U.S. Department of the Interior 

Bureau of Land Management 

Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement 

Volume I: Executive Summary, Chapters 1-3, References, Glossary 

December 2018 

Prepared by: 

US Department of the Interior 

Bureau of Land Management 

In cooperation with: 

US Fish and Wildlife Service 

US Environmental Protection Agency 

State of Alaska 

North Slope Borough 

Native Village of Kaktovik 

Native Village of Venetie Tribal Government 

Venetie Village Council 

Arctic Village Council 

Estimated Lead Agency Total 

Costs Associated with Developing 

and Producing this EIS

$1,200,000
The Bureau of Land Management’s multiple-use mission 

is to sustain the health and productivity of the public 

lands for the use and enjoyment of present and future 

generations. The Bureau accomplishes this by managing 

such activities as outdoor recreation, livestock grazing, 

mineral development, and energy production, and by 

conserving natural, historical, cultural, and other 

resources on public lands.

Cover Photo: Northward view in central coastal plain area 

near the Sadlerochit River showing gently rolling 

topography typical of the area. Natural oil indications are 

visible of an oil seep that occurs along the coast (Barter 

Island). Photo by David Houseknecht (USGS). 

DOI-BLM-AK-0000-2018-0002-EIS 

BLM/AK/PL-19/002+1610+F020 
In Reply, Refer To 

1793 (930) 

December 2018

Dear Reader: 

I am pleased to present the Coastal Plain Oil and Gas Leasing Program Draft Environmental 

Impact Statement (Leasing EIS) for your review. It addresses a list of issues and contains three 

action alternatives for the Bureau of Land Management's (BLM) implementation of an oil and 

gas program in the Coastal Plain ofthe Arctic National Wildlife Refuge (Arctic Refuge). This 

program is required by the Tax Cuts and Jobs Act of 2017, Public Law 115-97 (PL 115-97). 

The Coastal Plain is within the political boundary ofthe North Slope Borough and is 

predominantly managed by the US Fish and Wildlife Service as part ofthe Arctic Refuge. The 

decisions to be made as part ofthis Leasing EIS concern which areas ofthe Coastal Plain would 

be offered for oil and gas leasing and the terms and conditions to be applied to such leases and 

subsequent authorizations for oil and gas activities. 

The action alternatives .discussed in the Leasing EIS include lease stipulations and required 

operating procedures designed to mitigate impacts on natural resources and their uses. All future 

on-the-ground actions requiring BLM approval, including potential exploration and development 

proposals, will require further National Environmental Policy Act analysis based on the sitespecific proposal. 

The BLM will evaluate all comments received and address substantive comments in the final 

Leasing EIS scheduled to be released in 2019. 

The most useful comments are specific and address one or more ofthe following: 

• 	 Identification of new information that would have a bearing on the analysis. 

• 	 Inaccuracies or discrepancies in information or any errors in our portrayal ofthe 


resources and uses ofthe program area. 


• 	 Suggestions for improving implementation ofan oil and gas leasing program, consistent 

with the purposes ofthe Arctic Refuge. 

• 	 Identification ofnew impacts, alternatives, or potential mitigation measures. 

When you share your comments with us, please be as specific as possible. Identify the specific 

concern or correction you are suggesting, where it appears in the Leasing EIS, and the 

modification you feel is necessary or appropriate. 
2 

I appreciate your comments on the Leasing EIS and there are three ways to submit them: 

• 	 Electronically at https://goo.gi/HVo5Mj 

• 	 By mail to: 


Ms. Nicole Hayes 


Project Manager 


BLM Alaska State Office 


222 West 7th Avenue, #13 


Anchorage, AK 99513 


• 	 In person at the BLM Public Information Center, located on the first floor in the 

James M. Fitzgerald United States Courthouse and Federal Building, 222 W. 7th Avenue, 

Anchorage, Alaska, or at the public meetings. 

The 45-day public comment period for the Leasing EIS begins with the Notice ofAvailability 

published by the Environmental Protection Agency in the Federal Register. The precise dates of 

the comment period, as well as information about public meetings and subsistence hearings 

pursuant to Section 810 ofthe Alaska National Interest Lands Conservation Act, will be posted 

on our website at www.blm.gov/Aiaska. 

Submitted comments will be publicly available and may be published as part ofthe Final 

Leasing EIS. Before including your address, phone number, email address, or other personal 

identifying information in your comment, be aware that your entire comment, including your 

personal identifying information, may be made publicly available at any time. While you can 

ask us in your comment to withhold your personal identifying information from public review, 

we cannot guarantee that we will be able to do so. All submissions from organizations and 

businesses and from individuals identifying themselves as representatives or officials of 

organizations and businesses will be available for public inspection in their entirety. 

For additional information about the public comment process or the Leasing EIS, please go to the 

program website at: https://www.blm.gov/programs/planning-and-nepa/plans-indevelopment/alaskalcoastal-plain-eis 

Sincerely, 

=1'-&')t.~ Ted A. Murphy 

Acting State Director 
Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Lead Agency: United States (US) Department of the Interior, Bureau of Land Management

(BLM)

Cooperating Agencies: US Fish and Wildlife Service, US Environmental Protection Agency (EPA), 

State of Alaska, North Slope Borough, Native Village of Kaktovik, Native 

Village of Venetie Tribal Government, Venetie Village Council, and the

Arctic Village Council

Proposed Action: In accordance with the Section 20001 of Public Law 115-97 (PL 115-97), 

establish and administer a competitive oil and gas program for the leasing, 

development, production, and transportation of oil and gas in and from the 

Coastal Plain in the Arctic National Wildlife Refuge (Arctic Refuge).

Abstract: The BLM will establish and administer an oil and gas leasing program for the 

Coastal Plain in the Arctic Refuge, as required by PL 115-97. The Coastal 

Plain Oil and Gas Leasing Program Draft Environmental Impact Statement 

(Leasing EIS) will inform the BLM’s implementation of PL 115-97, Section 

20001(c)(1), which requires the BLM to hold multiple oil and gas lease sales.

The Leasing EIS considers three action alternatives. The No Action 

Alternative, Alternative A, is included for comparison only; it does not meet 

the purpose and need of the EIS. Alternatives B, C, and D propose a range 

of the extent of the Coastal Plain that would be available for lease sale—

from 66 to 100 percent of the 1.56 million-acre Coastal Plain—while 

balancing biological and ecological concerns. These alternatives also include 

lease stipulations and required operating procedures designed to mitigate 

impacts on resources and their uses. Alternative D contains two subalternatives, Alternatives D1 and D2, for varied analysis of caribou summer 

habitat lease stipulations. There is no preferred alternative. The Leasing EIS 

considers and analyzes the environmental impact of these various leasing 

alternatives, including the areas to offer for sale, and the indirect impacts 

that could result in consideration of the hypothetical development scenario.

These include potential effects from future on-the-ground post-lease 

activities on climate and meteorology, air quality, noise, physiography, 

geology and minerals, petroleum resources, paleontological resources, sand 

and gravel, soil, water, solid and hazardous waste, vegetation and wetlands, 

wildlife, landownership and uses, cultural resources, subsistence uses and 

resources, sociocultural systems, environmental justice, recreation, visual 

resources, special designations (including marine protected areas, eligible 

and suitable wild and scenic rivers, and wilderness characteristics, qualities, 

and values), transportation, public health, and the economy.

Review Period: The review period on the Leasing EIS is 45 calendar days. The review period 

began when the EPA published a notice of availability in the Federal Register

on December 28, 2018. The comment period ends on February 11, 2019.

Further Information: Contact Nicole Hayes of the BLM at (907) 271-4354 or visit the Leasing EIS

website at https://goo.gl/HVo5Mj.
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Coastal Plain Oil and Gas Leasing Program i 

Draft Environmental Impact Statement

TABLE OF CONTENTS

Chapter Page 

EXECUTIVE SUMMARY.............................................................................................................ES-1

Introduction ................................................................................................................................................ ES-1

Purpose and Need ..................................................................................................................................... ES-1

Decisions to Be Made ............................................................................................................................... ES-1

Program Area ............................................................................................................................................. ES-2

Scoping and Issues ..................................................................................................................................... ES-2

Alternatives ................................................................................................................................................. ES-2

Alternative A—No Action Alternative ................................................................................. ES-2

Alternative B ................................................................................................................................ ES-3

Alternative C ............................................................................................................................... ES-3

Alternative D ............................................................................................................................... ES-3

Hypothetical Development Scenario .................................................................................................... ES-3

Impact Analysis ........................................................................................................................................... ES-4

Collaboration and Coordination ............................................................................................................ ES-5

CHAPTER 1. INTRODUCTION .................................................................................................... 1-1

1.1 Overview ........................................................................................................................................ 1-1

1.2 Purpose and Need ........................................................................................................................ 1-1

1.3 Decisions to be Made .................................................................................................................. 1-2

1.4 Program Area ................................................................................................................................ 1-2

1.5 Scoping and Issues ........................................................................................................................ 1-2

1.6 EIS Process ..................................................................................................................................... 1-3

1.7 Collaboration and Coordination ............................................................................................... 1-4

1.7.1 Lead and Cooperating Agencies ................................................................................. 1-4

1.7.2 Consultation with Tribes and ANCSA Corporations .......................................... 1-4

1.7.3 Coordination and Consultation with Local, State, and Federal Agencies ........ 1-4

1.8 Requirements for Further Analysis .......................................................................................... 1-5

1.9 International Agreements, Laws, Regulations, and Permits ................................................ 1-5

1.9.1 Tax Cuts and Jobs Act of 2017 (Public Law 115-97) ............................................ 1-6

1.10 ANILCA Section 810 Evaluation ............................................................................................... 1-7

1.11 Translation ...................................................................................................................................... 1-7

CHAPTER 2. ALTERNATIVES ..................................................................................................... 2-1

2.1 Introduction ................................................................................................................................... 2-1

2.2 Description of the Alternatives ................................................................................................. 2-1

2.2.1 Alternative A—No Action Alternative .................................................................... 2-2

2.2.2 Alternative B ................................................................................................................... 2-2

2.2.3 Alternative C .................................................................................................................. 2-2

2.2.4 Alternative D .................................................................................................................. 2-2

2.2.5 Lease Stipulations and Required Operating Procedures ...................................... 2-2

2.3 Alternatives Considered But Eliminated From Detailed Analysis ................................... 2-39

CHAPTER 3. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES.................. 3-1

3.1 Introduction ................................................................................................................................... 3-1

3.2 Physical Environment ................................................................................................................... 3-2

3.2.1 Climate and Meteorology ............................................................................................ 3-2
TABLE OF CONTENTS (continued) 

Chapter Page 

ii Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

3.2.2 Air Quality ..................................................................................................................... 3-10

3.2.3 Acoustic Environment ................................................................................................ 3-17

3.2.4 Physiography ................................................................................................................. 3-23

3.2.5 Geology and Minerals ................................................................................................. 3-27

3.2.6 Petroleum Resources ................................................................................................. 3-35

3.2.7 Paleontological Resources ......................................................................................... 3-41

3.2.8 Soil Resources .............................................................................................................. 3-44

3.2.9 Sand and Gravel Resources ....................................................................................... 3-48

3.2.10 Water Resources ......................................................................................................... 3-51

3.2.11 Solid and Hazardous Waste ...................................................................................... 3-60

3.3 Biological Resources .................................................................................................................. 3-65

3.3.1 Vegetation and Wetlands ........................................................................................... 3-65

3.3.2 Fish and Aquatic Species ............................................................................................ 3-75

3.3.3 Birds ................................................................................................................................ 3-84

3.3.4 Terrestrial Mammals ................................................................................................ 3-103

3.3.5 Marine Mammals ....................................................................................................... 3-122

3.4 Social Systems ........................................................................................................................... 3-149

3.4.1 Landownership and Use .......................................................................................... 3-149

3.4.2 Cultural Resources ................................................................................................... 3-151

3.4.3 Subsistence Uses and Resources .......................................................................... 3-159

3.4.4 Sociocultural Systems .............................................................................................. 3-178

3.4.5 Environmental Justice ............................................................................................... 3-193

3.4.6 Recreation .................................................................................................................. 3-202

3.4.7 Special Designations ................................................................................................. 3-209

3.4.8 Visual Resources ....................................................................................................... 3-217

3.4.9 Transportation .......................................................................................................... 3-224

3.4.10 Economy ..................................................................................................................... 3-227

3.4.11 Public Health .............................................................................................................. 3-239

3.5 Unavoidable Adverse Effects ................................................................................................. 3-247

3.6 Relationship Between Local Short-Term Uses and Long-Term Productivity ........... 3-248

3.7 Irreversible and Irretrievable Commitments of Resources ........................................... 3-248

REFERENCES............................................................................................................ REFERENCES-1 

GLOSSARY.................................................................................................................. GLOSSARY-1 

TABLES Page 

ES-1 Land Administration .................................................................................................................................. ES-2

1-1 Land Administration .................................................................................................................................... 1-2

2-1 Quantitative Summary of Lease Stipulations by Alternative ............................................................. 2-1

2-2 Lease Stipulations, Required Operating Procedures, and Lease Notice by Alternative ............. 2-4

3-1 Kaktovik Airport Period of Record Monthly Climate Summary ...................................................... 3-3

3-2 GHG Emissions at Various Geographic Scales in 2015 ...................................................................... 3-5

3-3 Projected Oil Production and Direct GHG Emissions Estimates .................................................... 3-7

3-4 Projected Oil Production and Indirect GHG Emissions Estimates for the Coastal Plain .......... 3-8
TABLES (continued) Page 

Coastal Plain Oil and Gas Leasing Program iii

Draft Environmental Impact Statement

3-5 Estimated Future Development GHG Emissions versus 2015 Emissions at Various 

Geographic Scales ........................................................................................................................................ 3-8

3-6 Average Air Pollutant Monitoring Values, 2014-2016 ...................................................................... 3-11

3-7 Documented Mineral Occurrences within 15 Miles of the Coastal Plain .................................... 3-33

3-8 Estimated Mean Undiscovered Petroleum Resources in the Coastal Plain ................................. 3-36

3-9 Lease Stipulation Acreages for Alternative B ...................................................................................... 3-39

3-10 Lease Stipulation Acreages for Alternative C ..................................................................................... 3-39

3-11 Lease Stipulation Acreages for Alternative D1................................................................................... 3-40

3-12 Lease Stipulation Acreages for Alternative D2................................................................................... 3-40

3-13 PFYC Values of Program Area Geologic Bedrock Units ................................................................. 3-42

3-14 Spill Characteristics by Seasons.............................................................................................................. 3-63

3-15 Relative Rate of Occurrence for Spills from Main Sources ............................................................. 3-64

3-16 Wetland Types Mapped in the Arctic Refuge Program Area by the National Wetland 

Inventory Program .................................................................................................................................... 3-68

3-17 Fish Habitat in the Program Area and Surrounding Area ................................................................ 3-75

3-18 Fish Species that May Use the Program Area ..................................................................................... 3-78

3-19 Summary of the Type, Context, and Duration of Potential Effects of Oil and Gas 

Exploration, Construction, and Drilling and Operations on Terrestrial Mammals ................ 3-111

3-20 Marine Mammal Species Occurring within 5 NM of the Arctic Refuge Coastline and 

Their Status in the Program Area ....................................................................................................... 3-123

3-21 Additional Marine Mammal Species Occurring Along Vessel Transit Routes in the 

Bering and Chukchi Seas ....................................................................................................................... 3-124

3-22 Number of Documented Dens and Extent of Potential Terrestrial Denning Habitat for 

Maternal Polar Bears within the Three Zones of Estimated HCP in the Program Area ...... 3-134

3-23 Number and Percentage of Documented Polar Bear Dens by Alternative, Hydrocarbon 

Potential, and Lease Type ..................................................................................................................... 3-145

3-24 Estimated Acreage and Percentage of Potential Maternal Denning Habitat by 

Alternative, Hydrocarbon Potential, and Lease Type .................................................................... 3-145

3-25 Cultural Themes and Periods of the Arctic Refuge Area ............................................................. 3-152

3-26 Cultural Resource Sites by Action Alternative ................................................................................ 3-158

3-27 Selected Kaktovik Harvest and Participation Data, Average Across Available Study 

Years .......................................................................................................................................................... 3-162

3-28 Selected Nuiqsut Harvest and Participation Data, Average Across Available Study Years .. 3-164

3-29 Selected Arctic Village Harvest and Participation Data, Average Across Available Study 

Years .......................................................................................................................................................... 3-165

3-30 Selected Venetie Harvest and Participation Data, Average Across Available Study Years .. 3-166

3-31 Arctic National Wildlife Refuge Purposes ........................................................................................ 3-209

3-32 Eligible and Suitable Rivers within the Program Area .................................................................... 3-211

3-33 Eligible and Suitable River Setback Distances Under Alternative B ............................................ 3-214

3-34 Eligible and Suitable River Setback Distances under Alternative D ............................................ 3-215

3-35 Projected Direct and Indirect Jobs: Exploration, Development, and Production Phases ..... 3-234

3-36 Projected Direct and Indirect Labor Income: Exploration, Development, and 

Production Phases .................................................................................................................................. 3-235

3-37 Projected North Slope Borough, State, and Federal Government Revenues.......................... 3-236
iv Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

MAPS AND FIGURES (see Appendix A)

MAPS: 

1-1 Program Area 

2-1 Alternative B 

2-2 Alternative B, Lease Stipulations 

2-3 Alternative C 

2-4 Alternative C, Lease Stipulations 

2-5 Alternative D1 

2-6 Alternative D1, Lease Stipulations 

2-7 Alternative D2 

2-8 Alternative D2, Lease Stipulations 

3-1 Physiographic Provinces 

3-2 Mineral Occurrences 

3-3 Oil and Gas Infrastructure 

3-4 Hydrocarbon Potential, Alternative B 

3-5 Hydrocarbon Potential, Alternative C 

3-6 Hydrocarbon Potential, Alternative D1 

3-7 Hydrocarbon Potential, Alternative D2 

3-8 Paleontological Resources 

3-9 Hazardous Waste Sites 

3-10 Vegetation 

3-11 Wetlands 

3-12 Fish Habitat and Distribution 

3-13 Essential Fish Habitat 

3-14 Nest Sites, Observations, and Density of Pre-Nesting Spectacled Eider 

3-15 Post-Breeding and Fall Staging Common Eider 

3-16 Post-Breeding and Fall Staging King Eider 

3-17 Post-Breeding and Molting Surf Scoter 

3-18 Post-Breeding and Molting Long Tailed Duck 

3-19 Post-Breeding and Fall Staging Yellow-Billed Loon 

3-20 Frequency of Occurrence of Snow Goose Flocks with >500 Birds Observed During Aerial 

Surveys, 1982–2004 

3-21 Seasonal Distribution of the Porcupine Caribou Herd 

3-22 Seasonal Distribution of the Central Arctic Herd 

3-23 Porcupine Caribou Herd, Alternatives B, C, D1, and D2 

3-24 Polar Bear Habitat 

3-25 Bowhead and Beluga Whale Sightings 

3-26 Seal Sightings 

3-27 Coastal Plain EIS Subsistence Study Communities 

3-28 Kaktovik Subsistence Use Areas 

3-29 Kaktovik Caribou Subsistence Use Areas in Coastal Plain 

3-30 Kaktovik Moose Subsistence Use Areas in Coastal Plain 

3-31 Kaktovik Grizzly and Sheep Subsistence Use Areas in Coastal Plain 

3-32 Kaktovik Furbearer Subsistence Use Areas in Coastal Plain 

3-33 Kaktovik Fish Subsistence Use Areas in Coastal Plain 

3-34 Kaktovik Bird Subsistence Use Areas in Coastal Plain 

3-35 Kaktovik Vegetation and Wood Subsistence Use Areas in Coastal Plain 
MAPS AND FIGURES (see Appendix A) (continued)

Coastal Plain Oil and Gas Leasing Program v 

Draft Environmental Impact Statement

3-36 Kaktovik Whale Subsistence Use Areas in Coastal Plain 

3-37 Kaktovik Seal Subsistence Use Areas in Coastal Plain 

3-38 Kaktovik Walrus Subsistence Use Areas in Coastal Plain 

3-39 Kaktovik Polar Bear Subsistence Use Areas in Coastal Plain

3-40 Nuiqsut Subsistence Use Areas 

3-41 Nuiqsut Whales Subsistence Use Areas in Coastal Plain 

3-42 Nuiqsut Seal Subsistence Use Areas in Coastal Plain 

3-43 Nuiqsut Wolf and Wolverine Subsistence Use Areas in Coastal Plain 

3-44 Arctic Village and Venetie Subsistence Use Areas 

3-45 Kaktovik Subsistence Use Areas and Areas of Hydrocarbon Potential 

3-46 Special Designations 

FIGURES: 

3-1 Wind Rose Plot for Barter Island, Kaktovik, Alaska 

3-2 Visibility data for Gates of the Arctic National Park 

3-3 Stratigraphy of the Coastal Plain 

3-4 Generalized Surficial Deposits of the Coastal Plain Area 

3-5 Population Size of Three Caribou Herds in Arctic Alaska, 1977-2017 

3-6 Marine Barge Route—Dutch Harbor to Program Area 

3-7 Average Portion of Harvest of Porcupine Caribou Herd Between the US and Canada (1992-

1994) 

3-8 Visual Resources Photo 1 

3-9 Visual Resources Photo 2 
vi Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

APPENDICES

A Maps and Figures 

B Reasonably Foreseeable Development Scenario for Oil and Gas Resources in the Public Law 

115-97 Coastal Plain, Alaska 

C Collaboration and Coordination 

D Laws and Regulations 

E ANILCA Section 810 Preliminary Evaluation 

F Approach to the Environmental Analysis 

G Potential Fossil Yield Classification System 

H Water Resources 

I Solid and Hazardous Waste 

J Vegetation and Wetlands, Birds, and Terrestrial Mammals 

K Fish and Aquatic Species 

L Cultural Resources 

M Subsistence Uses and Resources 

N Environmental Justice 

O Economy 
Coastal Plain Oil and Gas Leasing Program vii 

Draft Environmental Impact Statement

ACRONYMS AND ABBREVIATIONS Full Phrase

μg/m3 micrograms per cubic meter 

μPa micro Pascal 

AAAQS Alaska Ambient Air Quality Standards 

AAC Alaska Administrative Code 

ACCS Alaska Center for Conservation Science 

ACP Arctic Coastal Plain 

ACRC Alaska Climate Research Center 

ADEC Alaska Department of Environmental Conservation 

ADFG Alaska Department of Fish and Game 

ADNR Alaska Department of Natural Resources 

ADOLWD Alaska Department of Labor and Workforce Development 

AHRS Alaska Heritage Resources Survey 

ANCSA Alaska Native Claims Settlement Act 

ANILCA Alaska National Interest Lands Conservation Act of 1980 

AOGCC Alaska Oil and Gas Conservation Commission 

APD Application for Permit to Drill 

APDES Alaska Pollutant Discharge Elimination System 

AQRV air quality related value 

ARCP Arctic Refuge Coastal Plain 

[Arctic] Refuge Arctic National Wildlife Refuge 

asl above sea level 

ASRC Arctic Slope Regional Corporation 

AWOS automated weather observing system 

bbl blue barrel 

BBO billion barrels of oil 

BLM Bureau of Land Management 

BMP best management practice 

BOEM Bureau of Ocean Energy Management 

BOPD barrels of oil per day 

BS Beaufort Sea stock 

CAA conflict avoidance agreement 

CAH Central Arctic Herd 

CASTNET Clean Air Status and Trends Network 

CCP Comprehensive Conservation Plan 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

CI confidence interval 

CO carbon monoxide 

CO2 carbon dioxide 

CO2e carbon dioxide equivalent 

CPF central processing facility 
ACRONYMS AND ABBREVIATIONS (continued) Full Phrase

viii Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

CSU controlled surface use 

dB decibels 

dBA A-weighted decibel 

DEW Distant Early Warning 

DOD Department of Defense 

DOI Department of the Interior 

DPS distinct population segment 

dv deciview 

ECS Eastern Chukchi Sea stock 

EFH Essential Fish Habitat 

EIS environmental impact statement 

EO executive order 

EPA US Environmental Protection Agency 

ESA Endangered Species Act of 1973 

°F Fahrenheit 

FAA Federal Aviation Administration 

FLIR forward-looking infrared radiometry 

FY fiscal year 

GFUR general fund unrestricted revenue 

GHG greenhouse gas 

GIS Geographic Information System 

GMT2 Greater Mooses Tooth 2 

GMU Game Management Unit 

HCP hydrocarbon potential 

IAP Integrated Activity Plan 

IHLC Iñupiat History, Language, and Cultural Division 

IMPROVE Interagency Monitoring for the Protection of Visual Environments 

ITR Incidental Take Regulation 

kg/ha-yr kilograms per hectacre per year 

kHz kilohertz 

KIC Kaktovik Iñupiat Corporation 

Leasing EIS Coastal Plain Oil and Gas Leasing Program Environmental Impact Statement 

LOA Letter of Authorization 

LRRS long-range radar sites 

M magnitude 
ACRONYMS AND ABBREVIATIONS (continued) Full Phrase

Coastal Plain Oil and Gas Leasing Program ix

Draft Environmental Impact Statement

MMPA Marine Mammal Protection Act 

MMT million metric tons 

MPA Marine Protected Area 

mya millions of years ago 

NAAQS National Ambient Air Quality Standards 

NDVI Normalized Difference Vegetation Index 

NEPA National Environmental Policy Act of 1969 

NHPA National Historic Preservation Act of 1966 

NMFS National Marine Fisheries Service 

NO2 nitrogen dioxide 

NOAA National Oceanographic and Atmospheric Administration 

NPDES National Pollutant Discharge Elimination System 

NPR-A National Petroleum Reserve-Alaska 

NRHP National Register of Historic Places 

NSB North Slope Borough 

NSO no surface occupancy 

NWI National Wetland Inventory 

NWS National Weather Service 

NWT Northwest Territory 

O3 ozone 

ORV outstandingly remarkable value 

Pb lead 

PCH Porcupine Caribou Herd 

PDO Pacific decadal oscillation 

PFYC Potential Fossil Yield Classification 

PL Public Law 

PM10 particulate matter less than 10 microns in diameter 

PM2.5 particulate matter less than 2.5 microns in diameter 

PSO protected species observer 

ROD record of decision 

ROP required operating procedure 

ROW right-of-way 

RS Revised Statute 

SAR stock assessment report 

SBS Southern Beaufort Sea 

SCC social cost of carbon 

SEIS Supplemental Environmental Impact Statement 

SHPO State Historic Preservation Office 

SO Secretarial Order 
ACRONYMS AND ABBREVIATIONS (continued) Full Phrase

x Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

SO2 sulfur dioxide 

STP seawater treatment plant 

TAPS Trans-Alaska Pipeline System 

TCF trillion cubic feet 

TCP Traditional Cultural Property 

TL timing limitation 

TLUI Traditional Land Use Inventory 

US United States 

USACE US Army Corps of Engineers 

USC United States Code 

USFWS US Fish and Wildlife Service 

USGS US Geological Survey 

VOC volatile organic compound 

VRI Visual Resource Inventory 

VSM vertical support member 

WSR wild and scenic river 
Coastal Plain Oil and Gas Leasing Program ES-1

Draft Environmental Impact Statement

Executive Summary

INTRODUCTION

The United States (US) Department of the Interior (DOI), Bureau of Land Management (BLM), Alaska 

State Office, is preparing this environmental impact statement (EIS) in accordance with the National 

Environmental Policy Act of 1969, as amended (NEPA), to implement an oil and gas leasing program in the 

Arctic National Wildlife Refuge (Arctic Refuge) Coastal Plain. Congress identified the Coastal Plain in 

Section 1002 of the Alaska National Interest Lands Conservation Act of 1980 (ANILCA) for its oil and 

natural gas potential; legislation was passed in December 2017 lifting a prohibition on oil and gas 

development imposed by Section 1003 of ANILCA and requiring BLM to implement an oil and gas leasing 

program. The Coastal Plain program area is composed of approximately 1,563,500 acres in the 

approximately 19.3-million-acre Arctic Refuge (Map 1-1, Program Area, in Appendix A). The oil and gas 

leasing program must also consider the Arctic Refuge purposes set out in Section 303(B)(2) of ANILCA, as 

amended, and modified by Section 20001 of Public Law (PL) 115-97 (Dec. 22, 2017) (PL 115-97).

PURPOSE AND NEED

Section 20001 of PL 115-97 requires the Secretary of the Interior, acting through the BLM, to establish and 

administer a competitive oil and gas program for the leasing, development, production, and transportation 

of oil and gas in and from the Coastal Plain area within the Arctic Refuge. Further, Section 20001 of PL 

115-97 requires that at least two lease sales be held by December 22, 2024, and that each sale offer for 

lease at least 400,000 acres of the highest hydrocarbon potential (HCP) lands within the Coastal Plain, 

allowing for up to 2,000 surface acres of Federal land to be covered by production and support facilities.

The BLM is undertaking this Coastal Plain Oil and Gas Leasing Program Environmental Impact Statement 

(Leasing EIS) to implement the leasing program consistent with PL 115-97. The Leasing EIS will serve to 

inform BLM’s implementation of PL 115-97, Section 20001(c)(1), which is the requirement to hold multiple 

lease sales. It may also inform post-lease activities, including seismic and drilling exploration, development, 

and transportation of oil and gas in and from the Coastal Plain. Specifically, the Leasing EIS considers and 

analyzes the environmental impact of various leasing alternatives, including the areas to offer for sale, and 

the indirect impacts that could result in consideration of the hypothetical development scenario. The 

alternatives analyze various terms and conditions (i.e., lease stipulations and required operating procedures

[ROPs]) to be applied to leases and associated oil and gas activities, to properly balance oil and gas 

development with protection of surface resources.

Future on-the-ground actions requiring BLM approval, including potential exploration and development 

proposals, would require further NEPA analysis based on the site-specific proposal. Potential applicants 

would be subject to the terms of the lease; however, the BLM Authorized Officer may require additional 

site-specific terms and conditions before authorizing any oil and gas activity based on the project level 

NEPA analysis.

DECISIONS TO BE MADE

The BLM’s decisions will include which tracts of land will be offered for lease and the terms and conditions 

to be applied to such leases and subsequent authorizations for oil and gas activities. The decisions 

evaluated in this Leasing EIS and its record of decision (ROD) would not authorize any on-the-ground 

activity associated with the exploration or development of oil and gas resources on the Coastal Plain. 
Executive Summary (Program Area)

ES-2 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

PROGRAM AREA

The US Fish and Wildlife Service (USFWS) is the predominant land manager in the program area. Other 

lands in the Coastal Plain include Alaska Native lands conveyed pursuant to Alaska Native Claims 

Settlement Act (ANCSA) and Native allotments (see Table ES-1 and Map 1-1 in Appendix A). The 

program area excludes a northern coastal portion of Air Force-administered lands near Kaktovik. Lands 

outside the BLM’s oil and gas leasing authority are those excluded from the definition of the Coastal Plain 

in PL 115-97, Native conveyed, and Native selected lands.

Table ES-1

Land Administration

Included in PL 115-97 Coastal Plain 

and Subject to the BLM’s Oil and 

Gas Leasing Authority

Acres

Included in PL 115-97 Coastal Plain 

but Outside the BLM’s Oil and Gas 

Leasing Authority

Acres

USFWS-managed lands, including 

submerged lands

1,562,600 Native-conveyed 24,400

Native allotment 900 Native-selected 4,400

Total 1,563,500 Total 28,800

Source: BLM Geographic Information Systems (GIS) 2018

Note: Acreages are rounded up or down to nearest 100.

SCOPING AND ISSUES

As part of the scoping process, the BLM considered public comments provided during scoping meetings 

held in Anchorage, Arctic Village, Fairbanks, Kaktovik, Utqiaġvik, and Venetie, Alaska, and in Washington, 

DC, during May and June 2018, when developing the alternatives for analysis in the Leasing EIS. It also 

considered input from cooperating agencies, tribes, and Native corporations. For more information on the 

scoping process, see the final scoping report on the BLM’s project website: https://goo.gl/HVo5Mj.

Issues such as fish and wildlife, including the Porcupine caribou herd (PCH), special status species, including 

polar bear, analysis of oil and gas activities, and subsistence use and traditional ways of life, were identified 

during scoping and addressed in this Leasing EIS. The full list of issue summaries is available in the final 

scoping report.

ALTERNATIVES

Alternative A—No Action Alternative

Under Alternative A (No Action Alternative), no federal minerals in the Coastal Plain would be offered for 

future oil and gas lease sales after the ROD for this EIS is signed. Alternative A would not comply with the 

directive under PL 115-97 to establish and administer a competitive oil and gas program for leasing, 

developing, producing, and transporting oil and gas in and from the Coastal Plain. Under this alternative, 

current management actions would be maintained, and resource trends are expected to continue, as 

described in the Arctic National Wildlife Refuge Revised Comprehensive Conservation Plan (CCP) 

(USFWS 2015a).

Alternative A would not meet the purpose and need of the action, which is the BLM’s implementation of 

PL 115-97, including the requirement to hold multiple lease sales and to permit associated post-lease oil 

and gas activities; however, Alternative A is being carried forward for analysis to provide a baseline for 

comparing impacts under the action alternatives, in accordance with the Council on Environmental Quality 

(CEQ) NEPA regulations.
Executive Summary (Alternatives)

Coastal Plain Oil and Gas Leasing Program ES-3

Draft Environmental Impact Statement

Alternative B

The entire program area under Alternative B could be offered for lease sale, and there would be the 

fewest acres with no surface occupancy (NSO) stipulations. In addition to applicable lease stipulations, 

several ROPs would apply to post-lease oil and gas activities to reduce potential impacts. Approximately 

1,563,500 acres would be offered for lease, 359,400 acres would be subject to a NSO stipulation, and 

585,400 acres would be subject to timing limitations (TLs). Standard terms and conditions would apply to 

approximately 618,700 acres.

Alternative C

The entire program area could also be offered for lease sale under Alternative C; however, a large portion 

of the program area would be subject to NSO. The BLM would rely on the same ROPs as under 

Alternative B to reduce potential impacts from post-lease oil and gas activities. Approximately 1,563,500 

acres would be offered for lease, 932,500 acres would be subject to NSO, and 317,100 acres would be 

subject to TLs. Standard terms and conditions would apply to approximately 313,900 acres.

Alternative D

Under Alternative D, portions of the Coastal Plain would not be offered for lease sale to protect biological 

and ecological resources. In addition, a large portion of the remaining area would be subject to NSO. In 

some instances, more prescriptive ROPs are analyzed under Alternative D, than under Alternatives B and 

C.

Alternative D contains two sub-alternatives, Alternatives D1 and D2, for the issue of caribou summer 

habitat. The two sub-alternatives use different approaches to mitigate impacts on caribou summer habitat 

through lease stipulations. Under both sub-alternatives, approximately 1,037,200 acres would be offered 

for lease, 708,600 acres would be subject to NSO, and 123,900 acres would be subject to controlled 

surface use (CSU). Alternative D1 would have no areas subject to TLs but would have approximately 

204,700 acres subject to standard terms and conditions. Alternative D2 would have approximately 204,700 

acres of TLs and no areas subject to standard terms and conditions.

The complete list of lease stipulations and ROPs under each alternative are presented in Table 2-2 in 

Chapter 2.

HYPOTHETICAL DEVELOPMENT SCENARIO

The BLM developed a hypothetical development scenario for oil and gas exploration, development, production, 

and abandonment in the PL 115-97 Coastal Plain. The agency used this to analyze the environmental impacts of 

leasing and development over approximately the next 50 years. An estimated 427,900 acres of the program 

area has high potential for petroleum resources, 658,400 acres have medium potential, and 477,200 acres have 

low potential. This hypothetical baseline scenario assumes all potentially productive areas can be open under 

standard lease terms and conditions, except those areas outside the BLM’s oil and gas leasing authority. This 

hypothetical baseline scenario allows decision-makers to analyze the effect that different discretionary 

management decisions could have on future oil and gas activities in the program area. The BLM then developed 

different hypothetical scenarios, with different terms and conditions relating to environmental protection, so 

that a range of impacts on resources could be analyzed.

The program area contains an estimated 7.687 billion barrels of technically recoverable oil and 7.04 trillion 

cubic feet (TCF) of technically recoverable natural gas (Attanasi 2005). Due to high costs associated with 

operating in the Arctic, it is extremely unlikely that all technically recoverable resources would be 

produced. The US Energy Information Administration estimated that a total of approximately 3.4 billion 
Executive Summary (Hypothetical Development Scenario)

ES-4 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

barrels of oil (BBO) would be produced in the Arctic Refuge by 2050 (Van Wagner 2018). Estimated 

natural gas production from the Coastal Plain ranges from 0 to 7 TCF of gas produced (Attanasi 2005). See 

Appendix B for more information on development potential, assumptions behind potential estimates, and 

estimates for the baseline future hypothetical development scenario for petroleum.

IMPACT ANALYSIS

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis in Chapter 3 is of potential direct, indirect, 

and cumulative impacts from on-the-ground post-lease activities, which can be considered potential 

indirect impacts of leasing.

The geographic scope of the analysis includes marine vessel traffic from the shore of the refuge to Dutch 

Harbor, Alaska. Direct and indirect impacts cannot be analyzed on a site-specific basis within this EIS, but 

they are analyzed for the program area generally, based on the hypothetical development scenario. 

Additional site-specific analyses would be conducted during the permit review process for subsequent 

exploration and development applications.

If leases were explored and developed, the following general impacts would be expected from future oil 

and gas exploration, development, and production activities:

 Potential impacts on subsistence users, both from impacts on subsistence species and from direct 

disturbance of hunts, displacement of resources from traditional harvest areas, and hunter 

avoidance of industrialized areas

 Impacts on water quality caused by water extraction and construction of ice roads and pads, 

gravel mining, and wastewater discharges from a central processing facility (CPF)

 Impacts from routine activities on air quality due to release of pollutants

 Greenhouse gas (GHG) emissions from exploration and development 

 Potential impacts on birds from predators and increased human presence

 Potential impacts on marine mammals, including human-polar bear interactions; vehicle, aircraft 

and boat traffic and noise disturbance; and accidental, unplanned take by vessel strikes or oil spills

 Impacts on terrestrial mammals, including disturbance from vehicle and aircraft noise, human 

presence, and habitat fragmentation and loss 

 Disturbance and loss of permafrost, vegetation, and wetlands

 Potential impacts on state employment, labor income, and revenues

 Potential impacts on North Slope Borough (NSB) employment, income, and revenue

 Potential impacts on cultural resources by lease development

 Visual impacts from infrastructure and artificial light

 Loss or reduced quality of some access to recreation and use opportunities around areas leased 

for energy infrastructure
Executive Summary (Impact Analysis)

Coastal Plain Oil and Gas Leasing Program ES-5

Draft Environmental Impact Statement

Residents of Kaktovik are the primary users of the program area and would therefore be most likely to 

experience potential impacts from future development. The community of Nuiqsut could experience 

impacts on caribou, waterfowl, and fish harvests from development. Residents of Arctic Village, Venetie, 

and other communities that use the PCH and Central Arctic Caribou Herd (CAH) could experience 

potential impacts from future development on caribou and, to a lesser extent, waterfowl. Most visitors to 

the Arctic Refuge come specifically to locations within the program area. With expected increases in 

recreation, coupled with decreased access to recreation in areas, users of the Coastal Plain would be likely 

to experience impacts from future post-lease development.

COLLABORATION AND COORDINATION

The BLM is the lead agency for this EIS. Cooperating agencies are the USFWS, US Environmental 

Protection Agency (EPA), State of Alaska, NSB, Native Village of Kaktovik, Native Village of Venetie Tribal 

Government, Venetie Village Council, and the Arctic Village Council.

The BLM, as the lead federal agency, consulted with federally recognized tribal governments during 

preparation of this EIS. The BLM has contacted the Arctic Village Council, Inupiat Community of the Arctic 

Slope, Native Village of Kaktovik, Venetie Village Council, Native Village of Venetie Tribal Government, 

Beaver Village Council, Birch Creek Tribal Council, Chalkyitsik Village Council, Gwichyaa Zhee Gwich'in 

Tribal Government (Fort Yukon), Naqsragmiut Tribal Council (Anaktuvuk Pass), Native Village of Barrow 

Iñupiat Traditional Government, Native Village of Nuiqsut, and Native Village of Stevens. The BLM offered 

these entities the opportunity to participate in formal government-to-government consultation, to 

participate as cooperating agencies, or to simply receive information about the project. The dates and 

locations of government-to-government meetings that have taken place are provided in Appendix C. 

The BLM is also consulting with the Arctic Slope Regional Corporation (ASRC) and Kaktovik Iñupiat 

Corporation (KIC) under the DOI’s Policy for Consultation with ANCSA Corporations. The BLM also 

held consultations with Doyon, Limited, to discuss the EIS process (see Appendix C).

The BLM is consulting with the Alaska State Historic Preservation Office (SHPO), in accordance with 

Section 106 of the National Historic Preservation Act of 1966 (NHPA). This is to determine how 

proposed activities could affect cultural resources listed on or eligible for listing on the National Register 

of Historic Places (NRHP). 

To comply with Section 7(a)(2) of the Endangered Species Act of 1973 (ESA), the BLM began consulting 

with the USFWS and National Marine Fisheries Service (NMFS) early in the EIS process. Both provided 

input on issues, data collection and review, and alternatives development. The BLM is consulting with the 

USFWS and NMFS to identify ESA issues and to develop the draft biological assessment.

Section 810 of ANILCA focuses on issues related to the effects of proposed activities on subsistence use. 

An ANILCA Section 810 notice and public hearing process is required if a proposed action may 

significantly restrict subsistence uses and needs. A preliminary evaluation and proposed finding of effects on 

subsistence uses and needs from actions that could be undertaken under the four alternatives considered 

in this EIS is provided in Appendix E. The preliminary evaluation finds that the cumulative case, when 

taken in conjunction with Alternatives B, C, D1, and D2 may significantly restrict subsistence uses and 

needs for the community of Kaktovik. Due to these preliminary findings, a public subsistence hearing will 

be held in the potentially affected community of Kaktovik. 
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Coastal Plain Oil and Gas Leasing Program 1-1

Draft Environmental Impact Statement

Chapter 1. Introduction

1.1 OVERVIEW

The BLM Alaska State Office is preparing this EIS in accordance with NEPA, as amended, to implement an 

oil and gas leasing program in the Arctic Refuge Coastal Plain. Congress identified the Coastal Plain in 

Section 1002 of ANILCA for its oil and natural gas potential. Legislation was passed in December 2017, PL 

115-97, lifting a prohibition on oil and gas development imposed by Section 1003 of ANILCA and requiring 

BLM to implement an oil and gas leasing program. The Coastal Plain program area is composed of 

approximately 1,563,500 acres in the approximately 19.3-million-acre Arctic Refuge (Map 1-1, Program 

Area, in Appendix A). The oil and gas leasing program must consider the Arctic Refuge purposes set out 

in Section 303(2)(B) of ANILCA, as amended by Section 20001 of PL 115-97.

BLM is developing the EIS to implement Section 20001(c)(1) of PL 115-97, and, specifically, to analyze the 

environmental impacts of issuing oil and gas leases in accordance with that directive. Issuance of an oil and 

gas lease does not have any direct effects on the environment since it does not authorize drilling or any 

other ground disturbing activities; however, a lease does grant the lessee certain rights to drill for and 

extract oil and gas subject to reasonable regulation, including applicable laws, terms, conditions, and 

stipulations of the lease. Although the BLM cannot ascertain the precise extent of the effects of granting 

those rights until it receives and reviews potential future site-specific proposals for exploration and 

development, in order to meet the intent of NEPA, and as described in the CEQ Forty Most Asked Questions 

Concerning CEQ’s National Environmental Policy Act Regulations, the BLM has developed a hypothetical 

development scenario consistent with those leases, in a good faith effort to identify indirect effects that are 

not known at this time but nonetheless could be considered "reasonably foreseeable" (40 Code of Federal 

Regulations [CFR] Section 1508.8(b)) (see Appendix B).

