclusion zone of bears 

observed on land or ice during travel status. 

• Aircraft will maintain a minimum altitude of 1,500 ft (457 m) within 0.5 mi [800 m] of 

bears hauled out onto land or ice, unless weather does not permit this altitude. 

• When within 900 ft (274 m) of polar bears in water, vessels will reduce speed, and avoid 

multiple changes of direction. 

• Vessel speed to be reduced during inclement weather conditions in order to avoid 

collisions with bears. 

Polar bear monitoring, reporting, and survey activities will be conducted in accordance with the 

regulations that implement the MMPA as outlined in 71 FR 26770. The basic monitoring and 

reporting requirements are: 

• Follow a chain-of-reporting, and responding to polar bear sightings. Attachment D 

depicts the Wildlife Notification Flow Chart. 

• Designating a qualified individual or individuals to observe, record, and report the effects 

of the activity on polar bears. A USFWS-approved monitoring plan requires trained 

onboard MMOs. MMOs will monitor the exclusion zone for bears. If a bear is sighted, 

mitigation measures as specified in the 4MP (Attachment B) will be implemented. 

3.3 Protecting Workers and Walrus 

Worker safety is priority. The following procedures are to ensure worker awareness and 

knowledge about their own safety concerning walrus. 

• Drilling support vessels will observe a 0.5 mi (800 m) exclusion zone around walrus 

observed on land or ice during travel status except during active ice management (see 

Section 3.4 for procedures during ice management) 
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Shell Gulf of Mexico Inc. 22 May 2011 

• Aircraft will maintain a minimum altitude of 1,500 ft (457 m) within 0.5 mi (800 m) of 

Pacific walrus hauled-out onto land or ice, unless weather does not permit this altitude 

• When within 900 ft (274 m) of walrus in water, vessels will reduce speed, and avoid 

multiple changes of direction 

• Vessel speed to be reduced during inclement weather conditions in order to avoid 

collisions with walrus. 

Walrus monitoring, reporting, and survey activities will be conducted in accordance with those 

outlined in 71 FR 26770 of the MMPA. The basic monitoring and reporting requirements are: 

• Follow a chain-of-reporting, and responding to walrus sightings. Attachment D depicts 

the Wildlife Notification Flow Chart 

• Designating a qualified individual or individuals to observe, record, and report the effects 

of the activity on walrus. A USFWS-approved monitoring plan requires trained onboard 

MMOs. MMOs will monitor the exclusion zone for walrus. If a walrus is sighted, 

mitigation measures as specified in the 4MP (Attachment B) will be implemented. 

3.4 Protecting Polar Bear and Walrus During Ice Management 

Broken ice is an important habitat for walrus. Pack ice provides a moving platform that 

increases the likelihood of the animals finding fresh food resources on each foraging trip. The 

ice also creates a platform on which the walrus, especially females and their young in the 

Chukchi Sea, haul out for rest. Large numbers of walrus sometimes haul out on relatively small 

diameter ice floes resulting in densely packed distribution. Hundreds of walrus may be found on 

ice floes less than 600-1,000 ft (200-300 m) in diameter. The behavior of walrus at haulout sites 

renders them susceptible to stampedes from ice / land platforms, which can result in injuries or 

mortalities to the animals. 

Because ice management is conducted for the integrity and safety of the drillship and its crew, 

and because the vessels must come into contact with the ice floes during ice management 

activities, special protocols (as outlined below) will be in place during these activities to 

minimize the potential for effects on walrus. These are in addition to those identified above in 

Section 3.3. Shell will implement these protocols in a phased approach, based partially on the 

number of observed walrus in the vicinity of the ice management operations and the perceived 

ice threat to drilling operations and safety. The approach will also necessarily be one of adaptive 

management because all situations cannot be foreseen, because both the ice conditions 

(trajectory, size, density) and walrus behavior (hauled out, swimming, etc.) are subject to change 

as they approach the drill site without interference by Shell. 

Reconnaissance 

• Shell will conduct real-time monitoring of sea ice as described in the IMP (see 

Attachment A) and summarized above in Section 1.3. 

• Shell will have MMOs on the ice management vessels as required by the IHA and 4MP. 
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Shell Gulf of Mexico Inc. 23 May 2011 

Consultation with USFWS 

• A 24 hour duty phone will be established with the USFWS 

• All polar bear and walrus sightings will be reported to USFWS as described in Sections 

8.1 and 8.3, respectively 

• Indication that large areas of pack ice are approaching the area of the drillship and may 

require management, and/or sightings of large numbers of walrus on ice, will be reported 

to the USFWS contact identified in Section 8.3, immediately by telecommunications 

(duty phone); this will commence consultation and involve the USFWS in the adaptive 

management process 

Adaptive Management 

• If the polar bears are deemed to be a threat to personnel safety, or to themselves, hazing 

techniques as permitted under an intentional take authorization will be used to keep the 

bears out of harms way. Shell will follow the appropriate reporting protocol in this event 

(Section 8.1). 