The BLM developed the hypothetical development scenario in recognition of not only the rights granted by 

an oil and gas lease but also PL 115-97’s direction to the Secretary to “manage the oil and gas program in 

the Coastal Plain in a manner similar to the administration of lease sales under the Naval Petroleum 

Reserves Production Act of 1976 (including regulations).” However, there is tremendous uncertainty 

regarding potential exploration and development on the Coastal Plain and any development scenario at 

this point is highly speculative given that it is unknown whether or where leases will be issued, whether or 

where exploratory drilling may occur under such leases, whether or where economically developable oil 

and gas discoveries may be made, the remoteness and lack of previous exploration and development of the 

Coastal Plain as well as its harsh environment and challenging engineering considerations, and the extended 

time it has taken to go from leasing to development in other regions of the North Slope of Alaska 

including in the National Petroleum Reserve-Alaska (NPR-A). 

1.2 PURPOSE AND NEED

Section 20001 of PL 115-97 requires the Secretary of the Interior, acting through the BLM, to establish and 

administer a competitive oil and gas program for the leasing, development, production, and transportation 

of oil and gas in and from the Coastal Plain area within the Arctic Refuge. Further, Section 20001 of PL 

115-97 requires that at least two lease sales be held by December 22, 2024, and that each sale offer for 

lease at least 400,000 acres of the highest HCP lands within the Coastal Plain, allowing for up to 2,000 

surface acres of Federal land to be covered by production and support facilities.
1. Introduction (Purpose and Need)

1-2 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

The BLM is undertaking this Leasing EIS to implement the leasing program consistent with PL 115-97. The 

Leasing EIS will serve to inform BLM’s implementation of PL 115-97, Section 20001(c)(1), which is the 

requirement to hold multiple lease sales. It may also inform post-lease activities, including seismic and 

drilling exploration, development, and transportation of oil and gas in and from the Coastal Plain. 

Specifically, the Leasing EIS considers and analyzes the environmental impact of various leasing alternatives, 

including the areas to offer for sale, and the indirect impacts that could result in consideration of the 

hypothetical development scenario. The alternatives analyze various terms and conditions (i.e., lease 

stipulations and ROPs) to be applied to leases and associated oil and gas activities, to properly balance oil 

and gas development with protection of surface resources.

Future on-the-ground actions requiring BLM approval, including potential exploration and development 

proposals, would require further NEPA analysis based on the site-specific proposal. Potential applicants 

would be subject to the terms of the lease; however, the BLM Authorized Officer may require additional 

site-specific terms and conditions before authorizing any oil and gas activity based on the project level 

NEPA analysis.

1.3 DECISIONS TO BE MADE

The BLM’s decisions will include which tracts of land will be offered for lease and the terms and conditions 

to be applied to such leases and subsequent authorizations for oil and gas activities. The decisions 

evaluated in this Leasing EIS and its ROD would not authorize any on-the-ground activity associated with 

the exploration or development of oil and gas resources on the Coastal Plain.

1.4 PROGRAM AREA

The USFWS is the predominant land manager in the program area. Other lands in the Coastal Plain include 

Alaska Native lands conveyed pursuant to ANCSA and Native allotments (see Table 1-1).

Table 1-1

Land Administration

Included in PL 115-97 Coastal Plain 

and Subject to the BLM’s Oil and 

Gas Leasing Authority

Acres

Included in PL 115-97 Coastal Plain

but Outside the BLM’s Oil and Gas 

Leasing Authority

Acres

USFWS-managed lands, including 

submerged lands

1,562,600 Native-conveyed 24,400

Native allotment 900 Native-selected 4,400

Total 1,563,500 Total 28,800

Source: BLM GIS 2018

Note: Acreages are rounded up or down to nearest 100.

The Coastal Plain program area was previously referred to as the 1002 Area. The program area includes 

all Federal lands and waters comprising the approximately 1,563,500 acres of the Coastal Plain within the 

19.3 million-acre Arctic Refuge (Map 1-1 in Appendix A). The program area excludes a northern coastal 

portion of Air Force-administered lands near Kaktovik. Lands outside the BLM’s oil and gas leasing 

authority are those lands excluded from the definition of the Coastal Plain in PL 115-97, Native conveyed 

lands, and Native selected lands.

1.5 SCOPING AND ISSUES

The BLM conducted formal scoping for the Leasing EIS following publication of a Notice of Intent in the 

Federal Register on April 20, 2018. In May and June 2018, the BLM held scoping meetings in Alaska, in 
1. Introduction (Scoping and Issues)

Coastal Plain Oil and Gas Leasing Program 1-3

Draft Environmental Impact Statement

Anchorage, Arctic Village, Fairbanks, Kaktovik, Utqiaġvik, and Venetie, and also in Washington, DC. Oral 

comments were captured by a court reporter at all meetings. The BLM formally accepted scoping

comments through June 15, 2018. For more information on the scoping process, see the final scoping 

report on the BLM’s project website: https://goo.gl/HVo5Mj.

The following summaries highlight a few of the issues identified during scoping and addressed in this

Leasing EIS. The full list of summaries is available in the final scoping report.

 Fish and wildlife—Commenters stated concerns about impacts on fish and wildlife, including 

caribou and other large terrestrial mammals, marine mammals, migratory birds, and fish and other 

aquatic species. Potential impacts on the PCH were of particular concern. Commenters requested 

that the EIS evaluate the use and importance of the program area to herd movement during 

different life stages and seasons and how the proposed program might affect calving grounds, 

insect relief areas, and migration routes.

 Special status species—Commenters noted that the proposed program could reduce and 

fragment available terrestrial denning habitat for the Southern Beaufort Sea (SBS) subpopulation of 

polar bear, which is listed as threatened under the ESA. Commenters requested that the BLM

analyze impacts on all special status species, including marine mammals, such as ringed seals, 

bearded seals, and bowhead whales.

 Oil and gas—Commenters requested that the EIS analysis consider direct, indirect, and 

cumulative impacts of all aspects of oil and gas exploration and development; examples given were 

access routes, support facilities, and other infrastructure needed for exploration and development 

and their potential future impacts.

 2,000-acre disturbance limit—Commenters requested further definition of the 2,000-acre 

surface disturbance limit, as defined in PL 115-97, and asked for clarification on what types of 

surface disturbance would be included and how the 2,000-acre footprint would be measured.

 Subsistence and sociocultural systems—Commenters noted that local tribes are culturally 

tied to the Coastal Plain and the PCH and requested that the BLM analyze impacts on their 

traditional way of life. They asked that the BLM consider the positive and negative economic 

changes to communities, impacts on traditional subsistence-based economy, food scarcity, changes 

to access to traditional subsistence use areas, and subsistence food resources.

Issues outside of the scope of the EIS were also identified during scoping, as follows:

 Comments advocating keeping the Coastal Plain closed to oil and gas leasing

 Comments about land management actions outside of BLM’s jurisdiction

 Comments on issues that do not meet the stated purpose and need of the EIS, such as investing in 

renewable energy alternatives instead of an oil and gas leasing program

1.6 EIS PROCESS

The Leasing EIS process began with the notice of intent to prepare the EIS, followed by the formal scoping 

period (see Section 1.5, Scoping and Issues). After the scoping period and after receiving additional input 

from the public, the BLM consulted with the cooperating agencies, tribes, and ANCSA corporations, 

researched information on the resources and uses of the area, developed a range of reasonable 

management alternatives, and analyzed the impacts of those alternatives. These analyses underwent review 
1. Introduction (EIS Process)

1-4 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

within the BLM and among the cooperating agencies, resulting in this draft EIS. This is the second major 

public step in the EIS process. 

The public and agencies will be able to comment on this document. Based on these comments and any new 

studies or information that may come to light after publication of the draft EIS, the BLM will revise the 

document and issue a final EIS. The BLM will not issue its decision on the leasing program, called the ROD, until 

at least 30 days after the EPA publishes the Notice of Availability of the final EIS in the Federal Register.

1.7 COLLABORATION AND COORDINATION

1.7.1 Lead and Cooperating Agencies

The BLM is the lead agency for this EIS. Participating in the Leasing EIS as cooperating agencies are the 

USFWS, EPA, State of Alaska, NSB, Native Village of Kaktovik, Native Village of Venetie Tribal 

Government, Venetie Village Council, and Arctic Village Council. The BLM requested their participation 

because of their expertise; their participation does not constitute their approval of the analysis, 

conclusions, or alternatives presented in this EIS; for these, the BLM is solely responsible. The list of 

preparers for the Leasing EIS is in Appendix C. 

1.7.2 Consultation with Tribes and ANCSA Corporations

The BLM, as the lead federal agency, consulted with federally recognized tribal governments during 

preparation of this EIS and identified 16 tribes potentially affected by the leasing program. Consistent with 

DOI policy on government-to-government consultation with tribes, the BLM first sent a letter of 

notification and inquiry on March 2, 2018, to the Arctic Village Council, the Inupiat Community of the 

Arctic Slope, the Native Village of Kaktovik, the Venetie Village Council, and the Native Village of Venetie 

Tribal Government. In its letter, the BLM offered these entities the opportunity to participate in formal 

government-to-government and Section 106 consultations, to participate as cooperating agencies, or to 

simply receive information about the project. 

The BLM sent a second invitation letter on April 23, 2018, to the following tribal entities: Beaver Village 

Council, Birch Creek Tribal Council, Chalkyitsik Village Council, Gwitchyaa Zhee Gwich'in Tribal 

Government (Fort Yukon), Naqsragmiut Tribal Council (Anaktuvuk Pass), Native Village of Barrow Iñupiat 

Traditional Government, Native Village of Nuiqsut, and the Native Village of Stevens. The dates and 

locations of government-to-government meetings that have taken place are provided in Appendix C.

Discussions with potentially affected tribal governments will occur throughout the EIS process.

The BLM also sent a letter of notification and inquiry on March 2, 2018, to ASRC and KIC, offering the 

opportunity to participate in formal ANCSA corporations consultation. The BLM has held consultations

with both ANCSA corporations, as well as Doyon, Limited, to discuss the EIS process (see Appendix C).

1.7.3 Coordination and Consultation with Local, State, and Federal Agencies

The BLM is consulting with the Alaska SHPO, in accordance with Section 106 of the NHPA. This is to 

determine how proposed activities could affect cultural resources listed on or eligible for listing on the 

NRHP. Formal consultations with the SHPO also may be required when individual projects are 

implemented. SHPO consultations for the leasing program are ongoing and will be completed by the time 

the ROD is signed.

To comply with Section 7(a)(2) of the ESA, the BLM began consulting with the USFWS and NMFS early in 

the EIS process. The USFWS and NMFS provided input on issues, data collection and review, and 
1. Introduction (Collaboration and Coordination)

Coastal Plain Oil and Gas Leasing Program 1-5

Draft Environmental Impact Statement

alternatives development. The BLM is consulting with the USFWS and NMFS to identify ESA issues and to 

develop the draft biological assessment.

1.8 REQUIREMENTS FOR FURTHER ANALYSIS

The decision on oil and gas leasing resulting from this EIS will authorize multiple lease sales. Any lease sales 

based on this EIS could be conducted after the ROD is issued. For impact analysis, this EIS assumes that no 

fewer than 400,000 acres of land that the ROD determines to be available for leasing would be offered in 

the first two lease sales; however, the first sale and subsequent sales might offer only a portion of the lands 

identified in the ROD as available, making possible a phased approach to leasing and development. 

The timing of subsequent lease sales and the lands offered therein would depend in part on the response 

to the first sale and the results of the exploration that follows. This EIS is intended to fulfill NEPA 

requirements for lease sales conducted at least through December 2027 and potentially thereafter. Before 

it conducts the second and each subsequent lease sale, the BLM will evaluate the adequacy of the EIS in 

light of new information and circumstances to determine whether it requires supplementation or revision 

in order to comply with NEPA. 

Future on-the-ground actions requiring BLM approval, including potential exploration and development 

proposals, would require further NEPA analysis based on the site-specific proposal. Potential applicants 

would be subject to the terms of the lease; however, the BLM Authorized Officer may require additional 

site-specific terms and conditions before authorizing any oil and gas activity based on the project level 

NEPA analysis.

1.9 INTERNATIONAL AGREEMENTS, LAWS, REGULATIONS, AND PERMITS

In implementing the Coastal Plain Oil and Gas Leasing Program, the BLM would comply with applicable 

international agreements, federal, state, and local laws, regulations, and executive orders (EOs). Secretarial 

Order (SO) 3349, American Energy Independence, issued on March 29, 2017, directed the DOI, under EO

13783, Promoting Energy Independence and Economic Growth (March 28, 2017), to “review all existing 

regulations, orders, guidance documents, policies, and any other similar actions that potentially burden the 

development or utilization of domestically produced energy resources.” This SO can be viewed in its 

entirety at https://elips.doi.gov/elips/0/doc/4512/Page1.aspx. SO 3360, issued on December 22, 2017, 

rescinded orders and guidance that were found to be inconsistent with SO 3349. The SO can be viewed in 

its entirety at https://elips.doi.gov/elips/0/doc/4628/Page1.aspx.

In 1987, the United States and Canadian governments signed the Agreement between the Government of 

the United States of America and the Government of Canada on the Conservation of the Porcupine 

Caribou Herd. The main objectives of the agreement are to conserve the herd and its habitat through 

international cooperation and coordination. The goal is to minimize the risk of irreversible damage or 

long-term adverse effects, including cumulative effects, as a result of use of caribou or their habitat. 

Further, it ensures opportunities for customary and traditional uses of the PCH. The agreement set up the 

International Porcupine Caribou Board, composed of delegated representatives from both countries, who

give advice and recommendations to the countries on the conservation and management of the herd.

For a summary of other applicable international agreements, federal, state, and local laws, regulations, 

permits, and EOs, refer to Appendix D. The BLM will continue to consult with regulatory agencies, as 

appropriate, during the NEPA process and before oil and gas activities are authorized, to ensure that all 

requirements are met.
1. Introduction (International Agreements, Laws, Regulations, and Permits)

1-6 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

1.9.1 Tax Cuts and Jobs Act of 2017 (Public Law 115-97)

Section 20001(c)(3) of PL 115-97 states:

SURFACE DEVELOPMENT—In administering this section, the Secretary shall authorize up to 

2,000 surface acres of Federal land on the Coastal Plain to be covered by production and support 

facilities (including airstrips and any area covered by gravel berms or piers for support of pipelines) 

during the term of the leases under the oil and gas program under this section.

The BLM interprets this provision of PL 115-97 as limiting to 2,000 the total number of surface acres of all

Federal land across the Coastal Plain, regardless of whether such land is leased, which may be covered by 

production and support facilities at any given time. BLM is applying this acreage limit to non-leased Federal 

lands because Section 20001(c)(2) of PL 115-97 provides for the issuance of rights-of-way (ROWs) or 

easements across the Coastal Plain regardless of lease status and since in some cases production and 

support facilities (e.g., pipelines) may be constructed pursuant to such ROWs or easements. BLM is 

applying this limit to the total acreage of production and support facilities existing at any given moment in 

time, as opposed to the cumulative total acreage of production and support facilities that may ever exist, 

because the language “during the term of the leases” in Section 20001(a)(3) indicates a temporal limit was 

intended by Congress. Under this interpretation the reclaimed acreage of Federal land formerly containing 

production and support facilities would no longer count towards the 2,000-acre limit. 

The BLM interprets this limitation to generally refer to acres of land directly occupied by facilities that are 

primarily used for the purpose of development, production, and transportation of oil and gas in and from 

the Coastal Plain. In applying that standard, 1) “facility” is given its ordinary dictionary definition, which is 

something that is built, installed, or established to serve a particular purpose; here, the development, 

production, and transportation of oil and gas in and from the Coastal Plain; 2) the limitation does not apply 

to surface disturbance indirectly related to or resulting from those facilities, as those surface acres are not 

“covered by” the facilities themselves; and 3) given the explicit language of PL 115-97 relating to “piers” for 

supporting pipelines, the limitation applies only to those portions of oil and gas facilities that actually touch 

the land’s surface. Thus, BLM interprets the types of “production and support” facilities that will count 

toward the 2,000-acre limit as including any type of gravel or other fill constructed facility which touches 

the land’s surface, to include: gravel pads used for processing facilities (including wells), production facilities, 

or pump or compressor stations; gravel airstrips or roads; and any other area covered by gravel berms or 

piers for support of pipelines. Examples of types of facilities or disturbance that will not count toward the 

2,000-acre limit include facilities constructed with snow or ice (e.g., ice roads/pads) and the portion of 

facilities that do not touch the land’s surface (e.g., elevated pipelines). Facilities constructed with snow or 

ice have a fleeting existence, and thus this aspect of BLM’s interpretation is consistent with the temporal 

limit intended by Congress. Moreover, inclusion of such facilities would make Congress’s clear purpose –

establishment of an oil and gas program on the Coastal Plain – impracticable. In addition, the BLM 

interprets “production and support facilities” to exclude gravel mines given that they supply raw materials 

for construction of oil and gas facilities but are not themselves oil and gas facilities any more than are mills 

that supply steel for construction of pipelines and other facilities.

The BLM employs this interpretation of Section 20001(c)(3) of PL 115-97 as an assumption in each of the 

action alternatives analyzed in the EIS. This interpretation limits surface use in any instance where the 

construction of facilities substantially disturbs the tundra surface but does not restrict the use of winter 

snow/ice surfaces which melt away each summer and leave the tundra surface largely undisturbed. It also 
1. Introduction (International Agreements, Laws, Regulations, and Permits)

Coastal Plain Oil and Gas Leasing Program 1-7

Draft Environmental Impact Statement

appropriately conserves surface resources and provides an incentive to rapidly reclaim impacted land while 

still allowing for a reasonable amount of practical and feasible oil and gas development to occur.

The BLM welcomes public comment on its interpretation of PL 115-97 provision Section 20001(c)(3), in 

addition to comment on the draft EIS generally.

1.10 ANILCA SECTION 810 EVALUATION

Section 810 of ANILCA focuses on issues related to the effects of proposed activities on subsistence use. 

An ANILCA Section 810 notice and public hearing process is required if a proposed action may 

significantly restrict subsistence uses and needs. A preliminary evaluation and proposed finding of effects on 

subsistence uses and needs from actions that could be undertaken under the four alternatives considered 

in this EIS is provided in Appendix E. The preliminary evaluation finds that the cumulative case, when 

taken in conjunction with Alternatives B, C, D1, and D2 may significantly restrict subsistence uses and 

needs for the community of Kaktovik. Due to these preliminary findings, a public subsistence hearing will 

be held in the potentially affected community of Kaktovik. 

1.11 TRANSLATION

This EIS may be translated into a language other than English to facilitate public participation in the decision 

process. The English-language version has been prepared by BLM and is the official version of the 

document for all purposes. Any translated version of this document has been prepared for the 

convenience of non-English-speaking members of the public. In the event of any discrepancy, the Englishlanguage version controls.
This page intentionally left blank.
Coastal Plain Oil and Gas Leasing Program 2-1 

Draft Environmental Impact Statement

Chapter 2. Alternatives

2.1 INTRODUCTION

The alternatives presented in this chapter address the public’s concerns, particularly those comments 

expressed during the formal scoping period, as well as those raised through consultation with tribes, 

Native corporations, and cooperating agencies. The range of alternatives presented in this chapter was 

developed by the BLM’s Alaska State Office, in coordination with the cooperating agencies. The 

alternatives respond to the purpose and need for action, including the legislative requirement to establish 

and administer a competitive oil and gas program in the Coastal Plain in the Arctic Refuge. 

The alternatives have benefitted from the insights and expertise of the cooperating agencies, though those 

agencies are not responsible for the range of alternatives examined in this Leasing EIS (see Section 1.7.1, 

Lead and Cooperating Agencies, for a list of the cooperating agencies). The BLM as the lead agency is 

solely responsible for the alternatives in this Leasing EIS. 

The action alternatives (Alternatives B, C, and D) described in Section 2.2, Description of the 

Alternatives, include a mix of lease stipulations and ROPs that contain measures to avoid or mitigate 

surface damage and minimize ecological disturbance throughout the program area. There is no BLMpreferred alternative. A preferred alternative will be identified in the final EIS. 

The BLM is analyzing this range of alternatives to ensure that a wide range of management options are 

considered, consistent with applicable law and the purposes of the Arctic Refuge, and to address public 

scoping suggestions and agency concerns to protect resources. Any decision that the BLM makes following 

the analysis in this Leasing EIS must be consistent with PL 115-97. It must also conform to other applicable 

laws and regulations. The oil and gas leasing program must also consider the Refuge purposes set out in 

Section 303(B)(2) of ANILCA, as amended, and modified by Section 20001 of PL 115-97.

2.2 DESCRIPTION OF THE ALTERNATIVES

Table 2-1 highlights the key differences among alternatives relative to areas available for leasing and lease 

stipulations. Table 2-2 is a complete description of all decisions proposed for each alternative. 

Table 2-1 

Quantitative Summary of Lease Stipulations by Alternative 

Lease Availability/Stipulations Alternative (Acres)

B C D1 D2

Available 

for lease 

sale

Subject to NSO 359,400 932,500 708,600 708,600

Subject to CSU 0 0 123,900 123,900

Subject to TLs 585,400 317,100 0 204,700

Subject to only standard terms and 

conditions

618,700 313,900 204,700 0

Total available for lease sale 1,563,500 1,563,500 1,037,200 1,037,200

Not offered for lease sale 0 0 526,300 526,300

Source: BLM GIS 2018 
2. Alternatives (Description of the Alternatives) 

2-2 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

2.2.1 Alternative A—No Action Alternative 

Under Alternative A, the No Action Alternative, no federal minerals in the Coastal Plain would be offered 

for future oil and gas lease sales after the ROD for this EIS has been signed. Alternative A would not 

comply with the directive under PL 115-97 to establish and administer a competitive oil and gas program 

for leasing, developing, producing, and transporting oil and gas in and from the Coastal Plain in the Arctic 

Refuge. Under this alternative, current management actions would be maintained, and resource trends are 

expected to continue, as described in the Arctic Refuge Revised CCP (USFWS 2015a). 

Alternative A would not meet the purpose and need of the action, which is the BLM’s implementation of 

PL 115-97, including the requirement to hold multiple lease sales and to permit associated post-lease oil 

and gas activities; however, Alternative A is being carried forward for analysis to provide a baseline for 

comparing impacts under the action alternatives, as required by the CEQ NEPA regulations. 

2.2.2 Alternative B 

The entire program area under Alternative B could be offered for lease sale and there would be the fewest 

acres with NSO stipulations. In addition to applicable lease stipulations, several ROPs would apply to postlease oil and gas activities to reduce potential impacts. Areas of the Coastal Plain that are available for lease 

sale under Alternative B are shown in Map 2-1, Alternative B, and Map 2-2, Alternative B, Lease 

Stipulations. 

2.2.3 Alternative C 

The entire program area could also be offered for lease sale under Alternative C; however, a large portion 

of the program area would be subject to NSO. The BLM would rely on the same ROPs as under 

Alternative B to reduce potential impacts from post-lease oil and gas activities. Areas of the Coastal Plain 

that are available for lease sale under Alternative C are shown in Map 2-3, Alternative C, and Map 2-4, 

Alternative C, Lease Stipulations. 

2.2.4 Alternative D 

Under Alternative D, portions of the Coastal Plain would not be offered for lease sale to protect biological 

and ecological resources. In addition, a large portion of the remaining area would be subject to NSO. In 

some instances, more prescriptive ROPs are analyzed under Alternative D than under Alternatives B and 

C. 

Alternative D contains two sub-alternatives, Alternatives D1 and D2, which use different approaches to 

mitigate impacts on caribou summer habitat through lease stipulations. Areas of the Coastal Plain that are 

available for lease sale under Alternative D1 are shown in Map 2-5, Alternative D1, and Map 2-6, 

Alternative D1, Lease Stipulations. Alternative D2 lands available for lease sale are shown in Map 2-7, 

Alternative D2, and Map 2-8, Alternative D2, Lease Stipulations. 

2.2.5 Lease Stipulations and Required Operating Procedures 

Protective measures in Alternatives B, C, and D are of two types: lease stipulations and ROPs (see Table 

2-2, below). 

Lease Stipulations 

Appropriate stipulations are attached to the lease before the BLM issues it. As part of a lease contract, 

stipulations are specific to the lease. All oil and gas activity permits issued to a lessee must comply with the 

lease stipulations appropriate to the activity under review, such as exploratory drilling or production pad 

construction. 
2. Alternatives (Description of the Alternatives)

Coastal Plain Oil and Gas Leasing Program 2-3

Draft Environmental Impact Statement

A stipulation included in an oil and gas lease would be subject to the following, as appropriate:

 A waiver—A permanent exemption to a stipulation on a lease

 An exception—A one-time exemption to a lease stipulation, determined on a case-by-case basis

 A modification—A change attached to a lease stipulation, either temporarily or for the life of the 

lease

The BLM Authorized Officer may authorize a modification to a lease stipulation only if they determine that 

the factors leading to the stipulation have changed sufficiently to make the stipulation no longer justified; 

the proposed operation would still have to meet the objective stated for the stipulation.

While the BLM may grant a waiver, exception, or modification of a stipulation through the permitting 

process, it may also impose additional requirements through permitting terms and conditions to meet the 

objectives of any stipulation. This would be the case if the BLM Authorized Officer considers that such 

requirements are warranted to protect the land and resources, in accordance with the BLM’s 

responsibility under relevant laws and regulations.

Required Operating Procedures

The ROPs under Alternatives B, C, and D describe the protective measures that the BLM would impose 

on applicants during the permitting process. Together with the lease stipulations, the ROPs also provide a 

basis for analyzing the potential impacts of the alternatives in this Leasing EIS.

Any applicant requesting authorization for an activity from the BLM will have to address the applicable 

ROPs in one of the following ways:

 Before submitting the application (e.g., performing and documenting subsistence consultation or 

surveys)

 As part of the application proposal (e.g., including in the proposal statements that the applicant will 

meet the objective of the ROP and how the applicant intends to achieve that objective)

 As a term imposed by the BLM in a permit

At the permitting stage, the BLM Authorized Officer would not include those ROPs that, because of their 

location or other inapplicability, are not relevant to a specific permit application. Note also that at the 

permit stage, the BLM Authorized Officer may establish additional requirements as warranted to protect 

the land and resources, in accordance with the BLM’s responsibility under relevant laws and regulations.
2. Alternatives (Description of the Alternatives) 

2-4 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Table 2-2 

Lease Stipulations, Required Operating Procedures, and Lease Notice by Alternative1

Alternative B Alternative C Alternative D 

LEASE STIPULATIONS 

PROTECTIONS THAT APPLY IN SELECT BIOLOGICALLY SENSITIVE AREAS 

Lease Stipulation 1—Rivers and Streams 

(Map 2-2)

Objective: Minimize the disruption of natural flow 

patterns and changes to water quality; the 

disruption of natural functions resulting from the 

loss or change to vegetative and physical 

characteristics of floodplain and riparian areas; the 

loss of spawning, rearing, or overwintering fish 

habitat; the loss of cultural and paleontological 

resources; the loss of raptor habitat; impacts on 

subsistence cabins and campsites; and the 

disruption of subsistence activities. Protect the 

water quality, quantity, and diversity of fish and 

wildlife habitats and populations associated with 

springs and aufeis across the Coastal Plain. 

Requirement/Standard: (NSO) Permanent oil and 

gas facilities, including gravel pads, roads, airstrips, 

and pipelines, are prohibited in the streambed and 

within the described setback distances outlined 

below, from the southern boundary of the Coastal 

Plain to the stream mouth. For streams that are 

entirely in the Coastal Plain, the setback extends 

to the head of the stream, as identified in the 

National Hydrography Dataset. On a case-by case 

basis, essential pipeline and road crossings would 

be permitted through setback areas. The setbacks 

may not be practical in river deltas; in these 

Lease Stipulation 1—Rivers and Streams 

(Map 2-4)

Objective: Same as Alternative B.

Requirement/Standard: (NSO) Same NSO 

requirements and setback distances as described 

under Alternative B; the setback distances for the 

following rivers have changed under Alternative C: 

a. Canning River: from the western boundary of 

the Coastal Plain to 2 miles east of the eastern 

edge of the active floodplain 

b. Hulahula River: 2 miles in all directions from 

the active floodplain 

c. Okpilak River: 2 miles from the banks’ ordinary 

high-water mark 

Lease Stipulation 1—Rivers and Streams 

(Map 2-6 and Map 2-8)

Objective: Minimize the disruption of natural flow 

patterns and changes to water quality; the 

disruption of natural functions from the loss or 

change to vegetation and physical characteristics of 

floodplain and riparian areas; the loss of spawning, 

rearing, or overwintering habitat for fish; the loss 

of cultural and paleontological resources; the loss 

of raptor habitat; impacts on subsistence cabins and 

campsites; the disruption of subsistence activities; 

impacts on hunting and recreation; and impacts on 

scenic and other resource values. Protect the 

water quality, quantity, and diversity of fish and 

wildlife habitats and populations associated with 

springs and aufeis across the Coastal Plain. 

 

Requirement/Standard: (NSO) Same NSO 

requirements as Alternative B. River setback 

distances under Alternative D are the following: 

a. Canning River: From the western boundary of 

the Coastal Plain to 3 miles east of the eastern 

edge of the active floodplain 

b. Hulahula River: 4 miles in all directions from the 

active floodplain 

c. Aichilik River: 3 miles from the eastern edge of 

the Coastal Plain boundary 

d. Okpilak River: 3 miles from the banks’ ordinary 

 

1While the language in Table 2-2 refers only to the BLM or its Authorized Officer, it is understood that all activities, including plan development and 

consideration of exceptions, modifications, or waivers would include coordination with the USFWS as the surface management agency. In addition, the BLM 

would coordinate with other appropriate federal, state, and NSB agencies, tribes, and ANCSA corporations. 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-5 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

situations, permanent facilities would be designed 

to withstand a 200-year flood. 

a. Canning River: from the western boundary of 

the Coastal Plain to 1 mile east of the eastern 

edge of the active floodplain 

b. Hulahula River: 1 mile in all directions from 

the active floodplain 

c. Aichilik River: 1 mile from the eastern edge of 

the Coastal Plain boundary 

d. Okpilak River: 1 mile from the banks’ ordinary 

high-water mark 

e. Jago River: 1 mile from the banks’ ordinary 

high-water mark 

f. The following rivers and creeks will have a 0.5-

mile setback from the banks’ ordinary highwater mark: 

i. Sadlerochit River 

ii. Tamayariak River 

iii. Okerokovik River 

iv. Katakturuk River 

v. Marsh Creek 

high-water mark 

e. The following rivers would have a 1-mile 

setback from the banks’ ordinary high-water 

mark: 

i. Sadlerochit River 

ii. Jago River 

f. The following rivers and creeks would have a 

0.5-mile setback from the banks’ ordinary highwater mark: 

i. Tamayariak River 

ii. Katakturuk River 

iii. Nularvik River 

iv. Okerokovik River 

v. Niguanak River 

vi. Sikrelurak River 

vii. Angunwill River 

viii. Kogotpak River 

ix. Marsh Creek 

x. Carter Creek 

xi. Itkilyariak Creek 

Lease Stipulation 2—Canning River Delta and Lakes 

Objective: Protect and minimize adverse effects on the water quality, quantity, and diversity of fish and 

wildlife habitats and populations, subsistence resources, and cultural resources; protect and minimize the 

disruption of natural flow patterns and changes to water quality, the disruption of natural functions 

resulting from the loss or change to vegetation and physical characteristics of floodplain and riparian 

areas; the loss of passage, spawning, rearing, or overwintering habitat for fish; the loss of cultural and 

paleontological resources; and the loss of migratory bird habitat. 

Requirement/Standard: See ROP 9 for additional requirements/standards

Lease Stipulation 2—Canning River Delta and 

Lakes (Map 2-6 and Map 2-8)

Objective: Same as Alternatives B and C. 

Requirement/Standard: (NSO) Permanent oil and 

gas facilities, including gravel pads, roads, airstrips, 

and pipelines, are prohibited within 0.5 miles of the 

ordinary high-water mark of any waterbody2 in 

Townships 8 and 9, north of the Canning and 

Tamyariak watersheds. On a case-by-case basis, 

essential pipelines, road crossings, and other 

permanent facilities may be considered through the 

permitting process in these areas where the 

 

2

For the purposes of this document, waterbody is defined as any feature included in the National Hydrography Dataset. This is a feature-based database that 

interconnects and uniquely identifies the stream segments or reaches that make up the nation's surface water drainage system. 
2. Alternatives (Description of the Alternatives) 

2-6 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

lessee/operator/contractor can demonstrate on a 

site-specific basis that impacts would be minimal.

Lease Stipulation 3—Springs/Aufeis 

Objective: Protect the water quality, quantity, and diversity of fish and wildlife habitats and populations 

associated with springs and aufeis across the Coastal Plain. River systems with springs provide yearround habitat and host the most diverse and largest populations of fish, aquatic invertebrates, and 

wildlife; they are associated with major subsistence activity and cultural resources. An aufeis is a unique 

feature associated with perennial springs. It helps sustain river flow during summer and provides insect 

relief for caribou. Because the subsurface flow paths to perennial springs are unknown and could be 

disturbed by drilling or fracking, use buffer areas around the major perennial springs that support fish 

populations in which no leasing is permitted. 

Requirement/Standard: 

a. Before drilling, the lessee/operator/permittee would conduct studies in areas containing springs to 

ensure drilling would not disrupt flow of the perennial springs, unless such studies have already been 

completed. Study plans would be developed in consultation with the BLM, USFWS, and other 

agencies, as appropriate. 

See Lease Stipulation 1 for additional requirements/standards.

Lease Stipulation 3—Springs/Aufeis (Map 2-6 

and Map 2-8)

Objective: Same as Alternatives B and C. 

Requirement/Standard: Same as Alternatives B and 

C, with the addition of the following areas 

identified that would not be offered for lease sale 

or identified as NSO: 

a. No leasing and no new non-subsistence 

infrastructure would be permitted within 3 

miles adjacent to or above Sadlerochit Spring 

(04N031E) nor within a 1-mile buffer below the 

spring to where it enters the Sadlerochit River 

and along the aufeis formation (04N031E and 

05N031E). This spring supports an isolated, 

dwarf population of Dolly Varden, unique plant 

and invertebrate communities, and an extensive 

aufeis field that persists through much of the 

summer, providing insect relief habitat for 

caribou. 

b. No leasing would be permitted within 3 miles 

adjacent to or above the perennial spring at Fish 

Hole 1 on the Hulahula River (05N032E). 

Further, no new non-subsistence infrastructure 

would be permitted within 4 miles of the 

perennial spring at Fish Hole 1 on the Hulahula 

River (05N032E), per Lease Stipulation 1, 

nor within 1 mile of the aufeis field (05N032E 

and 06N032E). The Fish Hole 1 spring provides 

overwintering habitat for arctic grayling and a 

large population of anadromous Dolly Varden. 

Residents of Kaktovik routinely harvest Dolly 

Varden in Fish Hole 1 during winter. The spring 

produces an extensive aufeis field that persists 

through much of the summer. 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-7 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

c. No leasing would be permitted within 3 miles 

adjacent to or above the perennial Tamayariak 

Spring, and no new non-subsistence 

infrastructure would be permitted within 1 mile 

of the associated aufeis field (07N026E). 

d. No leasing would be permitted within 3 miles 

adjacent to or above the perennial Okerokavik 

Spring (04N036E), and no new non-subsistence 

infrastructure would be permitted within 1 mile 

of the associated aufeis field in the Jago River 

drainage (05N035E and 05N036E). 

e. NSO within 3 miles of the eastern bank of the 

Canning River, including through the delta. The 

Canning River is the largest river crossing the 

Coastal Plain. It has several perennial springs 

originating upstream of the Coastal Plain that 

provide steady flow under ice across the 

Coastal Plain. The river supports several fish 

species, including arctic grayling and a large 

population of anadromous Dolly Varden. Aufeis 

fills the river corridor across the Coastal Plain 

and extends well into the delta, providing insect 

relief to caribou during the early summer. 

Lease Stipulation 4—Nearshore marine, lagoon, and barrier island habitats of the Southern 

Beaufort Sea within the boundary of the Arctic Refuge (Map 2-2 and Map 2-4)

Objective: Protect fish and wildlife habitat, including that for waterfowl and shorebirds, caribou insect 

relief, marine mammals, and polar bear summer and winter coastal habitat; preserve air and water 

quality; and minimize impacts on subsistence activities, recreation, historic travel routes, and cultural 

resources on the major coastal water bodies. 

Requirement/Standard: (NSO) Exploratory well drill pads, production well drill pads, or a CPF for oil or 

gas would not be permitted in coastal waters, lagoons, or barrier islands within the boundaries of the 

Coastal Plain. 

a. The BLM Authorized Officer may approve infrastructure necessary for oil and gas activities in these 

critical and sensitive coastal habitats, such as barge landing, docks, spill response staging and storage 

areas, and pipelines. Approval would be on a case-by-case basis, in consultation with the USFWS or 

NMFS or both, as appropriate. 

Lease Stipulation 4—Nearshore marine, 

lagoon, and barrier island habitats of the 

Southern Beaufort Sea within the boundary of 

the Arctic Refuge (Map 2-6 and Map 2-8)

Objective: Same as Alternatives B and C. 

Requirement/Standard: (NSO) Same as Alternatives 

B and C, with the following additional 

requirements: 

a. The BLM Authorized Officer may approve 

infrastructure necessary for oil and gas activities 

in these critical and sensitive coastal habitats, 

such as barge landing, docks, spill response 

staging and storage areas, and pipelines. 
2. Alternatives (Description of the Alternatives) 

2-8 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

Approval would be on a case-by-case basis, in 

consultation with the USFWS or NMFS or 

both, as appropriate. 

b. All lessees/operators/contractors involved in 

authorized activities in the coastal area must 

coordinate construction and use infrastructure 

with all other prospective Arctic Refuge users 

or user groups. Before conducting open water 

activities, the lessee/operator/contractor would 

consult with the Alaska Eskimo Whaling 

Commission, the NSB, and local whaling 

captains’ associations to minimize impacts on 

subsistence whaling and other subsistence 

activities of the communities of the North 

Slope. In a case in which the BLM authorizes 

permanent oil and gas infrastructure in the 

coastal area, the lessee/operator/contractor 

would develop and implement an impact and 

conflict avoidance and monitoring plan. This 

would be used to assess, minimize, and mitigate 

the effects of the infrastructure and its use on 

these Coastal Area habitats and their use by 

wildlife and people, including the following: 

i. Design and construct facilities to minimize 

impacts on subsistence uses, travel 

corridors, and seasonally concentrated fish 

and wildlife resources. 

ii. Daily operations, including use of support 

vehicles, watercraft, and aircraft, alone or in 

combination with other past, present, and 

reasonably foreseeable activities, would be 

conducted to minimize impacts on 

subsistence and other public uses, travel 

corridors, and seasonally concentrated fish 

and wildlife resources. 

iii. The location of oil and gas facilities, 

including artificial islands, platforms, 

associated pipelines, ice or other roads, 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-9 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

bridges or causeways, would be sited and 

constructed to not pose a hazard to public 

navigation, using traditional high-use 

subsistence-related travel routes into and 

through the major coastal lagoons and bays, 

as identified by the community of Kaktovik 

and the NSB. 

iv. Operators would be responsible for 

developing comprehensive prevention and 

response plans, including Oil Discharge 

Prevention and Contingency Plans and spill 

prevention, control, and countermeasure 

plans and maintain adequate oil spill 

response capability to effectively respond 

during periods of broken ice or open water, 

based on the statutes, regulations, and 

guidelines of the EPA, Alaska Department of 

Environmental Conservation (ADEC), and 

the Alaska Oil and Gas Conservation 

Commission (AOGCC), as well as best 

management practices (BMPs), stipulations, 

and policy guidelines of the BLM. 

(TL) Oil and gas exploration operations, such as 

drilling, seismic exploration, and testing, are not 

allowed on the major coastal water bodies and 

coastal islands between May 15 and November 1 

or when sea ice extent (as defined by Fetterer et 

al. 2017) is beyond 10 miles of the coast each 

season, whichever is later. Requests for approval of 

any activities must be submitted in advance and 

must be accompanied by evidence and 

documentation that demonstrates to the 

satisfaction of the BLM Authorized Officer that the 

actions or activities meet all the following criteria: 

a. Exploration would not unreasonably conflict 

with subsistence uses or significantly affect 

seasonally concentrated fish and wildlife 
2. Alternatives (Description of the Alternatives) 

2-10 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

resources. The location of exploration and 

related activities would be sited to not pose a 

hazard to navigation by the public using highuse, subsistence-related travel routes into and 

through the major coastal waterbodies, as 

identified by the NSB and the Native Village of 

Kaktovik, recognizing that marine and 

nearshore travel routes change over time and 

are subject to shifting environmental conditions.

Lease Stipulation 5—Coastal Polar Bear Denning River Habitat 

Objective: Minimize disturbance to denning polar bears, and disturbance or alteration of key river and 

creek maternal denning habitat areas. 

Requirement/Standard: Comply with ESA and Marine Mammal Protection Act (MMPA) requirements. 

Lease Stipulation 5—Coastal Polar Bear 

Denning River Habitat (Map 2-6 and Map 2-8)

Objective: Same as Alternatives B and C. 

Requirement/Standard: The following 

requirements/standards apply from the coastline to 

5 miles inland within the program area boundary. 

This area encompasses approximately 105,400

acres: 

a. (NSO) From the coastline to 5 miles inland, no 

permanent oil and gas infrastructure would be 

within 1 mile of potential polar bear denning 

habitat on the Niguanak River, Katakturuk 

River, Marsh Creek, Carter Creek, and 

Sadlerochit River, and all associated tributaries 

as defined by Durner et al. (2006), unless the 

BLM Authorized Officer approves alternative 

protective measures. 

b. (TL) From the coastline to 5 miles inland, 

between October 30 and April 15 of any year, 

the lessee/operator/contractor would not 

conduct oil and gas activities within 1 mile of 

potential polar bear denning habitat on the 

Niguanak River, Katakturuk River, Marsh 

Creek, Carter Creek, and Sadlerochit River, 

and all associated tributaries as defined by 

Durner et al. (2006), unless the BLM 

Authorized Officer approves alternative 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-11

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

protective measures. 

Lease Stipulation 6—Caribou Summer Habitat 

Note: All lands in the Arctic Refuge Coastal Plain are recognized as habitat of the PCH and CAH and would be 

managed to ensure unhindered movement of caribou through the area. 

Objective: Minimize disturbance and hindrance of caribou or alteration of caribou movements. 

Requirement/Standard: See ROP 23.

Lease Stipulation 6—Caribou Summer Habitat 

(Map 2-8)

Note: Same as Alternatives B and C. 

Objective: Same as Alternatives B and C. 

ALTERNATIVE D1 

Requirement/Standard: 

Same as Alternatives B 

and C. 

ALTERNATIVE D2 

Requirement/Standard: 

Same as Alternatives B 

and C, with the 

following additional 

requirement: 

(TL) Major 

construction activities 

using heavy equipment, 

but not drilling from 

existing production 

pads, would be 

suspended from no 

later than May 20 

through no earlier than 

July 20, unless approved 

by the BLM Authorized 

Officer, in consultation 

with the appropriate 

federal, state, and NSB 

regulatory and 

resource agencies. The 

intent of this 

requirement and 

allowance for deviation 

is to restrict activities 

that would disturb 

caribou during calving 

and insect-relief periods 
2. Alternatives (Description of the Alternatives) 

2-12 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

but allow for activity if 

caribou are unlikely to 

be disturbed in 

significant numbers. If 

caribou arrive on the 

calving grounds before 

May 20, or if they 

remain in the area past 

July 20 in significant 

numbers (greater than 

approximately 10 

percent of the 

estimated calving cow 

population or 1,000 

during insect-relief 

periods), major 

construction would be 

suspended. The lessee 

would submit with the 

development proposal 

a stop work plan that 

considers this, and any 

other mitigation related 

to caribou early arrival 

or late departure. 

Major equipment, 

materials, and supplies 

to be used at oil and 

gas work sites would 

be stockpiled before or 

after the period of May 

20 through July 20 to 

minimize road traffic. 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-13

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

Lease Stipulation 7—Porcupine Caribou 

Primary Calving Habitat Area (Map 2-2)

Note: PCH primary calving habitat area was defined 

as the area with a higher-than-average density of cows 

about to give birth during more than 40 percent of the 

years surveyed. 

Objective: Minimize disturbance and hindrance of 

caribou or alteration of their movements in the 

south-southeast portion of the Coastal Plain, 

which has been identified as important caribou 

habitat during calving. 

Requirement/Standard: (TL) Major construction 

activities using heavy equipment, but not drilling 

from existing production pads, would be 

suspended in the PCH primary calving habitat area 

from May 20 through June 20, unless approved by 

the BLM Authorized Officer, in consultation with 

the appropriate federal, State, and NSB regulatory 

and resource agencies. These areas encompass 

approximately 721,200 acres. If caribou arrive on 

the calving grounds before May 20, major 

construction would be suspended. The lessee 

should submit with the development proposal a 

stop work plan that considers this, and any other 

mitigation related to caribou early arrival. The 

intent of this latter requirement is to provide 

flexibility to adapt to changing climate conditions 

that may occur during the life of fields in the 

region. 

a. The following ground and air traffic 

restrictions would apply to permanent oil and 

gas-related roads in the areas and time periods 

indicated: 

i. Within the calving habitat area, from May 

20 through June 20, traffic speed should 

Lease Stipulation 7—Porcupine Caribou 

Primary Calving Habitat Area (Map 2-4)

Note: Same as Alternative B. 

Objective: Same as Alternative B. 

Requirement/Standard: 

a. (NSO) Approximately 606,200 acres of the 

PCH primary calving habitat area may be 

offered for lease but subject to NSO. 

b. (TL) Approximately 115,000 acres may be 

offered for lease but subject to the same TLs 

under Alternative B. 

Lease Stipulation 7—Porcupine Caribou 

Primary Calving Habitat Area (Map 2-6 and

Map 2-8)

Note: Same as Alternative B. 

Objective: Same as Alternative B. 

Requirement/Standard: 

a. (No leasing) Approximately 476,600 acres of 

the PCH primary calving habitat area would not 

be offered for lease and would not be available 

for surface occupancy. 

b. (NSO) Approximately 244,600 acres may be 

offered for lease but subject to NSO. 
2. Alternatives (Description of the Alternatives) 

2-14 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

not exceed 15 miles per hour when 

caribou are within 0.5 mile of the road. 

Additional strategies may include limiting 

trips and using convoys and different 

vehicle types, to the extent practicable. 

The lessee should submit with the 

development proposal a vehicle use plan 

that considers these and any other 

mitigation. The plan should include a 

vehicle-use monitoring plan. The BLM 

Authorized Officer would require 

adjustments if resulting disturbance is 

determined to be unacceptable. 

a. Major equipment, materials, and 

supplies to be used at oil and gas work 

sites in the calving habitat area should 

be stockpiled prior to the period of 

May 20 through June 20 to minimize 

road traffic during that period. 

Lease Stipulation 8—Porcupine Caribou PostCalving Habitat Area 

Note: The PCH post-calving area was defined as the 

area with a higher-than-average density of cows during 

the post-calving period for more than 40 percent of 

the years. This includes and extends beyond the 

primary calving area. 

Objective: To protect key surface resources and 

subsistence resources/activities resulting from 

permanent oil and gas development and associated 

activities in areas used by caribou during postcalving and insect-relief periods. 

Requirement/Standard: See ROP 23.

Lease Stipulation 8—Porcupine Caribou PostCalving Habitat Area (Map 2-4)

Note: Same as Alternative B. 

Objective: Same as Alternative B. 

Requirement/Standard: (TL) Sections of road 

would be evacuated whenever an attempted 

crossing by a large number of caribou 

(approximately 100 or more) appears to be 

imminent (June 15–July 20). This area encompasses 

approximately 985,500 acres.

Lease Stipulation 8—Porcupine Caribou PostCalving Habitat Area (Map 2-6 and Map 2-8)

Note: Same as Alternative B. 

Objective: Same as Alternative B. 

Requirement/Standard: (CSU) No CPFs would be 

allowed in the PCH post-calving habitat area. Well 

pads, roads, airstrips, and pipelines would be 

permitted, in accordance with ROP 23. This area 

encompasses approximately 264,300 acres. 

Infrastructure would be limited across the area to 

100 acres per township, not to exceed 510 acres 

total in this area. 

(TL) Sections of road would be evacuated 

whenever an attempted crossing by a large number 

of caribou (approximately 100 or more) appears to 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-15

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

be imminent (June 15–July 20). This area 

encompasses approximately 264,300 acres.

Lease Stipulation 9—Coastal Area (Map 2-2)

Objective: Protect coastal waters, lagoons, barrier 

islands, shorelines, and their value as fish and 

wildlife habitat, including for waterfowl, 

shorebirds, and marine mammals; minimize the 

hindrance or alteration of caribou movement in 

caribou coastal insect-relief areas; minimize 

hindrance or alteration of polar bear use and 

movement in coastal habitats; protect and 

minimize disturbance from oil and gas activities to 

coastal habitats for polar bears and seals; prevent 

loss and alteration of important coastal bird 

habitat; and prevent impacts on coastal 

subsistence resources and activities. 

Requirement/Standard: Before beginning 

exploration or development within 2 miles of the 

coast, the lessee/operator/contractor would 

develop and implement an impact and conflict 

avoidance and monitoring plan to assess, minimize, 

and mitigate the effects of the infrastructure and 

its use on these coastal habitats and their use by 

wildlife and people.

Lease Stipulation 9—Coastal Area (Map 2-4)

Objective: Same as Alternative B. 

Requirement/Standard: Same as Alternative B, plus: 

(NSO) Exploratory well drill pads, production well 

drill pads, or CPFs for oil and gas would not be 

permitted within 1 mile inland of the coast. The 

BLM Authorized Officer may approve 

infrastructure necessary for oil and gas activities in 

these critical and sensitive coastal habitats, such as 

barge landing, docks, spill response staging and 

storage areas, or pipelines. Approval would be on a 

case-by-case basis, in consultation with the 

USFWS, or the NMFS, or both, as appropriate. All 

lessees/operators/contractors involved in 

authorized activities in the coastal area must 

coordinate construction and use infrastructure 

with all other prospective Arctic Refuge users or 

user groups. Before conducting open water 

activities, the lessee/operator/contractor would 

consult with the Alaska Eskimo Whaling 

Commission, the NSB, and local whaling captains’ 

associations to minimize impacts on subsistence 

whaling and other subsistence activities of the 

communities of the North Slope. 

Lease Stipulation 9—Coastal Area (Map 2-6 

and Map 2-8)

Objective: Same as Alternative B. 

Requirement/Standard: Same as Alternative C, plus: 

(NSO) Exploratory well drill pads, production well 

drill pads, or CPFs for oil or gas would not be 

permitted within 2 miles inland of the coast.

Lease Stipulation 10—Wilderness Boundary 

No similar objective or requirement/standard.

Lease Stipulation 10—Wilderness Boundary 

(Map 2-6 and Map 2-8)

Objective: Protect wilderness values in the Mollie 

Beattie Wilderness Area. 

Requirement/Standard: (NSO) Surface occupancy, 

including exploratory and production well drill 

pads, structures and facilities, and gravel and ice 

roads, would not be allowed within 3 miles of the 
2. Alternatives (Description of the Alternatives) 

2-16 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

southern and eastern boundaries of the Coastal 

Plain where they are near designated wilderness. 

To the extent practicable, aircraft operations 

would be planned to minimize flights below 2,000 

feet when flying within 3 miles of the Mollie Beattie 

Wilderness Area boundary. 

REQUIRED OPERATING PROCEDURES 

WASTE PREVENTION, HANDLING, DISPOSAL, SPILLS, AND PUBLIC SAFETY 

Required Operating Procedure 1 

Objective: Protect public health, safety, and the environment by disposing of solid and waste and garbage, in accordance with applicable federal, State, and local 

laws and regulations. 

Requirement/Standard: Areas of operation would be left clean of all debris. 

Required Operating Procedure 2

Objective: Minimize impacts on the environment from nonhazardous and hazardous waste generation. Encourage continuous environmental improvement. 

Protect the health and safety of oil and gas field workers, local communities, Arctic Refuge subsistence users, Arctic Refuge recreationists, and the general 

public. Avoid human-caused changes in predator populations. Minimize attracting predators, particularly bears, to human use areas. 

Requirement/Standard: The lessee/operator/contractor would prepare and implement a comprehensive waste management plan for all phases of exploration, 

development, and production, including seismic activities. The plan would include methods and procedures to use bear resistant containers for all waste 

materials and classes. The plan would be submitted to the BLM Authorized Officer for approval, in consultation with federal, State, and NSB regulatory and 

resource agencies, as appropriate (based on agency legal authority and jurisdictional responsibility), as part of a plan of operations or other similar permit 

application. 

Management decisions affecting waste generation would be addressed in the following order of priority: (1) prevention and reduction, (2) recycling, (3) 

treatment, and (4) disposal. The plan would consider and take into account the following requirements: 

a. Methods to avoid attracting wildlife to food and garbage: The plan would identify precautions that are to be taken to avoid attracting wildlife to food and 

garbage. The use of bear-resistant containers for all waste would be required. 

b. Disposal of rotting waste: Requirements prohibit burying garbage. Lessees/operators/contractors would have a written procedure to ensure that rotting 

waste would be handled and disposed of in a manner that prevents the attraction of wildlife. All rotting waste would be incinerated, backhauled, or 

composted in a manner approved by the BLM Authorized Officer. All solid waste, including incinerator ash, would be disposed of in an approved wastedisposal facility, in accordance with EPA and ADEC regulations and procedures. Burying human waste is prohibited, except as authorized by the BLM 

Authorized Officer. The use of bear-resistant containers for all waste would be required. 

c. Disposal of pumpable waste products: Except as specifically provided, the BLM requires that all pumpable solid, liquid, and sludge waste be disposed of by 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-17

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

injection, in accordance with the EPA, ADEC, and the AOGCC regulations and procedures. On-pad temporary muds and cuttings storage, as approved by 

the ADEC, would be allowed as necessary to facilitate annular injection and backhaul operations. 

d. Disposal of wastewater and domestic wastewater: The BLM prohibits wastewater discharges or disposal of domestic wastewater into bodies of fresh, 

estuarine, and marine water, including wetlands, unless authorized by a National Pollutant Discharge Elimination System (NPDES) or State permit. 

Required Operating Procedure 3 

Objective: Minimize the impact of contaminants from refueling operations on fish, wildlife, and the 

environment. 

Requirement/Standard: Refueling equipment within 100 feet of the active floodplain of any waterbody is 

prohibited. Fuel storage stations would be located at least 100 feet from any waterbody, except for small 

caches (up to 210 gallons) for motor boats, float planes, and ski planes, and for small equipment, such as 

portable generators and water pumps. The BLM Authorized Officer may allow storage and operations at 

areas closer than the stated distances if properly designed to account for local hydrologic conditions. 

Required Operating Procedure 3 

Objective: Same as Alternatives B and C. 

Requirement/Standard: Refueling equipment within 

500 feet of the active floodplain of any waterbody 

is prohibited. Fuel storage stations would be at 

least 500 feet from any waterbody, except for small 

caches (up to 210 gallons) for motor boats, float 

planes, ski planes, and small equipment, such as 

portable generators and water pumps. The BLM 

Authorized Officer may allow storage and 

operations at areas closer than the stated distances 

if properly designed to account for local hydrologic 

conditions. 

Required Operating Procedure 4 

Objective: Minimize conflicts from the interaction between humans and bears during oil and gas activities. 

Requirement/Standard: The lessee/operator/contractor, as a part of lease operation planning, would prepare and implement bear-interaction plans to minimize 

conflicts between bears and humans. These bear interaction plans would be developed in consultation with and approved by the USFWS and the Alaska 

Department of Fish and Game (ADFG). The plans would include specific measures identified in the current USFWS Polar Bear Mitigation Plan and would be 

adapted as needed for grizzly bears.

Required Operating Procedure 5 

Objective: Reduce air quality impacts. 

Requirement/Standard: All oil and gas operations (vehicles and equipment) that burn diesel fuels must use ultra-low sulfur diesel, as defined by the EPA.

Required Operating Procedure 6 

Objective: Prevent unnecessary or undue degradation of the lands and protect health. 

Requirement/Standard: 
2. Alternatives (Description of the Alternatives) 

2-18 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

a. To support the BLM’s NEPA analysis for an application to develop a CPF, production pad/well, airstrip, road, gas compressor station, or other potential air 

pollutant emission source (hereafter called project), the BLM Authorized Officer may require the project proponent to provide a minimum of 1 year of 

baseline ambient air monitoring data for any pollutant of concern, as determined by the BLM. This would go into effect if no representative air monitoring 

data are available for the project area or if existing representative ambient air monitoring data are insufficient, incomplete, or do not meet minimum air 

monitoring standards set by the ADEC or the EPA. If the BLM determines that baseline monitoring is needed, this pre-analysis data must meet ADEC and 

EPA air monitoring standards and cover the year before the submittal. Pre-project monitoring may not be appropriate where the life of the project is less 

than 1 year.

b. To inform analysis of subsequent proposals and allow ongoing assessment of air quality conditions, the BLM may require monitoring for the life of the 

project, depending on the magnitude of potential air emissions from the project, proximity to a federally mandated Class I area, population center, or 

location in or near a nonattainment or maintenance area, meteorological or geographic conditions, existing air quality conditions, magnitude of existing 

development in the area, or issues identified during NEPA analysis for the project.

c. For an application to develop a CPF, production pad/well, airstrip, road, gas compressor station, or other potential substantial air pollutant emission source, 

the BLM may require the operator to submit for BLM approval an emissions inventory that includes quantified emissions of regulated air pollutants from all 

direct and indirect sources related to the proposed project, including reasonably foreseeable air pollutant emissions of criteria air pollutants, volatile 

organic compounds (VOCs), hazardous air pollutants, and GHGs estimated for each year for the life of the project. The BLM uses this estimated emissions 

inventory to identify pollutants of concern and to determine the appropriate air analysis methodology for the proposed project. The BLM also uses the 

information in the analysis.

d. For an application to develop a CPF, production pad/well, airstrip, road, gas compressor station, or other potential substantial air pollutant emission source, 

the BLM may require the proponent to provide, for the BLM’s analysis, an emissions reduction plan that includes a detailed description of operatorcommitted measures to reduce project related air pollutant emissions, including GHGs, mercury and other heavy metals, and fugitive dust.

e. The BLM’s analysis of the air quality impacts from a proposed CPF, production pad/well, airstrip, road, gas compressor station, or other potential 

substantial air pollutant emission source may require air quality modeling, depending on the magnitude of potential air emissions from the project or 

activity, the duration of the proposed action, the proximity to a federally mandated Class I area, population center, location in a nonattainment or 

maintenance area, meteorological or geographic conditions, existing air quality conditions, magnitude of existing development in the area, or issues 

identified during NEPA analysis. The BLM would determine the information required for a project-specific modeling analysis to determine if sufficient data 

exists to perform a quantitative air quality analysis. The BLM Authorized Officer would consult with appropriate federal, State, or local agencies regarding 

modeling to inform his or her modeling decision and avoid duplication of effort. The modeling would compare predicted impacts with local, State, and 

federal air quality standards and increments, as well as other scientifically defensible significance thresholds, such as impacts on air quality related values 

(AQRVs) and incremental cancer risks.

f. If the air quality analysis shows potential future exceedances of National Ambient Air Quality Standards (NAAQS) or Alaska Ambient Air Quality Standards 

(AAAQS) or impacts above specific levels of concern for AQRVs, the BLM would require air quality mitigation measures and strategies within its authority 

and in consultation with local, State, federal, and tribal agencies with responsibility for managing air resources, in addition to regulatory requirements and 

proponent committed emission reduction measures and for emission sources not otherwise regulated by the ADEC or EPA.

g. If ambient air monitoring indicates that project-related emissions are causing or contributing to impacts that would unnecessarily or unduly degrade the 

lands, exceed NAAQS, or fail to protect health (either directly or through use of subsistence resources), the BLM Authorized Officer may at any time 

require changes in activities, within the scope of BLM’s authority, to minimize or reduce impacts on air quality through additional emission control 

strategies. 

h. Publicly available reports on air quality baseline monitoring, emissions inventory and modeling results developed in conformance with this ROP would be 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-19

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

provided by the project proponent to the NSB and to local communities and tribes in a timely manner.

Required Operating Procedure 7 

Objective: Ensure that permitted activities do not create human health risks by contaminating subsistence foods. 

Requirement/Standard: A lessee/operator/contractor proposing a permanent oil and gas development would design and implement a monitoring study of 

contaminants in locally used subsistence foods. The monitoring study preparers would examine subsistence foods for all contaminants that could be associated 

with the proposed development. The study would identify the level of contaminants in subsistence foods before the proposed permanent oil and gas 

development and would monitor the level of these contaminants throughout the operation and abandonment phases. If ongoing monitoring detects a 

measurable and persistent increase in a contaminant in subsistence foods, the operator would design and implement a study to determine how much, if any, of 

the increase originates from the operator’s activities. If the study preparers determine that a portion of the increase in contamination is caused by the 

operator’s activities, the BLM Authorized Officer may require changes in the operator’s processes to reduce or eliminate emissions of the contaminant. The 

design of the study must meet the approval of the BLM Authorized Officer, who may coordinate with appropriate entities before approving the study design. 

The BLM Authorized Officer may require or authorize changes in the design of the studies throughout the operations and abandonment period or terminate 

or suspend studies if results warrant. 

WATER USE FOR PERMITTED ACTIVITIES 

Required Operating Procedure 8 

Objective: Maintain natural hydrologic regimes and populations of, and adequate habitat for, fish, and aquatic invertebrates. 

Requirement/Standard: Withdrawal of unfrozen water from springs, rivers and streams during winter is prohibited. The removal of ice aggregate from 

grounded areas 4 feet deep or less may be authorized from rivers on a site-specific basis. 

Required Operating Procedure 9 

Objective: Maintain natural hydrologic regimes in soils surrounding lakes and ponds, and maintain 

populations of, and adequate habitat for, fish, birds, and aquatic invertebrates. 

Requirement/Standard: Withdrawal of unfrozen water from lakes and the removal of ice aggregate from 

grounded areas 4 feet deep or less during winter and withdrawal of water from lakes during the summer 

may be authorized on a site-specific basis, depending on water volume and depth, the fish community, 

and connectivity to other lakes or streams. Current water use guidelines are as follows: 

Winter Water Use 

a. Lakes with sensitive fish (i.e., any fish except ninespine stickleback or Alaska blackfish): unfrozen 

water available for withdrawal is limited to 15 percent of calculated volume deeper than 7 feet; only 

ice aggregate may be removed from lakes that are 7 feet deep or less. 

b. Lakes with only non-sensitive fish (i.e., ninespine stickleback or Alaska blackfish): unfrozen water 

available for withdrawal is limited to 30 percent of calculated volume deeper than 5 feet; only ice 

Required Operating Procedure 9 

Objective: Same as Alternatives B and C. 

Requirement/Standard: Same as Alternatives B and 

C, with the following additional requirement: 

a. Additional modeling and monitoring of lake 

recharge may be required to ensure natural 

hydrologic regime, water quality, and aquatic 

habitat for migratory birds. 
2. Alternatives (Description of the Alternatives) 

2-20 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

aggregate may be removed from lakes that are 5 feet deep or less. 

c. Lakes with no fish, regardless of depth: water available for use is limited to 20 percent of total lake 

volume. 

d. In lakes where unfrozen water and ice aggregate are both removed, the total use would not exceed 

the respective 15 percent, 20 percent, or 30 percent volume calculations above. 

e. Compacting snow cover or removing snow from fish-bearing water bodies would be prohibited, 

except at approved ice road crossings, water pumping stations on lakes, or areas of grounded ice. 

Summer Water Use 

f. Requests for summer water use must be made separately, and the volume allowance would be 

evaluated on a case-by-case basis. Approval from the BLM Authorized Officer is required. 

All Water Use 

g. Any water intake structures in fish-bearing or non-fish-bearing waters would be designed, operated, 

and maintained to prevent fish entrapment, entrainment, or injury. Note: All water withdrawal 

equipment must be equipped with and use fish screening devices approved by the ADFG, Division of 

Habitat. 

h. Additional modeling or monitoring may be required to assess water level and water quality 

conditions before, during, and after water use from any fish-bearing lake or lake of special concern. 

WINTER OVERLAND MOVES AND SEISMIC WORK 

The following ROPs apply to overland and over-ice moves, seismic work, and any similar cross-country vehicle use and heavy equipment on surfaces without 

roads during winter. These restrictions do not apply to the use of such equipment on ice roads after they are constructed. 

Required Operating Procedure 10 

Objective: Protect grizzly bear, polar bear, and marine mammal denning and birthing locations. 

Requirement/Standard: 

a. Cross-country use of all vehicles, equipment, and oil and gas activity is prohibited within 0.5 miles of 

occupied grizzly bear dens identified by the ADFG, unless alternative protective measures are 

approved by the BLM Authorized Officer, in consultation with the ADFG.

b. All oil and gas activity, including cross-country use of vehicles, equipment, and seismic survey activity, 

is prohibited within 1 mile of known or observed polar bear dens, unless alternative protective 

measures are approved by the BLM Authorized Officer and are consistent with incidental take 

regulations (ITRs) and letters of authorization (LOA) issued by the USFWS as part of MMPA 

regulations. 

Required Operating Procedure 10 

Objective: Same as Alternatives B and C. 

Requirement/Standard: Same as Alternatives B and 

C, with the following additional requirements: 

a. Specific to ringed seals and seismic operations

i. Before the seismic survey begins, the 

operator will conduct a sound source 

verification test to measure the distance of 

vibroseis3 sound levels through grounded 

ice to the 120 decibels (dB) re 1 μPa 

threshold in open water. Once that distance 

is determined, it will be shared with the 

BLM and NMFS. The distance will be used 

 

3Vibroseis is a truck-mounted system that uses a large oscillating mass to put a range of frequencies into the earth. 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-21

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

to buffer all on-ice seismic survey activity 

operations from any open water or 

ungrounded ice throughout the project 

area. The operator will draft a formal study 

proposal that will be submitted to the BLM 

and NMFS for review and approval before 

the activity begins. 

ii. Maintain airborne sound levels of seismic 

equipment below 120 dB. If different 

equipment will be used than was originally 

proposed, the applicant must inform the 

BLM Authorized Officer and share sound 

levels and air and water attenuation 

information for the new equipment. 

iii. Operations after May 1 would employ a fulltime trained protected species observer 

(PSO) on vibroseis vehicles to ensure all 

basking seals are avoided by vehicles by at 

least 500 feet and would ensure that all 

equipment with airborne noise levels above 

100 dB re 20 μPa were operating at 

distances from observed seals that allowed 

for the attenuation of noise to levels below 

100 dB. All sightings of seals will be 

reported to the BLM using a NMFSapproved observation form. 

iv. Ice paths must not be greater than 12 feet 

wide. No driving beyond the shoulder of the 

ice path or off planned routes unless 

necessary to avoid ungrounded ice or for 

other human or marine mammal safety 

reasons. 

v. No unnecessary equipment or operations 

(e.g., camps) will be placed or used on sea 

ice. 

b. Between October 30 and April 15 of any year, a 

lessee/operator/contractor working in polar 

bear denning and seal birthing habitat would 
2. Alternatives (Description of the Alternatives) 

2-22 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

conduct a survey for polar bear dens and seal 

birthing lairs, in consultation with the USFWS, 

or NMFS, or both, as appropriate, throughout 

the planned area of activities and before 

initiating activities.

Required Operating Procedure 11 

Objective: Protect stream banks and freshwater sources, minimize soils compaction and the breakage, 

abrasion, compaction, or displacement of vegetation. 

Requirement/Standard: 

a. Ground operation would be allowed when soil temperatures at 12 inches below the tundra surface 

(defined as the top of the organic layer) reaches 23 degrees Fahrenheit (°F) and snow depths are an 

average of 9 inches, or 3 inches of snow water equivalent, whichever is less. Ground operations 

would cease when the spring snowmelt begins (approximately May 5 in the foothills, where 

elevations reach or exceed 500 feet and approximately May 15 in the northern coastal areas). The 

exact dates would be determined by the BLM Authorized Officer. 

b. Low ground pressure vehicles used for off-road travel would be defined by the BLM Authorized 

Officer. These vehicles would be selected and operated in a manner that eliminates direct impacts on 

the tundra by shearing, scraping, or excessively compacting the tundra. Note: This provision does 

not include the use of heavy equipment required during ice road construction; however, heavy 

equipment would not be allowed on the tundra until conditions in “a,” above, are met.

c. Bulldozing tundra mat and vegetation, trails, or seismic lines is prohibited. Clearing or smoothing 

drifted snow is allowed to the extent that the tundra mat is not disturbed. Only smooth pipe snow 

drags would be allowed for smoothing drifted snow. 

d. To reduce the possibility of excessive compaction, vehicle operators would avoid using the same 

routes for multiple trips, unless necessitated by serious safety or environmental concerns and 

approved by the BLM Authorized Officer. This provision does not apply to hardened snow trails or 

ice roads. 

e. Ice roads would be designed and located to avoid the most sensitive and easily damaged tundra types 

as much as practicable. Ice roads may not use the same route each year; ice roads would be offset to 

avoid portions of an ice road route from the previous 2 years.

f. Conventional ice road construction may not begin until off-road travel conditions are met (as 

described in “a,” above) within the ice road route and approval to begin construction is given by the 

BLM Authorized Officer.

g. Snow fences may be used in areas of low snow to increase snow depths within an ice road or snow 

trail route.

h. Seismic operations and winter overland travel may be monitored by agency representatives, and the 

Required Operating Procedure 11 

Objective: Same as Alternatives B and C. 

Requirement/Standard: 

a. Ground operation would be allowed when soil 

temperature at 12 inches below the tundra 

surface (defined as the top of the organic layer) 

reaches 23 °F and snow depth and density 

amounts to no less than a snow water 

equivalent of 3 inches over the highest tussocks. 

Ground operations would cease when the 

spring snowmelt begins (approximately May 5 in 

the foothills, where elevations reach or exceed 

500 feet, and approximately May 15 in the 

northern coastal areas). The exact dates would 

be determined by the BLM Authorized Officer. 

b. Low ground pressure vehicles used for off-road 

travel would be defined by the BLM Authorized 

Officer. These vehicles would be selected and 

operated in a manner that eliminates direct 

impacts on the tundra by shearing, scraping, or 

excessively compacting it. Note: This provision 

does not include the use of heavy equipment 

required during ice road construction; 

however, heavy equipment would not be 

allowed on the tundra until conditions in “a,” 

above, are met. 

c. Bulldozing tundra mat and vegetation, trails, or 

seismic lines is prohibited. Clearing or 

smoothing drifted snow is allowed, to the 

extent that the tundra mat is not disturbed. 

Only smooth pipe snow drags would be 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-23

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

operator may be required to accommodate the representative during operations. 

i. Incidents of damage to the tundra would be reported to the BLM Authorized Officer within 72 hours 

of occurrence. Follow-up corrective actions would be determined in consultation with and approved 

by the BLM Authorized Officer.

allowed for smoothing drifted snow. 

d. To reduce the possibility of excessive 

compaction, vehicle operators would avoid 

using the same routes for multiple trips unless 

necessitated by serious safety or environmental 

concerns and approved by the BLM Authorized 

Officer. This provision does not apply to 

hardened snow trails or ice roads. 

e. Ice roads would be designed and located to 

avoid the most sensitive and easily damaged 

tundra types as much as practicable. Ice roads 

may not use the same route each year; they 

would be offset to avoid portions of an ice road 

route from the previous 2 years. 

f. Conventional ice road construction may not 

begin until off-road travel conditions are met 

(as described in “a,” above) within the ice road 

route and approval to begin construction is 

given by the BLM Authorized Officer. 

g. To minimize changes in snow distribution 

resulting from oil and gas activities that could 

affect bear denning habitat and water quality 

and quantity, snow fences may be used in areas 

of low snow to increase snow depths within an 

ice road or snow trail route, with the approval 

of the BLM Authorized Officer. 

h. Seismic operations and winter overland travel 

may be monitored by agency representatives, 

and the operator may be required to 

accommodate the representative during 

operations. 

i. Incidents of damage to the tundra would be 

reported to the BLM Authorized Officer within 

72 hours of occurrence. Follow-up corrective 

actions would be determined in consultation 

with and approved by the BLM Authorized 

Officer and the USFWS. 
2. Alternatives (Description of the Alternatives) 

2-24 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

Required Operating Procedure 12 

Objective: Maintain natural spring (breakup) runoff patterns and fish passage, minimize flooding from human-made obstructions, prevent streambed 

sedimentation and scour, and protect water quality and stream banks. 

Requirement/Standard: Waterway courses would be crossed using a low-angle approach. Crossings that are reinforced with additional snow or ice (bridges) 

would be removed, breached, or slotted before spring breakup. Ramps and bridges would be substantially free of soil and debris.

Required Operating Procedure 13 

Objective: Avoid additional freeze-down of aquatic habitat harboring overwintering fish and aquatic invertebrates that fish prey on. 

Requirement/Standard: Travel up and down streambeds is prohibited unless it can be demonstrated that there would be no additional impacts from such travel 

on overwintering fish, the aquatic invertebrates they prey on, and water quality. Rivers, streams, and lakes would be crossed at areas of grounded ice or with 

the approval of the BLM Authorized Officer and when it has been demonstrated that no additional impacts would occur on fish or aquatic invertebrates.

Required Operating Procedure 14 

Objective: Minimize the effects of high-intensity acoustic energy from seismic surveys on fish. 

Requirement/Standard: 

a. When conducting vibroseis-based surveys above potential fish overwintering areas (water 6 feet 

deep or greater, ice plus liquid depth), lessees/operators/contractors would follow recommendations 

by Morris and Winters (2005): only a single set of vibroseis shots would be conducted if possible; if 

multiple shot locations are required, these would be conducted with minimal delay; multiple days of 

vibroseis activity above the same overwintering area would be avoided, if possible.

Required Operating Procedure 14 

Objective: Same as Alternatives B and C. 

Requirement/Standard: 

a. Seismic surveys would not be conducted over 

unfrozen water with fish overwintering 

potential.

Required Operating Procedure 15 

Objective: Reduce changes in snow distribution associated with the use of snow fences to protect water quantity and wildlife habitat, including snow drifts used 

by denning polar bears. 

Requirement/Standard: The use of snow fences to reduce or increase snow depth requires permitting by the BLM Authorized Officer.

OIL AND GAS EXPLORATORY DRILLING 

Required Operating Procedure 16 

Objective: Protect water quality in fish-bearing water bodies and minimize alteration of riparian habitat. 

Requirement/Standard: Exploratory drilling is prohibited in fish-bearing rivers and streams and other fish-bearing water bodies. On a case-by-case basis, the 

BLM Authorized Officer may consider exploratory drilling in floodplains of fish-bearing rivers and streams. 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-25

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

Required Operating Procedure 17 

Objective: Minimize surface impacts from exploratory drilling. 

Requirement/Standard: Construction of a gravel road for permanent oil and gas facilities would be prohibited for exploratory drilling. Use of a previously 

constructed road or pad may be permitted if it is environmentally preferred. 

FACILITY DESIGN AND CONSTRUCTION 

Required Operating Procedure 18 

Objective: Protect subsistence use and access to subsistence hunting and fishing areas and minimize the impact of oil and gas activities on air, land, water, fish, 

and wildlife resources. 

Requirement/Standard: All roads must be designed, constructed, maintained, and operated to create minimal environmental impacts and to avoid or minimize 

impacts on subsistence use and access to subsistence hunting and fishing areas. The BLM Authorized Officer would consult with appropriate entities before 

approving construction of roads. Subject to approval by the BLM Authorized Officer, the construction, operation, and maintenance of oil and gas field roads is 

the responsibility of the lessee/operator/contractor, unless the construction, operation, and maintenance of roads are assumed by the appropriate governing 

entity.

Required Operating Procedure 19 

Objective: Protect water quality and the diversity of fish, aquatic invertebrates, and wildlife populations and habitats. 

Requirement/Standard: 

a. Permanent oil and gas facilities, including roads, airstrips, and pipelines, are prohibited within 500 feet, as measured from the ordinary high-water mark, of 

fish-bearing water bodies, unless further setbacks are stipulated under Lease Stipulation 1. Pipeline and road crossings would be permitted on a case-bycase basis by the BLM Authorized Officer, following coordination with the appropriate entities. 

b. Temporary winter exploration and construction camps are prohibited on frozen lakes and river ice. 

c. Siting temporary winter exploration and construction camps on river sand and gravel bars is allowed and encouraged. Where trailers or modules must be 

leveled and the surface is vegetation, they would be leveled using blocking in a way that preserves the vegetation. 

Required Operating Procedure 20 

Objective: Maintain free passage of marine and anadromous fish, protect subsistence use and access to subsistence hunting and fishing and anadromous fish, and 

protect subsistence use and access to subsistence and non-subsistence hunting and fishing. 

Requirement/Standard: 

a. Causeways and docks are prohibited in river mouths and deltas. Artificial gravel islands and bottom-founded structures are prohibited in river mouths and 

active stream channels on river deltas. 

b. Causeways, docks, artificial islands, and bottom-founded drilling structures would be designed to ensure free passage of marine and anadromous fish and to 
2. Alternatives (Description of the Alternatives) 

2-26 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

prevent significant changes to nearshore oceanographic circulation patterns and water quality characteristics. A monitoring program, developed in 

coordination with appropriate entities, would be required to address the objectives of water quality and free passage of fish. 

Required Operating Procedure 21

Objective: Minimize impacts of the development footprint. 

Requirement/Standard: Facilities would be designed and located to minimize the development footprint and impacts on other purposes of the Arctic Refuge. 

Issues and methods that are to be considered are as follows: 

a. Using maximum extended-reach drilling for production drilling to minimize the number of pads and the network of roads between pads 

b. Sharing facilities with existing development 

c. Collocating all oil and gas facilities with drill pads, except airstrips, docks, base camps, and seawater treatment plants (STPs) 

d. Using gravel-reduction technologies, e.g., insulated or pile-supported pads 

e. Using impermeable liners under gravel infrastructure to minimize the potential for hydrocarbon spills 

f. Harvesting the tundra organic layer within gravel pad footprints for use in rehabilitation 

g. Coordinating facilities with infrastructure in support of adjacent development 

h. Locating facilities and other infrastructure outside areas identified as important for wildlife habitat, subsistence uses, and recreation 

i. Where aircraft traffic is a concern, balancing gravel pad size and available supply storage capacity with potential reductions in the use of aircraft to support 

oil and gas operations

Required Operating Procedure 22 

Objective: Reduce the potential for ice-jam flooding, damage from aufeis, impacts on wetlands and floodplains, erosion, alteration of natural drainage patterns, 

and restriction of fish passage. 

Requirement/Standard: 

a. To allow for sheet flow and floodplain dynamics and to ensure passage of fish and other organisms, bridges are preferred over culverts, if technically 

feasible. When necessary, culverts could be constructed on smaller streams, if they are large enough to avoid restricting fish passage or adversely affecting 

natural stream flow.

b. To ensure that crossings provide for fish passage, all proposed crossing designs would adhere to the BMPs outlined in Fish Passage Design Guidelines, 

developed by the USFWS Alaska Fish Passage Program (McDonald & Associates 1994), Stream Simulation: An Ecological Approach to Providing Passage for 

Aquatic Organisms at Road-Stream Crossings (Forest Service 2008), and other generally accepted best management procedures prescribed by the BLM 

Authorized Officer and the USFWS.

c. In addition to the BMPs outlined in the aforementioned documents for stream simulation design, the design engineer would ensure that crossing structures 

are designed for aufeis, permafrost, sheet flow, additional freeboard during breakup, and other unique conditions of the arctic environment.
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-27

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

Required Operating Procedure 23 

Objective: Minimize disruption of caribou movement and subsistence use. 

Requirement/Standard: Pipelines and roads would be designed to allow the free movement of caribou and the safe, unimpeded passage of those participating in 

subsistence activities. Listed below are the accepted design practices. 

a. Aboveground pipelines would be elevated a minimum of 7 feet, as measured from the ground to the bottom of the pipeline at vertical support members 

(VSMs).

b. In areas where facilities or terrain would funnel caribou movement or impede subsistence or public access, ramps of appropriate angle and design over 

pipelines, buried pipelines, or pipelines buried under roads may be required by the BLM Authorized Officer, in coordination with the appropriate entity.

c. A minimum distance of 500 feet between pipelines and roads would be maintained. Separating roads from pipelines may not be feasible within narrow land 

corridors between lakes and where pipelines and roads converge on a drill pad. Where it is not feasible, alternative pipeline routes, designs, and possible 

burial under the road for pipeline road crossings would be considered by the BLM Authorized Officer.

d. Aboveground pipelines would have a nonreflective finish. 

e. When laying out oil and gas field developments, lessees would orient infrastructure to avoid impeding caribou migration and to avoid corralling effects.

f. Before the construction of permanent facilities is authorized (limited as they may be by restricted surface occupancy areas established in other lease 

stipulations), the lessee would design and implement and report a study of caribou movement, unless an acceptable study specific to the PCH and CAH has 

been completed within the last 10 years and approved by the BLM Authorized Officer.

g. A vehicle use management plan would be developed by the lessee/operator/contractor and approved by the BLM Authorized Officer, in consultation with 

the appropriate federal, State, and NSB regulatory and resource agencies. The management plan would minimize or mitigate displacement during calving 

and would avoid, to the extent feasible, delays to caribou movements and vehicle collisions during the midsummer insect season, with traffic management 

following industry practices. By direction of the BLM Authorized Officer, traffic may be stopped throughout a defined area for up to 4 weeks, to prevent 

displacement of calving caribou. If required, a monitoring plan could include collection of data on vehicle counts and caribou interaction. 

Required Operating Procedure 24 

Objective: Minimize the impact of mineral materials mining on air, land, water, fish, and wildlife 

resources. 

Requirement/Standard: Gravel mine site design and reclamation would be done in accordance with a 

plan approved by the BLM Authorized Officer. The plan would be developed in coordination with the 

appropriate entity and would take into consideration the following: 

a. Locations outside the active floodplain

b. Design and construction of gravel mine sites in active floodplains to serve as water reservoirs for 

future use

c. Potential use of the site for enhancing fish and wildlife habitat

d. Potential storage and reuse of sod/overburden for the mine site or at other disturbed sites on the 

North Slope 

Required Operating Procedure 24 

Objective: Same as Alternatives B and C. 

Requirement/Standard: Gravel mine site design, 

construction, and reclamation would be done in 

accordance with a plan approved by the BLM 

Authorized Officer. The plan would be developed 

in coordination with the appropriate entity and 

would take into consideration the following: 

a. Construction of gravel mine sites or water 

reservoirs may not be considered within the 

active floodplains of the four rivers that support 

populations of freshwater, anadromous, or 

endemic fish (Canning, Sadlerochit, Hulahula, 
2. Alternatives (Description of the Alternatives) 

2-28 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

and Aichilik Rivers) 

b. Design and construction of gravel mine sites 

may be considered at locations outside the 

active floodplain 

c. Design and construction of gravel mine sites 

that may also serve as water reservoirs may be 

considered in active floodplains, except for 

waters identified in “a,” above

d. Potential storage and reuse of sod/overburden 

for the mine site or at other disturbed sites on 

the North Slope 

e. All constructed water storage reservoirs should 

be a sufficient distance from drill sites, fueling 

stations, or other temporary or permanent site 

that generates or maintains more than 220 

gallons of fuel, drilling fluids, or other hazardous 

materials to avoid contamination via surface or 

groundwater of the storage reservoir; the 

lessee should implement a water quality and 

contaminants monitoring program for any 

constructed water storage facility 

Required Operating Procedure 25 

Objective: Avoid human-caused changes in predator populations of ground-nesting birds. 

Requirement/Standard: 

a. Lessee/operator/contractor would use best available technology to prevent facilities from providing nesting, denning, or shelter sites for ravens, raptors, 

and foxes. The lessee/operator/contractor would provide the BLM Authorized Officer with an annual report on the use of oil and gas facilities by ravens, 

raptors, and foxes as nesting, denning, and shelter sites.

b. Feeding of wildlife and allowing wildlife to access human food or odor-emitting waste is prohibited.

Required Operating Procedure 26 

Objective: Reduction of risk of attraction and collisions between migrating birds and oil and gas and related facilities during low light conditions. 

Requirement/Standard: All structures would be designed to direct artificial exterior lighting, from August 1 to October 31, inward and downward, rather than 

upward and outward, unless otherwise required by the Federal Aviation Administration (FAA).
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-29

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

Required Operating Procedure 27 

Objective: Minimize the impacts to bird species from direct interaction with oil and gas facilities. 

Requirement/Standard: 

a. To reduce the possibility of birds colliding with aboveground utility lines (power and communication), such lines would either be buried in access roads or 

would be suspended on VSMs, except in rare cases, limited in extent. Exceptions are limited to the following situations: 

i. Overhead power or communication lines may be allowed when located entirely within the boundaries of a facility pad; 

ii. Overhead power or communication lines may be allowed when engineering constraints at the specific and limited location make it infeasible to bury or 

connect the lines to a VSM; or 

iii. Overhead power or communication lines may be allowed in situations when human safety would be compromised by other methods. 

b. To reduce the likelihood of birds colliding with them, communication towers would be located, to the extent practicable, on existing pads and as close as 

possible to buildings or other structures and on the east or west side of buildings or other structures, if possible. Support wires associated with 

communication towers, radio antennas, and other similar facilities, would be avoided to the extent practicable. If support wires are necessary, they would 

be clearly marked along their entire length to improve visibility to low-flying birds. Such markings would be developed through consultation with the 

USFWS. 

Required Operating Procedure 28 

Objective: Use ecological mapping as a tool to assess wildlife habitat before developing permanent facilities to conserve important habitat types. 

Requirement/Standard: An ecological land classification map of the area would be developed before approval of facility construction. The map would integrate 

geomorphology, surface form, and vegetation at a scale and level of resolution and position accuracy adequate for detailed analysis of development alternatives. 

The map would be prepared in time to plan one season of ground-based wildlife surveys, if deemed necessary by the BLM Authorized Officer, before the exact 

facility location and facility construction is approved. 

Required Operating Procedure 29 

Objective: Protect cultural and paleontological resources. 

Requirement/Standard: The lessee/operator/contractor would conduct a cultural and paleontological resources survey before any ground-disturbing activity, 

based on a study designed and approved by the BLM Authorized Officer. If any potential cultural or paleontological resource is found, the 

lessee/operator/contractor would notify the BLM Authorized Officer and would suspend all operations in the immediate area until she or he issues a written 

authorization to proceed.

Required Operating Procedure 30 

Objective: Prevent or minimize the loss of nesting habitat for cliff-nesting raptors. 

 

Requirement/Standard: 

a. Removing greater than 100 cubic yards of bedrock outcrops, sand, or gravel from cliffs displaying evidence of raptor nests would be prohibited.
2. Alternatives (Description of the Alternatives) 

2-30 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

b. Any extraction of sand or gravel from an active river or stream channel would be prohibited, unless preceded by a hydrological study that indicates no 

potential impact on the integrity of the river bluffs.

Required Operating Procedure 31 

Objective: Prevent or minimize the loss of raptors due to electrocution by power lines. 

Requirement/Standard: Comply with the most up-to-date, industry-accepted, suggested practices for raptor protection on power lines. Current accepted 

standards were published in Suggested Practices for Avian Protection on Power Lines: The State of the Art in 2006, by the Avian Power Line Interaction 

Committee (APLIC 2006) and are updated as needed. 

Required Operating Procedure 32 

Objective: Avoid and reduce temporary impacts on productivity from disturbance near Steller’s or spectacled eider nests.