• If hauled-out walrus are present, Shell will monitor to ascertain whether the walrus 

appear as if they are going to stay on the ice or might abandon the ice on their own. Shell 

will avoid, to the maximum extent possible, the management of ice on which walrus have 

hauled out. Shell will attempt to communicate with the USFWS and consult with the 

agency before management of ice with hauled out walrus. 

• If the walrus stay on the ice in the vicinity of ice management activities, Shell will notify 

the USFWS (via the USFWS 24 hour duty line) and begin discussions regarding 

appropriate action. With the USFWS input, we would consider the following ice 

management options: 

• Low Threat Level: If the ice does not represent a significant threat to the drill vessel, 

allow the ice to pass through the drilling area with walrus onboard 

• Moderate Threat Level: If ice poses a significant threat and hauled out walrus presence is 

moderate on the ice, carefully conduct ice management 

• High Threat Level: If ice poses a significant threat to the drill vessel and hauled out 

walrus presence is high on the ice, or the consequences of ice management are high, Shell 

will engage in further consultation with USFWS to come to a resolution regarding 

intentional harassment of walrus 

All mitigation measures listed in Section 3.2 and 3.3 will be adhered to unless the mitigation 

measures need to be adjusted/altered/or avoided based on guidance from USFWS because they 

are in conflict with the adaptive management approach described in this section. 
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3.5 Protecting Polar Bears and Walrus During an Oil Spill 

The probability of a very large oil spill from a well blowout occurring is extremely low. Worker 

safety is a priority during the unlikely event that there will be an oil spill response situation. 

Shell has prepared an ODPCP for implementation in the event of an oil spill and the plan 

includes procedures to be implemented in order to protect wildlife. The ODPCP has been 

approved by BOEMRE and the State of Alaska, Alaska Department of Environmental 

Conservation (ADEC) and is currently being revised for the 2012 exploration program. ACS is 

Shell’s primary response action contractor. Wildlife protection strategies to be implemented in 

the event of an oil spill are outlined in Tactics W1-W6 in Volume 1 of the ACS’ Technical 

Manual, and summarized below. The tactics manual is part of the ODPCP approved without 

conditions in 2010, has undergone revision for exploration drilling planned to begin in 2012 and 

is currently under review by BOEMRE. 

The following procedures are to ensure worker awareness and knowledge about their own safety 

concerning polar bears and walrus. The approach will also necessarily be one of adaptive 

management because all situations cannot be foreseen. Defined levels of response for both 

offshore and onshore in the event of an oil spill are adapted from the ACS Tactics Manual 

Section W-1, which in turn is based on the Wildlife Protection Guidelines for Alaska, Annex G 

of the Alaska Regional Response Team Unified Plan: 

• Primary Response – Containment and Recovery of Oil: this level of response deals with 

controlling the spread of oil and keeping it from important habitat; oil is recovered as 

quickly as possible: 

o Primary response for protecting polar bears and walrus from oil spills shall be to 

prevent oil from reaching areas where the animals are concentrated 

o Areas of concentration for walrus include areas of pack ice, and locations on the 

mainland and barrier island shores of the Chukchi Sea, where walrus are known to 

haul out – such as Cape Thompson, Cape Lisburne, and Icy Cape as well as 

numerous locations along the Chukotka coast and Wrangel Island in Russia 

o Areas of concentration for polar bears include areas of pack ice and barrier islands 

• Secondary Response – wildlife hazing by trained personnel: haze wildlife away from and 

prevent them from entering the spill area; hazing techniques include passive excluders 

(e.g., balloons, reflector tape), propane fueled cannons, shotguns, pistols, cracker shells, 

banger, rubber bullets (for bear deterrence) and shotgun slugs (for protection from bears); 

electric fencing may be used on land. 

o Secondary response for protecting polar bears and walrus from oil spills shall be 

to deter the animals from an oil slick or contaminated habitat 

o Any deterrence or hazing of polar bears or walrus would require an intentional 

take authorization from the on-scene coordinator and a permit from USFWS or 

National Marine Fisheries Service (NMFS), and would be conducted according to 

protocol identified in Tactic W-1 of the ACS Technical Manual 
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o Dead oiled wildlife shall be collected and disposed of as indicated in Tactic W-14 

of the ACS Technical Manual to prevent any secondary poisoning through 

ingestion of petroleum 

• Tertiary Response – Capture, stabilization and treatment of oiled wildlife by trained and 

authorized personnel. 