Requirement/Standard: Ground-level vehicle or foot traffic within 656 feet of occupied Steller’s or spectacled eider nests, from June 1 through July 31, would 

be restricted to existing thoroughfares, such as pads and roads. Construction of permanent facilities, placement of fill, alteration of habitat, and introduction of 

high noise levels within 656 feet of occupied Steller’s or spectacled eider nests would be prohibited. Between June 1 and August 15, support/construction 

activity must occur off existing thoroughfares, and USFWS-approved nest surveys must be conducted during mid-June before the activity is approved. 

Collected data would be used to evaluate whether the action could occur based on a 656-foot buffer around nests or if the activity would be delayed until 

after mid-August once ducklings are mobile and have left the nest site. The BLM would also work with the USFWS to conduct nest surveys or oil spill 

response training in riverine, marine, and intertidal areas that is within 656 feet of shore outside sensitive nesting/brood-rearing periods. The protocol and 

timing of nest surveys for Steller’s or spectacled eiders would be determined in cooperation with and must be approved by the USFWS. Surveys would be 

supervised by biologists who have previous experience with Steller’s or spectacled eider nest surveys.

Required Operating Procedure 33 

Objective: Provide information to be used in monitoring and assessing wildlife movements during and after construction. 

Requirement/Standard: A representation, in the form of ArcGIS-compatible shape-files, of all new infrastructure construction would be provided to the BLM 

Authorized Officer and State of Alaska. During the planning and permitting phase, GIS shape files representing proposed locations would be provided. Within 6 

months of construction completion, shape-files (within Global Positioning System accuracy) of all new infrastructure would be provided. Infrastructure includes 

all gravel roads and pads, facilities built on pads, pipelines, and independently constructed power lines (as opposed to those incorporated in pipeline design). 

Gravel pads would be included as polygon features. Roads, pipelines, and power lines may be represented as line features but must include ancillary data to 

denote such data as width and number of pipes. Poles for power lines may be represented as point features. Ancillary data would include construction 

beginning and ending dates. 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-31

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

USE OF AIRCRAFT FOR PERMITTED ACTIVITIES 

Required Operating Procedure 34 

Objective: Minimize the effects of low-flying aircraft on wildlife, subsistence activities, local communities, 

and recreationists of the area, including hunters and anglers. 

Requirement/Standard: The operator would ensure that operators of aircraft used for permitted oil and 

gas activities and associated studies maintain altitudes according to the following guidelines (Note: This 

ROP is not intended to restrict flights necessary to survey wildlife to gain information necessary to meet 

the stated objectives of the lease stipulations and ROPs; however, such flights would be restricted to the 

minimum necessary to collect such data.): 

a. Land users would submit an aircraft use plan as part of an oil and gas exploration or development 

proposal, which includes a plan to monitor flights and includes a reporting system for subsistence 

hunters to easily report flights that disturb subsistence harvest. The plan would address strategies to 

minimize impacts on subsistence hunting and associated activities, including the number of flights, 

type of aircraft, and flight altitudes and routes, and would also include a plan to monitor flights. 

Proposed aircraft use plans would be reviewed by the appropriate Alaska Native or subsistence 

organization. Consultations with these same agencies would be required if unacceptable disturbance 

is identified by subsistence users. Adjustments, including possible suspension of all flights, may be 

required by the BLM Authorized Officer, if resulting disturbance is determined to be unacceptable. 

The number of takeoffs and landings to support oil and gas operations with necessary materials and 

supplies would be limited to the maximum extent possible. During the design of proposed oil and gas 

facilities, larger landing strips and storage areas would be considered to allow larger aircraft to be 

used, resulting in fewer flights to the facility.

b. Use of aircraft, especially rotary wing aircraft, would be kept to a minimum near known subsistence 

camps and cabins or during sensitive subsistence hunting periods (spring goose hunting, summer 

caribou, and fall moose hunting) and when recreationists are present.

c. Operators of aircraft used for permitted activities would maintain an altitude of at least 1,500 feet 

above ground level (except for takeoffs and landings) within 0.5 miles of cliffs identified as raptor 

nesting sites, and over caribou calving range, unless doing so would endanger human life or violate 

safe flying practices. 

d. Minimize the number of helicopter landings in caribou calving ranges from May 20 through June 20.

e. Pursuing running wildlife is hazing. Hazing wildlife by aircraft pilots is prohibited, unless otherwise 

authorized. If wildlife begins to run as an aircraft approaches, the aircraft is too close, and the 

operator must break away.

Required Operating Procedure 34 

Objective: Same as Alternatives B and C. 

Requirement/Standard: Same as Alternatives B and 

C, except that requirements “c” and “d” include 

the caribou post-calving and calving range, and “d” 

minimizes the number of helicopter landings in 

caribou calving ranges from May 20 through July 20. 
2. Alternatives (Description of the Alternatives) 

2-32 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

OIL AND GAS FIELD ABANDONMENT 

Required Operating Procedure 35 

Objective: Ensure ongoing and long-term reclamation of land to its previous condition and use. 

Requirement/Standard: Before final abandonment, land used for oil and gas infrastructure—including well 

pads, production facilities, access roads, and airstrips—would be reclaimed to ensure eventual 

restoration of ecosystem function. The leaseholder would develop and implement a BLM-approved 

abandonment and reclamation plan. The plan would describe short-term stability, visual, hydrological, 

and productivity objectives and steps to be taken to ensure eventual ecosystem restoration to the land’s 

previous hydrological, vegetation, and habitat condition. The BLM Authorized Officer may grant 

exceptions to satisfy stated environmental or public purposes.

Required Operating Procedure 35 

Objective: Same as Alternatives B and C. 

Requirement/Standard: 

a. Oil and gas infrastructure, including gravel pads, 

roads, airstrips, wells and production facilities, 

would be removed and the land restored on an 

ongoing basis, as extraction is complete. 

b. Before final abandonment, land used for oil and 

gas infrastructure—including well pads, 

production facilities, access roads, and 

airstrips—would be restored to ensure 

eventual restoration of ecosystem function and 

meet minimal standards to restore general 

wilderness characteristics. The leaseholder 

would develop and implement a BLM-approved 

abandonment and reclamation plan. The plan 

would describe short-term stability, visual, 

hydrological, and productivity objectives and 

steps to be taken to ensure eventual ecosystem 

restoration to the land’s previous hydrological, 

vegetation, and habitat condition, wild and 

scenic river (WSR) eligibility/suitability, and 

intent to restore general wilderness 

characteristics of the area. The BLM Authorized 

Officer may grant exceptions to satisfy stated 

environmental or public purposes. 

SUBSISTENCE CONSULTATION FOR PERMITTED ACTIVITIES 

Required Operating Procedure 36 

Objective: Provide opportunities for subsistence users to participate in planning and decision-making to prevent unreasonable conflicts between subsistence 

uses and other activities. 

Requirement/Standard: The lessee/operator/contractor would coordinate directly with affected communities, using the following guidelines: 

a. Before submitting an application to the BLM, the applicant would work with directly affected subsistence communities, the Native Village of Kaktovik, NSB, 

and the North Slope and Eastern Interior Alaska Subsistence Regional Advisory Councils. They would discuss the siting, timing, and methods of their 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-33

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

proposed operations to help discover local traditional and scientific knowledge. This is to minimize impacts on subsistence uses. Through this coordination, 

the applicant would make every reasonable effort, including such mechanisms as conflict avoidance agreements (CAAs) and mitigating measures, to ensure 

that proposed activities would not result in unreasonable interference with subsistence activities. In the event that no agreement is reached between the 

parties, the BLM Authorized Officer would work with the involved parties and determine which activities would occur, including the time frames.

b. Applicants would submit documentation of coordination as part of operation plans to the North Slope and Eastern Interior Alaska Subsistence Regional 

Advisory Councils for review and comment. Applicants must allow time for the BLM to conduct formal government-to-government consultation with 

Native Tribal governments if the proposed action requires it.

c. A plan would be developed that shows how the activity, in combination with other activities in the area, would be scheduled and located to prevent 

unreasonable conflicts with subsistence activities. The plan would also describe the methods used to monitor the effects of the activity on subsistence use. 

The plan would be submitted to the BLM Authorized Officer as part of the plan of operations. The plan would address the following items:

i. A detailed description of the activities to take place (including the use of aircraft). 

ii. A description of how the applicant would minimize or address any potential impacts identified by the BLM Authorized Officer during the coordination 

process. 

iii. A detailed description of the monitoring to take place, including process, procedures, personnel involved, and points of contact both at the work site 

and in the local community. 

iv. Communication elements to provide information on how the applicant would keep potentially affected individuals and communities up-to-date on the 

progress of the activities and locations of possible, short-term conflicts (if any) with subsistence activities. Communication methods could include 

holding community open house meetings, workshops, newsletters, and radio and television announcements. 

v. Procedures necessary to facilitate access by subsistence users to conduct their activities. 

vi. Barge operators requiring a BLM permit are required to demonstrate that barging activities will not have unmitigable adverse impacts, as determined by 

NMFS, on the availability of marine mammals to subsistence hunters. 

vii. All operators of vessels over 50 feet in length engaged in operations requiring a BLM permit must have an automatic identification system transponder 

system on the vessel. 

d. During development, monitoring plans must be established for new permanent facilities, including pipelines, to assess an appropriate range of potential 

effects on resources and subsistence, as determined on a case-by-case basis, given the nature and location of the facilities. The scope, intensity, and duration 

of such plans would be established in consultation with the BLM Authorized Officer and North Slope and Eastern Interior Subsistence Advisory Panels.

e. Permittees who propose transporting facilities, equipment, supplies, or other materials by barge to the Coastal Plain in support of oil and gas activities in 

the Arctic Refuge would notify, confer, and coordinate with the Alaska Eskimo Whaling Commission, the appropriate local community whaling captains’ 

associations, and the NSB to minimize impacts from the proposed barging on subsistence whaling.

Required Operating Procedure 37 

Objective: Avoid conflicts between subsistence activities and seismic exploration. 

Requirement/Standard: In addition to the coordination process described in ROP 36 for permitted activities, before seismic exploration begins, applicants 

would notify the local search and rescue organizations in proposed seismic survey locations for that operational season. For the purpose of this standard, a 

potentially affected cabin or campsite is defined as one used for subsistence purposes and located within the boundary of the area subject to proposed 

geophysical exploration or within 1 mile of actual or planned travel routes used to supply the seismic operations. 

a. Because of the large land area covered by typical geophysical operations and the potential to affect a large number of subsistence users during the 
2. Alternatives (Description of the Alternatives) 

2-34 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

exploration season, the permittee/operator would notify all potentially affected subsistence use cabin and campsite users.

b. The official recognized list of subsistence users of cabins and campsites is the NSB’s most current inventory of cabins and campsites, which have been 

identified by the subsistence users’ names.

c. A copy of the notification letter, a map of the proposed exploration area, and the list of potentially affected users would also be provided to the office of 

the appropriate Native Tribal government.

d. The BLM Authorized Officer would prohibit seismic work within 1 mile of any known subsistence use cabin or campsite, unless an alternate agreement 

between the owner or user is reached through the consultation process and presented to the BLM Authorized Officer.

e. Each week, the permittee would notify the appropriate local search and rescue of the operational location in the Coastal Plain. This notification would 

include a map indicating the extent of surface use and occupation, as well as areas previously used or occupied during the operation. The purpose of this 

notification is to give hunters up-to-date information regarding where seismic exploration is occurring and has occurred, so that they can plan their hunting 

trips and access routes accordingly. A list of the appropriate search and rescue offices to be contacted can be obtained from the coordinator of the North 

Slope and Eastern Interior Alaska Subsistence Regional Advisory Councils in the BLM’s Arctic Field Office.

Required Operating Procedure 38 

Objective: Minimize impacts from non-local hunting and trapping activities on subsistence resources. 

Requirement/Standard: Hunting and trapping by lessees/operators/contractors are prohibited when persons are on work status. This is defined as the period 

during which an individual is under the control and supervision of an employer. Work status is terminated when workers’ shifts ends, and they return to a 

public airport or community (e.g., Kaktovik, Utqiaġvik, or Deadhorse). Use of operator/permittee facilities, equipment, or transport for personnel access or aid 

in hunting and trapping is prohibited. 

Required Operating Procedure 39 

Objective: Prevent disruption of subsistence use and access. 

Requirement/Standard: Before starting exploration or development, lessees/operators/contractors are required to develop a subsistence access plan, in 

coordination with the Native Village of Kaktovik and the City of Kaktovik, to be approved by the BLM Authorized Officer. 

ORIENTATION PROGRAMS ASSOCIATED WITH PERMITTED ACTIVITIES 

Required Operating Procedure 40 

Objective: Minimize cultural and resource conflicts. 

Requirement/Standard: All personnel involved in oil and gas and related activities would be provided with information concerning applicable lease stipulations, 

ROPs, standards, and specific types of environmental, social, traditional, and cultural concerns that relate to the region. The operator would ensure that all 

personnel involved in permitted activities would attend an orientation program at least once a year. The proposed orientation program would be submitted to 

the BLM Authorized Officer for review and approval and would accomplish the following: 

a. Provide sufficient detail to notify personnel of applicable lease stipulations and ROPs and to inform individuals working on the project of specific types of 

environmental, social, traditional, and cultural concerns that relate to the region.
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-35

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

b. Address the importance of not disturbing archaeological and biological resources and habitats, including endangered species, fisheries, bird colonies, and 

marine mammals, and provide guidance on how to avoid disturbance, including on the preparation, production, and distribution of information cards on 

endangered or threatened species.

c. Be designed to increase sensitivity and understanding of personnel to community values, customs, and lifestyles in areas in which personnel would be 

operating.

d. Include information concerning avoidance of conflicts with subsistence and pertinent mitigation.

e. Include information for aircraft personnel concerning subsistence activities and areas and seasons that are particularly sensitive to disturbance by low-flying 

aircraft; of special concern is aircraft use near traditional subsistence cabins and campsites, flights during spring goose hunting and fall caribou and moose 

hunting seasons, and flights near potentially affected communities.

f. Provide that individual training is transferable from one facility to another, except for elements of the training specific to a site.

g. Include on-site records of all personnel who attend the program for so long as the site is active, though not to exceed the 5 most recent years of 

operations; this record would include the name and dates of attendance of each attendee.

h. Include a module discussing bear interaction plans to minimize conflicts between bears and humans.

i. Provide a copy of 43 CFR 3163 regarding noncompliance assessment and penalties to on-site personnel.

j. Include training designed to ensure strict compliance with local and corporate drug and alcohol policies; this training would be offered to the NSB Health 

Department for review and comment.

k. Include employee training on how to prevent transmission of communicable diseases, including sexually transmitted diseases, to the local communities; this 

training would be offered to the NSB Health Department for review and comment.

ENDANGERED SPECIES ACT SECTION 7 CONSULTATION 

Lease Notice 1. The lease areas may now or hereafter contain plants, animals, or their habitats determined to be threatened or endangered. The BLM may 

require modifications to exploration and development proposals to further its conservation and management objective to avoid BLM-approved activities that 

would contribute to the need to list such a species or their habitat. The BLM would not approve any activity that may affect any such species or critical habitat 

until it completes its obligations under applicable requirements of the ESA, as amended (16 United States Code [USC] 1531 et seq.), including completion of 

any required procedure for conference or consultation. 

SUMMER VEHICLE TUNDRA ACCESS

Required Operating Procedure 41 

Objective: Protect stream banks and water quality; minimize compaction and displacement of soils; minimize the breakage, abrasion, compaction, or 

displacement of vegetation; protect cultural and paleontological resources; maintain populations of and adequate habitat for birds, fish, and caribou and other 

terrestrial mammals; and minimize impacts on subsistence activities. 

Requirement/Standard: On a case-by-case basis, the BLM Authorized Officer, in consultation with the USFWS, may permit low-ground-pressure vehicles to 

travel off gravel pads and roads during times other than those identified in ROP 11. Permission for such use would be granted only after an applicant has 

completed the following: 

a. Submitted studies satisfactory to the BLM Authorized Officer of the impacts on soils and vegetation of the specific low-ground-pressure vehicles to be 

used; these studies would reflect use of such vehicles under conditions like those of the route proposed and would demonstrate that the proposed use 

would have no more than minimal impacts on soils and vegetation.
2. Alternatives (Description of the Alternatives) 

2-36 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

b. Submitted surveys satisfactory to the BLM Authorized Officer of subsistence uses of the area as well as of the soils, vegetation, hydrology, wildlife, and fish 

(and their habitats), paleontological and archaeological resources, and other resources, as required by the BLM Authorized Officer.

c. Designed or modified the use proposal to minimize impacts to the BLM Authorized Officer’s satisfaction; design steps to achieve the objectives and based 

on the studies and surveys may include timing restrictions (generally it is considered inadvisable to conduct tundra travel before August 1 to protect 

ground-nesting birds), shifting work to winter, rerouting, and not proceeding when certain wildlife are present or subsistence activities are occurring. At 

the discretion of the BLM Authorized Officer, the plan for summer tundra vehicle access may be included as part of the spill prevention and response 

contingency plan required by 40 CFR 112 (Oil Pollution Act).

GENERAL WILDLIFE AND HABITAT PROTECTION 

Required Operating Procedure 42 

Objective: Minimize disturbance and hindrance of wildlife or alteration of wildlife movements through the Coastal Plain. 

Requirement/Standard: Chasing wildlife with ground vehicles is prohibited. Particular attention would be given to avoid disturbing caribou. 

Required Operating Procedure 43 

Objective: Prevent the introduction or spread of nonnative, invasive species in the Coastal Plain. 

Requirement/Standard: Certify that all equipment and vehicles (including barges) intended for use either off or on roads are free of nonnative invasive species 

before transiting into the Coastal Plain. Monitor annually along roads for nonnative invasive species and begin effective weed control measures on evidence of 

their introduction. Before beginning operations in the Coastal Plain, submit a plan for the BLM’s approval, detailing the methods for cleaning equipment and 

vehicles, and monitoring for nonnative, invasive species and identifying control measures. 

Required Operating Procedure 44 

Objective: Minimize loss of populations and habitat for plant species designated as sensitive by the BLM in Alaska. 

Requirement/Standard: If a development is proposed in an area that provides potential habitat for a BLM sensitive plant species, the development proponent 

would conduct surveys at appropriate times of the summer season and in appropriate habitats for the sensitive plant species. The results of these surveys 

would be submitted to the BLM with the application for development. 

Required Operating Procedure 45 

Objective: Minimize loss of individuals and habitat for mammalian species designated as sensitive by the BLM in Alaska. 

Requirement/Standard: If a development is proposed in an area that provides potential habitat for the Alaska tiny shrew, the development proponent would 

conduct surveys at appropriate times of the year and in appropriate habitats into detect the presence of the shrew. The results of these surveys would be 

submitted to the BLM with the application for development. 
2. Alternatives (Description of the Alternatives) 

Coastal Plain Oil and Gas Leasing Program 2-37

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

MARINE VESSEL TRAFFIC-ASSOCIATED ACTIVITIES 

Required Operating Procedure 46 

Objective: Minimize impacts on marine mammals from vessel traffic. 

Requirement/Standard: 

General Vessel Traffic

a. Operational and support vessels would be staffed with dedicated PSOs to alert crew of the presence of marine mammals and to initiate adaptive mitigation 

responses. 

b. When weather conditions require, such as when visibility drops, support vessel operators must reduce speed and change direction, as necessary (and as 

operationally practicable), to avoid the likelihood of injuring marine mammals. 

c. The transit of operational and support vessels is not authorized before July 1. This operating condition is intended to allow marine mammals the 

opportunity to disperse from the confines of the spring lead system and minimize interactions with subsistence hunters. Exemption waivers to this 

operating condition may be issued by the NMFS and USFWS on a case-by-case basis, based on a review of seasonal ice conditions and available information 

on marine mammal distributions in the area of interest. 

d. The transit route for the vessels would avoid NMFS-identified known fragile ecosystems. 

e. Vessels may not be operated in such a way as to separate members of a group of marine mammals from other members of the group. 

f. Operators should take reasonable steps to alert other vessel operators in the vicinity of marine mammals. 

g. Operators should report any dead or injured listed marine mammals to NMFS and the USFWS. 

Vessels in Vicinity of Whales 

a. Vessel operators should avoid groups of 5 or more whales. 

b. All nonessential boat and barge traffic would be scheduled to avoid periods when bowhead whales are migrating through the area to where they may be 

affected by sound from the project. 

c. If the vessel approaches within 1 mile of observed whales, except when providing emergency assistance to whalers or in other emergency situations, the 

operator would take reasonable precautions to avoid potential interaction with the whales by taking one or more of the following actions, as appropriate: 

i. Reducing vessel speed to less than 5 knots within 300 yards of the whale 

ii. Steering around the whale if possible 

iii. Operating the vessel to avoid causing a whale to make multiple changes in direction 

iv. Checking the waters around the vessel to ensure that no whales will be injured when the propellers are engaged 

v. Reducing vessel speed to 9 knots or less when weather conditions reduce visibility to avoid the likelihood of injury to whales 

d. Special consideration of North Pacific right whale and their critical habitat: 

i. Vessel operators will avoid transit in North Pacific right whale critical habitat. If this cannot be avoided, operators must exercise caution and reduce 

speed to 10 knots while in North Pacific right whale critical habitat. 

ii. Vessels transiting through North Pacific right whale critical habitat must have PSOs sighting marine mammals. Vessel operators will maneuver to keep 

875 yards away from any observed North Pacific right whale, while within their designated critical habitat, and avoid approaching whales head-on, 

consistent with vessel safety. 
2. Alternatives (Description of the Alternatives) 

2-38 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement

Alternative B Alternative C Alternative D 

Vessels in Vicinity of Pacific Walruses and Polar Bears 

a. Operators should take all reasonable precautions, such as reduce speed or change course heading, to maintain a minimum operational exclusion zone of 0.5 

mile around groups of feeding walruses. 

b. Except in an emergency, vessel operators would not approach within 0.5 mile of observed polar bears, within 0.5 mile of walrus observed on ice, or within 

1 mile of walrus observed on land. 

Vessels in Vicinity of Seals 

a. Vessels used as part of a BLM-authorized activity would be operated in a manner that minimizes disturbance to wildlife in the coastal area. Vessel operators 

would maintain a 1-mile buffer from the shore when transiting past an aggregation of seals (primarily spotted seals) when they have hauled out on land, 

unless doing so would endanger human life or violate safe boating practices. 

Vessels in Ledyard Bay 

a. Follow USFWS guidelines in relation to Ledyard Bay and Steller’s and spectacled eider critical habitat area.
2. Alternatives (Alternatives Considered but Eliminated from Detailed Analysis)

Coastal Plain Oil and Gas Leasing Program 2-39

Draft Environmental Impact Statement

2.3 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED ANALYSIS

The BLM considered an alternative that would make only 800,000 acres available for lease sales, which is 

the minimum acreage necessary to comply with the requirement in Section 20001(c)(1) of PL 115-97 to 

hold not fewer than two lease sales, each of which offers not fewer than 400,000 acres of the areas having 

the highest potential for discovery of hydrocarbons. The best available information regarding hydrocarbon 

discovery potential in the Coastal Plain provides a rough estimate of 427,900 acres of high HCP, 658,400 

acres of medium HCP, and 477,200 acres of low HCP. Acreages within low and medium HCP areas must 

be made available, in addition to the high HCP areas, for the two lease sales to meet the 800,000-acre 

minimum under PL 115-97. In addition, the actual potential development area would be much less with the 

2,000-acre limitation on surface disturbance. This alternative would also be similar in concept to 

Alternatives D1 and D2, which make only 1,037,200 acres available for lease sales. For all these reasons, an 

alternative that considered only 800,000 acres available for leasing was eliminated from detailed analysis.
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Coastal Plain Oil and Gas Leasing Program 3-1

Draft Environmental Impact Statement

Chapter 3. Affected Environment and 

Environmental Consequences

3.1 INTRODUCTION

This chapter combines the description of baseline environmental conditions and the analysis of 

environmental impacts for each resource. Though these two aspects are often in separate chapters in an 

EIS, they are combined here to facilitate continuity for the reader from baseline conditions to potential 

impacts on each resource. Following the description of baseline conditions, the discussion of potential 

direct, indirect, and cumulative impacts from future oil and gas development under each resource provides 

the scientific and analytic basis for evaluating the potential impacts of each of the alternatives described in 

Chapter 2. The approach to impact analysis is discussed further in Appendix F.

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis in Chapter 3 is of potential direct, indirect, 

and cumulative impacts from on-the-ground post-lease activities.

The proposed leasing alternatives are a result of surface resource and management considerations and 

describe areas to offer for lease and the terms and conditions that would apply to post-lease exploration 

and development activities; they do not specifically propose development of oil and gas resources. For this 

reason, the analysis relies on a hypothetical development scenario consistent with those alternatives and 

PL 115-97 in a good faith effort to identify indirect effects of leasing that are not known at this time but 

nonetheless could be considered "reasonably foreseeable" (40 CFR Section 1508.8(b)) (see Appendix B). 

The regulations governing leasing and development provide for multiple decision stages prior to any 

ground-disturbing activities being authorized and require further compliance with applicable laws, including 

NEPA, during post-leasing decision stages. Until the BLM receives and evaluates an application for an 

exploration permit, permit to drill, or other authorization that includes site-specific information about a 

particular project, impacts of actual exploration and development that might follow lease issuance are 

speculative, as so much is unknown as to location, scope, scale, and timing of that exploration and 

development. At each decision stage, the BLM retains the authority to approve, deny, or reasonably 

condition any proposed on the ground-disturbing activity based on compliance with the terms and 

conditions of the lease and applicable laws and policies. Therefore, the analysis of effects of exploration and 

development in this Leasing EIS necessarily reflects a more general, programmatic approach than could 

occur at the post-lease project-specific stage.

There are many uncertainties associated with projecting future petroleum exploration and development. 

These uncertainties include the amount and location of technically and economically recoverable oil; the 

timing of oil field discoveries and associated development; the future prices of oil and gas, and, more to the 
3. Affected Environment and Environmental Consequences (Introduction)

3-2 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

point, the many exploration companies’ individual assessment of future prices and other competitive 

calculations that play into corporate investment decisions; and the ability of industry to find petroleum and 

to mobilize the requisite technology to exploit it.

To address these uncertainties, the BLM has made reasonable assumptions based on the previous twodimensional seismic exploration of the Coastal Plain, the history of development in the NPR-A and other 

North Slope developments, its own knowledge of the almost entirely unexplored petroleum endowment 

of the Coastal Plain and current industry practice, and professional judgment. In making these assumptions, 

the BLM has striven to minimize the chance that the resultant impact analysis will understate potential 

impacts; therefore, the hypothetical development scenarios (Appendix B) are intended to represent 

optimistic high-production, successful discovery, in a situation of favorable market prices.

The BLM has relied on the best available science to inform its consideration of the environmental impacts 

surrounding an oil and gas leasing program in the Coastal Plain; however, the nature, abundance, and 

quality of the data often vary, depending on the action, the geographic region in which it occurs, and the 

environmental resources that may be affected. All these variables influence the understanding of how 

certain oil and gas exploration and development activities may affect environmental features. Where 

information is missing, this EIS complies with 40 CFR 1502.22.

3.2 PHYSICAL ENVIRONMENT

3.2.1 Climate and Meteorology

Affected Environment

Climate is described by the National Weather Service (NWS) as the most recent 30-year averages of 

meteorological parameters, such as temperature, precipitation, humidity, and winds; thus, climate change is 

treated here as the longer-term change in such variables. Climate change can be driven by natural forces, 

such as volcanic activity, solar output variability, and the earth’s orbital variations, or by human activity, 

such as land use changes or GHG emissions. Much attention in recent decades has focused on the 

potential climate change effects of GHGs, especially carbon dioxide (CO2), which has been increasing in 

concentration in the global atmosphere since the end of the last ice age. 

For a description of climate trends in the Arctic and on the North Slope, the reader is referred to Section 

3.2.3.1 of the Greater Mooses Tooth 2 (GMT2) Development Project Final Supplemental Environmental 

Impact Statement (GMT2 Final SEIS), issued in August 2018 (BLM 2018a). Because climate is defined as 

weather conditions over the most recent three decades, the information contained in the GMT2 Final SEIS 

is applicable to the program and thus is incorporated here by reference. 

The program area is in the Arctic Refuge in northeast Alaska, along the Beaufort Sea, which is part of the 

Arctic Ocean. The area is considered an arctic climate zone, with cold winters spanning approximately 8 

months of the year (October through May) and cool summers, spanning approximately 4 months of the 

year (June through September).

Weather data measured at the Kaktovik Airport on Barter Island from late 1947 through mid-2016 are 

available on the Western Regional Climate Center website under the historical climate data pages. The 

period of record climatological data summary for this location is shown in Table 3-1.
3. Affected Environment and Environmental Consequences (Climate and Meteorology)

Coastal Plain Oil and Gas Leasing Program 3-3

Draft Environmental Impact Statement

Table 3-1

Kaktovik Airport Period of Record Monthly Climate Summary

Parameter Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual

Average max. 

temperature (F)

-7.7 -13.9 -8.8 6.7 26.3 38.4 45.4 43.8 35.4 20.3 5.1 -5.8 15.4

Average min. 

temperature (F)

-20.3 -26.3 -22.5 -9.3 15.7 30.4 34.8 34.4 27.9 10.1 -6.7 -18.3 4.1

Average total 

precipitation (in.)

0.48 0.23 0.21 0.19 0.31 0.53 1.03 1.1 0.68 0.77 0.41 0.26 6.19

Average total 

snowfall (in.)

5 2.7 2.6 2.4 3 1.6 0.5 1.5 4.9 9.2 5 3.4 41.8

Average snow 

depth (in.)

12 14 15 15 10 2 0 0 1 5 8 10 8

Source: WRCC 2018a. Historical Climate Summaries. https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ak0558. 

Percent of possible observations from September 23, 1947, to June 7, 2016: maximum temperature: 98.6; minimum

temperature: 99.7; precipitation: 99.7; snowfall: 95.7; snow depth: 98.5 

Based on the Kaktovik climate data, average monthly precipitation in the area is heaviest in July and 

August, with slightly more than an inch in each of these months. Annual total precipitation averages a little 

greater than 6 inches of liquid equivalent. Monthly snowfall is highest in October, with slightly more than 9 

inches, on average. Snow is typically on the ground for approximately 10 months of the year, with only July 

and August usually having little or no snow depth. July is the warmest month, with an average maximum 

temperature around 45°F and an average minimum temperature around 35°F. February is the coldest 

month, with an average maximum temperature of around -14°F and an average minimum temperature of 

around -26°F. 

Wind speed and direction is measured on Barter Island, at the Kaktovik Airport, as part of the automated 

weather observing system (AWOS) network, operated and controlled by the FAA. The Kaktovik AWOS 

station is near the coast, next to the Coastal Plain area. Using the Iowa State University, Iowa 

Environmental Mesonet website, the Barter Island wind data for the most recent 10 full years, 2008–2017, 

were plotted to produce the wind rose in Figure 3-1, Wind Rose Plot for Barter Island, Kaktovik, Alaska,

in Appendix A (ISU 2018). The wind rose shows a very strong predominance of winds from the east and 

the west, with east winds being the most common. Winds from northerly and southerly directions are 

very infrequent in this area. Average wind speed is also relatively high at 13.8 miles per hour, which would 

imply relatively rapid dispersion of any emitted air pollutants most of the time. Calm winds are recorded 

less than 5 percent of the time.

Farther inland, near the Brooks Range, monthly mean wind speeds are slightly lower (9.4 miles per hour; 

Olsson et al. 2002), but strong winds from the south, readily exceeding exceed 45 miles per hour, can 

originate as katabatic1 flows down the many north-oriented valleys of the Brooks Range (Sturm and 

Stuefer 2013). In general, snow depth and snow water equivalent decrease from inland to the coast (snow 

water equivalent values of 6 to 8 inches near the foothills to 2 to 5 inches near the coast; Liston and Sturm 

1998), while bulk snow density and the prevalence of wind slabs increase (Sturm and Liston 2003).

Wind speed and direction are important to the dilution and transport of air pollutants; wind direction 

determines where the air pollutants emitted in the area are transported. Based on the Kaktovik wind rose, 

 

1Caused by local downward motion of cool air
3. Affected Environment and Environmental Consequences (Climate and Meteorology)

3-4 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

air pollutants are most often transported in a westerly direction, and secondarily, in an easterly direction. 

Wind speed affects the concentration of air pollutants. This is because dispersion and turbulence increase 

with increasing wind speeds, thereby decreasing air pollutant concentrations resulting from an emitted 

plume of pollutants.

The degree of stability in the atmosphere is also a key factor in the dispersion of emitted pollutants. 

During stable conditions, vertical movement in the atmosphere is limited, and the dispersion of pollutants 

is inhibited. Conversely, during unstable conditions, upward and downward movement in the atmosphere 

is enhanced, and dispersion of pollutants in the atmosphere increases. Conditions where temperatures 

increase with height, known as temperature inversions, can result in very stable conditions, with virtually 

no vertical air motion. The program area typically experiences more large-scale temperature inversions in

the winter than in the summer due to colder stable air masses settling closer to the ground during winter. 

Summer periods in the program area typically have greater instability, due to warming and solar-induced 

vertical (convective) air currents.

Recorded climate trends in Alaska, including the North Slope, show a significant increase in temperatures, 

mostly occurring as a step change in 1977, when the Pacific decadal oscillation (PDO) changed from a 

negative phase to a positive phase. The positive phase of the PDO correlates with more southerly winds 

over Alaska in the winter, leading to positive temperature anomalies.

The only North Slope weather station summarized for temperature trends by the Alaska Climate 

Research Center (ACRC) is in Utqiaġvik. Temperature records there show an increase in annual average 

temperature of 6.3°F from 1949 to 2016; a 5.9°F increase has occurred since the PDO shift in 1977. 

Conversely, the 18 other primary reporting stations distributed throughout Alaska show an average of less 

than 1.0°F warming since 1977 (ACRC 2018); thus, it is likely that a reduction in ice cover along the north 

coast of Alaska has had a disproportionate effect on temperature trends since 1977 along the northern 

coast, compared with the rest of Alaska. This is apparent by looking at changes in monthly ice 

concentration on the north Alaska coast and its correlation with changes in temperature (Wendler et al. 

2014).

In contrast to temperature, annual average total precipitation shows no discernable trend from 1925 

through 2016 in the North Slope climate division of Alaska (WRCC 2018b).

In addition to weather data provided by the FAA and NWS stations in northern Alaska, such as at 

Kaktovik and Utqiaġvik, the US Geological Survey (USGS) operates a 16-station, permafrost monitoring 

network in the NPR-A (12 stations) and the Arctic Refuge (4 stations) to help detect changes in 

meteorological conditions and soil temperatures. This network, known as the DOI/Global Terrestrial 

Network for Permafrost Observing System, began operations at some sites as early as 1998, and now has 

over 10 years of data from each site. The four Arctic Refuge stations include three in the program area: 

Marsh Creek, Camden Bay, and Niguanak. The data collected can be found in the 2016 annual report for 

this monitoring network (Urban and Clow 2018) at the following website: 

https://pubs.usgs.gov/ds/1092/ds1092.pdf.

An inventory of recent GHG emissions at various geographic scales is provided in Table 3-2, in units of 

million metric tons (MMT) per year. Development-related emissions can be compared against these values 

to provide an estimate of the relative contribution of such emissions at various geographic scales. Note 

that the emissions in the table do not include sinks that tend to remove some of the emissions from the 
3. Affected Environment and Environmental Consequences (Climate and Meteorology)

Coastal Plain Oil and Gas Leasing Program 3-5

Draft Environmental Impact Statement

Table 3-2

GHG Emissions at Various Geographic Scales in 2015

Geographic Area Data Source Annual Emissions

(MMT/year)

Percent of Global 

Emissions

Alaska ADEC 2018a 41.3 0.084

US EPA 2018a 6,638 13.5

Global Olivier et al. 2017 49,100 100

Source: Olivier et al. 2017; ADEC 2018a; EPA 2018a

atmosphere. For example, a significant fraction of CO2 emitted by human sources each year is taken up by 

the biosphere, which is gaining mass in response to the emissions.

Local and Global Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct, indirect, and cumulative 

impacts on the climate from on-the-ground post-lease activities.

This assessment deals primarily with climate, defined as longer-term (30 years or more) variations in 

meteorological conditions. Any potential effects of post-lease oil and gas activities on meteorological 

conditions would be on a very small scale (microscale) and would cover very small portions of the 

program area, for example, such as a decrease in localized wind speeds and the creation of snowdrifts 

immediately downwind of structures; therefore, impacts on meteorological conditions are not addressed 

further in this section. Also, the climate and meteorology impacts of the Coastal Plain oil and gas leasing 

program are generally similar between the action alternatives being considered. 

Regarding the potential effects of climate change on the region in general, the reader is referred to Section 

3.2.4 of the GMT2 Final SEIS for a detailed discussion (BLM 2018a). With respect to climate change effects 

of post-lease oil and gas activities, there are two aspects of potential indirect climate impacts that are 

addressed below:

1. Impacts associated with potential development on climate change (due to emissions of GHGs)

2. Climate change impacts on potential development

Impacts Associated with Potential Development on Climate Change

The potential impacts of post-lease oil and gas activities on the climate could occur at the microscale, due 

to building structures and installing combustion sources that can heat localized areas near development. 

These effects would be very small and of little effect in the vast majority of the program area. 

The macroscale effects on climate change would be through GHG emissions that can contribute to a 

change in the composition of the global atmosphere, thereby increasing the so-called greenhouse effect on 

the planet’s heat retention. The GHG emissions that could result from post-lease oil and gas activities

would be through combustion of fossil fuels (mainly natural gas, diesel fuel and gasoline) for construction, 
3. Affected Environment and Environmental Consequences (Climate and Meteorology)

3-6 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

drilling, production, processing, and transport of the petroleum products. There is also a potential for 

additional GHG emissions from combustion of the products themselves in the global marketplace.

Estimates of potential GHG emissions changes resulting from future development following the leasing 

decision can be described as either direct emissions or indirect emissions. The direct emissions are those 

resulting from construction, drilling, production, processing, and transportation. The indirect emissions are 

those resulting from the combustion of the petroleum products, due to a relatively small increase in US 

demand for liquid petroleum products, which could result from increased US supply due to potential 

development. The natural gas produced as a result of future oil and gas development may initially be reinjected to conserve the natural gas and maintain reservoir pressure for oil recovery, as is currently done 

with excess gas that is not used as fuel on the North Slope. Some amount of natural gas would be 

produced as a byproduct of oil production in some formations. Use of this natural gas on the global 

markets is anticipated at some point in the future; the State of Alaska is pursuing a plan to build a natural 

gas transport pipeline from the North Slope to access markets in Asia. Gas transported through the 

pipeline is expected to come from established fields with proven reserves initially but could eventually 

include natural gas from the Coastal Plain. 

Direct GHG Emissions from Future Development

To provide an approximation of total potential GHG emissions from construction, drilling, production, 

processing, and transportation of post-lease oil and gas activities (not accounting for the fact that such 

emissions are likely not entirely additive in a global context), the GMT2 Final SEIS (BLM 2018a) projections 

for direct GHG emissions were scaled according to the respective total amounts of estimated oil 

production from GMT2, versus the ranges projected for the Coastal Plain leasing program. For the GMT2 

development, total recoverable oil is estimated at approximately 170 million barrels (BLM 2018a). For the 

Coastal Plain development, total production potential is estimated to range from 1.5 to 10 BBO, or 

anywhere from 9 to 59 times as much as for GMT2.

Assuming that the potential direct GHG emissions are directly proportional to oil production, and using 

the GMT2 emissions estimates (BLM 2018a, Table 79) as a basis for scaling the Coastal Plain development 

emissions, a comparison of estimated oil production and related maximum annual GHG emissions for the 

Coastal Plain development is provided in Table 3-3. The GHG emissions in Table 3-3 are estimated as 

carbon dioxide equivalents (CO2e). Note that based on the GMT2 Final SEIS, the estimated GHG 

emissions vary substantially by year of the development; thus, the GMT2 Final SEIS annual average over an 

assumed 37-year construction, drilling, and production period is used for this analysis. The Coastal Plain 

production could extend much longer than 37 years, perhaps from 50 to 100 years; 70 years is assumed 

for purposes of making annual GHG projections for this Leasing EIS. While a 100-year production duration 

would substantially decrease annual average emissions from the Coastal Plain, the effect on total 

development GHG emissions would not change. This is because the Coastal Plain development would still 

represent approximately 9 to 59 times the estimated oil production and therefore 9 to 59 times the direct 

GHG emissions of the GMT2 development.
3. Affected Environment and Environmental Consequences (Climate and Meteorology)

Coastal Plain Oil and Gas Leasing Program 3-7

Draft Environmental Impact Statement

Table 3-3

Projected Oil Production and Direct GHG Emissions Estimates

Development Total Oil Produced 

(Million Barrels)

Average Annual Oil 

Produced (Million 

Barrels)

Average Annual GHG 

Emissions

(Metric Tons of CO2e)

GMT2 170.1 4.6 12,180

Coastal Plain 1,500 to 10,000 21 to 143 56,739 to 378,261

Source: BLM 2018a

Indirect GHG Emissions from Future Development

While petroleum is obviously a global commodity, the analysis here is based on changes in US demand, 

projected from estimates made with a market demand model called MarketSim, developed by the Bureau 

of Ocean Energy Management (BOEM). The MarketSim model considers only the US supply and demand 

for petroleum; thus, the accuracy of the change (increase) in petroleum demand estimated from 

MarketSim projections is limited, given its scope is just the US market; however, any type of supply and 

demand projections must be considered as quite uncertain, given the inherent difficulties in economic 

projections.

According to the US Department of Energy, Energy Information Administration (EIA 2018), global 

petroleum liquids production and consumption in 2018 is projected to average approximately 100 million 

barrels of oil (equivalents) per day. The proposed Coastal Plain oil and gas leasing program is expected to 

result in potential production totaling in the range of 1.5 to 10 BBO. Assuming a 70-year period for this 

production, the average for this development over its operating life would therefore range from 0.06 to 

0.39 million barrels per day; thus, post-lease oil and gas activities could supply in the range of 0.1 to 0.5 

percent of global oil production, once the field has reached peak production. Given that global oil 

production continues to increase, the development that could occur with the Coastal Plain oil and gas 

leasing program would represent a smaller fraction of global production as the years pass. The potential 

natural gas production estimate for the Coastal Plain ranges from 0 to 7 trillion cubic feet (TCF) of gas 

produced (Attanasi 2005).

BOEM applied its MarketSim model for the Coastal Plain development on the North Slope, for both the 

low- and high-end production cases (BOEM 2018a). The BOEM projections show that without the Coastal 

Plain production, US oil demand would be lower by an amount equal to 3.4 percent, in barrels of oil 

equivalent, of the low-end production case, and 3.9 percent lower for the high-end production case. 

Looking at it another way, post-lease oil and gas activities is projected to increase US oil demand by 3.4 

percent (low-end case) to 3.9 percent (high-end case) of the projected Coastal Plain leasing production. 

Conversely, over 96 percent of the Coastal Plain oil production is projected to replace other US (and 

likely global) production that would not happen if development goes forward. The BOEM projections 

include production of both oil and natural gas from the Coastal Plain, expressed as barrels of oil equivalent. 

For natural gas, the analysis assumes the production eventually makes its way to the US or global market, 

regardless of whether some of the natural gas production is initially reinjected. 

Using the MarketSim projections for the incremental (Action minus No-Action) production in barrels of 

oil equivalent, BOEM applied its Greenhouse Gas Lifecycle model (GHG Model) to estimate total GHG 

emissions with and without Coastal Plain development. Based on this analysis, and assuming a 70-year 

production and consumption period for the Coastal Plain, the incremental (Action minus No-Action) 

annual indirect GHG emissions estimates are shown in Table 3-4. 
3. Affected Environment and Environmental Consequences (Climate and Meteorology)

3-8 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Table 3-4

Projected Oil Production and Indirect GHG Emissions Estimates for the Coastal Plain

Case Total Oil Produced 

(Million Barrels)

MarketSim Fraction of 

Coastal Plain Demand 

Increase (%)

Annual GHG Emissions 

Increase (Million Metric 

Tons of CO2e)

Low-end Case 1,500 3.4 0.7

High-end Case 10,000 3.9 5.0

Source: BOEM 2018a

The estimated Coastal Plain oil and gas development potential direct and indirect emissions portion of 

estimated 2015 global emissions are shown in Table 3-5, along with the percentage of developmentrelated GHG emissions at the state and national scales. The projected annual average Coastal Plain drilling 

and operational direct emissions represent up to 0.0008 percent of 2015 global emissions. The estimated 

indirect emissions resulting from development due to post-lease oil and gas activities represent up to 

approximately 0.01 percent of global GHG emissions, as shown in Table 3-5. As discussed above, the 

direct emissions are those from production, processing and transport activities, while the indirect 

emissions are those from combustion of the net fuels production exported to markets.

Table 3-5

Estimated Future Development GHG Emissions versus 2015 Emissions at Various 

Geographic Scales

Geographic Area Inventory 

Year Data Source

Annual CO2e 

Emissions

(Million Metric 

Tons of CO2e)

Portion of 

US 

Emissions

(%)

Portion of 

Global 

Emissions

(%)

Coastal Plain Direct 

Emissions

NA Projected 0.06 to 0.38 0.0009 to 

0.006

0.0001 to 

0.0008 

Coastal Plain Minimum 

Indirect Emissions

NA Projected 0.7 0.01 0.0014

Coastal Plain Maximum 

Indirect Emissions

NA Projected 5.0 0.08 0.01

Alaska 2015 ADEC 2018a 41.3 0.62 0.084

US 2015 EPA 2018a 6,638 100 13.5

Global 2015 Olivier et al. 

2017

49,100 740 100

Source: Olivier et al. 2017; ADEC 2018a; EPA 2018a

MMT = million metric tons of GHG measured as CO2e.

In addition to the combustion-related emissions estimates provided above, some of the reservoir 

hydrocarbons, most importantly methane, escape to the atmosphere without being combusted. These 

methane emissions are due to leaks during the drilling, production, processing and transport of natural gas. 

It is difficult to obtain accurate estimates of the amount of GHG emissions (as CO2e) from such leaks as 

compared to the GHG emissions from combustion processes. The 2016 emission inventory from the EPA 

estimates that 81 percent of US GHG emissions (as CO2e) are CO2, 10 percent are methane, and the 

remainder are other GHGs (EPA 2018b). EPA estimates that 31 percent of the 2016 methane contribution 

is from oil and gas production activities, which would mean that 3.1 percent of US total GHG emissions 

are from methane associated with oil and gas production. Nationally, the EPA estimate of methane’s GHG 
3. Affected Environment and Environmental Consequences (Climate and Meteorology)

Coastal Plain Oil and Gas Leasing Program 3-9

Draft Environmental Impact Statement

contribution from petroleum production processes represents on the order of 5 percent of the CO2e 

contribution from the nationwide petroleum and natural gas combustion. Thus, this would represent a 

marginal incremental amount of GHG emissions, equal to roughly 5 percent of the estimated indirect 

emissions from combustion of Coastal Plain products shown in Table 3-4 for the low-end and high-end 

cases. 

Social Costs of GHG Emissions

Another approach to analyzing possible climate change impacts on potential development is to calculate 

what is commonly known as the social cost of carbon (SCC). Section F2.1 in Appendix F provides 

detail on the reasons why the use of the SCC protocol was not included in this EIS. 

Impacts of Climate Change on Potential Development

The impacts of climate change on potential development could include a shorter winter construction 

season. This is defined as the time when the ground and lakes are adequately frozen to support heavy 

equipment movement. Permafrost is not likely to disappear in the program area during the life of any oil 

and gas development in the program area; however, if temperatures continue to warm in the area, the 

warm season active zone (thawed soil zone) would go deeper, making equipment movement more difficult 

in warm months, possibly increasing road maintenance frequency and costs. If summer active soil depth 

increases substantially, allowances would need to be made for more substantial structural supports that 

rely on permafrost, perhaps requiring deeper anchoring of such supports. 

Summer sea ice extent in the Arctic has risen slightly from the lows of the past decade, with July 2018 

monthly average sea ice extent the highest it has been of any July since 2005, at 3.66 million square miles. 

This is approximately 20 percent lower than the maximum measured July average Arctic sea ice extent of 

4.56 million square miles in 1983, and about 12 percent higher than the lowest July extent of 3.27 million 

square miles measured in 2012 (DMI 2018). The period of record for these satellite measurements goes 

back only to 1979, which is likely near a modern peak in Arctic ice, given the shift in the PDO that 

occurred in 1977. After 1977 there was a dramatic shift upward in annual mean temperatures in Alaska, 

along with a multi-decade decrease in Arctic ice extent. Continued recovery or further declines in Arctic 

sea ice can have their most significant impacts on temperatures in North Slope coastal areas, such as the 

program area. Inland areas are buffered from the moderating effects of open water, so the program area 

would be more sensitive to changes in sea ice, compared to developments farther inland.

At current rates of sea level rise, from around 7 inches per century (tide gauge record) to 12 inches per 

century (satellite measurements), sea waters are not expected to encroach on any potential development 

within an approximate 50-year life of production facilities or access roads for the program area. 

Cumulative Impacts

GHG emissions disperse through the global atmosphere relatively quickly relative to the time scales of 

concern for climate, which are decades to centuries. The emissions projections above compare the effects 

of post-lease oil and gas activities in the context of statewide, US, and global GHG emissions, which 

continue to increase. The potential cumulative climate impacts of global development and associated GHG 

emissions have been discussed extensively in the published literature, including several reports by the 

Intergovernmental Panel on Climate Change and numerous scientific journals, and therefore, are not 

repeated here (BLM 2018a; IPCC 2014; Melillo et al. 2014; ACIA 2005).
3. Affected Environment and Environmental Consequences (Air Quality)

3-10 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

3.2.2 Air Quality

Affected Environment

Air quality is measured by the concentration of air pollutants in a geographic area. Wind, temperature, 

humidity, and geographic features, in addition to natural and anthropogenic emissions sources, are factors 

that have the potential to affect the resource. Indicators of impacts on air quality are the inability to meet 

NAAQS and a degradation of air quality-related values, such as visibility and deposition.

Air Quality

The federal Clean Air Act provides the framework for protecting air quality at the national, state, and local 

level. The act designates the EPA as the chief governing body of air resources in the US; however, it 

provides states with the management authority to implement their own air quality legislation, monitoring, 

and control measures. With EPA approval, state and local air districts can implement their own permitting 

and emissions control regulations to implement federal requirements, and the state and local requirements 

cannot be less stringent than the federal requirements. The ADEC is the regulating authority to enforce 

the Alaska Air Quality Control Regulations under 18 Alaska Administrative Code (AAC) 50.

Under the authority of the Clean Air Act, the EPA has set time-averaged NAAQS for six criteria air 

pollutants considered to be key indicators of air quality: carbon monoxide (CO), nitrogen dioxide (NO2), 

ozone (O3), sulfur dioxide (SO2), lead (Pb), and two categories of particulate matter (less than 10 microns 

in diameter [PM10] and less than 2.5 microns in diameter [PM2.5]) (EPA 2018c). These standards may be 

updated periodically based on peer-reviewed scientific data. States may set their own ambient air quality 

standards for criteria pollutants and other pollutants, but their criteria pollutant standards must be at least 

as stringent as the federal standards. AAAQS are the same as the NAAQS, except for the addition of a 

standard for ammonia. The program area is in attainment or unclassifiable (treated as attainment for 

regulatory purposes) for each of the NAAQS (EPA 2018d). The nearest nonattainment area is in 

Fairbanks, approximately 350 miles southwest of the Coastal Plain; Fairbanks is in a nonattainment status 

for the PM2.5 NAAQS (EPA 2018d).

The Clean Air Act requires each state to identify areas that have ambient air quality in violation of federal 

standards using monitoring data collected through state and federal monitoring networks. There are no 

state or federal air quality monitoring stations in or near the program area. Industry monitoring that 

conforms to EPA guidance is the only available quantitative indicator of air quality on the North Slope. 

There are two monitoring stations that report complete, multiyear data near the program area: BPXA’s APad Meteorological and Ambient Air Monitoring Station, approximately 60 miles west of the Coastal Plain 

boundary, and the ConocoPhillips Alaska, Inc.’s Nuiqsut Ambient Air Quality and Meteorological

Monitoring Station, approximately 110 miles west of the Coastal Plain boundary. Table 3-6, below, shows 

the average pollutant concentrations at each of these stations for the most recent 3 years of verified data 

(2014–2016) and the percentage of the relevant NAAQS/AAAQS for the 3-year average.

In addition, ADEC reports monitoring values for short-term, project-specific air quality monitors used in 

the air permitting process. There are nine monitors on the North Slope, including the two described in 

Table 3-6, from which data have been collected and verified since 2009, usually for 1 year. None of the 

data from any of these monitors have shown exceedances of the NAAQS/AAAQS (ADEC 2018b). Based 

on the limited oil and gas development and the small size of the resident population near the Coastal Plain, 

it is likely that the baseline air quality pollutant concentrations in the program area are lower than those 

reported by A-Pad, Nuiqsut, and other monitoring stations on the North Slope.
3. Affected Environment and Environmental Consequences (Air Quality)

Coastal Plain Oil and Gas Leasing Program 3-11

Draft Environmental Impact Statement

Table 3-6

Average Air Pollutant Monitoring Values, 2014-2016

Pollutant Average 

Time

A-Pad Monitoring 

Station Average 

Background Conc. 

(2014-2016) a

Nuiqsut Monitoring 

Station Average 

Background Conc. 

(2014-2016) b

NAAQS/ 

AAAQS c

Percent of NAAQS

A-Pad Nuiqsut

CO 1-hour — 1,230 μg/m340,000 μg/m3 — 3

CO 8-hour — 1,230 μg/m310,000 μg/m3 — 12

O3 8-hour 89.0 μg/m3 — 140 μg/m364 —

NO2 1-hour 59.3 μg/m341.9 μg/m3188 μg/m332 22

NO2 Annual 5.2 μg/m33.8 μg/m3100 μg/m35 4

SO2 1-hour 10.4 μg/m35.9 μg/m3196 μg/m35 3

SO2 3-hour 7.5 μg/m36.2 μg/m31,300 μg/m30.6 0.5

SO2 24-hour 1.8 μg/m34.8 μg/m3365 μg/m30.5 1

SO2 Annual 0.5 μg/m30.003 μg/m3 — 0.6 —

PM10 24-hour — — 150 μg/m3 — 30

PM2.5 24-hour — 7.3 μg/m335 μg/m3 — 21

PM2.5 Annual — 2.1 μg/m312 μg/m3 — 18

Source: a ADEC 2018b; b BLM 2018a, c Standards converted to micrograms per cubic meter (μg/m3) 

In addition to criteria pollutants, the Clean Air Act regulates toxic air pollutants, or hazardous air 

pollutants, that are known or suspected to cause cancer or other serious health effects or adverse 

environmental impacts. The hazardous air pollutant regulatory process identifies specific chemical 

substances that are potentially hazardous to human health. It sets emission standards to regulate the 

amount of those substances that can be released by individual facilities or by specific types of equipment. 

Controls can be required at the source, either through manufacturer requirements, or via add-on control 

devices, to limit the release of these air toxics into the atmosphere. The hazardous air pollutants most 

relevant to oil and gas operations are formaldehyde, n-hexane, benzene, toluene, ethylbenzene, xylenes, 

acetaldehyde, ethylene glycol, and methanol; other compounds may be identified as potentially hazardous 

air pollutants and evaluated during project-specific analysis. There are limited sources for these pollutants 

on the Coastal Plain.

Visibility 

Haze is a form of air pollution that occurs from refraction of sunlight on particles in the atmosphere. The 

result of haze is impaired visibility. In 1999, the EPA published the Regional Haze Rule, implementing a 

visibility protection program for certain areas; these are national parks and wilderness areas classified as 

Class I areas. The Class I area nearest to the program area is Denali National Park, which lies about 425 

miles southwest. In a NEPA context, analysis is sometimes done to assess potential visibility impacts in 

areas considered sensitive in the context of preserving the visitor experience, such as federally managed 

national parks, monuments, wilderness areas, and wildlife refuges that were not designated as Class I areas. 

The nearest such areas are the Arctic Refuge, in which the Coastal Plain is located, and Gates of the Arctic 

National Park, approximately 125 miles southwest of the Coastal Plain.

Visibility in some of these areas is monitored through the Interagency Monitoring for the Protection of 

Visual Environments (IMPROVE). Visibility is described by two units of measure: haze index in deciviews 

(dv) and standard visual range. Visibility at Gates of the Arctic National Park (Bettles Field Station), the 

closest monitored location to the program area, is shown in Figure 3-2, Visibility Data for Gates of the 

Arctic National Park, in Appendix A (IMPROVE 2018a). Data collected at the monitor showed an 

improvement in conditions on the haziest days and essentially constant visibility conditions for the clearest 
3. Affected Environment and Environmental Consequences (Air Quality)

3-12 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

days from 2010 to 2014. The 4 dv measure on the clearest days corresponds to a visual range of about 

160 miles; the approximately 13 to 9 dv on the haziest days corresponds to a visual range of 65 to 100 

miles (IMPROVE 2018b).

Deposition 

In atmospheric deposition, air pollutants are removed from the atmosphere and subsequently deposited in 

aquatic and land-based ecosystems. This can occur through precipitation or through the dry gravitational 

settling of particles onto soil, water, and vegetation. A primary issue of atmospheric deposition is the 

formation of acids, particularly nitrogen and sulfur species. This can happen as acid rain and snow and the 

subsequent deterioration of lakes, streams, soils, nutrient cycling, and biological diversity. Additional 

compounds that can accumulate from atmospheric deposition are air toxins, heavy metals, such as 

mercury, and nutrients, such as nitrates and ammonium.

Gates of the Arctic National Park, described above under Visibility, is the nearest area where nitrogen 

critical loads have been analyzed and recorded. The critical load ranged between 1 and 3 kilograms per 

hectare per year (kg/ha-yr), based on 2010 and 2011 estimates, while the maximum nitrogen deposition 

was 0.94 kg/ha-yr, based on recorded values from 2008 through 2015 (BLM 2018a).

The National Acid Deposition Program/National Trends Network measures concentrations and 

deposition rates of constituents removed from the atmosphere by precipitation (wet deposition). It 

focuses on those that affect rainfall acidity and those that may cause adverse ecological effects. Trends for 

ammonium, nitrate, and sulfate ions show that for Gates of the Arctic National Park, recorded deposition 

is decreasing (BLM 2018a, Figures 3.2-4 to 3.2-6). 

The Clean Air Status and Trends Network (CASTNET) measures air quality and deposition trends in rural 

areas. In conjunction with other national monitoring networks, CASTNET data are used to assess 

relationships between regional pollution and total deposition patterns and to evaluate the effectiveness of 

national and regional emission control programs. For dry deposition, CASTNET logs flux data from 

monitoring stations across the country; flux is the rate at which dry particles reach the ground. The 

nearest monitor with recent data is in Denali National Park. From 1998 through 2016, sulfate ion dry 

deposition reached its maximum at 2.5 kg/ha/yr, in 2006. Nitrate ion dry deposition reached its maximum 

just below 2.0 kg/ha/yr in 2004, and ammonium ion dry deposition reached its maximum of 1.4 kg/ha/yr, in 

2004. The annual average trend for all three ion fluxes has been consistent over the period of record for 

this monitoring station (BLM 2018a, Figure 3.2-7).

Air Pollutant Sources 

There are few sources of air pollutants on the Coastal Plain. The primary pollutant sources are residential 

and commercial heating sources and mobile sources, such as snowmachines, vehicles, and aircraft. 

Additional emission sources on the wider region of the North Slope are oil and gas facilities, with lesser 

contributions by electricity generation and waste treatment. The nearest oil and gas facilities occur in the 

Point Thompson, Badami, Liberty, and Duck Island oil and gas units, west of the Coastal Plain (Alaska 

Division of Oil and Gas 2017). As of 2003, there were more than 4,800 exploratory and production wells 

on Alaska’s North Slope (NRC 2003); as of 2018, there were approximately 2.7 million acres of active 

leases there (Alaska Division of Oil and Gas 2018). There are no active leases or active wells in the 

Coastal Plain. 
3. Affected Environment and Environmental Consequences (Air Quality)

Coastal Plain Oil and Gas Leasing Program 3-13

Draft Environmental Impact Statement

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

air quality from on-the-ground post-lease activities.

This section describes the potential impacts of future Coastal Plain oil and gas development on air 

resources. Oil and gas leasing would have no direct impacts on air quality or AQRVs, as it would not 

authorize any on-the-ground actions. This EIS may lead to indirect impacts because its ROD would 

authorize lease sales and the issuance of leases that then could result in on-the-ground oil and gas activities 

being permitted. These post-lease activities would emit air pollutants from a variety of sources during 

exploration, development, and production. These pollutants could affect air quality and AQRVs on the 

Coastal Plain and in nearby areas. 

Alternative A

Under Alternative A, no federal minerals in the program area would be offered for future oil and gas lease 

sales following the ROD for this EIS. No potential impacts on air quality or AQRVs from oil and gas 

development on the Coastal Plain would occur. Local and regional air emission sources, described above 

under Affected Environment, would continue to contribute air pollutants at levels commensurate with the 

increase or decrease in these emission sources over time. 

Impacts Common to All Action Alternatives

Potential increases in pollutant emissions and associated impacts on air resources are expected to be 

similar across all action alternatives. While the locations of facilities would vary by alternative based on the 

lease stipulations that would be applied to protect other resources, the overall levels of surface 

disturbance and well development would be the same across alternatives (Appendix B). In addition, 

similar air quality ROPs would be applied across all alternatives (Table 2-2 in Chapter 2). Where

potential impacts on air quality can be differentiated, these are described under the specific alternatives, 

below.

The types of air emission sources associated with oil and gas development on the North Slope of Alaska 

are described in detail in a number of recent studies, including the NPR-A Final Integrated Activity Plan 

(IAP)/EIS (BLM 2012), the air analysis prepared for the GMT2 Final SEIS (BLM 2018a), and the BOEM 

Arctic Air Quality Modeling Study reports (BOEM 2014, 2016, 2017). These studies detail the oil and gas 

development phases and the associated emission sources required during each phase to bring oil and gas 

resources on the North Slope to production. The types of emissions sources analyzed in those studies are 

assumed to be similar to those required to recover oil and gas resources on the Coastal Plain. Future

development proposals on the Coastal Plain are anticipated to be similar in scope to the GMT2 project 

described and analyzed in the GMT2 Final SEIS (BLM 2018a).

As described by these reports, emissions and emission sources would vary based on the phase of 

development, as summarized below:
3. Affected Environment and Environmental Consequences (Air Quality)

3-14 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

 During seismic surveying, emissions would be produced by vibreosis rubber tracked vehicles, 

helicopters, and bulldozers or larger tracked vehicles used to pull the camp trains. Pollutant 

emissions would consist primarily of nitrogen oxides and CO, with lower levels of other criteria 

pollutants. 

 During exploratory drilling, emissions would be produced mainly by drilling equipment required 

for exploratory and delineation wells. Additional sources of emissions would be support 

equipment and vehicles and intermittent activities such as mud degassing and well testing. Pollutant 

emissions would be dominated by nitrogen oxides, with more moderate levels of VOCs and CO, 

and lower levels of other criteria and hazardous pollutants. 

 During the development phase, emissions would be produced by heavy construction equipment 

used to construct the CPFs, satellite well pads, ice roads, and pipelines; well drilling and 

completion drilling engines/turbines; and support vehicles and aircraft. The primary emissions 

would be nitrogen oxides and CO, with lesser amounts of VOCs, particulate matter, and SO2.

 During the production phase, the primary source of emissions would be power generation for 

heating, oil pumping, and water injection. The emissions would consist primarily of CO and 

nitrogen oxides, with smaller amounts of particulate matter. There would also be minimal 

evaporative losses of VOCs from oil/water separators, pump and compressor seals, valves, and 

storage tanks. Venting and flaring could be an intermittent source of nitrogen oxides, VOCs, and 

possibly SO2.

Emissions from seismic surveying and exploratory drilling are expected to be low compared with 

emissions from development and production. The emissions inventory developed for the BOEM Arctic Air 

Modeling Study estimated that for all phases of onshore oil and gas development (seismic surveys, 

exploratory drilling, and development/production), seismic survey operations accounted for less than 1 

percent of each type of criteria or hazardous air pollutant emitted, and exploratory drilling accounted for 

less than 20 percent of VOCs and less than 10 percent of each other type of pollutant emitted (BOEM 

2014, Table VI-4). The seismic survey activities evaluated in the BOEM emissions inventory report (BOEM 

2014, page III-1) would be similar in scale to seismic survey activities on the Coastal Plain (Brumbaugh pers 

comm 2018)2. Thus, potential emissions in the short term would be less than emissions in the long term, 

assuming that exploration ultimately led to the buildout of oil and gas facilities as described by the 

hypothetical development scenario (Appendix B).

Since the program area is undeveloped, oil and gas resource development would require the construction 

of a system of gravel and ice roads and airstrips to access the CPFs and satellite well pads, as well as 

construction of the CPFs and satellite pads themselves. This construction would require the development 

of gravel pits, which are not included in the 2,000-acre limit on the surface development of production and 

support facilities. Infrastructure and gravel pit development would be sources of localized fugitive 

particulate matter emissions, both during construction of these features and during use of the roads and 

operation of the gravel pits (e.g., blasting, loading, and hauling).

Because the location, timing, and level of future oil and gas development on the Coastal Plain is unknown 

at this time, a qualitative analysis is being performed. At this initial leasing stage, there is a lack of locationand timing-specific information regarding any potential on-the-ground oil and gas activities that may result 

from leasing. Thus, a quantitative analysis would be highly speculative and result in a worst-case scenario 

 

2Brumbaugh, Robert. Personal communication. Email from Robert Brumbaugh, BLM to Amy Cordle, EMPSi on 

September 4, 2018 regarding seismic survey activity levels.
3. Affected Environment and Environmental Consequences (Air Quality)

Coastal Plain Oil and Gas Leasing Program 3-15

Draft Environmental Impact Statement

outcome that is not helpful to the understanding of decision makers and the public. Future on-the-ground 

actions requiring BLM approval, including seismic surveys, exploratory drilling, and specific development 

proposals, would each require further NEPA analysis based on specific and detailed information about 

where and what kind of activity is proposed. Potential emissions from future development proposals are 

anticipated to be of a type and scale evaluated in the GMT2 Final SEIS (BLM 2018a) and included in the 

BOEM air study (BOEM 2016) onshore oil and gas emissions assumptions.

Based on the air analyses performed for the NPR-A, GMT2, and BOEM Air Modeling Study (BLM 2012; 

BLM 2018a; BOEM 2016, 2017, respectively), the monitoring data reported by ADEC for nine oil and gas 

development projects on the North Slope (ADEC 2018b), the low levels of criteria air pollutants in the 

ambient air (Table 3-6), and the meteorological conditions of the Coastal Plain described in Section 

3.2.1, Climate and Meteorology, it is unlikely that a future project-specific proposal on the Coastal Plain 

would exceed a project-level Prevention of Significant Deterioration increment or cause ambient 

conditions to exceed an NAAQS/AAAQS, a critical visibility threshold, or a deposition analysis threshold 

as determined through project-specific air modeling.

However, because air quality conditions at the time of future project proposals would be different than air 

quality conditions today and because oil and gas development on the North Slope is expected to increase 

and contribute to cumulative air quality impacts over time, each project-specific NEPA analysis would 

require a determination of potential direct, indirect, and cumulative impacts on air quality and AQRVs.

In addition, ADEC would require air emission permits and dispersion modeling to assess potential impacts 

of specific facilities in accordance with EPA and Alaska rules and guidance. Air pollutant emissions from a 

proposed future project would be subject to federal and state air quality regulations under the Clean Air 

Act. Air pollution impacts are limited by air quality regulations and standards, and state implementation 

plans, established under the federal Clean Air Act and the Clean Air Act amendments of 1990. In Alaska, 

air pollution impacts are managed by ADEC under the Alaska Air Quality Control Regulations (18 AAC 

50) and the EPA-approved state implementation plan. In Alaska, portable oil and gas operations must be 

authorized under an ADEC minor air quality permit. Future projects would be required to obtain all 

applicable state air quality permits.

Site-specific terms and conditions that may be required prior to authorizing any future oil and gas activity 

would be determined as part of future NEPA analyses and may include one or more of the following as 

outlined in detail in ROP 6 (Chapter 2):

 Collecting baseline ambient air data for a time period sufficient to support air quality modeling to 

analyze direct, indirect, and cumulative impacts (typically, one year) prior to initiation of NEPA 

analysis and air permit application review if no monitoring data are available

 Preparing an emissions inventory to determine pollutants of concern

 Preparing an emissions reduction plan to reduce project-related air emissions, fugitive dust, or 

GHGs 

 Conducting air modeling to analyze direct, indirect, and cumulative impacts

 Implementing mitigation measures and strategies in addition to regulatory requirements if the air 

quality analysis shows potential future impacts on NAAQS/AAAQS or AQRVs

 Conducting monitoring for the life of the project depending on the magnitude of potential air 

emissions from the project, proximity to population centers, or other factors
3. Affected Environment and Environmental Consequences (Air Quality)

3-16 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

 Modifying activities if monitoring indicates that emissions are causing or contributing to impacts 

that would cause unnecessary or undue degradation of the lands, cause exceedances of NAAQS, 

or fail to protect health 

 Providing air quality baseline monitoring, emissions inventory, and modeling results to the state, 

local communities, tribes, and other entities in a timely manner

Alternatives B through D

Potential impacts under Alternatives B through D would be the same as described under Impacts Common 

to All Action Alternatives. In addition to ROP 6, all oil and gas operations (vehicles and equipment) that burn 

diesel fuels must use “ultra-low sulfur” diesel as defined by the EPA, which would minimize certain 

emissions from these sources.

Cumulative Impacts

Potential cumulative effects on air quality and AQRVs over the life of this EIS would result from existing 

sources of air pollutants in combination with the reasonably foreseeable future actions described in 

Appendix F. The cumulative effects analysis area for air quality includes the North Slope and the areas 

described under Affected Environment as sensitive in the context of preserving visitor experience, 

including the Arctic Refuge and Gates of the Arctic National Park. The nearest federal Class I area, Denali 

National Park and Preserve, is over 425 miles south of the Coastal Plain and is therefore not included in 

the cumulative effects analysis area. 

No quantitative cumulative analysis has been prepared specifically for this EIS. Air analyses prepared for the 

GMT2 Final SEIS (BLM 2018a) and the BOEM Arctic Air Quality Modeling Study’s Photochemical Modeling 

Report (BOEM 2016) are used to inform the cumulative effects analysis for this EIS, recognizing that these 

efforts did not include oil and gas development on the Coastal Plain in the modeling of potential cumulative 

effects on air quality and AQRVs. No such development had been proposed at the time of those analyses.

The methodology for analyzing cumulative effects on air quality in the GMT2 Final SEIS was described in 

Section 4.6.5 of that document (BLM 2018a). This included evaluating the effects of 14 onshore and 

offshore oil and gas development sources and the Deadhorse Power Plant. The results were included in 

Tables 4.6-5 through 4.6-8 in BLM 2018a. Cumulative criteria air pollutant concentrations in the Arctic 

Refuge (Table 4.6-5, BLM 2018a) and Gates of the Arctic National Park (Table 4.6-6, BLM 2018a) were 

modeled to be well under the NAAQS/AAAQS. Cumulative visibility impacts were estimated at a change 

of less than 5 dv at the Arctic Refuge and approximately 1 dv at Gates of the Arctic National Park (Table 

4.6-7, BLM 2018a). Cumulative deposition impacts were estimated at 0.025 kg/ha-yr for nitrogen and 0.006 

kg/ha-yr for sulfur at the Arctic Refuge and 0.004 kg/ha-yr for nitrogen and 0.001 kg/ha-yr for sulfur at 

Gates of the Arctic National Park (Table 4.6-8, BLM 2018a). As described above under the Affected 

Environment, measured maximum nitrogen deposition was 0.94 kg/ha-yr at Gates of the Arctic National 

Park; adding the cumulative nitrogen deposition level of 0.004 kg/ha-yr would yield a value of 0.944 kg/hayr, which is below the critical load range of 1 to 3 kg/ha-yr. Nitrogen deposition and critical load 

information for the Arctic Refuge was not available to make a similar calculation. Future development 

proposals on the Coastal Plain are anticipated to be similar in scope to the GMT2 project, though 

cumulative impacts would depend on the location and extent of other air emissions sources at the time of 

project proposal.

The BOEM Photochemical Modeling Report (BOEM 2016) evaluated the potential for cumulative effects 

on air quality and AQRVs from BOEM-authorized offshore oil and gas development along the North Slope 
3. Affected Environment and Environmental Consequences (Air Quality)

Coastal Plain Oil and Gas Leasing Program 3-17

Draft Environmental Impact Statement

in combination with other offshore vessel traffic, onshore oil and gas fields, airports, the Trans-Alaska 

Pipeline System (TAPS), and onshore non-oil and gas activities such as power plants, stationary fuel 

combustion sources, on- and off-road mobile sources, waste burning, wastewater treatment, fuel 

dispensing operations, and road dust (BOEM 2014, Table I-1). The study showed local and regional 

concentrations of criteria air pollutants below the NAAQS for all pollutants except PM10 and PM2.5. The 

study showed potential exceedances of the PM10 and PM2.5 NAAQS only in Utqiaġvik, approximately 260 

miles northwest of the program area boundary at the northern point of the North Slope; these 

exceedances were attributed to high projected levels of unpaved road dust and sea salt contributions and 

were reported to not have a high level of certainty because the road dust concentrations were 

extrapolated from other parts of the state (BOEM 2016, Section 7.1). Modeled visibility impacts from new 

oil and gas sources showed a change in visibility of 1 dv or greater on 160 days of the year at the Arctic 

Refuge’s Coastal Plain and on 24 days of the year at Gates of the Arctic National Park (BOEM 2016, 

Section 7.3, Table 7-4). Deposition levels were modeled above 0.01 kg/ha-yr for nitrogen and sulfur in the 

Arctic Refuge and above 0.01 kg/ha-yr for nitrogen in the Gates of the Arctic National Park (BOEM 2016, 

Section 7.3.2, Tables 7-6 to 7-8). Cumulative visibility impacts and deposition levels for all sources included 

in the BOEM analysis were above thresholds and warrant additional quantitative (project and cumulative 

level) analysis.

As described above, the cumulative analyses for the GMT2 Final SEIS and the BOEM Arctic Air Quality 

Modeling Study did not account for proposed oil and gas development in the Coastal Plain, and therefore 

the potential cumulative effects of future oil and gas activities are not fully known at this time. As described 

by ROP 6, the direct, indirect, and cumulative effects of proposed oil and gas development proposals 

would be analyzed at the time of a specific project proposal to fully assess the effect of Coastal Plain 

development on air resources.

In addition, the BLM is undertaking its own study, the Cumulative Alaska North Slope Air Quality Regional 

Model, to assess the cumulative effects of BLM-authorized oil and gas development on the North Slope, 

including on the Coastal Plain. This study would tier off the BOEM study to provide an up-to-date 

assessment of the potential cumulative effects of North Slope onshore and offshore oil and gas 

development on air quality and AQRVs in the region. The BLM anticipates that this model would provide 

the foundation for future updated analyses. Because it is expected that the growth of oil and gas activities 

on the North Slope would continue for many years, the model would be updated periodically to reflect 

actual development rates and locations, allowing the BLM, other federal land managers, and the state to 

monitor the effects oil and gas development is having on air quality and AQRVs so that appropriate 

measures can be put in place to minimize the impact on these resources as needed. The modeling study 

would not be tied to a specific NEPA effort; rather, it would be used to inform future oil and gas-related 

NEPA analyses on the North Slope.

3.2.3 Acoustic Environment

Affected Environment

This section excerpts the analysis and incorporates by reference the Acoustical Environment section from 

the GMT2 Final SEIS (BLM 2018a), specifically for its overview of acoustical principles. Because the greater 

Nuiqsut area, the focus of the GMT2 Final SEIS, has a different acoustical setting than the Coastal Plain, the 

2010 background acoustic monitoring done by the US Army Corps of Engineers (USACE) at Point 

Thomson, next to the western Coastal Plain boundary, is used as a comparable description of existing 

acoustic environment in the program area (USACE 2012, Appendix O).
3. Affected Environment and Environmental Consequences (Acoustic Environment)

3-18 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Terrestrial Acoustic Environment

The acoustic environment is the combination of all sounds in a given area. These include natural sounds, 

such as those caused by wildlife, blowing wind, and running water, as well as unwanted human-caused 

sounds. The latter are considered noise because they have the potential to affect the natural acoustical 

environment and noise-sensitive resources and values. In the context of a leasing program, noise-sensitive 

resources, along with wildlife, are people engaged in subsistence pursuits, recreation, and other activities 

(BLM 2018a).

The degree to which noise may disturb wildlife and human receptors depends on many factors, such as the 

following (Francis and Barber 2013 in BLM 2018a):

 Wildlife responses to noise are known to vary by species

 Acoustical factors, such as the frequency, intensity (loudness), and duration of noise

 Non-acoustical factors, such as life-history stage, environmental or behavioral context, and degree 

of past exposure

Noise that is abrupt and unpredictable may be perceived as a threat, potentially triggering a startle 

response or antipredator behavior (Frid and Dill 2002; Francis and Barber 2013 in BLM 2018a). Chronic 

noise may affect sensory capabilities via masking of biologically important natural sounds, such as those 

used for communication or detection of predators or prey (Francis and Barber 2013). Similarly, human 

responses to noise also are contingent both on acoustical and non-acoustical factors. Examples of the 

latter are social context and perceived ability to exert control over the noise source (Kroesen et al. 2008; 

Stallen 1999 in BLM 2018a).

The spread (propagation) of sound in outdoor settings is affected by many variables: distance from the 

source; meteorological conditions, such as temperature, wind, and humidity; and landscape features and 

surface characteristics that may interfere with sound through absorption, reflection, or diffraction 

(Attenborough 2014 in BLM 2018a). 

Among these, distance is the most significant factor. For a point source producing a constant sound, sound 

levels are expressed as dB and generally decrease by approximately 6 dB for each doubling of distance 

from the source. The same 6 dB reduction with doubling distance holds for the maximum sound level 

produced by a single moving source, such as an aircraft in flight, when the source is at its closest point of 

approach to the receptor (Attenborough 2014 in BLM 2018a). For a line of moving sources, such as 

vehicle traffic on a road, sound levels decrease by approximately 3 dB with doubling distance. 

When wind is present, sound diminishes with distance is less than expected in the downwind direction—

downwind propagation is enhanced—and greater than expected in the upwind direction. Temperature 

inversions reduce decreases and enhance propagation. In general, meteorological conditions tend to 

enhance sound levels to a lesser degree, such as 1 to 5 dB, than decrease sound levels, such as 5 to 20 dB 

(Attenborough 2014 in BLM 2018a). 

Existing noise sources in the Coastal Plain area are the following:

 On-road and off-road vehicles and snowmobiles and community noise, such as generators and 

other small equipment motors, in the village of Kaktovik

 On-road and off-road vehicles and snowmobiles used for subsistence activities and travel between 

villages and subsistence camps
3. Affected Environment and Environmental Consequences (Acoustic Environment)

Coastal Plain Oil and Gas Leasing Program 3-19

Draft Environmental Impact Statement

 Motorboats 

 Aircraft in Kaktovik 

 Tourism aircraft in the Arctic Refuge

 Aircraft and boats in the region used for recreationists and scientific researchers 

Passive Acoustic Monitoring

The USACE conducted baseline acoustical monitoring in 2010 approximately 9 miles inland from the coast 

and 3 miles west of the Canning River. In this area, noise from human activities was generally absent 

(USACE 2012). Those conducting the baseline monitoring recorded hourly median sound levels of 23 to 

28 A-weighted decibels (dBA) during winter conditions (April 27–June 8) and 24 to 26 dBA during summer 

conditions (July 12–August 12).

The program area is expected to have an acoustic environment similar to that described by the USACE 

(2012). In that study, the USACE noted that the low levels of sound recorded across all hours of the day, 

and across different seasons of the year, show loud events are rare. Natural sources, such as wildlife and 

wind, were the dominant sound of the sampling areas in the soundscape in both winter and summer. The 

USACE (2012) observed that human-caused noise, dominated by aircraft, ranged from zero to one event 

per hour (see also Section 3.4.9, Transportation).

Marine Acoustic Environment

The underwater and terrestrial acoustic environment is particularly important to marine mammals since 

they use noise to navigate, find prey, communicate, and detect disturbances or threats. While cetaceans 

typically rely on underwater acoustics, pinnipeds and polar bears perceive noises in and out of the water, 

such as when individuals are hauled out, spy-hopping, or traveling across the sea ice as is the case with 

polar bears (BOEM 2018b).

In the Beaufort Sea, natural sources of marine sound include wind stirring the surface of the ocean, storms, 

ice movements, and animal vocalizations and noises (including whale calls and echolocation clicks). The 

frequency and magnitude of noise from each of these producers can differ dramatically, as a result of 

variation in the seasonal presence of the sound sources. Existing human sources of sound in the Beaufort 

Sea include vessels (motor boats used for subsistence and local transportation, commercial shipping, 

research vessels, etc.); navigation and scientific research equipment (e.g., benthic trawls); airplanes and 

helicopters; human settlements; military activities; and offshore industrial activities. Differences in impacts 

of noise on wildlife among the alternatives are analyzed in Section 3.3.4, Terrestrial Mammals, and 

Section 3.3.5, Marine Mammals.

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

the acoustic environment from on-the-ground post-lease activities.
3. Affected Environment and Environmental Consequences (Acoustic Environment)

3-20 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Impacts from noise are characterized by their effects on wildlife and the human environment. Impacts are 

most concentrated in places that are highly populated, highly sensitive to sound, or of disproportionate 

importance to people or wildlife. The village of Kaktovik is the only permanent settlement adjacent to the 

program area, though the broader coastal plain is used for a variety of subsistence activities, most notably 

hunting. The program area provides habitat for a number of species that are particularly susceptible to 

noise disturbance, including polar bears, especially during denning; caribou, especially during calving and 

post-calving activities; and migratory birds, especially during breeding and brood-rearing activities. Noise 

impacts specific to wildlife and subsistence users are analyzed more fully in those resource sections.

Methods of estimating noise impacts described in the GMT2 Final SEIS analysis (BLM 2018a) are applicable 

to this EIS. In evaluating potential impacts of future project-related noise, it is necessary to consider noise 

levels in relation to existing ambient sound levels at the location of the receptor:

 Noise that is 10 or more dBA below the existing ambient sound level likely would be inaudible to 

the human ear.

 Noise that is approximately equal to existing ambient sound level would only be marginally or 

slightly audible, depending on the hearing capabilities of the individual receptor.

 Noise that is 10 dBA or greater above existing ambient would become the dominant element of 

the acoustical environment. 

 Noise with a level of 40 dBA would be readily audible in a setting with an existing ambient sound 

level of 35 dBA or less, but likely would be inaudible in a setting where the existing ambient sound 

level is 50 dBA or more. 

Alternative A

Under Alternative A, no federal minerals in the Coastal Plain would be offered for future oil and gas lease 

sales and no changes would occur to the ambient noise environment as a result of future oil and gas 

development on the Coastal Plain. Alternative A would have direct or indirect impacts on the acoustic 

environment related to aircraft, and would retain background noise levels, which include the effect of noise 

generated by approximately nine flights per day to and from the Kaktovik Airport.

Impacts Common to All Action Alternatives

There are no potential impacts from future oil and gas development that are common to all action 

alternatives.

Alternative B

The primary noise sources associated with future oil and gas development would be ground-based 

equipment and aircraft.

Ground-based Equipment

Sources of noise associated with fluid mineral development are construction, operation, and support 

activities for oil and gas wells. Construction activities contribute shorter-term, temporary noises 

associated with the initial development of oil and gas infrastructure. This includes the construction of new 

roads, the use of vehicles and equipment to construct wells, and the drilling of wells.

Under Alternative B, the entire program area could be offered for lease sale, and there would be the 

fewest acres with restrictions on activities. Table 2-1 in Chapter 2 identifies acres available for lease sale 

subject to NSO, TL, or only to standard terms and conditions. There would be no sources of sound from 
3. Affected Environment and Environmental Consequences (Acoustic Environment)

Coastal Plain Oil and Gas Leasing Program 3-21

Draft Environmental Impact Statement

ground-based equipment in areas with NSO (359,400 acres). The remaining acres available for lease sale 

subject to TL (585,400 acres) or only standard terms and conditions (618,700 acres) would experience 

sound from ground-based equipment; however, this would not occur during certain times for acres 

available for lease sale subject to TL. Acres available for lease sale subject to TL or only standard terms 

and conditions would involve ground-based equipment that can increase ambient sound level.

Median noise levels of drill rigs at 1,000 feet is estimated to be 52 dB, and maximum noise levels are 

estimated to be 84.4 dB. In a 35-dB ambient sound level, representative of the program area, both would 

be high-impact, dominant sounds. At a 50-dB ambient sound level, representative of developed coastal 

areas, the median noise levels would be marginally audible, but maximum sound levels would still be 

dominant. Assuming a diminishing rate of 6 dB per doubling of distance, sounds from onshore drilling 6 

miles away would be below 24 dB at their median level. This median noise level would be inaudible in a 35-

dB ambient sound level, but maximum noise levels would be audible and dominant from 6 miles away at 

that same ambient noise level. These impacts would not occur under Alternative A. 

Aircraft

Kaktovik Airport is approximately 1 mile from the village Kaktovik and is the nearest and most central 

airport to the program area. The amount of air traffic through Kaktovik and routing of aircraft through the 

region could be strongly influenced by the future construction of additional air strips within the program 

area. It is difficult to estimate the magnitude of aircraft use that would result from enabling fluid mineral 

activity on the Coastal Plain; the rate of development and potential use of ships or vehicles on new roads 

are two key uncertainties that would affect air traffic.

A highly conservative estimate of the level of air traffic related to oil and gas activities in the region is 

represented by Deadhorse Airport, which serves as the primary hub for oil and gas activities on the North 

Slope of Alaska. Airport Master Records for this airport, which provides key air connections to Fairbanks 

and Anchorage, report a 12-month average of 91 flights per day, relative to Kaktovik Airport’s average of 9 

flights per day (AMR 2018a and 2018b). A 2010 USACE noise analysis that reported aircraft noise levels on 

the order of one event per hour is consistent with these numbers; however, the 2010 analysis could be 

capturing elevated levels of air traffic on the western portions of the program area from air traffic utilizing 

other airports (USACE 2012 Section 5.20.8). 

In addition to the air traffic resulting from flights into Kaktovik, support activities using helicopters are 

likely to be enabled by leasing. Currently, the BLM/USFWS permit a very small number of helicopter 

landings in the Arctic Refuge, mostly related to scientific research and photography. 

The noise reduction estimates tabulated as part of the GMT2 Final SEIS analysis (BLM 2018a, Table 4.1-45) 

suggest that air traffic could be discernable 5 to 10 miles from the source for the loudest aircraft routinely 

operating in the region (based on a background noise level of 35 dB). At a higher ambient noise level (50 

dB), more typical of the environment and villages west of the Arctic Refuge, this distance can reduce to 1 

to 2.5 miles. The extent to which flights are routed from Fairbanks, or routed farther north between 

Deadhorse and Kaktovik, could significantly alter the location, number, and intensity of affected acres.

Because of the proximity of Kaktovik Airport to the community of Kaktovik, there is a potential for high, 

localized impacts on the acoustic environment of the community from future oil and gas exploration, 

development, and production, with impacts commensurate with use of the airport. Take-offs and landings 

at the airport are audible and dominant sounds in Kaktovik. The different action alternatives do not 

present a clear basis for differences in use of the airport, so use levels are estimated to be the same among 
3. Affected Environment and Environmental Consequences (Acoustic Environment)

3-22 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

them. These use levels could be up to ten times current use levels if air traffic levels at the Deadhorse 

Airport are indicative of future air traffic levels at Kaktovik Airport. Although measures to manage aircraft 

type could influence the noise levels experienced by the community, even quieter aircraft dominate the 

soundscape at 1 mile under 35 dB background noise conditions. At a 50-dB level, there is an appreciable 

difference in audibility of noises in the 45 to 60 dB range.