o Tertiary response includes the capture, stabilization, and treatment of oiled 

wildlife 

o Any capture or treatment of polar bears or walrus would require authorization 

from the on-scene coordinator and a permit from USFWS or NMFS 

o Any tertiary response would be conducted according to protocol identified in 

Tactic W-1 and W-2 of the ACS Technical Manual 

Oiled walrus or polar bears may be captured by authorized USFWS personnel (or personnel 

authorized by the USFWS; not Shell) using tranquilizers or baited culvert traps (polar bears 

only). Upon capture, it will transported by truck or helicopter to an ACS stabilization facility. 

Those animals that are determined to be able to survive in the wild are released. Other animals 

that are deemed incapable of surviving release to the wild will be held for potential transport to a 

zoo. In some cases, animals may be euthanized depending on the extent of their injuries. Details 

surrounding the capture, stabilization and treatment of oiled polar bears can be found in the 

DRAFT version of the Oil Spill Response Plan for Polar Bears in Alaska, USFWS Marine 

Mammal Management June 2010. 

ACS maintains a facility and equipment in Prudhoe Bay that is capable of being transported in an 

emergency situation. Equipment includes a cleaning, treatment and necropsy kit; three 

temporary holding cages and a large water tank. Potential short term holding facilities occur in 

Barrow at the BASC/NARL facility, the Anchorage Zoo and the Seward Sealife Center. All 

mitigation measure listed in Section 3.2 and 3.3 will be adhered to by Shell personnel involved in 

implementing response tactics, unless after consultation with USFWS personnel they are in are 

in direct conflict with the adaptive management procedures. 

4.0 FOOD WASTE MANAGEMENT PLAN 

The most important factor in the avoidance of attracting bears to active operations is to correctly 

handle food and associated waste. Proper handling of food and food-associated waste is 

important in reducing the potential for bears to associate humans and facilities with food. The 

following practices will be implemented. 

• Food wastes will not be discharged overboard from the drillship. 

• Personnel will separate food waste from other solid wastes. Food and food-associated 

waste will be placed only into containers secured from wildlife access aboard vessels or 

in vehicles. Personnel will use only designated receptacles for food and associated waste 

inside facilities or those that are secure from wildlife access. 

• No food-associated wastes may be placed into solid-waste containers. 
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• Containers will be located where there is good visibility and away from high-traffic areas. 

• Personnel will back-haul food-associated waste to approved bear-proof containers. 

• Dedicated receptacles will be secured – there should be no food-associated attractants in 

the containers. 

• Back-hauled food-associated waste will not be left in unmanned facilities, vessels, or 

unsecured vehicles. 

5.0 SAFETY AND COMMUNICATION 

The following safety and communication practices will be implemented. 

• Personnel should contact the designated Bear Guard or designated representative for the 

most recent bear sighting information. 

• If you sight a bear, look around for other bears while moving to a safe location. Alert 

other workers in the area. Do not attempt to scare the bear away. Do not approach a bear 

for any reason. Once in a secure location, immediately report the bear sighting to the onsite Shell representative. Only trained personnel are authorized to deal with animal 

problems. Do not try to photograph a bear unless you are in a secure location. Early bear 

detection is essential to limit human/bear encounters. 

• Use the “buddy system” during outside jobs. 

• Make sure personnel are trained to operate radios or other communication equipment. 

• Make noise before walking into an area with poor visibility. 

• Do NOT take food with you. If it is necessary to eat away from the designated camp 

mess unit, make sure that all food is safely stored inside secure containers. 

• Personnel should coordinate with other field operations to ensure the activities are 

compatible with bear avoidance and protection. 