Alternative B would minimize the potential effects of low-flying aircraft on wildlife, subsistence activities, 

local communities, and recreationists of the area, including hunters and anglers through ROP 34. 

Alternative C

Ground-Based Equipment

The potential impacts from future oil and gas exploration, development, and production would be similar 

to Alternative B; however, they would occur in fewer areas. The BLM would rely on the same ROPs as 

under Alternative B but would apply more restrictive lease stipulations. Table 2-1 in Chapter 2 identifies 

acres available for lease sale subject to NSO, TL, or standard terms and conditions. There would be no 

sources of sound from ground-based equipment in areas with NSO (932,500 acres). The remaining acres 

available for lease sale subject to TL (317,100 acres) or standard terms and conditions only (313,900 acres) 

would experience sound from ground-based equipment; however, this would not occur during certain 

times for acres available for lease sale subject to TL. Acres available for lease sale subject to TL or 

standard terms and conditions would involve ground-based equipment that can increase ambient sound 

level, as described under Alternative B.

Aircraft

The potential impacts from future oil and gas exploration, development, and production would be similar 

to Alternative B; however, they would occur in a smaller area within the Coastal Plain, primarily due to an 

increase in NSO acreages from 359,400 acres to 932,500 acres.

Alternative D

Ground-Based Equipment

The potential impacts from future oil and gas exploration, development, and production would be similar 

to Alternative B; however, they would occur in a smaller area within the Coastal Plain. Table 2-1 in 

Chapter 2 identifies acres not offered for lease sale (Alternatives D1 and D2) and acres available for lease 

sale subject to NSO (Alternatives D1 and D2), CSU (Alternatives D1 and D2), TL (Alternative D2), or 

standard terms and conditions (Alternative D1). There would be no sources of sound from ground-based 

equipment in areas not offered for lease sale (526,300 acres) or areas with NSO stipulations (708,600 

acres). The remaining acres available for lease sale subject to CSU (123,900 acres), TL in Alternative D2 

(204,700 acres), or only standard terms and conditions in Alternative D1 (204,700 acres) would 

experience sound from ground-based equipment; however, this would not occur during certain times of 

the year for acres available for lease sale subject to TL. Acres available for lease sale subject to CSU, TL, or 

only standard terms and conditions would involve ground-based equipment that can increase ambient 

sound level, as described under Alternative B. 

Aircraft

The potential impacts from future oil and gas exploration, development, and production would be similar 

to Alternative B; however, they would occur in a smaller area within the Coastal Plain, primarily due to an 

increase in areas not offered for lease sale from 0 acres to 526,300 acres and an increase in NSO acreages 

from 359,400 acres to 708,600 acres. Lease Stipulation 10 would protect wilderness values (including 
3. Affected Environment and Environmental Consequences (Acoustic Environment)

Coastal Plain Oil and Gas Leasing Program 3-23

Draft Environmental Impact Statement

impacts from noise) in the Mollie Beattie Wilderness Area. To the extent practicable, aircraft operations 

would be planned to minimize flights below 2,000 feet when flying within 3 miles of the Mollie Beattie 

Wilderness Area boundary. As a result, fewer impacts from aircraft noise, as described under Alternative 

B, would be expected in that area.

Cumulative Impacts

Past activities have increased ambient sound levels on the North Slope, including those resulting from 

development in the NPR-A, development on state lands on the Prudhoe Bay Oil Field, offshore drilling 

activities, and surface, air, and marine transportation. Present and future oil and gas development on the 

North Slope could result in localized but additive impacts on the acoustic environment from drilling 

operations and air traffic levels in the region, whose reach extends at least 50 miles from any standard 

connection route. The action alternatives would involve similar types of potential noise from oil and gas 

development and transportation activities. Projected levels of air traffic have the greatest potential for 

contributing to cumulative impacts by increasing the number of flights over an area per day. The potential 

cumulative impacts on the acoustic environment would affect the community of Kaktovik and individuals 

throughout the program area, as well as noise-sensitive resources along aircraft flight paths outside of the 

program area. There would be no cumulative impacts under Alternative A.

3.2.4 Physiography

Affected Environment

Physiography describes the physical features of an area, including landforms and topography. The Coastal 

Plain of the Arctic Refuge occupies about 1,563,500 acres in the northeast corner of Alaska. It stretches 

about 100 miles from the Staines River, the westernmost distributary of the Canning River, on the west to 

the Aichilik River on the east. From the coast of the Beaufort Sea, the Coastal Plain extends south about 

40 miles at its widest point. Elevations range from sea level along the coast to about 1,000 feet at the 

southern boundary. The Coastal Plain is drained by braided channel rivers, which have their headwaters in 

highlands to the south. These sediment-laden rivers form deltas where they flow into the sea.

A physiographic province is a region of similar topography and climate that has had a unified geomorphic 

history. The Coastal Plain encompasses parts of three physiographic provinces, as defined by Wahrhaftig 

(1965). These provinces, shown on Map 3-1 in Appendix A, consist of the Arctic Coastal Plain, the 

Arctic Foothills, and the Arctic Mountains. 

Ecoregions have also been defined for the State of Alaska, including the Coastal Plain. Besides climate and 

topography, ecoregions are based on additional characteristics such as soils and vegetation data. 

Ecoregions are described in Section 3.3.1, Vegetation and Wetlands. 

Arctic Coastal Plain

Ninety percent of the Coastal Plain is in the Arctic Coastal Plain physiographic province, a smooth plain 

rising gradually from the Beaufort Sea to a maximum elevation of 600 feet above sea level (asl). The 

coastline has low relief and the shore is typically only 1 to 10 feet asl (Wahrhaftig 1965). Coastal cliffs in 

the Coastal Plain of the Arctic Refuge have a maximum height of 25 feet (Clough et al. 1987, p. 9). 

Much of the Arctic Coastal Plain is dominated by a series of large alluvial fans (USFWS 2015a, p. 4-17); 

these are deposits occurring where the carrying capacity of the stream lessens, resulting in deposition. This 

often occurs where stream gradient decreases, and the deposits spread out downslope. The alluvial fans 

create upland terrain with moderate slopes that can extend to the coast, especially south of Camden Bay 

(Jorgenson et al. 2015).
3. Affected Environment and Environmental Consequences (Physiography)

3-24 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

The Arctic Coastal Plain province is underlain by permafrost that extends to depths of over 1,000 feet 

(Wahrhaftig 1965). Although permafrost generally occurs in materials where the temperature is below 32 

°F, in areas of elevated salinity or liquid hydrocarbons, materials may not be frozen because the freezing 

point is lower. 

Permafrost is covered by a surface “active layer,” which freezes and thaws annually. The thickness of the 

active layer in the Coastal Plain is generally 1 to 4 feet (USFWS 2015a). A year-round thawed layer, 

termed a thaw bulb, may be present beneath lakes 7 feet deep or greater and beneath some parts of 

deeper rivers, such as the Canning. Based on studies of seawater and borehole temperatures, the 

permafrost layer in the nearshore area of the Beaufort Sea probably extends out to water depths of 500 

feet (Brewer 1987). 

A number of topographic features are associated with permafrost, the most prominent of which are icewedge polygons (Wahrhaftig 1965). These are vertical wedge-shaped veins of ice that develop in thermalcontraction cracks. These cracks form in a pattern of interconnected polygons that can vary in size. Most 

range from 30 to 200 feet in diameter and are visible at the surface, although some in the southern part of 

the Coastal Plain are masked by tussock-type tundra (Brewer 1987). 

Other features associated with permafrost that can be found in the Coastal Plain are as follows:

 Beaded streams—series of small ponds connected by small streams

 Frost boils—upwellings of mud that result in barren and partially vegetated areas

 Pingos—low, ice-cored mounds formed as soil-covered water freezes and expands upward

Permafrost is described in greater detail in Section 3.2.8, Soil Resources.

Arctic Foothills

Most of the southern edge of the Coastal Plain is in the northern section of the Arctic Foothills 

physiographic province, as shown on Map 3-1 in Appendix A. This province consists of rolling plateaus 

and low, east-west trending linear mountains. Elevations in the northern section of the Arctic Foothills 

province range from about 600 feet asl on the north to 1,200 feet asl on the south. Like the Arctic Coastal 

Plain province, the Arctic Foothills province is underlain by thick permafrost and has many of the same 

permafrost features described above: thaw lakes, polygonal ground, and beaded stream drainages. Other 

ice-related features in the Arctic Foothills are gelifluction lobes

3 and stone stripes, consisting of lines of 

stones that form through frost heaves (Wahrhaftig 1965; USFWS 2015a, p. 4-17).

Arctic Mountains

About 28,000 acres, or less than 2 percent, of the Coastal Plain along the southern border is in the 

Central and Eastern Brooks Range section of the Arctic Mountains physiographic province (see Map 3-1

in Appendix A). The Central and Eastern Brooks Range consists of rugged east-west trending ridges, 

reaching elevations of 7,000 to 8,000 feet asl. The mountains in the Brooks Range typically have cliff-andbench slopes formed by glacial erosion of bedded rocks (Wahrhaftig 1965). 

Beaufort Sea Coast

The Coastal Plain extends outward from the coastline to the Arctic Refuge boundary, which includes 

tidally influenced areas of the Beaufort Sea. The Beaufort Sea coast is not identified as a separate 

 

3Tongue-shaped deposits formed from slow flows of the active layer on slopes of 5 to 20 degrees
3. Affected Environment and Environmental Consequences (Physiography)

Coastal Plain Oil and Gas Leasing Program 3-25

Draft Environmental Impact Statement

physiographic province, but it is an integral part of the Coastal Plain, with distinct physical features. The 

Beaufort Sea coastline is irregular, with narrow beaches and small tides. It is characterized by numerous 

deltas, peninsulas, offshore shoals, mudflats, spits, bars, low-lying barrier islands, and shallow lagoons. The 

most pronounced deltas are associated with the Canning, Hulahula-Okpilak, Jago, and Aichilik Rivers 

(Clough et al. 1987). Rivers of the Coastal Plain are discussed in Section 3.2.10, Water Resources.

Coastal bluffs are typically 4 to 5 feet high but, as noted above, can be as high as 25 feet. The highest 

elevation along the coast is at 3-mile-wide Barter Island, which is more than 50 feet. Lagoons and bays are 

generally only 3 to 12 feet deep, except for Camden Bay where depths are greater than 15 feet (Clough et 

al. 1987, p. 9). Camden Bay extends across more than half of the Coastal Plain coastline and is the largest 

single feature. The Beaufort Sea coastline is gradually receding. Coastal erosion, one factor that can 

contribute to a receding coastline, is discussed under geologic hazards in Section 3.2.5, Geology and 

Minerals.

Climate Change

Changes to the coast and overall topography in the Coastal Plain could occur as a result of climate 

warming. The general warming of the Arctic appears to have lengthened the open-water period in the 

Beaufort Sea (USACE 2012, Ch. 5). A longer open-water period allows for longer exposure of beaches to 

coastal processes and increases the fetch4 for generating larger sea waves. These factors combine to 

produce more rapid coastal erosion and shoreline retreat, especially at locations not protected by barrier 

islands. 

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

physiography from on-the-ground post-lease activities.

The effects of climate change described under Affected Environment above, could influence the rate or 

degree of the potential direct and indirect impacts.

Alternative A

Under Alternative A, current management actions would be maintained as described in the Arctic Refuge 

Revised CCP (USFWS 2015a). No potential impacts on physiographic features from future oil and gas 

exploration, development, and production would occur.

Impacts Common to All Action Alternatives

Future construction of infrastructure would affect topography in the program area and could reshape 

geomorphological features, such as water bodies and permafrost features.

 

4The area of water over which the wind blows in an essentially constant direction, thus generating waves.
3. Affected Environment and Environmental Consequences (Physiography)

3-26 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

All the action alternatives would require placement of gravel fill, which would have the potential direct 

impact of altering the topography within the development footprint. Gravel infrastructure would include 

pads, roads, and an airstrip, as described in Chapter 2. This potential long-term impact would begin 

during the construction phase and would last throughout the development phase until the gravel is 

removed and the site has been restored to pre-program conditions. Impacts would last longer if not all 

gravel infrastructure (e.g., access roads) is removed.

In addition to the potential direct effects on topography that would result from placement of gravel fill, the 

presence of gravel infrastructure would alter existing geomorphic features. For example, the sea barge 

landing and staging structures would affect the pattern of sediment erosion and deposition, which could 

result in local, long-term changes to the coastline configuration. Likewise, if the gravel pad for the STP is 

placed in water rather than on land, similar effects on physiography would occur. This impact would last 

throughout the development phase and for some period after the structure is removed during 

reclamation. Other gravel infrastructure could affect permafrost features or result in changes to stream or 

lake morphology. Potential direct and indirect impacts on permafrost features are further described in 

Section 3.2.8. Potential direct and indirect impacts on surface water features are further described in 

Section 3.2.10.

All action alternatives assume a surface disturbance area of approximately 2,000 acres from future oil and 

gas exploration, development, and production, not including the gravel pits. Most, but not all, of the surface 

disturbance is associated with placement of gravel fill. The size of the STP would be an estimated 15 acres 

under all action alternatives. For the sea barge landing, each action alternative assumes a 10-acre gravel pad 

for staging modular units next to a landing at Camden Bay and a 5-acre pad at a landing along the eastern 

coast of the Coastal Plain. The footprint of other gravel infrastructure would vary, depending on the 

alternative (see discussion of each alternative below).

All the action alternatives would include potential future development of a gravel mine or mines, which 

would also result in potential direct long-term impacts on topography. The surface area of the gravel mines 

would total approximately 300 acres for each action alternative (not included in the 2,000-acre limit on 

surface disturbance). Impacts of gravel mining on physiography would last beyond the development phase 

because the pits remaining from gravel extraction would typically not be completely backfilled, and any 

remaining depression could fill with water and become a permanent lake. Gravel mines are described 

further in Section 3.2.9, Sand and Gravel Resources. 

Future ice infrastructure (e.g., pads and roads) would have negligible impacts on topography but could 

affect permafrost and surface water geomorphic features, as discussed further in Section 3.2.8 and 

Section 3.2.10. 

Potential changes to physiography associated with geologic hazards (e.g., subsidence or slope failure) are 

addressed in Section 3.2.5.

Alternative B

Approximate acreages associated with future gravel infrastructure specific to Alternative B are as follows:

 204 acres for 17 satellite drill pads

 200 acres for four CPFs

 1,560 acres for 208 miles of gravel roads
3. Affected Environment and Environmental Consequences (Physiography)

Coastal Plain Oil and Gas Leasing Program 3-27

Draft Environmental Impact Statement

Alternative C

Approximate acreages associated with future gravel infrastructure specific to Alternative C are as follows:

 216 acres for 18 satellite drill pads

 150 acres for three CPFs

 1,598 acres for 213 miles of gravel roads

Alternative D

Approximate acreages associated with future gravel infrastructure specific to Alternative D are as follows:

 242 acres for 21 satellite drill pads

 100 acres for two CPFs

 1,635 acres for 218 miles of gravel roads

Cumulative Impacts

Potential impacts on topography and geomorphic features resulting from future gravel infrastructure are 

generally localized to the footprint or adjacent area; therefore, the geographic area relevant for assessing 

cumulative impacts on physiography is the program area. While other past, present, and reasonably 

foreseeable future actions on the North Slope (Appendix F) have had or would have impacts on 

physiography, none of these actions have been or are proposed to be in the program area and so would 

not contribute to cumulative impacts on physiographic features in the Coastal Plain. The effects of climate 

change described under Affected Environment above, could influence the rate or degree of the potential 

cumulative impacts. Alternative A would have no cumulative impacts on physiography.

3.2.5 Geology and Minerals

Affected Environment

Geology 

The Coastal Plain is in the eastern part of the North Slope geologic province and has greater geologic 

complexity than that found elsewhere in northern Alaska. The North Slope geologic province is part of a 

tectonic feature referred to as the Arctic Alaska microplate. The geologic history for this continental 

microplate includes three primary tectonic settings: a south-facing passive continental margin during the 

Devonian to Triassic, a northern rifted margin in the Jurassic to Early Cretaceous, and a southern 

orogenic5 margin, with a related foreland basin and fold-and-thrust belt from the Jurassic to recent time 

(Bird 1999). 

A thin layer of surficial deposits covers the bedrock geology in most of the Coastal Plain; therefore, 

information and understanding of the bedrock geology has been obtained primarily from geophysical 

remote sensing, observations in the mountains south of the area, and wells drilled west and north of the 

area (Bird 1999).

Four tectono-stratigraphic sequences characterize the Northern Alaska geologic province (see Figure 

3-3, Stratigraphy of the Coastal Plain, in Appendix A) (USGS 1998a). The oldest sequence is the 

Franklinian, which consists of a thick succession of metamorphosed sedimentary, volcanic, and igneous 

rocks of Proterozoic to Early Devonian age. The overlying Ellesmerian sequence of Middle Devonian to 

Triassic age rocks represents the south-facing passive margin referred to above. The Beaufortian sequence 

 

5Mountain building
3. Affected Environment and Environmental Consequences (Geology and Minerals)

3-28 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

records the Jurassic and Cretaceous rifting, which severed the continental connection of northern Alaska 

and opened the Canada basin. The Brookian sequence, Cretaceous to recent age, consists of sediments 

originating from the ancestral and modern Brooks Range and deposited in foreland basin and passive 

margin settings (Bird 1999). Information regarding the oil and gas potential for these sequences is provided 

in Section 3.2.6, Petroleum Resources.

Geologic structures in the Coastal Plain consist of closely spaced folds and faults in rocks that were 

deposited in the foreland basin setting and broad, domed faulted structures in the pre-foreland basin and 

basement rocks. These structures formed in one or more episodes of Brooks Range-related deformation 

during Cenozoic time. Devonian and possibly older structures are also present in the Coastal Plain, and 

these structures have controlled the orientation of some younger Cenozoic structures (Bird 1999). 

A major structural feature of the Coastal Plain is the east-northeast trending Marsh Creek anticline, which 

formed during the Oligocene (Bird 1999). Rather than being a simple anticline, the Marsh Creek anticline is 

interpreted to be either a triangle zone or an anticlinorium6 (Bird and Magoon 1987). The Marsh Creek 

anticline divides the Coastal Plain into two areas having different structural characteristics. Rocks 

northwest of the Marsh Creek anticline are in the “undeformed area” and have remained nearly 

undeformed since their deposition. Rocks to the southeast of the Marsh Creek anticline, the “deformed 

area,” have been thrust faulted, folded, and uplifted (Magoon et al. 1987). The deformed area is about 

twice the size of the undeformed area.

Figure 3-4, Generalized Surficial Deposits of the Coastal Plain Area, in Appendix A is a surficial geologic 

map of the Coastal Plain. The plain is largely covered by a thin mantle of Quaternary unconsolidated 

sediments that range in thickness from a few feet to about 100 feet (Clough et al. 1987). These include 

river deposits (alluvium), beach deposits, colluvium, alluvial fans, terrace deposits, marine terrace deposits, 

glacial deposits, glaciofluvial deposits, and landslides (Marshall et al. 1998). 

Only about 10 percent of the Coastal Plain was glaciated during the Pleistocene. In the southwest corner, a 

large valley glacier extended northeastward approximately 12 miles into the area for approximately 7 miles 

along the Tamayariak River. Smaller valley glaciers extended about 4 miles into the area along the Hulahula 

River, just across the Coastal Plain boundary along the Jago River, and 2 miles along the Aichilik River. 

Glaciofluvial deposits and eolian7 materials are widespread, even in unglaciated areas (Clough et al. 1987).

As shown in Figure 3-4 in Appendix A, two types of surficial deposits predominate in the Coastal Plain: 

gravel and sand and silt and very fine sand over gravel. Gravel and sand include deposits associated with 

river floodplains and terraces and upland terraces that lack a silt cover. Silt and very fine sand over gravel 

comprise a fine-grained cover, generally more than 6.6 to 10 feet thick and ice rich, and commonly 

containing fine-grained organic debris. Morainal deposits composed of compact, silty, bouldery till are 

present in the previously glaciated areas along the southern border of the Coastal Plain. Near the coast, 

surficial unconsolidated deposits typically consist of alluvial sediments (silt, sand, and gravel) overlying finergrained marine sediments. 

The cover of unconsolidated sediments is broken up by outcrops of Tertiary-Cretaceous sedimentary 

rocks. The largest of these outcrop areas occurs along the Marsh Creek anticline and upper Jago River. 

Outcrops in the Marsh Creek anticline area include the Sagavanirktok and Canning Formations (Marshall et 

 

6An intensely deformed series of anticlines and synclines that together form a general arch

7Windblown
3. Affected Environment and Environmental Consequences (Geology and Minerals)

Coastal Plain Oil and Gas Leasing Program 3-29

Draft Environmental Impact Statement

al. 1998). The Sagavanirktok Formation, which overlies the Canning Formation, consists of poorly 

consolidated gray siltstone, mudstone, sandstone, and lesser amounts of conglomerate that were 

deposited in non-marine and shallow marine environments. This rock unit is as much as 4,900 feet thick on 

the north flank of the Marsh Creek anticline and 7,500 feet thick in wells near the mouth of Canning River. 

The Canning Formation consists of gray shale and siltstone containing interbeds of mostly thin-bedded, 

very fine to fine-grained lithic sandstone; they represent turbidites deposited in a deep-water marine 

environment by a sediment gravity flow. The Canning Formation was measured at 4,900 to 5,000 feet thick 

in wells west of Canning River (Molenaar et al. 1987). 

The Jago River Formation crops out in the upper Jago River area (Marshall et al. 1998). This formation 

consists of well hardened, thick-bedded, fine- to coarse-grained, lithic sandstone and conglomerate. There 

are also minor amounts of coal and carbonaceous shale deposited in a primarily nonmarine environment 

with minor shallow marine influence. The Jago River Formation is 9,800 feet thick in its type section along 

Igilatvik (Sabbath) Creek (Buckingham 1987). 

Smaller bedrock outcrops occur around the Sadlerochit Mountains and in the east-central part of the 

Coastal Plain. In addition to the Canning Formation, these outcrops expose the Cretaceous Hue Shale, 

Pebble Shale unit, and Kemik Sandstone; Cretaceous-Jurassic Kingak Shale; Triassic Karen Creek 

Sandstone; Permian and Triassic Sadlerochit Group; and Pennsylvanian-Mississippian Lisburne Group 

(Marshall et al. 1998).

For more detailed information regarding the rock units and geologic structure of the Coastal Plain, refer to 

Bird and Magoon (1987) and Bird (1999).

Geologic Hazards

Geologic hazards are natural physical conditions that could damage land or structures and injure humans. 

Potential geologic hazards in the Coastal Plain are earthquakes, surface faults, landslides, land subsidence, 

flooding, sea ice ride-up and override, coastal erosion, and storm surge.

Earthquakes and Surface Faults

The USGS has prepared seismic hazard maps for Alaska that portray the probability of ground motion 

(peak ground acceleration) due to an earthquake (Wesson et al. 2007). For the Coastal Plain, the USGS 

estimates that peak ground accelerations of up to 0.2 g (where g equals the acceleration due to gravity); 

there is a 5 percent probability that this acceleration would be exceeded in 50 years; thus, the Coastal 

Plain is in an area of relatively low seismic risk. This risk may be revised in the future, based on August 

2018 seismic activity, described below. 

Historically the level of earthquake activity in the Coastal Plain has been low. Earthquakes of magnitude 

(M) 6 and larger on the Richter scale of intensity are potentially destructive; earthquakes of M 5 could 

cause local damage (Clough et al 1987). Prior to August 2018, epicenters of five earthquakes with M 4.5 to 

M 5.0 had been recorded in or within 15 miles of the Coastal Plain (USGS 2018a). Of these, three were 

centered in the Coastal Plain: A M 4.7 earthquake in February 2006 and M 4.5 and M 4.9 earthquakes in 

April 2007. Three earthquakes above M 5.0 had been recorded in the northeast corner of Alaska, the 

closest of which was an M 5.2 earthquake centered about 30 miles southwest of the Coastal Plain in

August 1995. The largest of the three was an M 5.5 earthquake in August 2003 about 80 miles from the 

southwest corner of the Coastal Plain (USGS 2018a). 
3. Affected Environment and Environmental Consequences (Geology and Minerals)

3-30 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

On August 12, 2018, an M 6.4 earthquake occurred 52 miles southwest of Kaktovik (and less than 10 miles 

south of the Coastal Plain) in the Sadlerochit Mountains. It was felt widely across the eastern NSB, and 

was, by a wide margin, the largest earthquake ever recorded north of the Brooks Range in Alaska (Alaska 

Earthquake Center 2018). This earthquake was followed by a number of aftershocks on the same day, 

including an M 6.0 earthquake about 20 miles east of the M 6.4 event. From August 13 to September 2, 

2018, 13 earthquakes between M 4.0 and M 4.8 were recorded in the same area. The Alaska Earthquake 

Center indicated that this seismic activity is consistent with natural earthquake activity. Aftershocks are 

expected to slowly decline but remain active for many weeks or months.

The USGS’s Quaternary fault and fold database (USGS and ADNR 2006) contains information on faults 

and associated folds in the US that are believed to be sources of earthquakes greater than M 6 during the 

Quaternary (i.e., the past 1.6 million years). This database indicates the presence of one Quaternary 

surface feature in the Coastal Plain, which is the Marsh Creek anticline (described above and depicted on 

Map B-1, Hydrocarbon Potential, in Appendix B). A group of several faults, known as the Camden faults 

or Camden fault zone, is offshore. The closest of these faults is about 10 miles from the coast. The most 

recent deformation on the Camden faults is less than 15,000 years old. 

Slope Failure

Slope failure in the Coastal Plain can occur in the form of solifluction8 and creep or slump along coastal 

bluffs, terrace escarpments, lake margins, and ridge slopes. Locally along a stretch of the Katakturuk River 

and near Marsh and Carter Creeks, landslides have occurred in weathered and soft Tertiary shale, 

siltstone, and sandstone. In all areas having any appreciable slope and exposed mineral soil, the soil 

migrates gradually downslope because of seasonal frost heaving of individual soil grains (Clough et al. 

1987). 

Retrogressive thaw slumps are slope failures resulting from thawing, ice-rich permafrost. They develop 

along streams or coastlines and expand inland to form landslide-like U-shaped scars (Lantuit et al. 2013).

Subsidence

The volume of ice in permafrost soils, particularly in the first few tens of feet below the ground surface, 

can be several times the volume of the mineral components (Brewer 1987). Natural and human-induced 

thawing of this near-surface ice generally results in uneven lowering of the ground surface, which may lead 

to water ponding or preferential erosion or both (Rawlinson 1993). Because of the presence of ice-rich 

permafrost, about one-third of the Coastal Plain has the potential for thaw settlement of 16 to 98 feet 

(Jorgenson et al. 2015).

Flooding and River Ice Jams 

Most streams in the Coastal Plain have swift, braided courses across broad gravel flats that typically freeze 

to the bottom in the winter. In addition, groundwater from seeps and springs that flow throughout the 

winter freezes and forms thick, layered sheets of ice, called aufeis.9 During spring when meltwater begins 

to flow, the presence of ice in the stream channels causes the streams to flood. As meltwater runs over 

the top of river ice, the ice breaks into pieces. As the ice flows downstream, it may lodge in constricted 

parts of the channel, creating jams and forcing more water out of the stream channel (USACE 2012, p. 3-

61). Streams draining the Brooks Range also have the potential to produce significant summer 

 

8Very slow deformation of the seasonally thawed surface, forming elongated shallow lobes

9A mass of layered ice that forms from successive flows of groundwater during freezing temperatures
3. Affected Environment and Environmental Consequences (Geology and Minerals)

Coastal Plain Oil and Gas Leasing Program 3-31

Draft Environmental Impact Statement

precipitation-driven flood discharges (USACE 2012, p. 3-47). Flooding is discussed further in Section

3.2.10.

Sea Ice Ride-up and Override

On shorelines exposed to the open ocean, onshore winds can push sea ice 100 feet or more onshore and 

10 to 20 feet high, in a process called sea ice ride-up and override (USACE 2012, p. 3-42). Any natural or 

human-made features exposed to this sea ice push are susceptible to damage, including shoreline and 

seabed scouring. Lagoon areas are not generally subject to this phenomenon. 

Coastal Erosion and Storm Surge

Beach erosion varies greatly from place to place and year to year along the entire Beaufort coast, 

depending on storm intensities and the nearness of pack ice. Erosion and deposition of eroded sands and 

gravel also produce barrier island or spit migration, especially where established vegetation is absent 

(Brewer 1987). Gibbs and Richmond (2017) have calculated average and maximum shoreline change rates 

for two regions of the Coastal Plain. Region 1 is the shoreline from the US-Canada border to the Hulahula 

River, and Region 2 is the shoreline from the Hulahula River to the Staines River. For both Regions 1 and 

2, the average rate of shoreline change is -3.0 feet per year over the short term and long term. The 

negative value indicates that, overall, erosion is greater than accretion. The maximum long-term and shortterm rates of erosion observed in Region 1 are -48.6 and -64.3 feet per year; the maximum long-term and 

short-term rates of erosion in Region 2 are both -22.3 feet per year. In this study, erosion indicates 

landward movement or retreat of the shoreline and does not distinguish between physical erosion and 

flooding of the coast, due to land subsidence or sea level rise.

Erosion along the coast can also be caused by wind. Wind erosion is generally confined to exposed spits 

and barrier islands and the Canning, Hulahula, Okpilak, and Jago River deltas, where active dunes are found 

along their western banks (Clough et al. 1987). Abnormally high rises in sea level, referred to as storm 

surges, are caused by strong westerly winds and can be 4 to 6 feet above the elevation of sea level, or even 

greater with winds at 50 to 60 knots (USACE 2012, p. 3-31). Storm surges can cause coastal flooding, 

particularly along low-profile beaches common in the Coastal Plain.

Additional details regarding shoreline erosion and storm surge along the Beaufort Sea coast can be found 

in Barnes et al. (1992), USACE (2012, Chapter 3), and Gibbs and Richmond (2017).

Minerals

In the 1970s, before ANILCA, the USGS and former US Bureau of Mines conducted limited 

reconnaissance geological and mineral investigations in northeast Alaska. Limited mineral industry work 

was also conducted in the 1970s (USFWS 2015a, p. 4-37). Under ANILCA, the Arctic Refuge was closed 

to all forms of appropriation under the public land laws, including the mineral leasing and mining laws 

(USFWS 2015a, p. 4-1).

The BLM classifies mineral resources it manages as salable, leasable, or locatable. Salable minerals are 

subject to the Materials Act of 1947, as amended, and include common construction materials, such as 

sand, gravel, decorative rock, and building stone. Salable minerals relevant to the Coastal Plain (sand and 

gravel) are addressed in Section 3.2.9. 

Leasable minerals generally include energy minerals, such as petroleum, geothermal, and coal resources, as 

well as potash, sodium, and phosphate; petroleum resources are addressed in Section 3.2.6. Geothermal 
3. Affected Environment and Environmental Consequences (Geology and Minerals)

3-32 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

resources in Alaska are associated with the Aleutian volcanic arc or thermal springs in the interior or 

southeastern Alaska and have not been identified around the Coastal Plain (Miller 1994). 

Coal occurs in isolated areas throughout Alaska, referred to as provinces. The North Slope coal province 

has the largest coal deposits in Alaska, and the eastern edge of the province extends into the Coastal Plain 

(Flores et al. 2004; Stricker et al. 2011). The most important Cretaceous coal-bearing rocks in the 

province are in the Colville and Nanushuk groups west of Prudhoe Bay (Flores et al. 2004). Coal deposits 

in the eastern North Slope coal province primarily occur in the Tertiary Sagavanirktok Formation in two 

separate zones and are characterized as sub-bituminous (Stricker et al. 2011). 

Locatable minerals are subject to the General Mining Law of 1872 and include metallic minerals, such as 

gold, silver, copper, lead, zinc, and uranium; nonmetallic minerals, such as alunite, asbestos, barite, gypsum, 

and mica; and certain varieties of stone. These are also referred to as hardrock minerals. The following 

discussion addresses locatable minerals and phosphate (a leasable mineral).

The USGS maintains a database with descriptions of mines, prospects, and mineral occurrences in Alaska. 

The records in the database are generally for metallic mineral commodities only but also may include 

certain high value industrial minerals, such as barite and rare earth elements. No mineral occurrences are 

documented in the Coastal Plain; however, seven mineral occurrences are documented within 15 miles 

(see Table 3-7; Map 3-2, Mineral Occurrences, in Appendix A). These minerals are copper, rare earth 

elements, phosphorus, uranium, and phosphates.

Hartman (1973) assessed mineral potential in the Arctic Refuge and identified granitic intrusions with 

metallic mineral deposits in the Romanof Mountains and along the southern edge of the Brooks Range. 

Closer to the Coastal Plain, Hartman identified abundant low-grade phosphate deposits in the Shublik 

Formation that crops out along the northern edge of the Brooks Range. 

A 1978 report of the mineral resource potential for the Brooks Range included all but the northwest 

corner of the Coastal Plain (Grybeck and DeYoung 1978). This assessment indicates that most of the 

Coastal Plain has uranium potential. Just to the south are areas with copper and phosphate potential. The 

phosphate areas are described as deposits of marine phosphate beds with minor uranium, vanadium, and 

fluorite content. No information is provided regarding the areas of copper potential.

The Geochemical Atlas of Alaska (Lee et al. 2016) provides maps of the distribution of 68 elements for the 

state, including the Coastal Plain. The maps are based on compilation and modeling of sediment and soil 

samples. These maps indicate, in part, that portions of the Coastal Plain have relatively higher 

concentrations of gold, uranium, phosphorus, and copper. The maps can be viewed online at 

https://pubs.er.usgs.gov/publication/ds908.

Climate Change

Climate change produces changes in several geologic hazards, including subsidence, flooding, and coastal 

erosion. An increase in the active layer expected from a warming climate could result in greater areas of 

land subsidence. Climate change is also expected to affect the frequency and severity of extreme storms 

and floods. Storms with surges would be stronger and more frequent, which, combined with rising sea 

levels, could lead to greater coastal erosion (BLM 2012). The spring warming period would begin earlier,

causing snowmelt to occur during a period of lower solar radiation, which could lead to a more protracted 
3. Affected Environment and Environmental Consequences (Geology and Minerals)

Coastal Plain Oil and Gas Leasing Program 3-33

Draft Environmental Impact Statement

Table 3-7

Documented Mineral Occurrences within 15 Miles of the Coastal Plain

Site Latitude Longitude Location 

Description Commodities Ore Minerals

Geologic 

Description

Unnamed 69.47 -142.82 Accurate to within 

5,000 feet

Copper Chalcopyrite Mafic volcanic rocks

Aichilik 

River

69.53 -143.15 Deposit along the 

Aichilik River; 

accurate to within 

5,000 feet

Rare earth 

elements

Ytterbium, 

yttrium

Efflorescent salts 

coat outcrops of 

Kingak shale and 

accumulate along the 

margins of 

ephemeral pools at 

the foot of cut banks.

Itkilyariak 

Creek

69.63 -144.75 Accurate to within 

4,000 feet

Copper Native 

copper

Greenstone, 

probably Proterozoic

Katakturuk 

River

69.59 -145.6 1,890-foot hill at the 

confluence of two 

forks of the 

Katakturuk River, in 

the headwaters of 

the Katakturuk River, 

near the south flank 

of the Sadlerochit 

Mountains; accurate 

to within 1,500 feet

Phosphorus, 

uranium

Phosphate, 

uranium

Shublik Formation

Fire Creek 69.53 -145.2 Within 1 mile Phosphate - Shublik Formation

Hulahula 

River

69.48 -144.38 Not provided Phosphate - Shublik Formation

Unnamed 69.63 -144.42 Accurate to within 1 

mile

Phosphate - Shublik Formation

Source: USGS 2018b

Note:

- = not applicable

melt and less intense runoff. Overall, the magnitude and frequency of high flows would decline while low 

flows would increase. These effects are described in more detail in the GMT2 Final SEIS (BLM 2018a, 

Section 3.2.4).

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

geology and minerals from on-the-ground post-lease activities.

The effects of climate change described under Affected Environment above, could influence the rate or 

degree of the potential direct and indirect impacts.
3. Affected Environment and Environmental Consequences (Geology and Minerals)

3-34 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Alternative A

Under Alternative A, current management actions would be maintained as described in the Arctic Refuge 

CCP (USFWS 2015a). Consistent with ANILCA, the Coastal Plain would remain closed to all forms of 

appropriation under the public land laws, including the mineral leasing and mining laws. No potential 

impacts on geology or mineral resources from future oil and gas exploration, development, and production 

would occur.

Impacts Common to All Action Alternatives

As described above, bedrock is minimally exposed across much of the Coastal Plain; therefore, existing 

bedrock outcrops are highly valuable in developing the best possible surface and subsurface geologic 

understanding of the area. There are a number of relatively small, low-relief, but critically important 

bedrock outcrops exposed along the Niguanak and Jago Rivers and their tributaries in the northeastern 

part of the program area (specifically in the area ranging from Townships 6-8 North and Ranges 35-37 

East). These exposures are reported to include strata of the Kingak shale, pebble shale unit, Hue shale, and 

Canning Formation (Marshall et al. 1998). This strata’s structural, stratigraphic, and source rock 

implications remain enigmatic and warrant further geologic study.

Important bedrock exposures also occur along the Marsh Creek anticline in the western part of the 

program area. If gravel infrastructure is placed in these outcrop areas in the future, the bedrock would no 

longer be accessible for research. Potential impacts would be long term and would last until the gravel is 

removed.

Land within 1 mile of the Jago River and 0.5 mile of the Tamayariak River, Katakturuk River, and Marsh 

Creek would be subject to the NSO limitations (i.e., only essential pipeline and road crossings permitted) 

under all action alternatives. This would provide some protection for the outcrops in these areas. No 

other potential direct or indirect impacts on geology have been identified.

Oil and gas exploration, development, and production could also affect the risk of several geologic hazards 

identified in the Affected Environment section, including seismicity, slope failure, subsidence, flooding, and 

river ice jams.

Future development of petroleum resources would include injection of seawater or gas into the 

production field to maintain reservoir pressure. Also, wastewater, produced water, spent fluids, and 

chemicals would be disposed of in injection wells. Injection of large volumes of fluids into low permeability 

and brittle rocks has potential to trigger low level seismicity (earthquakes). This phenomenon is generally 

associated with the high volumes of waste injection associated with the high density of wells needed to 

fully develop tight unconventional resource plays, such as shale source rocks, rather than conventional 

hydrocarbon production. The potential for induced seismicity associated with the action alternatives would 

be low. 

Slope failure could be triggered or exacerbated by placement of gravel fill in the future. Most of the 

program area is relatively flat and gravel infrastructure would not likely be placed on slopes with potential 

for ground movement. At water body crossings, roads would be constructed using methods that would 

minimize potential slope failure along stream banks; therefore, the potential for leasing and development to 

influence slope failure risk would be low. Likewise, slope failure is unlikely to affect infrastructure 

associated with oil and gas exploration, development, and production.
3. Affected Environment and Environmental Consequences (Geology and Minerals)

Coastal Plain Oil and Gas Leasing Program 3-35

Draft Environmental Impact Statement

Subsidence associated with thawing permafrost could adversely affect oil and gas infrastructure. To 

minimize the potential for subsidence associated with thawing of near surface ice, gravel pads and roads 

would be constructed with a thickness sufficient to maintain a stable thermal regime (see Chapter 2). 

Future pipelines would be constructed primarily aboveground and would not contribute to permafrost 

thaw. All future buildings would be supported aboveground on pilings to accommodate ground settling or 

frost heaving.

Warm production and injection wells can cause thawed areas around the well. In 2017, an oil well in the 

NPR-A suffered a cracked casing due to subsidence from thawing, which resulted in an oil spill. The well’s 

construction geometry contributed to the failure (AOGCC 2017). This type of failure can be minimized by 

modern well construction methods, including installing thermosyphons around wells to remove heat 

transfer from wellbore fluids.

Under all action alternatives, the risk of flooding and river ice jams would be mitigated by a ROP which 

states, “the design engineer should ensure that crossing structures are designed for aufeis, permafrost, 

sheet flow, additional freeboard during breakup, and other unique conditions of the arctic environment.” 

Alternative B

Potential impacts on geology and mineral resources from future oil and gas exploration, development, and 

production under Alternative B would be the same as identified above for all action alternatives.

Alternative C

Potential impacts on geology and mineral resources from future oil and gas exploration, development, and 

production under Alternative C would be the same as identified above for all action alternatives. 

Alternative D

In addition to the potential impacts described above for all action alternatives, NSO identified under 

Alternative D would be allowed within 0.5 mile of the Niguanak River. While this restriction could help 

mitigate the potential for outcrops in these areas to be covered by gravel fill, some of the key outcrops 

(those in the northern part of Township 6 North, Range 36 East) are along intermittent tributaries up to 5 

miles west of the Niguanak River.

Cumulative Impacts

The geographic area relevant for assessing cumulative impacts for geology and minerals is the program 

area. No other past, present, and reasonably foreseeable future actions that could affect geology or 

mineral resources have occurred or are expected to occur in the program area. The effects of climate 

change described under Affected Environment above, could influence the rate or degree of the potential 

cumulative impacts. Alternative A would have no contribution to cumulative impacts on geology and 

mineral resources.

3.2.6 Petroleum Resources

Affected Environment

Regulatory Information

Section 20001 of PL 115-97 directs the BLM to undertake an oil and gas leasing program on the Coastal 

Plain (also known as the 1002 Area) of the Arctic Refuge. Under the ANILCA, the Coastal Plain was not 

designated wilderness, and Congress reserved the area for potential future oil and gas development. The 

USFWS Revised CCP (2015a) recommended the area for wilderness designation and the area has been 

managed for wilderness characteristics. PL 115-97 opened the entire Coastal Plain to leasing, except for
3. Affected Environment and Environmental Consequences (Petroleum Resources)

3-36 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Alaska Native selected lands within the program area boundary; however, it limited surface disturbance 

from oil and gas production and support facilities to a maximum of 2,000 acres.

Oil and Gas Resources

The Coastal Plain encompasses approximately 1,563,500 acres. Currently no acreage is open to petroleum 

leasing. It is estimated that approximately 427,900 acres of the program area is high potential for 

petroleum resources, 658,400 acres are moderate potential, and 477,200 acres are low potential. 

Estimates are based on best available information, but due to the limited amount of exploration that has 

occurred in the area, petroleum development potential and acreages should be considered rough 

estimates. The one exploration well drilled in the Coastal Plain is held as confidential information, so exact 

formation compositions and oil and gas percentages are not well established across the entire region. 

Existing oil and gas wells are shown in Map 3-3, Oil and Gas Infrastructure, in Appendix A. See the 

hypothetical development scenario (Appendix B) for more information on development potential, 

assumptions behind potential estimates, and estimates for the baseline future development scenario for 

petroleum. 

Approximately 80 percent of petroleum resources are estimated to be in the undeformed western 

portion of the program area (USGS 1998b). As shown in Table 3-8, the identified potential plays in the 

undeformed area are the Topset play, Thompson play, Turbidite play, Wedge, Kemik, and Undeformed 

Franklinian. Potential plays in the deformed area are the Thin-Skinned Thrust Belt, Ellesmerian Thrust Belt, 

Deformed Franklinian, and Niguanak/Aurora (Attanasi 2005). 