6.0 TRAINING 

6.1 Marine Mammal Observer Training 

Prior to any vessel departure, MMOs will have completed a training course to recognize marine 

mammals, including polar bear and Pacific walrus, in water or on land or ice, to properly record 

sightings, and to advise what mitigation measures should be followed. The MMO training 

curricula will be pre-approved by the USFWS and NMFS. Trained MMOs will receive a 

document to verify course completion. Course information will include: 

• Overview of MMPA and relevance to drilling activity and mammals 

• Overview of drilling activities 

• Overview of mitigation measures 
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• MMO roles and responsibilities 

• MMO regulatory requirements 

• Identification of arctic marine mammals by species, sex, and age 

• Search methods for marine mammals 

• Overview of data collection and reporting requirements 

6.2 Bear Guard Training 

Bear guards will undergo an intensive training program performed by USFWS. Training will 

include: 

• bear habits, range, and habitat 

• how to minimize the number of human/bear interactions 

• the proper use of deterrents and projectiles to haze bears 

• how to report a bear sighting, hazing, and/or fatal taking 

• weapons handling/safety qualification 

6.3 Other Training Materials and Meetings 

Employees will be provided training that describes bear behavior and safety concerns, including 

hazing (e.g., new employee orientation, safety discussions). All hazing will be performed by a 

designated person who is trained in appropriate hazing tactics and firearms safety. The 

employee safety training program will include: 

• Bear Avoidance Action Plan; 

• USFWS or ADF&G (or comparable) Bear Encounter/Hazing Training; 

• Firearms training for designated Bear Guards; 

• Bear awareness reinforced at daily safety meetings; and 

• Video training material: 

o “Human/Polar Bear Interaction” (Alaska Oil and Gas Association) 

o Working in Polar Bear Country, for Industrial Managers, Supervisors and Workers 

o Staying Safe in Polar Bear Country, A Behavioral-based Approach to Reducing Risk. 

7.0 AT-RISK LOCATIONS AND SITUATIONS 

Work areas during the exploration drilling program will be exclusively offshore and distant from 

most prospective at-risk locations. Also, given that all personnel will be vessel-based, the 

prospect of at risk situations are remote for offshore exploration workers. However, in the event 
Polar Bear, Grizzly Bear, and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

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that exceptional circumstances occur, the following lists locations/situations where the risk of a 

bear encounter may be higher and where attention to mitigating these risks is essential: 

• sea ice floes, during ice management by vessels; 

• coastal bluffs; 

• barrier islands; 

• small watercraft (i.e., oil spill response drills or onshore equipment inspections); 

• marine vessels; 

• waste generation and collection facilities; and 

• “blind” areas that are obscured by facilities, equipment or other obstacles. 

At-risk situations and activities include: 

• transit in sea ice, and ice management by vessels; 

• activities on or around barrier islands; 

• any portable, temporary shelter (i.e., oil spill response drills or equipment caching); 

• emerging from vessels or facilities; and 

• dark/unlighted and visually obscured areas. 

8.0 REPORTING 

Sightings of bears or walrus by MMOs or other workers during the exploration drilling program 

will be recorded and reported to USFWS and ADF&G by a Shell Regulatory Affairs staff 

designee. Given that MMOs will be drillship-, and vessel-based, the majority of 

sightings/observations are expected to be marine mammals. Polar bear sightings will be reported 

according to the procedures and process described in Section 8.1 of this Plan. Grizzly bear 

sightings will be reported in accordance with Section 8.2.Walrus sightings will be reported in 

accordance with Section 8.3. 

Shell developed a 4MP (see Attachment B) for its exploration drilling program activities in the 

Chukchi Sea. The 4MP supports protection of the marine mammal resources in the area by 

adhering to mitigation measures, fulfilling wildlife sighting/observation and reporting obligations 

to the USFWS (and NMFS), and providing data useful for understanding the impacts of 

exploration drilling activities on Pacific walrus and polar bear. The 4MP dedicates multiple 

personnel 24-hours per day to the task of watching for, recording observations of, and instituting 

mitigation measures for wildlife observed, most notably those protected by the MMPA, ESA, or 

both. The outcome of conducting the 4MP will be resolute reporting of polar bear and Pacific 

walrus observed in the vicinities of the exploration drilling program activities. The 4MP for 

program activities is provided with the LOA application (see Attachment B) as well as included 

in the exploration plan. 
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After the appropriate bear or walrus encounter procedures have been followed, workers will be 

required to report the presence of a bear or walrus using the procedure outlined below. A copy 

of the Wildlife Notification Flow Chart is included as Attachment D. 

1) Workers are required to notify immediately the on-site Shell representative of a bear or 

walrus sighting and complete the appropriate sighting/observation form (Attachments E 

through G). 

2) Workers are to document any interactions (such as the use of cracker shells, vehicle 

horns, or other auditory devices; using vehicles or equipment to deter bears from an area; 

taking direct action to harass a bear out of an area; etc.) in the sighting/observation form. 

3) If the bear or walrus was sited within an exclusion zone or human/bear interaction took 

place (i.e., actions listed under bullet 2 above), the on-site Shell representative must 

promptly contact Shell Regulatory Affairs at 907-830-7435 (24 hours) or 907-646-7152 

(business hours). The on-site Shell representative must also fax or e-mail the completed 

sighting/observation form to the Shell Regulatory Affairs designee in Anchorage at 

907-646-7145 (fax). The Shell Regulatory Affairs designee will send (fax or e-mail) the 

completed sighting/observation form within 24 hours of the bear observation to the 

USFWS or ADF&G agency contact. 

4) If the bear or walrus was sighted outside an exclusion zone and no human/bear 

interaction took place, the MMO will provide the sighting/observation information to the 

Shell Regulatory Affairs designee in Anchorage by e-mail in the daily MMO report. 

8.1 Polar Bear Reporting 

Actions will be taken to the maximum extent practicable to avoid and minimize potential 

interactions with polar bears. MMOs will be assigned to project vessels to identify potential 

encounters and record polar bear behavior. Using the procedure provided in Section 8.0 and in 

the Wildlife Notification Flow Chart (Attachment D), the Shell Regulatory Affairs designee will 

be informed of polar bear sightings/observations. All relevant information must be recorded. 

The Polar Bear Sighting Report (Attachment E) must be completed to the greatest extent possible 

prior to submission. Regular reports of polar bear sightings in accordance with the LOA 

stipulations will be made to the USFWS. 

The primary polar bear contact: 

 Craig Perham 

 USFWS – Marine Mammals Section 

 1011 East Tudor Road 

 Anchorage, Alaska 99503 

 Telephone: 907-786-3810 (direct); 907-786-3800 (main office) 

 Fax: 907-786-3816 

 
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Alternate Polar Bear Contact: 

 Terry DeBruyn 

 USFWS – Marine Mammals Section 

 1011 East Tudor Road 

 Anchorage, Alaska 99503 

 Telephone: 907-786-3812 (direct); 907-786-3800 (main office) 

 Fax: 907-786-3816 

8.2 Grizzly Bear Reporting 

Actions will be taken to the maximum extent practicable to avoid and minimize potential 

interactions with grizzly bears. Using the procedure provided in Section 8.0 and in the Wildlife 

Notification Flow Chart (Attachment D), the Shell Regulatory Affairs designee will be informed 

of grizzly bear sightings/observations. All relevant information must be recorded. The Grizzly 

Bear Observation Form (Attachment F) is a typical report form must be completed to the greatest 

extent possible prior to submission. Regular reports of grizzly bear sightings will be made to the 

ADF&G. 

The ADF&G grizzly bear contact is: 

Dick Shideler 

Alaska Department of Fish & Game 

1300 College Road 

Fairbanks, AK 99709-4173 

Phone: 907-459-7283 

Fax: 907-459-3091 

E-mail: dick.shideler@alaska.gov 

Local Contact: 

Geoff Carroll, ADF&G 

Area Wildlife Biologist 

P.O. Box 1284 

Barrow, Alaska 99723-1284 

Phone: 907-852-3464 

Fax: 907-852-3465 

E-mail: geoff.carroll@alaska.gov 

8.3 Walrus Reporting 

Vessel traffic will avoid any walrus to the maximum extent practicable to avoid and minimize 

potential interactions. MMOs will be assigned to project vessels to identify potential encounters 

and record walrus behavior. Weekly reports of walrus sightings would be made to the USFWS 

using the Walrus Sighting Report Form (Attachment G). 
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Actions will be taken to the maximum extent practicable to avoid and minimize potential 

interactions with walrus. MMOs will be assigned to project vessels to identify potential 

encounters and record walrus behavior. Using the procedure provided in Section 8.0 and in the 

Wildlife Notification Flow Chart (Attachment D), the Shell Regulatory Affairs designee will be 

informed of walrus sightings/observations. All relevant information must be recorded. The 

Walrus Sighting Report (Attachment G) is a typical report that must be completed to the greatest 

extent possible prior to submission. Regular reports of walrus sightings in accordance with the 

LOA stipulations will be made to the USFWS. 