Table 3-8

Estimated Mean Undiscovered Petroleum Resources in the Coastal Plain

Play Name Oil (BBO) Gas (TCF)

Natural Gas Liquids 

(Billion Barrels of 

Liquid)

Undeformed Topset 4.325 1.193 0.010

Turbidite 1.279 1.120 0.065

Wedge 0.438 0.226 0.005

Thompson 0.246 0.470 0.039

Kemik 0.047 0.116 0.010

Undeformed Franklinian 0.085 0.30 0.029

Undeformed subtotal 6.420 3.424 0.159

Deformed Thin-Skinned Thrust Belt 1.038 1.608 0.017

Ellesmerian Thrust Belt 0.000 0.876 0.018

Deformed Franklinian 0.046 0.86 0.046

Niguanak/Aurora 0.183 0.273 0.016

Deformed subtotal 1.267 3.617 0.096

Total 7.687 7.041 0.225

Source: Attanasi 2005

Note: Totals are technically recoverable amounts; oil associated gas and natural gas liquid estimates were combined with nonoil associated gas and natural gas liquid estimates.

All oil and gas volumes represent the mean estimated technically recoverable volumes unless otherwise 

noted. The Topset is expected to be the primary play in the Coastal Plain, with an estimated technically 

recoverable 4.325 BBO and 1.193 TCF of gas. The Turbidite play is the second most productive, with an 

estimated technically recoverable 1.279 BBO and 1.120 TCF of gas. In the deformed area, the ThinSkinned Thrust Belt is the primary play, with an estimated technically recoverable 1.038 BBO and 1.608 
3. Affected Environment and Environmental Consequences (Petroleum Resources)

Coastal Plain Oil and Gas Leasing Program 3-37

Draft Environmental Impact Statement

TCF of gas (Attanasi 2005). In total, the undeformed area is estimated to contain a technically recoverable 

total of 6.420 BBO and 3.424 TCF of gas, and the deformed area is estimated to contain a technically 

recoverable total of 1.267 BBO and 3.617 TCF of gas. Natural gas liquids would also be produced as part 

of the oil and gas production process.

Trends

Due to the prior prohibition on leasing, there has been no development of oil and gas resources in the 

Coastal Plain to date. There has been interest in Alaska and from some Native corporations in developing 

the Coastal Plain ever since the 1002 Area was designated as a potential area for development in 1980 

(Doyon Limited 2018; Rexford 2017). The area has had limited exploration; as further exploration occurs, 

a greater understanding of the size and characteristics of petroleum resources would be gained.

Ninety percent of technically recoverable resources were estimated to be economically recoverable at 

$55/barrel (2005 dollars, approximately $70/barrel in 2018 dollars; Attanasi 2005). The threshold price to 

initiate exploration was estimated to be from $20 to $21/barrel (2005 dollars). (The economics may have 

changed significantly since that study was published.) As of August 2018, the price of West Coast crude 

was approximately $75/barrel and the price of West Texas Intermediate crude was approximately 

$65/barrel. The US Energy Information Agency forecasts the price of crude oil to steadily rise to over 

$85/barrel over the next 10 years (US Energy Information Agency 2018).

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

petroleum resources from on-the-ground post-lease activities.

Alternative A

Under Alternative A (No Action Alternative), no federal minerals in the Coastal Plain would be offered for 

future oil and gas lease sales. Alternative A would not establish and administer a competitive oil and gas 

program for the leasing, development, production, and transportation of oil and gas in and from the 

Coastal Plain in the Arctic Refuge. Current management actions would be maintained, and resource trends 

would continue, as described in the Arctic Refuge CCP (USFWS 2015a). No future extraction or use of 

petroleum resources would occur and as a result no potential direct or indirect impacts on petroleum 

resources from future oil and gas exploration, development, and production would occur.

Impacts Common to All Action Alternatives

Potential future impacts on petroleum resources under all action alternatives can reasonably be expected 

to result in the irreversible commitment of petroleum hydrocarbon resources of the PL 115-97 through 

future oil and gas exploration, development, and production; however, the stated purpose of this EIS is to 

facilitate petroleum leasing, development, and production.
3. Affected Environment and Environmental Consequences (Petroleum Resources)

3-38 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Potential impacts on petroleum resources would vary based on the amount of acreage available for leasing 

and restrictions on future access to available acreage. Under all action alternatives, surface disturbance is 

expected to reach the 2,000-acre maximum for surface disturbance. 

Mean estimates for the program area suggest it contains approximately 7.687 billion barrels of technically 

recoverable oil and 7.04 TCF of technically recoverable natural gas (Attanasi 2005). Due to high costs 

associated with operating in the Arctic it is extremely unlikely that all technically recoverable resources 

would be produced. The US Energy Information Administration estimated that a total of approximately 3.4 

BBO would be produced in the Arctic Refuge by 2050 (Van Wagner 2018). Oil would be transported to 

market by a connection to the TAPS. 

Given the uncertainty involved in defining undiscovered resources in the program area, attempting to 

define variances in production by alternative is too speculative to provide value in the analysis. NSO 

restrictions could require that well pads be located outside optimal locations for the most efficient oil 

recovery under some alternatives; however, horizontal drilling technology would allow operators to 

recover oil and gas from NSO areas. Under some alternatives, additional pads could be required to access 

all areas, potentially decreasing the overall volume of oil and gas that would be economically recoverable. 

A natural gas transport pipeline from the North Slope to southcentral Alaska could be expected, where 

the gas would be transformed into liquefied natural gas. Gas transported through the pipeline is expected 

to come from established fields with proven reserves initially. If proven gas resources are discovered in the 

Coastal Plain they could be connected to the pipeline to maintain pipeline capacity as the primary fields are 

depleted. Estimated natural gas production from the Coastal Plain ranges from 0 to 7 TCF of gas produced 

(Attanasi 2005). Any co-occurring gas produced with oil would be reinjected to maintain reservoir 

pressure or would be used to manufacture natural gas liquids to blend and transport with the oil 

(Appendix B). Gas flaring would be limited to the minimum necessary to safely operate processing 

facilities. Production wells would be fractured to stimulate initial production, but no hydraulic fracturing to 

produce unconventional resources is anticipated (Appendix B). There is no unconventional oil and gas 

production on Alaska’s North Slope (BLM 2012) due to high development and production costs in the 

Arctic. The viability of hydraulic fracturing of unconventional petroleum resources has not been proven in 

the Arctic from a technology or commercial viability standpoint. 

Under all action alternatives potential future spills and leakage of petroleum resources are expected to 

result in a loss of productive use of those resources. In the NPR-A the average crude oil spill rate from 

1985 to 2010, for large (500 barrels or greater) spills is 0.65 spills per BBO produced, with an average spill 

size of 1,229 barrels. During that time the North Slope produced a total of 12.40 BBO. The historic small 

(less than 500 barrels) crude oil spill rate from 1989 to 2009 for the Alaska North Slope is 187 spills per 

billion barrels produced, with an average spill size of 2.8 barrels (117.6 gallons). During this time 9.4 BBO 

were produced (BLM 2012).

With an estimated 3.4 BBO of production anticipated from the Coastal Plain, and assuming the same spill 

rates as NPR-A, it is reasonable to anticipate a program area spill total of approximately 1,780 barrels of 

oil spilled in approximately 636 small spills and a total of approximately 2,716 barrels spilled in two or 

three large spills. In addition to damage to the environment, spills represent a loss of petroleum resources 

from productive use. Using a high case scenario and a USGS estimate that 9.3 BBO would be economically 

recoverable (Attanasi and Freeman 2009), it could be expected that there would be approximately 1,739 

small spills with a total of approximately 4,869 barrels spilled, and approximately 6 large spills with a total 
3. Affected Environment and Environmental Consequences (Petroleum Resources)

Coastal Plain Oil and Gas Leasing Program 3-39

Draft Environmental Impact Statement

spill size of 7,374 barrels, if the spill rate stays consistent over time. The rate of spills may decrease over 

time as industry practices improve. 

Operators would be required to prepare and implement spill prevention and control plans in compliance 

with applicable federal regulations. 

Alternative B

Table 3-9 shows acreages that would be subject to NSO restrictions, TLs or would be open to leasing 

under standard terms and conditions only. This alternative opens the entire Coastal Plain to leasing, 

allowing the greatest acreage for potential petroleum extraction (see Map 3-4, Hydrocarbon Potential, 

Alternative B, in Appendix A for more detail). Fewer restrictions on the locations of future CPFs and 

drill pads exist under this alternative.

Table 3-9

Lease Stipulation Acreages for Alternative B

Lease 

Stipulations

Low Oil Potential 

(acres)

Medium Oil 

Potential (acres)

High Oil Potential 

(acres)

Total 

(acres)

NSO 96,300 120,900 142,200 359,400

Standard Terms 

and Conditions 

Only

45,600 287,300 285,700 618,700

TL 335,300 250,100 0 585,400

Total 477,200 658,300 427,900 1,563,500

Source: BLM GIS 2018

Alternative C

Table 3-10 shows acreages that would be subject to NSO or TL restrictions, that would not be offered 

for leasing, or that would be open to leasing under standard terms and conditions only. 

Table 3-10

Lease Stipulation Acreages for Alternative C

Lease 

Stipulations

Low Oil Potential 

(acres)

Medium Oil 

Potential (acres)

High Oil Potential 

(acres)

Total 

(acres)

NSO 410,200 328,200 194,000 932,400

Standard Terms

and Conditions 

Only

100 129,400 184,500 314,000

TL 66,900 200,800 49,400 317,100

Total 477,200 658,400 427,900 1,563,500

Source: BLM GIS 2018

This alternative also opens the entire program area to leasing (see Map 3-5, Hydrocarbon Potential, 

Alternative C, in Appendix A for more detail). Under this alternative, 20 percent of the area would have 

standard terms and conditions only, including only 28 percent of the medium and high potential areas. The 

acreage subject to NSO would still allow for CPF and drill pad siting to maximize recovery from each pad. 
3. Affected Environment and Environmental Consequences (Petroleum Resources)

3-40 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Alternative D1

Table 3-11 shows acreages that would be subject to NSO, CSU, or TL restrictions, that would not be 

offered for leasing, or that would be open to leasing under standard terms and conditions only. A total of 

1,037,200 acres would be available for leasing. 

The 526,300 acres that are not offered for leasing represent approximately 34 percent of the program 

area. The area closed to leasing is in low and moderate petroleum potential sections of the program area 

projected to have small accumulations of petroleum; thus, the percentage of petroleum resources closed 

to leasing would be less than 34 percent of the economically recoverable petroleum resources. See Map 

3-6, Hydrocarbon Potential, Alternative D1, in Appendix A. 

Under this alternative, only 19 percent of the medium and high potential areas would be available for 

leasing with standard terms and conditions. Approximately 45 percent of the program area is subject to 

NSO stipulations, which would limit the location of future CPFs and drill pads, potentially resulting in 

changes to pad configurations and reduced oil production. NSO restrictions are in portions of the high, 

mediums and low areas. 

Table 3-11

Lease Stipulation Acreages for Alternative D1

Lease Stipulations Low Oil 

Potential (acres)

Medium Oil 

Potential (acres)

High Oil 

Potential (acres) Total (acres)

CSU 11,000 80,500 32,400 123,900

Not offered for lease 398,300 120,700 7,300 526,300

NSO 67,900 384,600 256,200 708,600

Standard Terms and 

Conditions Only

0 72,800 131,900 204,700

Total 477,200 658,400 427,900 1,563,500

Source: BLM GIS 2018

Alternative D2

Table 3-12 shows acreages that would be subject to NSO, CSU, or TL restrictions or that would not be 

offered for leasing. No acres would be open to leasing under standard terms and conditions only; a total of 

1,037,200 acres would be available for leasing. Alternative D2 has TL restrictions on lands that were 

available with only standard terms and conditions under Alternative D1.

Table 3-12

Lease Stipulation Acreages for Alternative D2

Lease Stipulations Low Oil 

Potential (acres)

Medium Oil 

Potential (acres)

High Oil 

Potential (acres)

Total

(acres)

CSU 11,000 80,500 32,400 123,900

Not offered for lease 398,300 120,700 7,300 526,300

NSO 67,900 384,400 256,300 708,600

TL 0 72,800 131,900 204,700

Total 477,200 658,400 427,900 1,563,500

Source: BLM GIS 2018

The 526,300 acres that are not offered for leasing represent approximately 34 percent of the program 

area. The area closed to leasing is in low and moderate petroleum potential sections of the program area 

projected to have small accumulations of petroleum; thus, the percentage of petroleum resources closed 
3. Affected Environment and Environmental Consequences (Petroleum Resources)

Coastal Plain Oil and Gas Leasing Program 3-41

Draft Environmental Impact Statement

to leasing would be less than 34 percent of the economically recoverable petroleum resources. See Map 

3-7, Hydrocarbon Potential, Alternative D2, in Appendix A.

Under this alternative, there are no medium and high potential areas available for leasing subject only to 

standard terms and conditions; the acres that were available for leasing subject only to standard terms and 

conditions under Alternative D1 have TLs applied under Alternative D2. Approximately 45 percent of the 

program area is subject to NSO restrictions, which would limit the location of future CPFs and drill pads, 

potentially resulting in changes to pad configurations and reduced oil production. 

Cumulative Impacts

Oil and gas exploration, development, and production around the North Slope have resulted in and would 

continue to result in irreversible commitment of oil resources. The Alaska Liquid Natural Gas Project and 

the Alaska Stand Alone Gas Pipeline, if completed, could result in the irreversible commitment of gas 

resources. Scientific research could result in a better understanding of the type and size of petroleum 

resources in the program area. Spills of produced petroleum products associated with oil and gas 

exploration and development would result in an irreversible loss of those resources. Alternative A would 

have no potential cumulative impacts from future oil and gas exploration, development, and production on 

petroleum resources. The production and subsequent consumption of petroleum resources would 

contribute to climate change, which are discussed in Section 3.2.1.

3.2.7 Paleontological Resources

Affected Environment

Paleontological resources include any physical evidence of past life, including fossilized flora and fauna, 

imprints, and traces of plants and animals. The program area, and all the North Slope, are widely regarded 

as fossiliferous.10 It has borne evidence of past habitation that has expanded the scientific community’s 

understanding of the geologic and paleontological record worldwide (BLM 2012). 

As discussed in Section 3.2.5, various geologic units have been identified in the program area. This 

includes ten bedrock geologic units, with unconsolidated surficial deposits, covering more than 80 percent 

of the surface area. Eight of these ten units have potential or documented fossils, though the presence of 

paleontological features has not been specifically noted in outcrops in the program area. Program area 

bedrock geologic units and their approximate acreage in the program area are shown on Map 3-8,

Paleontological Resources, in Appendix A, and are noted below.

The Potential Fossil Yield Classification (PFYC) system is a tool used to assess potential occurrences of 

paleontological resources in mapped geologic units. It provides classifications that may be used to assist in 

determining the need for further assessment or actions. The PFYC system is created from available 

geologic maps and assigns a class value to each geological unit, representing the potential abundance and 

significance of paleontological resources that occur in that geological unit. PFYC values range from Class 1, 

Very Low, to Class 5, Very High, which indicate both the probability for the mapped unit to contain 

significant paleontological resources and the degree of management concern for the resource. Geologic 

units without enough information associated with them to assign a PFYC value may be assigned Class U, 

Unknown Potential. Characteristics of PFYC values are included in Appendix G. 

The PFYC model for Alaska is in development. Preliminary PFYC values have been assigned to the mapped 

geologic units in the program area and are included in Table 3-13. Excerpts from the in-progress PFYC 

 

10Rich in fossils or fossil potential
3. Affected Environment and Environmental Consequences (Paleontological Resources)

3-42 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

model regarding preliminary rankings and unit descriptions are included in Appendix G. These PFYC 

assignments are maintained and updated by the BLM as additional data is available. The PFYC model in 

development relies on the geologic mapping presented in Wilson et al. 2015; some of the mapped units 

are characterized differently than those presented in Section 3.2.5. 

Pleistocene, or ice age, fossils from between 2.59 million and 11,700 years ago have been identified across 

the North Slope in surficial quaternary deposits. These are the same deposits that cover approximately 1.4 

million acres of the program area. Most of the recorded fossils exposed in North Slope surficial deposits 

are a result of stream bank erosion. These fossils include remains of animals that existed at the same time 

as human habitation of the area: horses, mammoths, antelope, bison, bears, lions, muskoxen, caribou, and 

moose (BLM 2018a). 

Table 3-13

PFYC Values of Program Area Geologic Bedrock Units

Geologic Unit

Acres in 

Program Area 

(Approximate)

Age (Millions of 

Years Ago [mya]) PFYC Value Noted Fossil Presence in Unit

Sagavanirktok 

Formation

16,900 Tertiary (65–2.8) 3-4 Floral, microfauna, and 

mollusk fossils

Seabee Formation 

and Hue Shale

1,200 Cretaceous (145–66) 3-4 Ammonites, pelecypods, 

fish remains, bird trace 

fossil (footprint) 

Jago River Formation 25,300 Upper Cretaceous, 

(100.5–66)

3 Palynomorphs, plant 

fossils

Sadlerochit 

Formation

2,800 Lower Triassic to 

Permian (289.9–247.2)

3 Ammonites, pelecypods, 

and brachiopods 

Lisburne Group, 

undivided

500 Carboniferous (358.9–

298.9)

3 Group noted as generally 

fossiliferous; contains 

corals, brachiopods, 

ammonites, nautiloids, 

and plants

Kingak Shale 200 Jurassic (201.3–145) 3 Marine mollusks and 

crinoids; pelecypods and 

ammonites

Surficial Quaternary 

Deposits

1,421,700 Quaternary, 

Pleistocene, and upper 

Tertiary (2.59–

present)

2-3 Flora, fauna

Kemik Sandstone 200 Lower Cretaceous 

(146–100)

2-3 Trace fossils (footprints)

Kongakut Formation 200 Lower Cretaceous 

(146–100)

2-3 Pelecypods and abundant 

worm borings 

Canning Formation 8,500 Cretaceous to Tertiary 

(145–2.8)

2-3 Palynomorphs 

Sources: BLM GIS 2018; Breithaupt, B. BLM Regional Paleontologist, e-mail to Anna Kohl, HDR environmental scientist, on July 

30, 2018, regarding preliminary PFYC rankings and unit descriptions for the program area.

Most paleontological resources identified on the North Slope have been identified in areas west of the 

program area. A description of the history of fossil discovery on the North Slope and conclusions 

regarding the fossil record is in BLM 2012, Section 3.2.7, and BLM 2018a, Section 3.2.1.6.
3. Affected Environment and Environmental Consequences (Paleontological Resources)

Coastal Plain Oil and Gas Leasing Program 3-43

Draft Environmental Impact Statement

Climate Change

Changing climate conditions would not directly affect paleontological resources but could impact several 

geologic hazards, including thawing permafrost and coastal erosion. An increase in the active layer 

expected from a warming climate could result in greater areas of land subsidence, which may expose 

geologic units with paleontological resources to weathering action. Similarly, coastal erosion would expose 

previously protected units to weathering, which may expose and damage resources. Given the surficial 

context of these actions, the geologic unit with the greatest risk is the unconsolidated and poorly 

consolidated surficial Quaternary deposits, which may contain Pleistocene fossils.

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

paleontological resources from on-the-ground post-lease activities.

The effects of climate change described under Affected Environment above, could influence the rate or 

degree of the potential direct and indirect impacts.

Alternative A

Under Alternative A, current management actions would continue as described in the Arctic Refuge CCP 

(USFWS 2015a). Changes to paleontological resources, such as increased exposure due to changes in 

permafrost, river bank erosion, coastal erosion, and weathering, would continue to occur along current 

trends. There would be no potential direct or indirect impacts on paleontological resources from future 

oil and gas exploration, development, and production under Alternative A.

Impacts Common to All Action Alternatives

The limited bedrock outcrops and distribution of surficial quaternary deposits are the only sources for 

understanding the distribution and type of paleontological resources in the program area. As described in 

Section 3.2.5, if future program-related infrastructure includes gravel fill, the ability to evaluate and 

observe paleontological resources would be restricted; however, placement of gravel fill would also 

provide erosion protection, which may support preservation of the resource. Potential impacts would be 

long term and would last until the gravel is removed. Potential direct impacts on paleontological resources 

would be limited to future ground-disturbing activities, including drilling and gravel mining.

NSO restrictions associated with setbacks or exclusion from biological and ecological areas, as described 

in Table 2-2 in Chapter 2 would reduce the acreage of geologic units affected and therefore the 

potential for affecting paleontological resources. NSO restrictions associated with setbacks from March 

Creek and from the Canning, Hulahula, Aichilik, Okpilak, Jago, Sadlerochit, Tamayariak, Okerokovik, and 

Katakturuk Rivers would be common among all action alternatives. They would reduce ground-disturbing 

activities in the surficial quaternary deposits next to these water bodies. Since streambank erosion is a 

common mechanism to exposure Pleistocene fossils, these setbacks would prevent additional exposure of 

paleontological resources in surficial deposits. Marsh Creek and the Katakturuk, Jago, and Okerokovik 
3. Affected Environment and Environmental Consequences (Paleontological Resources)

3-44 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Rivers pass within 1 mile of several bedrock outcrops that may bear paleontological resources 

(Sagavanirktok, Canning, and Jago River formations); NSO setbacks from these rivers would reduce 

potential future impacts on paleontological resources in these outcrops simply because of the exclusion of 

ground-disturbing activities. 

Potential future indirect impacts on paleontological resources are due to increased exposure, either to 

humans or the elements. Since the resources in the program area have not been extensively studied, 

increased exposure from infrastructure construction and operation near bedrock outcrops may support 

additional scientific research and identification of paleontological resources. Similarly, improving access to 

areas with paleontological resources may increase unauthorized fossil removal, looting, and damage. 

Removal of ground cover that would expose fossil-bearing units would expose the unit to weathering 

influences, which may disturb the resource and its context. 

Alternative B

Potential future impacts on paleontological resources from oil and gas exploration, development, and 

production under Alternative B would be the same as identified above for all action alternatives. 

Alternative C

Alternative C includes a greater acreage of NSO restrictions, as well as additional setbacks from 

waterbodies than Alternative B. Because the land made available for ground-disturbing activities under 

Alternative C is less than that under Alternative B, fewer acres of surficial quaternary deposits and 

bedrock outcrops that may contain paleontological resources would be exposed and potentially affected 

by future oil and gas exploration, development, and production. 

Alternative D

Alternative D includes a greater acreage of NSO restrictions, as well as additional setbacks from 

waterbodies than Alternatives B and C. Because the amount of land made available for ground-disturbing 

activities under Alternative D is less than that under Alternatives B and C, fewer acres of surficial 

quaternary deposits and bedrock outcrops that may contain paleontological resources would be exposed 

and potentially affected by future oil and gas exploration, development, and production. 

Cumulative Impacts

BLM (2018a) notes that activities with the potential to adversely affect paleontological resources are 

required to have professional inventories filed with BLM before specific development projects begin. These 

include requirements to minimize or eliminate adverse impacts on paleontological resources. No past or 

present actions that could affect paleontological resources have occurred in the program area. Reasonably 

foreseeable future actions (Appendix F) that could affect paleontological resources have occurred or 

would occur in the program area; therefore, no cumulative impacts on paleontological resources would 

occur. The effects of climate change described under Affected Environment above, could influence the rate 

or degree of the potential cumulative impacts. Alternative A would have no potential cumulative impacts 

on paleontological resources from future oil and gas exploration, development, and production.

3.2.8 Soil Resources

Affected Environment

The Coastal Plain is in the Coastal Plain physiographic sub-province and portions of the Arctic Foothills 

physiographic sub-province (see Section 3.2.5). The soils in the Coastal Plain sub-province are composed 

of poorly drained, unconsolidated sediments transected by fluvial deposits of rivers and stream flowing 

northward from the rolling foothills to the south (Wahrhaftig 1965). Most uplands in the program area are 
3. Affected Environment and Environmental Consequences (Soil Resources)

Coastal Plain Oil and Gas Leasing Program 3-45

Draft Environmental Impact Statement

in the western half and extend from the foothills of the Sadlerochit Mountains southern boundary to near 

the coastline. Upland soils consist of loess, colluvium, and morainal deposits. Lowland Coastal Plain 

deposits east of the Hulahula River are interbedded marine and alluvial deposits associated with past 

marine transgressions. These soils generally include fluvial sands and gravels, silty sand, and organic silt over 

marine silts and clays. These soils are generally ice rich and contain ice wedges (Jorgenson et al. 2015).

Eolian deposits comprise nearly 30 percent of the surficial soil deposits in the program area and can range 

from 3 to 100 feet thick (Jorgenson et al. 2015; Rawlinson 1993). Eolian deposits in flat lowland areas are 

normally frozen, with a high ice content; hillslopes generally have a thin eolian deposit cover, less than 15 

inches thick. Alluvial and fluvial deposits, including active braided channels, terraces, and deltaic deposits, 

consist of sands and gravels in steeper gradients near the foothills. They transition to finer grained soils in 

floodplains and inactive channels (Jorgenson et al. 2015).

The Sadlerochit Mountains bordering the southwestern edge of the program area are composed of 

Tertiary sandstone and conglomerate noncarbonate sedimentary rocks. Colluvium deposits drape the 

northern slopes of the Sadlerochit Mountains and are composed of loose, silty to rubbly, unsorted 

deposits derived directly from weathering bedrock deposits upslope. Colluvium deposits are usually 

vegetated (Jorgenson et al. 2015). At the southern border of the program area, the Canning River and 

Hulahula River drainages are capped by glacial moraine deposits, consisting of silty sands and gravels, with 

some cobbles and boulders (Rawlinson 1993).

The entire program area is underlain by permafrost with isolated areas of thaw near deep lakes, springs, 

and rivers (Bird and Magoon 1987). Depending on their depth and size, lakes and rivers influence the 

presence of permafrost; deeper lakes and rivers, such as the Canning River, often form a thaw bulb below 

the water body (Rawlinson 1993). Permafrost and ground ice characteristics are variable, due to 

differences in climate, topography, soil properties, cryogenic processes, and environmental history 

(Jorgenson et al. 2015). Massive ice occurs in the form of ice wedges, buried glacial ice in glacial deposits, 

and intrusive ice (Jorgenson 2008). Permafrost in the Coastal Plain is generally between 650 and 1,300 feet 

thick (USFWS 2015a). Polygonal patterned ground is created when ice wedges form in the upper few feet 

of the ground surface and is indicative of ice-rich soils. Polygonal ground is a common surface feature in 

the program area, especially in lowland areas; polygons may be less apparent in drained upland areas, 

where vegetation can mask these surface features (Rawlinson 1993).

The top layer of the soil surface that typically thaws and refreezes annually is known as the active layer. In 

the Coastal Plain, the active layer is generally between 1 and 4 feet thick (USFWS 2015a). Active layer 

thickness can vary from year to year and depends on such factors as ambient air temperature, aspect, 

gradient, vegetation, drainage, snow cover, water content, and soil type. Long-term permafrost 

temperature monitoring shows a warming trend over the past 25 years, with the greatest warming near 

the coast. Soil temperatures increased 3 to 5°F between 1985 and 2004 (USFWS 2015a). At the 

approximately 4-foot depth at three USGS monitoring stations in the program area, average subsurface 

temperatures showed warming trends between 2000 and 2014 of 32.9 to almost 35.6°F (Urban and Clow 

2017).

Degradation of permafrost can be affected by ice content, soil or vegetation removal, and ground 

disturbances, with ice-rich and thaw-unstable soils and hillsides being the most sensitive to thawing (ADNR 

2018a). Thawing, ice-rich, permafrost soils create thermokarst features that transform the landscape by 

subsidence, erosion, and changes in drainages, including channelization and ponding (USFWS 2015a). 
3. Affected Environment and Environmental Consequences (Soil Resources)

3-46 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Changes in the landforms due to erosion and thermokarst, such as slumping and channelization, affects the 

vegetation and water characteristics of the area (USFWS 2015a).

Changes being experienced to soils and permafrost on the North Slope resulting from a changing climate 

are fully described in BLM (2018a).

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

soil resources from on-the-ground post-lease activities.

Potential impacts from the development and operation of facilities identified in the hypothetical 

development scenario (Appendix B) are as follows:

 The placement of gravel fills for pads, roads, and airstrips

 Construction of VSMs for pipelines and building foundations

 Construction of ice roads and pads

 Removal of sand and gravel resources for embankment fills

 Impacts from exploratory seismic activities

These future actions, including vehicular travel on snow and ice-covered tundra, change and disturb the 

insulating surface vegetation layer and increase the active layer thickness, thawing the permafrost, and 

developing thermokarst structures. Thermokarst changes the surface topography, increasing water 

accumulation, changing surface water drainage patterns, and increasing the potential for soil erosion and 

sedimentation (BLM 2018a; Jorgenson et al. 2010).

The effects of climate change described under Affected Environment above, could influence the rate or 

degree of the potential direct and indirect impacts.

Alternative A

Under Alternative A, current management actions would be maintained as described in the Arctic Refuge 

CCP (USFWS 2015a). The Coastal Plain would remain undeveloped. No direct or indirect impacts on soils 

or permafrost would occur from post-leasing oil and gas activities.

Impacts Common to All Action Alternatives

Under all action alternatives, approximately 2,000 acres of disturbance due to placement of gravel fills and 

VSMs for future construction of roads, pads, airstrips, and structures would occur and would result in 

potential direct impacts on soil quality and permafrost in and next to the gravel fill footprint. Changes to 

surface drainage due to the placement of fills causes permafrost thawing and subsidence and water 

accumulation, which would not occur under Alternative A. Placement of fills would cover soils and kill 

existing vegetation, altering the thermal active layer (USACE 2018). Installation of VSMs for pipelines 

would displace and disturb soils around the VSM (BLM 2018a). Seismic surveys supporting exploration for 
3. Affected Environment and Environmental Consequences (Soil Resources)

Coastal Plain Oil and Gas Leasing Program 3-47

Draft Environmental Impact Statement

resources would be performed during the winter to reduce impacts; however, impacts on vegetation and 

disturbance of the active layer would result in direct impacts on the soil quality and permafrost where 

seismic survey activities occur (USFWS 2014; Jorgenson et al. 2010).

By changing drainage patterns of surface water, ponds and channels form and concentrate water that 

accelerates permafrost thaw. Where drainage patterns are altered, blockages can lead to ponding and 

sediment deposition. Where drainage patterns redirect surface flow or increase velocities, such as at 

embankments, erosion of sediments occurs (BLM 2018a).

Potential indirect impacts on soil and permafrost in and next to the gravel fill footprints would be due to 

dust deposition and snow accumulation. Fugitive dust would be suspended in the air by vehicle and 

equipment use and would settle onto surrounding vegetation and snow, which would decrease surface 

albedo.11 A decrease in surface albedo can increase absorption of solar radiation, accelerate the rate of 

snowmelt, and lead to permafrost thaw (USACE 2018). Dust accumulation can also affect the pH of the 

surrounding soils, which leads to changes in the health and growth of vegetation that hold soil in place. 

Blowing snow conditions due to changes in topography from the construction of pads and roads and 

VSMs/infrastructure foundations changes the thermal regime of the soils and permafrost next to the pad 

and road or VSMs. Snow accumulation insulates the underlying soil during the winter, increasing the overall 

soil temperatures and leading to permafrost thaw at those locations. Snow accumulation would occur 

more frequently on the leeward side of embankments (USACE 2018).

Future sand and gravel material extraction and transport would be required to provide materials for 

embankment construction and would have impacts on the permafrost and soils in the mine site footprint, 

around its perimeter, and along transportation routes. Section 3.2.9 discusses the impacts of material 

extraction in further detail. 

Future reclamation of roads and pads would be subject to the permitting process. Removal of gravel would 

affect the underlying soil and permafrost resources by exposing the underlying soils to increased radiation 

and leading to continued permafrost degradation (USACE 2018). 

Alternative B

Potential impacts on soils and permafrost under Alternative B would be the same as identified above for all 

action alternatives. Approximately 12,509,000 cubic yards of material is required for constructing the 

embankment infrastructure, estimated to be up to 310 acres of disturbance to the ground surface and soils 

at material extraction sites. 

Alternative C

Potential impacts on soils and permafrost under Alternative C would be the same as identified above for 

all action alternatives; however, lease stipulations would limit surface occupancy to the western half of the 

program area, which consists of greater areal deposits of alluvial sands and gravels, as well as marine 

deposits along the northern boundary. Approximately 12,722,000 cubic yards of material is required for 

constructing the embankment infrastructure, estimated to be up to 315 acres of disturbance to the ground 

surface and soils at material extraction sites. 

 

11The light that is reflected from the surface
3. Affected Environment and Environmental Consequences (Soil Resources)

3-48 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Alternative D

Potential impacts on soils and permafrost under Alternative D would be the same as identified above for 

all action alternatives; however, lease stipulations would limit surface occupancy to the western third of 

the program area, which is primarily composed of fine sand and silt deposits with restricted use of areas 

next to alluvial plains, which are composed of sands and gravels. Approximately 12,420,000 cubic yards of 

material is required for constructing the embankment infrastructure, estimated to be up to 308 acres of 

disturbance to the ground surface and soils at material extraction sites. 

Cumulative Impacts

The geographic area relevant for assessing cumulative impacts for soils and permafrost is the program area. 

Previous seismic survey explorations and an exploratory test well in the program area have disturbed the 

surface vegetation and affected the thaw of permafrost, changed drainage patterns, and changed vegetation 

growth for over 25 years after disturbance (USFWS 2014; Jorgenson et al. 2010). Approximately 900 

square miles of additional seismic surveys over the program area are required (Appendix B); while 

improvements have been made to avoid impacts on the ground surface, future seismic surveys may have 

similar impacts. 

Each of the hypothetical development scenarios could affect over 2,000 acres of soils and permafrost, as 

acreage would be regained against the 2,000-acre surface disturbance limit during reclamation 

(Appendix B). The potential impacts are related to future changes to topography and landforms resulting 

in changes to soil chemical composition, drainage patterns, and erosion of soils. Disturbance to surface 

vegetation directly leads to changes in the thermal regime of soils due to placement of gravel fills for pads 

and roads. The effects of climate change described under Affected Environment above, could influence the 

rate or degree of the potential cumulative impacts.

Alternative A would have no cumulative impacts on soils and permafrost from future post-lease oil and gas 

activities.

3.2.9 Sand and Gravel Resources

Affected Environment

Sand and gravel are most commonly present in the Coastal Plain in the valleys of larger rivers and streams 

(Bird and Magoon 1987); the valleys of larger streams are underlain by coarse sand and gravel. These 

include the Canning, Sadlerochit, Hulahula, and Aichilik Rivers, which are heavily braided and have 

extensive gravel bars generally free of vegetation. Sediments on the Coastal Plain in the western half of the 

program area are dominated by outwash sediments covered by younger fluvial sands and gravels within 

approximately 10 miles of the coastline; the outwash sediments are either directly below the fluvium or 

have been eroded and replaced by the fluvium (Rawlinson 1993). The eastern half of the program area is 

also composed of fluvial sediments overlying outwash sediments; however, the fluvial and outwash 

sediments extend farther inland into the Sadlerochit Mountains than the western side of the program area, 

about 24 miles.

The Canning River valley on the western border of the program area was formed by a large valley glacier. 

It formed a piedmont lobe along the Canning and Tamayariak Rivers, depositing glaciofluvial soils (Bird and 

Magoon 1987). These soils are composed of outwash sediments deposited in multiple terraces, formed by 

glacial outwash washed downstream and are capped by younger alluvial deposits. The outwash deposits 

near the northern boundaries of the program area are covered by eolian sand and overlain by lacustrine 

silt and peat, exposed at stream cuts, and bank exposures (Rawlinson 1993).
3. Affected Environment and Environmental Consequences (Sand and Gravel Resources)

Coastal Plain Oil and Gas Leasing Program 3-49

Draft Environmental Impact Statement

Sediments in the program area are dominated by outwash sediments covered by younger fluvial sands and 

gravels. The outwash sediments are either directly below the fluvium or have been eroded and replaced by 

it (Rawlinson 1993). Sands and gravels are often found in elevated terrain between river valleys and alluvial 

fans originating from the foothills to the south (Rawlinson 1993). Soils downstream and closer to the 

coastline become progressively fine grained, transitioning to deltaic and marine deposits (Bird and Magoon 

1987).

Existing material sources in the Coastal Plain and west and outside of the program area are in similar 

geological environments and next to streams. These sites are reportedly excavated to depths of 

approximately 45 feet below the surface and are in similar glaciofluvial and fluvial deposits. These deposits 

have been observed to contain ice wedges and thin discontinuous beds of fine-grained material with 

abundant detrital wood debris (Rawlinson 1993).

Climate Change

Changes in climate may affect access to those sand and gravel resources. Developers of sand and gravel 

resources in the program area would use ice roads for access to the material sites. Depending on the 

excavation methods to mine sand and gravel resources, climate change could make the excavation easier, 

due to thawing permafrost, or more difficult, due to increased water or swampy conditions (BLM 2018a).

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

sand and gravel resources from on-the-ground post-lease activities.

Potential impacts from the future development and operation of facilities identified in the hypothetical 

development scenarios (Appendix B) include the removal of sand and gravel resources for embankment 

fills. These actions change and disturb the surface vegetation layer and excavate landforms, resulting in 

changes to surface drainage, erosion of soils, and thawing of permafrost. 

The effects of climate change described under Affected Environment above, could influence the rate or 

degree of the potential direct and indirect impacts.

Alternative A

Under Alternative A, current management actions would be maintained as described in the Arctic Refuge 

CCP (USFWS 2015a). The Coastal Plain would remain undeveloped. No direct or indirect impacts on sand 

and gravel resources would occur from future post-lease oil and gas activities.

Impacts Common to All Action Alternatives

Sand and gravel resources would be required for future development projects under each of the action 

alternatives. Sand and gravel resources would need to be extracted for the construction of roads and pads. 

Sand and gravel would likely be obtained from more than one newly permitted mine site near the 

proposed development and would be accessed during winter via ice roads. Sand and gravel mining would 
3. Affected Environment and Environmental Consequences (Sand and Gravel Resources)

3-50 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

alter the geomorphic landforms and remove vegetation, leading to permafrost thaw. At mine site closure, 

and depending on site characteristics and reclamation requirements, the mine sites could be inundated 

with surface water, forming a pond. By changing the drainage patterns of surface water, ponds and 

channels form and concentrate water that accelerates permafrost thaw. Where drainage patterns are 

altered, blockages can lead to ponding and sediment deposition. Where drainage patterns redirect surface 

flow or increase velocities, such as at embankments, sediments erode. Water impoundment in a flooded 

pit would likely remain unfrozen near the bottom, creating a thaw bulb around and beneath the pit, which 

may cause the excavation walls to slough and deposit material into the pit (BLM 2018a).

Removal of gravel in the future from areas near or in streams could change stream configurations, 

hydraulics, flow patterns, erosion, sedimentation, and ice damming (USACE 2018). These actions would 

not occur under Alternative A.

Alternative B

Approximately 12,509,000 cubic yards of material would need to be mined for future gravel pads and 

roads. The area footprint of a 25-foot-deep pit is 310 acres. Multiple material source sites are expected to 

be used to meet the material demands and reduce haul distances. Based on areas of high potential mineral 

leasing under this alternative (Map 3-4 in Appendix A), material sources are anticipated to be primarily 

in the outwash sediments from the Sadlerochit Mountains in the southwestern portion of the program 

area and in alluvial deposits of larger rivers. 

Alternative C

Approximately 12,722,000 cubic yards of material would need to be mined for future gravel pads and 

roads. The area footprint of a 25-foot-deep pit is 315 acres. Multiple material source sites are expected to 

be used to meet the material demands and reduce haul distances. Based on areas of high potential mineral 

leasing under this alternative, material sources are anticipated to be primarily in the outwash sediments 

from the Sadlerochit Mountains in the southwestern portion of the program area and in alluvial deposits of 

larger rivers.

Alternative D

Approximately 12,420,000 cubic yards of material would need to be mined for future gravel pads and 

roads. The area footprint of a 25-foot-deep pit is 308 acres. Multiple material sources sites are expected 

to be used to meet material demands and limit haul distances. Based on areas of high potential mineral 

leasing under this alternative, material sources are anticipated to be primarily from fluvial deposits between 

the Canning and Tamayariak Rivers, and material resources may be limited to streams and topographic 

high points.

Cumulative Impacts

The geographic area relevant for assessing potential cumulative impacts for sand and gravel resources is 

the program area. Potential direct impacts would include permanent changes to landforms and vegetation, 

due to material extraction, which would lead to changes in permafrost. Changes to permafrost would 

likely be due to thaw and would result in subsidence, formation of thaw bulbs, and changes to drainages in 

and around the perimeter of the material site. Alternative C would require more cubic yards of material, 

compared to the other action alternatives. Past and present actions affecting sand and gravel in the 

program area are expected to continue, including natural riverbank and slope erosion. The effects of 

climate change described under Affected Environment above, could influence the rate or degree of the 
3. Affected Environment and Environmental Consequences (Sand and Gravel Resources)

Coastal Plain Oil and Gas Leasing Program 3-51

Draft Environmental Impact Statement

potential cumulative impacts. Alternative A would have no cumulative impacts on sand and gravel 

resources from post-leasing oil and gas activities.

3.2.10 Water Resources

Affected Environment

The climate and permafrost of the Arctic Refuge Coastal Plain (ARCP)12 are the controlling physical forces 

of the hydrologic cycle and are characterized by low precipitation and below-freezing average 

temperatures during 8 months of the year (Lyons and Trawicki 1994). A comparison of average monthly 

temperatures at Barter Island on the coast and farther south in the coastal plain and northern Brooks 

Range foothills (represented by Kuparuk and Toolik Lake, respectively) are provided in Table H-1 in 

Appendix H.

Snowfall measurements date back to 1949 on Barter Island, but the monitoring site was taken out of 

service in 1989, resulting in a discontinuous record of snow climatology. In 2000, three meteorological 

stations were established (Urban and Clow 2017) as part of the DOI/Global Terrestrial Network for 

Permafrost Observing System in remote parts of the ARCP. Locations of the three climate monitoring 

gaging stations can be seen in Map 3-13, Essential Fish Habitat, in Appendix A. The limited data available 

from these stations are the only modern continuous record of snow accumulation in this region of Alaska. 

The available average annual water equivalent of monthly precipitation and snowfall data is provided in 

Tables H-2 and H-3 in Appendix H, respectively. 

Hydrology

Water resources on the North Slope consist mainly of rivers, shallow discontinuous streams, lakes, and 

ponds. Hydrology is influenced by climate, topography, and permafrost. Topography of the program area 

ranges from the steep Brooks Range foothills to relatively flat and poorly drained tundra underlain with 

continuous permafrost closer to the coast. 

Streams on the North Slope typically freeze in September and thaw in June. Due to the climate, the annual 

hydrologic cycle is dominated by an approximate 3-week period of spring breakup associated with 

snowmelt and overbank and overland flooding. The open water season is generally limited to June through 

September. While notable fall events have been recorded, annual peak stage (i.e., water level) and 

discharge in streams is associated with the spring break up in late May or early June. Runoff from summer 

rainfall are generally contained in the river channels.

Streams on the North Slope are generally divided into three types, based on the physiographic province of 

their origin: those that originate in (1) the coastal plain of the North Slope (a broader area than the 

program area), (2) the Arctic foothills, or (3) the Brooks Range (Gallant et al. 1995). Streams and rivers in 

the program area share flow characteristics that are typical of the region (Brabets 1996). In the winter, 

stream flow is generally nonexistent or so low as to not be measurable. During freeze-up, ice becomes 

anchored to the streambed, and in shallow locations the entire water column freezes. River flow begins 

during spring break up in late May or early June, and flooding may occur from rapid snowmelt, combined 

with ice- and snow-filled channels. 

Spring breakup can inundate extremely large areas in a matter of days. More than half of the annual 

discharge for a stream can occur over several days to a few weeks (Sloan 1987). Most streams continue to 

 

12Lands in the Arctic Refuge, including the program area, that are part of the larger Arctic Coastal Plain that 

stretches east into Canada.
3. Affected Environment and Environmental Consequences (Water Resources)

3-52 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

flow throughout the summer but at substantially lower discharges. Rainstorms can increase stream flow, 

but they are seldom sufficient to cause flooding in the Arctic Coastal Plain. Stream flow rapidly declines in 

most streams shortly after the onset of freeze-up in September and ceases in most rivers by December. 