Primary Pacific walrus contact: 

Joel Garlich-Miller 

 USFWS – Marine Mammals Section 

 1011 East Tudor Road 

 Anchorage, Alaska 99503 

 Telephone: 907-786-3820 (direct); 907-786-3800 (main office) 

 Fax: 907-786-3816 

 

Secondary Pacific walrus contact: 

Craig Perham 

 USFWS – Marine Mammals Section 

 1011 East Tudor Road 

 Anchorage, Alaska 99503 

 Telephone: 907-786-3810 (direct); 907-786-3800 (main office) 

 Fax: 907-786-3816 

9.0 INTENTIONAL“TAKE” ACTIONS FOR BEARS 

Early detection and worker awareness will reduce chance encounters with a bear. If a bear 

remains on site for an extended period, the on-site Shell representative/Shell Regulatory Affairs 

designee will contact USFWS or ADF&G (as appropriate) for advice. Firearms with bean bags 

or rubber bullets, noisemakers, or other appropriate materials will available on site to provide 

deliberate and intentional harassment of bears to ensure worker safety. These actions constitute 

a “take”. If a lethal or non-lethal “take” occurs, despite preventative action to protect human life, 

the following information must be recorded and actions performed: 

• Personnel must record all details of the event including time, exact location, bear’s 

behavior, preventive measures followed, etc. 

• Personnel must record all witness statements. 

• Polar Bears - Immediately notify Craig Perham with USFWS at (907) 786-3810 (direct 

line) or (907) 786-3800 (main office). An alternate contact is Terry DeBruyn with 

USFWS at 907-786-3812 (direct line) or 907-786-3800 (main office). 

• Grizzly Bears – Immediately notify Dick Shideler (Fairbanks ADF&G) at 

(907) 459-7283 and Geoff Carroll (Barrow ADF&G) at (907) 852-3464. 
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• If there is a lethal “take”, the entire animal carcass will be transported to Barrow for 

sealing and processing under the direction of either a responsible USFWS agent designee 

(polar bear) or ADF&G agent designee (grizzly bear). The agent designee will determine 

disposition of useable meat (e.g., donation to a Native village). 

The trained bear Guard (or Watch) or designated representative is responsible for: 

• recording all the event details including time, exact location, bear’s behavior, preventive 

measures followed, etc.; and 

• recording all witness statements. 

10.0 PLAN OF COOPERATION 

A Plan of Cooperation (POC) has been developed as a required component of a LOA application 

under 50 CFR 18.128(d). A POC is also required as part of an application for an IHA from 

NMFS under 50 CFR § 216.104(a) (12), and under the BOEMRE lease stipulation 5 for lease 

sales 195 and 202. A POC was prepared and was submitted with the initial Chukchi Sea EP. An 

addendum to the POC was prepared for this revised exploration program and it updates the initial 

POC with information regarding proposed changes in proposed exploration drilling program, and 

documentation of meetings undertaken to inform the stakeholders of the revise exploration 

drilling program. The POC Addendum builds upon the previous POC. The POC Addendum is 

provided to USFWS as Attachment H to this LOA. 

The POC Addendum identifies the measures that Shell has developed in consultation with North 

Slope communities and will implement during its planned Chukchi Sea exploration drilling 

program to minimize any adverse effects on the availability of marine mammals for subsistence 

uses. In addition, the POC Addendum details Shell’s communications and consultations with 

local communities concerning its proposed revised Chukchi Sea EP exploration drilling program 

beginning in the summer of 2012, potential conflicts with subsistence activities, and means of 

resolving any such conflicts (50 CFR § 18.128(d) and 50 CFR § 216.104(a) (12) (i), (ii), (iv)). 

Shell has documented its contacts with the North Slope communities, as well as the substance of 

its communications with subsistence stakeholder groups. Tables summarizing the substance of 

Shell’s communications, and responses thereto, are included in Attachment H. This POC 

Addendum may be further supplemented, as appropriate, to reflect additional engagements with 

local subsistence users and any additional or revised mitigation measures that are adopted as a 

result of those engagements. 
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11.0 REFERENCES 

ADF&G (Alaska Department of Fish and Game). 2008a. Wildlife Notebook Series, accessed 

February 2008. http://www.adfg.state.ak.us/pubs/notebook/marine/ . 

ADF&G. 2008b. Wildlife Notebook Series, accessed February 2008. 

http://www.adfg.state.ak.us/pubs/notebook/marine/walrus.php . 

Fischbach, A., S. Amstrup, and D. Douglas. 2007. Landward shift of Alaskan polar bear 

denning associated with recent sea ice changes. Polar Biol. 30:1395-1405. 
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Attachment A 

Ice Management Plan 

(Refer to Appendix K of the Chukchi Sea EP) 
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Attachment B 

Marine Mammal Monitoring and Mitigation Plan (4MP) 

(Refer to Appendix D of the Chukchi Sea EP) 
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Attachment C 

Bear Avoidance and Encounter Procedures 
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Attachment C 

Bear Avoidance and Encounter Procedures 

All personnel should understand and follow the procedures listed below to detect the presence of bears in 

work areas and avoid human/ bear encounters. 

If your work assignment requires you to be outside of areas that are secure from bears (buildings, heavy 

equipment cabs, etc.) check directly with your supervisor for the latest report from the designated 

representative Bear Guard to find out whether bears or bear sign were reported. Potential at-risk 

situations are walking between enclosed structures at the shore base, outside vehicles and at various work 

locations. 

Arrange with your crew foreman to maintain radio or visual contact with the designated Bear Guard so 

that you can be alerted immediately to select a secure place if a bear is sighted. Plan the best route in 

advance to reach safe locations at the shore base or on a vessel from your work area. 

Be especially alert in dark conditions and areas of poor visibility outside where most pedestrian areas are 

illuminated. 

Do NOT take food with you. If it is necessary to eat away from the vessel galley or shore base mess unit, 

make sure that all food is safely stored inside containers aboard ship or inside secure vehicles. 

Do NOT leave food wastes or other material that may attract bears outside. 

Report all bear sightings (including sign and tracks) immediately to the designated Shell representative 

when you are in a secure location. Do not expose yourself to look at the bear. Do not try to photograph a 

bear unless you are in a secure location. Early bear detection is essential to limit human/ bear encounters. 
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Attachment D 

Wildlife Notification Flow Chart 

 
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Lethal 

Take

Grizzly Bear Polar Bear 

Report to 

Bear 

Watch/MMO 

Contact on-site Shell 

representative & 

Shell RA designee 

Shell RA designee to 

contact ADF&G 

(Dick Shideler, 

dick.shideler@alsaka.gov) 

Shell RA designee to 

contact USFWS 

(Craig Perham, 

craig.perham@fws.gov ) 

or USFWS Law 

Enforcement 

Report to 

Bear 

Watch/MMO 

Contact on-site Shell 

representative & 

Shell RA designee 

Report to 

MMO 

Walrus 

Contact Barrow 

Wildlife Biologist 

Geoff Carroll 

(852-3464) or 

Bob Stevenson 

(459-7236)

Persistent 

Bear 

Grizzly Bear Polar 

Bear 

Report to 

Bear 

Watch/MMO 

Contact on-site Shell 

representative & Shell 

RA designee 

Shell RA designee to 

contact ADF&G (Dick 

Shideler, 

dick.shideler@alsaka.gov) 

for appropriate advice on 

deterrent or actions 

Record 

recommendations & 

actions on sightings 

form. Note whether 

deterrent was effective. 

Shell RA designee to 

contact USFWS 

(Craig Perham, 

(craig.perham@fws.gov)

for appropriate advice on 

Report to 

deterrent or actions 

Bear 

Watch/MMO 

Wildlife 

Sighting 

Grizzly Bear 

Polar Bear or 

Newly 

Discovered 

Den 

Report to 

Bear 

Watch/MMO 

Contact on-site Shell 

representative & 

Shell RA designee 

Shell RA to report by email to 

ADF&G 

(Dick Shideler, 

dick.shideler@alsaka.gov) 

Shell RA to report by 

e-mail to USFWS 

(Craig Perham, 

craig.perham@fws.gov) for 

Polar Bear) 

(Joel Garlich-Miller 

joel_garlichmiller@fws.gov

for walrus) 

Report to 

Bear 

Watch/MMO 

Contact on-site Shell 

representative & 

Shell RA designee 

Report to 

MMO 

Walrus 

WILDLIFE NOTIFICATION FLOW CHART 

Forms sent to either 

ADF&G (Dick Shideler) 

or USFWS (Craig 

Perham) 
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Attachment E 

Polar Bear Sighting Report 
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 United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

1011 E. Tudor Road 

Anchorage, Alaska 99503-6199 

POLAR BEAR SIGHTING REPORT

Date:__________ Observer name:_________________________________ 

Time:__________ Contact number/email:____________________________ 

Location: _____________________________________________________________________ 

_____________________________________________________________________________ 

Latitude:____________________ Longitude______________ Datum:_________ 

Weather conditions: Fog_____ Snow_____ Rain_____ Clear_____ Temperature______ F/C 

Wind speed______ mph/kts 

Wind direction__________ 

Visibility: Poor 

 Fair _____________ 

 Good _____________ 

 Excellent_____________ 

Number of bears: 

_____ Adult M/F 

_____ Sub-adult 

_____ Unknown 

________ Sow/cub(s) 

________ Sow/yearling(s) 

________ Sow/2YO(s) 

Estimated distance of bear(s) from personnel_____ (meters) and facility _____ (meters) 

 (closest point) (closest point) 

Bear behavior (Initial Contact): 

Bear behavior (After Contact): 

Description of encounter:_________________________________________________________ 

______________________________________________________________________________ 

______________________________________________________________________________ 

______________________________________________________________________________ 

Duration of encounter:_____________ Possible attractants present:________________

Deterrents used/distance: 

_____ Crackershell 

_____ Vehicle 

_____ Rubber bullet 

_____ Bean bag 

_____ Horn/siren 

_____ Spotlight/Headlight 

______Other ____________ 

Agency/Contacts: 

USFWS_Craig Perham (786-3810) (FAX: 786-

3816)________ Time_______ Date__________ 

ADF&G_Dick Shideler (459-7283) (FAX: 456-

3091)_______ Time_______ Date__________
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Attachment F 

Grizzly Bear Observation Form 

 
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Bear 10# ____ (ADF&G only) 

GRIZZLY BEAR OBSERVATION FORM 

Observer: Company / 

Agency: 

Observation Date: Time: Start Stop 

Observation from: Vehicle Ground Building Other 

Observer’s distance from bear: _______________ meters 

General Location: Barrow Wainright Point Lay Pt Hope Endicott 

 Milne Point Lisburne Point McIntyre TAPS (MP#): 

_________ 

 Other (latitude/longitude if known): 

Specific Location: meters (direction) of (facility name) 

Dumpster present: Yes No Unknown 

Weather: ________ oF Clear / Partly Cloudy Rain Fog Snow 

Direction of wind: at mph 

Bear Identification: Earflag color: Right Left 

(Note: “right” / “left” of bear, not observer) 

Natural Markings (scars, torn ear, 

etc.): 

Other Bears Present: None Cubs: # of cubs # of 

yearlings 

 # of other 

Bear Activity: When 1st seen, the bear was: Resting Feeding (natural food) 

 Feeding (garbage) Feeding/Traveling Traveling 

 Other: 

Bear’s reaction to Observer: Ignore Approach Avoid 

Were other people in area (i.e. not with observer): Yes No Unknown 

Bear’s reaction to other people: Ignore Approach Avoid 

Comments: 

Deterrence Action Taken: Yes No If “Yes”, did you use: 

 Horn Siren Plastic Slugs Cracker Shell Firecracker 

 Birdshot Other: 

Bear Reaction: Ignore Approach Withdraw 

Additional Remarks: 

Please return to: Dick Shideler, Alaska Department of Fish & Game 

1300 College Road, Fairbanks, Alaska 99701 

Phone: 907-459-7283, FAX: 907-459-3091 
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Polar Bear, Grizzly Bear and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

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Attachment G 

Walrus Sighting Report 
Polar Bear, Grizzly Bear and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

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Polar Bear, Grizzly Bear and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. May 2011 

United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

1011 E. Tudor Road 

Anchorage, Alaska 99503-6199 

WALRUS SIGHTING REPORT 

Date: __________ 

Time: __________ 

Location: (include GPS coordinates if possible) _______________________________________ 

_____________________________________________________________________________ 

Observer name: ________________________________________________________________ 

Weather conditions: Fog_____ Snow_____ Rain_____ Clear_____ Approx. temperature______ 

Wind speed__________ Wind direction__________ 

Total number of walrus: Adult_____ Sub-adult_____ Unknown_____ 

Estimated distance of walrus from personnel/facility:___________________________________ 

Possible attractants present:_______________________________________________________ 

Walrus behavior: Curious_____ Aggressive_____ Predatory_____ Other___________________ 

Description of encounter: _________________________________________________________ 

______________________________________________________________________________ 

______________________________________________________________________________ 

Duration of encounter: ___________________________________________________________ 

Deterrents used/distance: Vehicle_____ Noise-maker_____ Firearms_____ Other____________ 

Injuries sustained: Personnel: ___________________________________________________ 

Walrus: 

____________________________________________________ 

Agency/Contacts: 

USFWS_____________________________________________ Time_______ Date__________ 

ADF&G_____________________________________________ Time_______ Date__________ 

CLIENT_____________________________________________ Time_______ Date_________
Polar Bear, Grizzly Bear and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

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Polar Bear, Grizzly Bear and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

Shell Gulf of Mexico Inc. May 2011 

Attachment H 

Plan of Cooperation Addendum 

(Refer to Appendix H of the Chukchi Sea EP) 
Polar Bear, Grizzly Bear and Pacific Walrus Avoidance and Human Encounter/Interaction Plan Chukchi Sea, Alaska 

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