The spring season brings about major shifts in hydrology that recharge aquatic habitats and support fish 

migration. Snowmelt starts earliest in the foothills and then proceeds to the coastal plain. During this time, 

sheets of snowmelt water flow over frozen ground, extensive fields of aufeis play an important role, 

directing river flow paths over land and into new channels; snowmelt and flood waters create ephemeral 

connections between aquatic habitats and recharge floodplain lakes and wet meadow zones. On the North 

Slope, up to 40 percent of snowmelt recharges the evaporation deficit from the previous summer; 

immediately following snowmelt, surface waters are at their maximum extent (Bowling et al. 2003). Within 

two weeks of snowmelt, overland flow ceases and many hydrologic systems become disconnected 

(Bowling et al. 2003). 

Flooding of North Slope rivers is influenced by the type of physiographic region drained, the size of the 

drainage area, and the air temperatures during breakup. Snowmelt is the main cause of annual flooding in 

all North Slope rivers and it may be heavy during rapid temperature rises in late May or may occur to a 

lesser extent over a prolonged period of weeks. Snowmelt flooding nearly always produces the annual 

peak discharge on rivers in the study area. On some of the larger rivers, summer precipitation or late 

summer/fall snowmelt events have been observed to produce floods. Table H-5 in Appendix H

provides historic data of measured discharge for several rivers in the program area, and climate monitoring 

stream-gage locations are provided in Map 3-13 in Appendix A. 

Watersheds, Rivers, and Streams

Ten major rivers and numerous smaller streams and rivers flow north from mountain/foothill and tundra 

watersheds that traverse the program area before flowing into the Arctic Ocean. During winter, some 

rivers may freeze to the bed while others have small pockets of unfrozen water beneath ice hummocks 

and along spring-fed reaches or exhibit flow sub-bed in unfrozen gravels. At locations where water is 

forced to the surface, extensive fields of aufeis (an expansive mass of layered ice formed by successive 

freezing of emerging groundwater) may be generated and persist and melt during the summer, providing a 

continued source of flow. During late May to June, snowmelt begins in the foothills and proceeds to the 

coastal plain, providing as much as 50 percent of the annual flow to rivers (Clough et al. 1987; Sloan 1987). 

Table H-4 in Appendix H provides a list of the major drainage basins and waterbodies in the program 

area, their drainage areas, other characteristics, and stream lengths.

Lakes and Wetlands

Most of the program area is considered wetland; however, lakes are very scarce (less than 2 percent of 

the land surface area), compared with the eastern NPR-A, where lakes cover approximately 20 percent of 

the land surface area; here, using water from lakes for ice road building is common practice. Lakes are not 

evenly distributed across the program area but are concentrated near the mouth of the Canning River and 

in the region of the Sadlerochit and Jago Rivers, with very few lakes occupying the central Katakturuk 

River region (Trawicki et al. 1991). Lakes vary in surface area, from 1,500 acres to less than an acre and 90 

percent are less than 12 acres. A study of 115 of the largest lakes indicated most are shallow and freeze to 

the bottom during winter (Trawicki et al. 1991). The estimated volume of liquid water in these lakes is 1.1 

billion gallons by the end of the winter season. Eighty percent of this volume is concentrated in seven lakes 

in the Canning River Delta. One of these lakes is known to have salinity concentrations close to that of 

seawater. 
3. Affected Environment and Environmental Consequences (Water Resources)

Coastal Plain Oil and Gas Leasing Program 3-53

Draft Environmental Impact Statement

The recharge capacity of many lakes is generally limited to snowmelt and direct precipitation near the lake. 

Deep lakes also have a larger thermal mass; thus, the deeper lakes may remain covered by ice into early 

July, much later than the shallow lakes (BLM 2014). Some lakes in the program area have been measured 

for lake volume (Trawicki et al. 1991), with some characteristics listed in Table H-6 in Appendix H.

During winter, most waterbodies on the ARCP freeze solid as they are typically not as deep as the depth 

of freeze, reported to be 6 to 7 feet (Trawicki et al. 1991; Lyons and Trawicki 1994). Small pockets of 

unfrozen water occur in lakes with depths that exceed ice growth. By the end of the winter season, the 

volume of liquid water in these lakes has been estimated to be reduced by 98 percent (Craig 1989). Up to 

40 percent of snowmelt serves to recharge the evaporation deficit from the previous summer (Bowling et 

al. 2003).

Groundwater Springs and Aufeis

The perennial springs in the ARCP are unique, when compared with the lands to the west beyond the 

program area, which lacks major spring-fed habitats. Spring-fed reaches maintain relatively stable flows and 

temperatures year-round, have relatively large productive stands of riparian vegetation, and produce 

extensive fields of aufeis. Aufeis formations near springs can be 20 feet high and more than 1 mile wide by 

the end of the winter. Aufeis persists throughout much of the summer season and represents at least a 

third of the cumulative annual base flow (Yoshikawa et al. 2007); some spring-fed reaches stay ice-free 

during the winter and provide critical overwintering habitat for high concentrations of macroinvertebrates 

and Dolly Varden (Craig 1989). The most prolific springs in the program area are the Canning, Hulahula, 

Sadlerochit, Itkilyariak, and Katakturak Springs.

In general, usable groundwater is limited to distinct and unconnected shallow zones in the thaw bulbs of 

rivers and lakes, due to the presence of permafrost, which is continuous across the North Slope 

(Jorgenson et al. 2008). The frozen state of the soils, combined with their fine-grained characteristics and 

saturated conditions, form a confining layer that prevents percolation and recharge from surface water 

sources and prohibits the movement of groundwater. Because percolation and recharge are restricted, the 

formation of usable subsurface water resources is limited to unfrozen material on top of the permafrost or 

taliks (thawed zones) beneath relatively deep lakes, or zones in thawed sediments below major rivers and 

streams. In general, while these shallow groundwater zones do exist, they are typically very small and are 

likely to have similar water quality as the rivers and lakes nearby (BLM 2004, Section 3.2.2.1). Shallow 

supra-permafrost water also occurs seasonally in the active zone above the impervious permafrost; the 

thickness of the active layer is typically 1.5 feet but can range from 1 to 4 feet (Gryc 1985).

Nearshore Marine

There is a narrow continental shelf that extends offshore 31 to 62 miles into the Beaufort Sea. Surficial 

sediments of the shelf consist primarily of mud, with coarser material. The Beaufort shelf is most 

influenced by river input, but it is also affected by processes offshore in the deep basin, such as currents. 

During the open water season, surface currents are primarily wind driven close to shore. Ice covers the 

sea for up to 9 months, generally from September to July.

The nearshore environment in the SBS is a mix of open coast and lagoons bounded by barrier islands. In 

summer, water along the coast becomes brackish and water temperatures can rise due to flow from the 

Mackenzie River and other rivers along the eastern Arctic coastline into the oftentimes still ice-covered 

nearshore environment. (Craig 1984; Hale 1990; Dunton et al. 2006). The lagoons are relatively shallow, 
3. Affected Environment and Environmental Consequences (Water Resources)

3-54 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

the amplitude of the tides is very small (11.5 inches or less), and waters can vary in temperatures (28°F to 

57°F) and salinity (0 to >45) throughout the year.

Water Quantity

Water quantity in the program area has been calculated and documented by the USFWS (Lyons and 

Trawicki 1994). There are 119 lakes with an annual ice-free volume of 55,382 acre-feet, as summarized in 

Table H-6 in Appendix H. This volume is reduced to 3,366 acre-feet in April, when there is 

approximately 7 feet of ice. These values do not represent the total available quantity nor indicate suitable 

uses of the water, such as for ice road construction.

Water Rights

The Alaska Department of Natural Resources (ADNR) water rights records indicate there are two water 

right permits issued to North Slope Public Works for water supply and over 360 Instream Reservation 

completed and pending applications under the USFWS. While the Instream Reservations have not been 

issued as a water rights permit, those applications would have seniority over any new applications received 

by the ADNR. 

Water Quality

Most freshwater systems in the program area are pristine; however, fecal contamination above State of 

Alaska water quality standards may occur in areas with dense avian, caribou, and lemming populations. 

Cold water temperatures tend to prolong the viability of fecal coliform. Most freshwater bodies in the 

program area have low turbidity and dissolved oxygen near saturation. According to the ADEC, no 

freshwater in the program area has been documented as impaired by pollutants (ADEC 2017a).

Winter freeze and summer recharge cycles cause contrasting effects in water quality. During winter 

freezing, major ions of calcium, magnesium, sodium, potassium, chloride, sulfate, and nitrate and other 

impurities are excluded from downward-freezing ice and forced into the underlying sediment. Spring 

snowmelt and resulting water flowing across the surface of the ice removes the cover from lakes, allowing 

the wind to mix the water column throughout the summer. Recharge of lakes through sheet flow during 

spring counteracts the effects of water loss and ion concentration caused by evaporation in the summer. 

The net result of the input of snowmelt waters and spring sheet flow in deeper lakes is to refresh their 

existing water chemistry. Lakes in the program area generally have lower pH and alkalinity values that 

slowly increase in the winter; this reflects the ice exclusion process, which occurs during freeze-up 

(Trawicki et al. 1991). 

Climate Change

Climate variability would affect water resources by increasing the frequency and severity of extreme 

floods. Snowmelt would occur during a period of lower solar radiation, which could lead to a more 

protracted melt and less intense runoff. The magnitude and frequency of high flows would decline while 

low flows would increase, as changes in climate continue. These effects on water resources are described 

in more detail in the GMT2 Final SEIS (BLM 2018a, Section 3.2.4).

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 
3. Affected Environment and Environmental Consequences (Water Resources)

Coastal Plain Oil and Gas Leasing Program 3-55

Draft Environmental Impact Statement

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

water resources from on-the-ground post-lease activities

Hydrology and surface water quality are closely linked, and the discussion regarding potential impacts on 

water resources is combined in this section. Future development activities that can affect water resources 

include the following:

 Gravel mining

 Placement of gravel fill for infrastructure, such as roads, pads, and airstrips

 Installation of culverts and bridges

 Construction of pipelines and VSM footers

 Construction of ice roads and pads

 Extraction of water supply from local lakes for ice roads, construction, drilling, and operation

 Wastewater discharge

The following potential future impacts on surface water quality would be similar to those of the NPR-A, as 

described in BLM 2012, Section 4.5.4.2, and 2004, Section 4F.2.2.2:

 Shoreline disturbance and thermokarst (marshy hollows and small hummocks formed by thawing 

permafrost)

 Blockage or convergence of natural drainage

 Increased stages and velocities of floodwater

 Increased channel scour

 Increased bank erosion

 Increased sedimentation

 Increased potential for overbank flooding

 Changes in recharge potential from removal or compaction of surface soils and gravel

 Produced-water spills

 Petroleum hydrocarbon spills

 Demand for water supply

The effects of climate change described under Affected Environment above, could influence the rate or 

degree of the potential direct and indirect impacts.

Alternative A

Under Alternative A, no federal minerals in the program area would be offered for future oil and gas lease 

sales. Current management actions and resource trends would continue, as described in the Arctic Refuge 

CCP (USFWS 2015a). Changes to water resources would continue to occur along current trends. No 

direct or indirect impacts on water resources would result from post-lease oil and gas leasing activities 

under Alternative A.
3. Affected Environment and Environmental Consequences (Water Resources)

3-56 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Impacts Common to All Action Alternatives

Changes in Surface Water Flow

Changes to surface water flow would result from the various aspects of future development and include 

short-term, long-term, and permanent changes to water resources from exploration, construction, and 

production. The effects from these activities vary in intensity and involve alterations to stream stage (water 

level) and velocities, water quality and water volume, and surface runoff processes and drainage networks. 

Sand and gravel would be mined for future construction of pads, roads, and air strips (Appendix B). 

Removing gravel from areas near (or in) streams and lakes would change stream or lake configurations, 

stream hydraulics, lake shoreline flow patterns, erosion, sedimentation, and ice damming (National 

Research Council 2003). Gravel extraction would cause sedimentation, as discussed in BLM 2012, Section 

4.5.4.2, pp. 12 and 13. No specific gravel mining sites have been identified associated with the proposed 

leasing program; however, estimated volumes of the hypothetical development scenarios are summarized 

in Appendix B.

The water in a flooded gravel pit would likely remain unfrozen near the bottom, altering the thermal 

regime and creating a thaw bulb around and beneath the pit, potentially resulting in localized thermokarst. 

The steep side slopes of excavation pits would likely slough as they thaw, becoming more gradual over 

time and causing some slight infilling. USACE-approved reclamation plans would be required when the pit 

is decommissioned.

Future exploration and construction, such as the placement and construction of gravel pads, roads, air 

access facilities, culverts, and bridges, could affect natural drainage patterns (creation of new channels, 

inundation of dry areas, ground surface subsidence under some seismic trials, and starving wetlands of 

water on the downstream side of roads), stream stage (water level) and stream flow (volume), stream 

velocity (which influences erosion and sedimentation rates), groundwater flow, and lake levels. Potential 

disturbance of the vegetation or water and wind erosion could initiate thawing of the upper ice-rich zones 

and trigger the development of thaw-lakes.

Modification of the natural surface water drainage patterns could block or redirect flow. Disruption of 

streambeds and stream banks could remove protective shoreline vegetation and lead to channel erosion 

and sedimentation, formation of meltwater gullies, plunge pools from perched culverts, and formation of 

alluvial fans in streams and lakes (BLM 2012, Section 4.4.4.2. p. 377).

An example of future construction that could affect hydrology is the displacement of a lake or pond by fill 

or placing fill (such as an airstrip or road) transversely across grade, thereby blocking the natural drainage 

patterns when the snow melts. Placing fill transversely across grade or the predominant wind direction 

may also change snow accumulation patterns, which, in turn, may change drainage patterns when the snow 

melts. Impacts on drainage patterns would increase inundation or drying of affected areas. Increased 

inundation may in turn increase thermokarst action in the affected areas.

Placing gravel fill on tundra would change recharge potential, block natural drainage, and change the 

existing hydrologic regime; erosion of roads and pads could increase sedimentation onto the tundra or 

into waterways. During construction, sediments and dust would be disturbed and deposited on snow and 

ice during the winter or on tundra and open water during the summer. The sediments and dust would be 

introduced into the water column, increasing turbidity and sedimentation. A road or airstrip aligned 

perpendicular to stream channels and the direction of sheet flow would have a greater potential to 

impound sheet flow and shallow groundwater than a road or airstrip aligned parallel to existing drainage 
3. Affected Environment and Environmental Consequences (Water Resources)

Coastal Plain Oil and Gas Leasing Program 3-57

Draft Environmental Impact Statement

patterns. Details related to erosion and sedimentation during the construction phase are provided in BLM 

2004, Section F4.2.2.2. 

Future mining pads, airstrips, and roads would be designed to account for thermal criteria (minimum 

thickness to prevent permafrost degradation) and hydrologic criteria to minimize potential impacts on the 

surrounding area, as discussed in ROPs 23 and 24.

Where gravel fill is placed in wet areas to construct a future road, pad, or airstrip, the receiving waters 

would temporarily have higher suspended solids concentrations, greater turbidity, and contaminant 

concentrations (depending on the underlying geology). Fugitive dust that enters surface water bodies 

would also increase turbidity and sedimentation. Further information regarding turbidity during the 

construction phase is provided in BLM 2004, Section F4.2.2.2). 

Culverts would likely be used extensively under all action alternatives in the future for access road water 

crossings and to provide cross drainage. The design criteria for all culverts is such that they would avoid 

restricting fish passage or adversely affecting natural stream flow (ROP 24). Culverts would be installed at 

regularly spaced intervals to mitigate the risk of sheet flow interruption and thermokarst action. Final 

design of culverts depends of the spring ice breakup and snow melt characteristics for those drainages that 

could affect the road.

The potential impacts of increased stream velocities through culverts during floods are addressed in BLM 

2004, Section F4.2.2.1. Constricting flows would increase stream velocities and a higher potential for ice 

jams, scour, and stream bank erosion. Impeding flows would result in a higher potential for bank overflows 

and floodplain inundation. These potential impacts need to be minimized by incorporating design features 

to protect the structural integrity of the road- and pipeline-crossing structures to accommodate all but the 

low probability floods. Once installed, aboveground pipelines would have nearly no effect on stream and 

water flow characteristics.

The configuration of gravel fills also affects impacts; a linear road running perpendicular to the hydraulic 

gradient would result in a larger extent of hydrological impacts than a consolidated, square pad of similar 

acreage. The duration of potential impacts would be long term because the roads and pads would remain 

during operations.

Future pipeline construction in the program area would have effects on water resources related to ice 

road construction and associated water withdrawals from local lakes. Narrow drainages are typically 

crossed using elevated pipelines on suspension spans. Pipelines would be routed to avoid lakes. Once 

installed, aboveground pipelines would have nearly no impact on water flow characteristics but would 

affect water resources in the event of an oil spill.

Potential impacts on hydrology associated with construction of gravel pads, roads, and airstrip and ice 

roads would persist through the life of an individual project, including natural drainage patterns, stream 

stage and stream flow, stream velocity, groundwater flow, and lake levels, as described previously. The 

duration of impacts would be long term because the gravel infrastructures would remain during operation. 

Reclamation has not been proven for gravel removal in the arctic environment once operations have 

ceased. There is the potential to reclaim the gravel mines into water reservoirs suitable to support fish and 

wildlife habitats and potential water sources for further water use needs, if the gravel mines are near 

waterways (BLM 2004). 
3. Affected Environment and Environmental Consequences (Water Resources)

3-58 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Ice roads and ice pads would be used extensively in the future for seasonal vehicle access and would 

require removal, breaching, or slotting stream crossings if fish passage is a concern during spring break up

(ROP 13).

Water Withdrawals

Future water withdrawals to support components of the action alternatives would affect the water levels 

of lakes used as water sources and any connected water body, such as streams or wetlands. Only 

permitted lakes, rivers, or reservoirs (under ADNR Temporary Use Authorizations and, if required, 

ADFG Fish Habitat Permits) would serve as water sources. Typical consumptive water use would involve 

the following:

 Seasonal construction of ice roads and pads

 Drilling, hydraulic fracturing, and waterflooding

 Hydrostatic testing

 Dust abatement on roads, pads, and airstrips during summer

 Potable water

 Fire suppression and maintenance

Surface water withdrawals in the future for construction of ice roads, dust abatement, and operations 

would affect shallow groundwater levels, surface water levels, and drainage patterns during summer 

season. Lakes would be the principal supply for freshwater during construction. Ice roads and ice pads 

would be constructed to support construction under all action alternatives for access during the winter 

season. Although estimates of water use for oil and gas activities on the North Slope have been made in 

literature, the actual amount of water used would be project specific and would be based on BMPs, new 

technology, and the specific needs of the project, such as the width of ice roads, number of camps, number 

of crew, and ice pad size. Under all action alternatives, no potential long-term impacts on lakes and ponds 

are anticipated from ice roads, ice pads, or ice bridges, as discussed in BLM 2012, Section 4.5.4.2.

Future ice road construction over lakes that do not freeze to the bottom could affect dissolved oxygen 

concentrations. An ice road that crosses such an intermediate-depth lake could freeze the entire water 

column below the road, isolating portions of the lake basin and restricting circulation. With mixing thus 

reduced, isolated water pools with low oxygen would result. Details related to dissolved oxygen 

concentrations during ice road construction are provided in BLM 2004.

Changes to Surface Water Quality

Changes to water quality could occur during the exploration, construction, and operation phases of a 

future oil and gas development project. Increased turbidity of water bodies would result from dust fallout, 

flooding, erosion, or bank failure. After construction is complete, gravel from roads, pads, and airstrips 

would be the main dust source; dust fallout from vehicle traffic could increase turbidity in ponds, lakes, 

creeks, streams and rivers, and wetlands that are next to roads and construction areas.

A potential direct impact from winter road and pipeline construction would be disturbance of tundra soils 

and vegetation (see Section 3.2.8 and Section 3.3.1). Disturbed and exposed soils are more susceptible 

to erosion and subsequent sedimentation during spring breakup of ice than undisturbed areas. Fugitive dust 

from construction could also be deposited on snow and ice during the winter. When melting occurs, this 

dust can then enter surface water bodies, increasing turbidity and contaminant concentrations, depending 

on the underlying geology.
3. Affected Environment and Environmental Consequences (Water Resources)

Coastal Plain Oil and Gas Leasing Program 3-59

Draft Environmental Impact Statement

Freshwater would be withdrawn from lakes in the program area in the future for several primary uses: 

construction of ice roads and pads, pipeline maintenance, production drilling, and potable water at camps. 

Water would also be used for dust control on roads. This water would be recharged in the spring when 

snow and ice melt increase flow volumes in connected water bodies, assuming that withdrawal rates would 

not exceed recharge rates, based on BMPs, permitting, and permitting requirements.

There is a potential for wastewater discharge from future oil and gas activities, such as sanitary/domestic, 

secondary containment, gravel mine dewatering, and hydrostatic test water, and could increase pollutant 

loads to waterbodies. These discharges would occur under the appropriate Alaska Pollutant Discharge 

Elimination System (APDES) authorization; however, it is more likely that wastewater would be placed in 

underground injection control wells. A thorough discussion of the water quality effects resulting from 

development can be found in BLM 2004, Section 4F.2.2.2.

It is likely that only treated (secondary treatment) domestic wastewater would be discharged to water 

bodies/wetlands with authorization from the applicable APDES permits; it is not anticipated that there 

would be an increase in fecal coliform counts over the naturally occurring concentrations outside of 

authorized mixing zones.

Drinking water resources are unlikely to be affected because they would have to meet State of Alaska 

Water Quality Standards for drinking water. Permitting, permit authorizations, and BMPs of any oil and gas 

activities around the drinking water resources would mitigate any potential impacts on the resources.

Oil spills could occur in the future from pipelines, storage tanks, production facilities and infrastructure, 

drill rigs, and vehicles during the drilling and operation phases. Spills occurring from pipelines or oil leaving 

pads and roadbeds could enter water sources, reaching tundra ponds, lakes, creeks, or rivers. Spills can 

occur at any time during the year. The potential impacts associated with oil spills are described in Section 

3.2.11, Solid and Hazardous Waste.

Changes to Groundwater

During future gravel mining, it is probable that shallow taliks and supra-permafrost water zones would be 

temporarily eliminated in the immediate vicinity of a gravel mine. The effect of this loss on water resources 

is localized if the talik network is discontinuous. Supra-permafrost water zones may be reestablished over 

time if the ground does not refreeze after the mine is decommissioned. The subsurface water-bearing 

zone would be permanently eliminated in the immediate footprint of the mine and would be replaced by 

surface water that is connected to the shallow groundwater.

Changes to Marine Waters

There is a potential for impact on marine water from barge docking sites, primarily in the event of an oil 

spill. The extent of such contamination would be related to the size, nature, and timing of the spill. If a spill 

were to happen during the open-water or broken-ice seasons, hydrocarbons dispersed in the shallow 

estuarine water column could exceed acute-toxic criteria during the initial spill period but would be short 

term and localized. Impacts on marine waters are more thoroughly described in BLM (2018).

Discharges of various pollutant concentrations in the future from an STP would be required to meet 

standards in the treatment plant’s APDES discharge permit and potential mixing zone requirements.
3. Affected Environment and Environmental Consequences (Water Resources)

3-60 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Alternative B

Alternative B includes approximately 1,563,500 million acres available for lease sale. Lease Stipulation 1 

provides setbacks (0.5 mile to 1 mile) and prohibits permanent oil and gas facilities and supporting 

infrastructure in the streambeds of the Canning, Hulahula, Aichilak, Okpilak, Jago, Sadlerochit, Tamayariak, 

and Okerokovik Rivers.

These actions are designed to minimize the disruption of natural flow patterns and changes to water 

quality for these specific waterbodies. Additionally, ROPs 3, 4, 9, 10, 12, 13, 17, 20, 24, and 26 would 

minimize potential impacts on water resources under Alternative B.

Alternative C

Alternative C includes 1,563,500 million acres available for lease sale. The lease stipulations and ROPs 

would be the same as those discussed under Alternative B, except for the inclusion of additional 

protections from Lease Stipulation 9. Under Alternative C, this lease stipulation does not allow 

exploratory well drill pads, production well drill pads, and central processing facilities in coastal waters, 

lagoons, or barrier islands in the boundaries of the program area or 1 mile inland from the coast.

Alternative D

Alternative D includes 1,037,200 million acres available for lease sale and provides the most protections 

for water resources. Lease Stipulation 1 increases the setback distances on rivers from Alternative B and 

adds additional rivers to the list for setbacks. There are also seasonal operational restrictions on coastal 

water bodies or islands between May 15 and November 1, or when sea ice is on the coast of each season. 

Lease Stipulation 2 reduces impacts on water quality by prohibiting permanent oil and gas facilities and 

infrastructure within 0.5 mile of the ordinary high-water mark of any water body in Townships 8 and 9 

north of the Canning and Tamyariak watersheds. Lease Stipulation 3 protects water quality associated with 

these specific features and identifies areas that would not be offered for lease sale or would have NSO 

stipulations.

Cumulative Impacts

The geographic area relevant for assessing cumulative impacts for water resources is the program area. 

No other past, present, and reasonably foreseeable future actions that could affect water resources have 

occurred or would occur in the program area. Alternative A would have no cumulative impacts on water 

resources from post-leasing oil and gas activities.

3.2.11 Solid and Hazardous Waste

Affected Environment

The Coastal Plain has had limited human or industrial activity that could result in solid or hazardous wastes 

being introduced into the environment. Kaktovik is the only community in the Coastal Plain; however, it is 

excluded from the program area boundary under PL 115-97. Solid, human, and hazardous wastes identified 

in the Coastal Plain are related to industrial activities or community development typically along the coast. 

Industrial activity consists of past Department of Defense (DOD) Distant Early Warning (DEW) line 

facilities and Long-Range Radar Sites (LRRS) at Brownlow Point, Collinson Point, Barter Island, Griffin 

Point, and Nuvagapak Point. Construction of these facilities began as early as 1947, with the main 

installations built in 1952 and 1953. Brownlow Point was abandoned in 1958, Collinson Point and 

Nuvagapak Point were active between 1953 and 1962. Griffin Point was active between 1953 and 1957, 

and Barter Island White Alice Communications System was deactivated in 1979 and replaced with a 

minimally attended radar in the mid-1980s. 
3. Affected Environment and Environmental Consequences (Solid and Hazardous Waste)

Coastal Plain Oil and Gas Leasing Program 3-61

Draft Environmental Impact Statement

Most of the DOD’s cleanup and building demolition occurred in 1994, 2000, and 2006. Community 

development is associated with public facilities in Kaktovik. Most facilities and sites are on the coast at 

Brownlow Point, Collinson Point, Barter Island, Griffin Point, and Nuvagapak Point. See Section 3.4.1, 

Landownership and Use, for a further discussion of Kaktovik facilities and DOD facilities and activities. 

Appendix I identifies the facilities near the program area that are required to be registered with the EPA 

or ADEC for discharges associated with the Clean Air Act or the Clean Water Act; identifies ADEC 

authorized solid waste facilities closest to the program area; identifies ADEC documented contaminated 

sites, all of which are shown on Map 3-9, Hazardous Waste Sites, in Appendix A; and lists of spills near 

Kaktovik, Alaska.

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. Such post-lease activities could include seismic and drilling 

exploration, development, and transportation of oil and gas in and from the Coastal Plain. Therefore, the 

analysis is of potential direct and indirect impacts on solid and hazardous materials from on-the-ground 

post-lease activities

Potential impacts from the future development and operation of facilities identified in the hypothetical 

development scenarios (Appendix B) include the generation of solid waste, wastewater, produced fluids, 

drilling muds, and spills of oil, salt water, and hazardous substances. Analysis of these impacts is tiered from 

information contained in the GMT2 Final SEIS (BLM 2018a), and the NPR-A IAP/EIS (BLM 2012); the 

updated information from the spills database were used to supplement the analysis below. 

Spills can originate from pipelines, storage tanks, production facilities and infrastructure, drilling rigs, and 

heavy equipment or vehicles. Impacts from spills vary, based on material type, size, and season. For this 

analysis, the materials that could be spilled associated with post-lease activities are categorized and 

described as follows:

 Produced fluids are composed of crude oil, natural gas, and brine and formation sand.

 Crude oil is oil separated from the brine, natural gas, formation sand, and other impurities and 

would be transported in the proposed pipeline.

 Refined oil is Arctic diesel, Jet-A 50, unleaded gasoline, hydraulic fluid, transmission oil, lubricating 

oil and grease, waste oil, mineral oil, and other products.

 Salt water is treated water from the STP. 

 Other hazardous materials are methanol, propylene and ethylene glycol (antifreeze), water soluble 

chemicals, corrosion inhibitor, scale inhibitor, drag reducing agent, and biocides.

Spill impact quantities are categorized and described as follows (taken from BLM 2004, Section 4.3.2.3):

 Very small spills, less than 10 gallons

 Small spills, 10 to 99.5 gallons

 Medium spills, 100 to 999.5 gallons

 Large spills, 1,000 to 100,000 gallons
3. Affected Environment and Environmental Consequences (Solid and Hazardous Waste)

3-62 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

 Very large spills, greater than 100,000 gallons

Based on the GMT2 Final SEIS (BLM 2018a), more than half of the North Slope spills were less than 10 

gallons and approximately 98 percent of the total volume released resulted from spills larger than 99 

gallons (BLM 2014, Section 4.5.2). The probability of a spill over 100,000 gallons is low (BLM 2004, Section 

4.3.1)—only three documented spills have been greater than 100,000 gallons (BLM 2014, Section 4.5.2). 

Upon detection, spills have been contained and cleaned up, as required by federal, state, and NSB 

regulations (NRC 2003). 

Spills as a result of the development and operation of facilities identified in the hypothetical development 

scenarios (Appendix B) would occur on or close to oilfield infrastructure (BLM 2004, Section 4.3.2.3). 

Most Alaskan North Slope industry spills have been contained on gravel pads and roadbeds (BLM 2012, 

Section 4.2.2), and most of the spills that reach the tundra have affected fewer than 5 acres (BLM and MMS 

1998). Natural or anthropogenic-assisted restoration from these spills has generally occurred within a few 

months to years (NRC 2003).

The season in which a spill occurs can dramatically influence its behavior, impacts, and the cleanup 

response actions (BLM 2004, Section 4.3.2.3). The active soil layer in the program area ranges from less 

than 1 foot to 5 feet and is on average 2 feet thick; it consists of poorly drained, unconsolidated sediments, 

transected by fluvial deposits of rivers and streams. Dispersal of spilled materials would likely occur at or 

near the ground surface, as permafrost would likely inhibit infiltration of oil, salt water, or hazardous 

substances. Permafrost is at least 1,000 feet thick, except in isolated areas of natural thaw near deep lakes, 

springs, or rivers and areas of thaw exacerbated by climate change and anthropogenic earth-disturbing 

activities. Table 3-14 describes potential spill behavior during the four seasons and has been taken from 

the Alpine Satellite Development Plan EIS (BLM 2004).

The rate of potential oil, salt water, and hazardous substance spills from the hypothetical development 

scenario (Appendix B) is likely to be lower than the history of the past 30 years of oil exploration, 

development, production, and transportation on the North Slope. The combination of more stringent 

agency regulations, continually improving industry operating practices, and advancements in best available 

control technology reduce the probability and size of future spills (BLM 2004, Section 4.3.1).

Alternative A

Under Alternative A, current management actions would be maintained, as described in the Arctic Refuge 

CCP (USFWS 2015a). There would be no generation of solid waste, wastewater, or spills of oil, salt water, 

or hazardous substances in the Coastal Plain associated with future post-leasing oil and gas activities under 

Alternative A.

Impacts Common to All Action Alternatives

The hypothetical development scenario (Appendix B) identifies development activities in the program 

area and the potential timing of these activities that would require the management of solid waste, 

wastewater, and hazardous waste. 
3. Affected Environment and Environmental Consequences (Solid and Hazardous Waste)

Coastal Plain Oil and Gas Leasing Program 3-63

Draft Environmental Impact Statement

Table 3-14

Spill Characteristics by Seasons

Season Conditions Description

Summer 

(ice-free)

Most rivers and creeks are ice-free or 

flowing; ponds and lakes are open water; 

tundra is snow-free; and biological use of 

tundra and water bodies is high.

Currents, winds, and passive spreading forces 

would disperse spills that reach the water 

bodies. Spills to tundra would directly affect the 

vegetation, although the dispersal of the spilled 

material is likely to be impeded by the 

vegetation. Spills to wet tundra may float on the 

water or be dispersed over a larger area than 

would spills to dry tundra or to snow-covered 

tundra. Spills under pressure that spray into the 

air may be distributed downwind over 

substantial areas and affect the tundra vegetation 

and water bodies.

Fall 

(freeze-up)

Waterbodies are beginning to ice over, but 

the ice cover might vary, depending on 

temperature, wind, currents, and river flow 

velocities. Snow begins to cover tundra, and 

most of the migratory birds are leaving the 

North Slope.

Spilled material could be dispersed when it 

reaches flowing water but slowed or stopped 

when it reaches snow or surface ice. The spilled 

material could be contained by the snow or ice 

but dispersed if the ice breaks up and moves 

before it refreezes. The spilled material also 

could flow into ice cracks to the underlying 

water, where it could collect.

Winter 

(ice cover)

Waterbodies are covered by mostly 

unbroken ice, and snow covers the tundra. 

Dispersal of material spilled to the tundra 

generally would be slowed though not 

necessarily stopped by the snow cover. 

Depending on the depth of snow cover as well 

as temperature and volume of spilled material, it 

may reach the underlying dormant vegetation or 

tundra ponds and lakes. Similarly, spills to rivers 

and creeks generally would be restricted in 

distribution by the snow and ice covering the 

waterbody, compared to seasons when there is 

no snow or ice cover. Spills under the ice to 

creeks, rivers, and tundra ponds and lakes might 

disperse slowly, as the currents are generally 

slow to nonexistent in the winter. 

Spring 

(breakup)

Thawing begins in the higher foothills of the

Brooks Range and river flows increase 

substantially and quickly, often to flood 

stages. This is a short period of the year. 

These increased flows cause river ice cover 

to break up and flow downriver. River 

floodwaters usually flow over sea ice, which 

hastens the breakup of the sea ice. Snow 

cover begins to melt off the tundra and many 

migratory species, especially birds, return to 

the tundra.

Spills to waterbodies during breakup are likely 

to be widely dispersed and difficult to contain or 

clean up. Spills to the tundra might be widely 

dispersed if the flooding overtops the river and 

creek banks and entrains the spilled material.

All action alternatives would generate solid waste, consisting of food wastes, sewage sludge, and other 

nonhazardous burnable and unburnable wastes from future oil and gas exploration, development, and 

production. Solid wastes would be separated and stored in large trash receptacles or approved containers, 

as part of the CPF, until they are incinerated or transported to an approved landfill outside the Coastal 
3. Affected Environment and Environmental Consequences (Solid and Hazardous Waste)

3-64 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Plain, such as the landfill near Prudhoe Bay. Wastes that cannot be incinerated would be transported to 

approved offsite landfills. Burning waste would temporarily affect air quality.

Use of injection wells (Class I or Class 2) in the future would be used to dispose of wastewater, produced 

water, spent fluids, and chemicals, as approved by the EPA, the AOGCC, or ADEC. Injection wells would 

be used to dispose of wastewater generated from the estimated field use of 2 million gallons per day. As a 

result, injection of wastewater reduces potential impacts on surface waters or the land by injecting 

wastewater deep underground into zones isolated from drinking water sources. 

The potential occurrence of spills does not depend on any alternative chosen, as spills are not a planned 

activity and are unpredictable in cause, location, size, time, duration, and material type (Mach et al. 2000).

Table 3-15, taken from the Alpine Satellite Development Plan EIS, describes the relative rate of 

occurrence for spills from main sources.

Table 3-15

Relative Rate of Occurrence for Spills from Main Sources

Source Pipeline

Spill Size

Very Small 

(<10 

Gallons)

Small

(10–99.5 

Gallons)

Medium

(100–999.5 

Gallons)

Large

(1,000–

100,000 

gallons)

Very Large 

(>100,000 

Gallons)

Produced fluids H H M L VL

Salt water H H M L VL

Diesel H M L VL 0

Sales oil M M M L VL

Bulk storage tanks and 

containers of pads

L L L VL 0

Tank vehicles H M L VL 0

Vehicle and equipment 

operation and maintenance

VH VH M VL 0

Other routine operations VH VH H L VL

Drilling blowout VL VL VL VL VL

Production uncontrolled 

release

VL VL VL VL VL

Notes: 

VL = Very low rate of occurrence

VH = Very high rate of occurrence

L = Low rate of occurrence

M = Medium rate of occurrence

H = High rate of occurrence

0 = Would not occur

Alternative B

Potential impacts on solid and hazardous waste from post-leasing oil and gas activities under Alternative B 

would be the same as identified above for all action alternatives. 

Alternative C

Impacts on solid and hazardous waste from post-leasing oil and gas activities under Alternative C would be 

the same as identified above for all action alternatives. 

Alternative D

Impacts on solid and hazardous waste from post-leasing oil and gas activities under Alternative D would be 

the same as identified above for all action alternatives. 
3. Affected Environment and Environmental Consequences (Solid and Hazardous Waste)

Coastal Plain Oil and Gas Leasing Program 3-65

Draft Environmental Impact Statement

Cumulative Impacts

Cumulative impacts include the existing 34 spills of approximately 16,313 gallons of oils, salt water, or 

hazardous substances and potential spills from the hypothetical development scenario. Over half of 

documented spills associated with oil and gas operations are less than 10 gallons, and detected spills are 

promptly contained and cleaned up to federal, state, and borough regulations. Alternative A would have no 

cumulative impacts on solid and hazardous waste from post-leasing oil and gas activities.

3.3 BIOLOGICAL RESOURCES

3.3.1 Vegetation and Wetlands

Affected Environment

The program area encompasses much of the broad, treeless ARCP, including portions of the northern 

foothills of the Brooks Range and the Beaufort Sea coast, between the Canning and Staines Rivers to the 

west and the Aichilik River to the east (Map 1-1 in Appendix A). This area includes portions of two 

broad ecoregions, the Beaufort coastal plain and the Brooks foothills (Nowacki et al. 2003; Jorgenson and 

Grunblatt 2013). The Beaufort coastal plain generally is characterized by flat and very gently sloping tundra 

and the Brooks foothills by increasingly undulating terrain inland toward the Brooks Range. Within these 

two ecoregions are four subregions or eco-subsections: coastal lagoons, lowland peatlands (wet tundra), 

well-drained colluvium (upland moist tundra), and broad floodplains (shrub thickets) (Jorgenson and 

Grunblatt 2013; USFWS 2015a). 

Vegetation

The vegetation mapping chosen to quantify the coverage of each vegetation type in the program area 

(Map 3-10, Vegetation, in Appendix A) was prepared by the Alaska Center for Conservation Science 

(ACCS) (ACCS 2016; Boggs et al. 2016); the development of vegetation mapping is discussed further in 

Appendix J. Table J-1 in Appendix J provides estimates of the area covered by each vegetation class, 

based on the ACCS (2016) land cover mapping reproduced for the program area (see Map 3-10 in

Appendix A). 

The vegetation type descriptions below were developed using data sources that provide information at the 

plant community level for the specific vegetation types in the program area (Viereck et al. 1992; USFWS 

2015a). 

Dwarf Shrub

Dwarf shrub and dwarf shrub-lichen, combined, encompass less than 1 percent of the program area 

(Table J-1 in Appendix J). Dwarf prostrate shrub communities (heights of less than 8 inches) have a dry 

to moist moisture regime. Dry sites are characterized by lichens or bare ground, or both, throughout the 

understory, whereas moist sites tend to support grasses, sedges, and mosses throughout the understory. 

Dry dwarf shrub typically occupies raised and well-drained topographic features on the Coastal Plain, such 

as steep riverine banks and alluvial fans where little snow accumulates during winter. Moist sites generally 

have less topographic relief and a deeper snowpack that protects the vegetation from abrasion and 

desiccation by winter winds (USFWS 2015a). See Appendix J for individual species that characterize this 

vegetation type.

Low and Tall Shrub

Tall shrub (open-closed) communities are most often associated with riparian zones along rivers and 

streams and account for less than 1 percent of the program area (Table J-1 in Appendix J). Shrub 

heights in tall shrub communities are variable, ranging from low shrubs of 8 to 60 inches and tall shrubs 
3. Affected Environment and Environmental Consequences (Vegetation and Wetlands)

3-66 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

from 60 to 118 inches. Shrub density also varies, depending on the frequency of overbank flooding and 

drainage of the substrate. The low and tall shrubs are primarily deciduous, dominated by willows (Salix

spp.). 

Low shrub communities 8 to 60 inches tall also occur in riparian zones and in the larger expanses of 

tussock-shrub tundra in upland areas. This community accounts for 15 percent of the program area 

(Table J-1 in Appendix J). See Appendix J for individual species that characterize this vegetation type.

Moist Herbaceous Meadow

Moist herbaceous meadow types are dominated by graminoids13 and forbs,14 often growing alongside 

dwarf shrubs. Moist herbaceous meadow comprises the most common group of vegetation types in the 

program area. These types grow on reasonably well-drained but low-lying Coastal Plain substrates in flat 

or gently sloping terrain and undulating terrain in the northern Brooks Range foothills. Surface indicators 

of permafrost (ice wedges in particular) in the form of polygonized patterned ground are often present in 

flat or gently sloping areas. In such areas, raised centers of high-centered polygons or raised ridges of lowcentered polygons support moist tundra habitats, while the low troughs or polygon basins support wet 

herbaceous types (see Wet Herbaceous Meadow below) (USFWS 2015a).

Moist herbaceous meadow types include herbaceous (mesic) and tussock tundra (low shrub or 

herbaceous); combined, these types account for 59 percent of the program area (Table J-1 in Appendix 

J). See Appendix J for individual species that characterize this vegetation type.

Wet Herbaceous Meadow

Wet herbaceous vegetation types include freshwater and brackish water aquatic (marsh) vegetation, and 

saturated and seasonally flooded freshwater wetlands. The herbaceous (wet-marsh) tidal and herbaceous 

(marsh) types combined account for less than 2 percent of the program area (Table J-1 in Appendix J). 

The herbaceous (wet) vegetation type accounts for 17 percent of the program area (Table J-1 in

Appendix J). It is primarily found in low-lying drained lake basins, intermingled with moist tundra where 

the surface is patterned with low-centered polygons; this type has a limited occurrence on headwater 

stream floodplains (USFWS 2015a). See Appendix J for individual species that characterize this vegetation 

type.

Barrens

The barren type covers approximately 1 percent of the program area (Table J-1 in Appendix J). 

Vascular plants are scattered or absent, and bare soil is the dominant feature. This land cover type is most 

commonly found on exposed riverine surfaces or intertidal beaches; it occurs on a limited basis at higher 

elevations in the Brooks Range foothills.

Waters

The freshwater or saltwater type comprises 9 percent of the program area, primarily consisting of 

nearshore water in the coastal lagoons between the mainland and the barrier islands (Table J-1 in 

Appendix J). Freshwater lakes and ponds comprise a smaller proportion of this type, mostly 

concentrated in the river deltas and in abandoned floodplains, where flooded oxbow lakes are common. 

 

13Grass-like plants, including sedges, rushes, and grasses

14Herbaceous, broad-leaved, vascular plants
3. Affected Environment and Environmental Consequences (Vegetation and Wetlands)

Coastal Plain Oil and Gas Leasing Program 3-67

Draft Environmental Impact Statement

Rare Plants

There are no federally listed, threatened, or endangered plant species known to occur in the program area 

(USFWS and NMFS 2014). The ACCS maintains a listing of ranked, rare vascular plant species in Alaska, 

provides updates to a rare plant field guide, and manages a database of rare plant occurrences (ACCS 

2018a; 2018b). To obtain a preliminary listing of rare plants, the BLM searched the ACCS rare plant 

occurrence database for all known records in the program area; this search resulted in 14 vascular plant 

species with Alaska state rankings, 5 of which are BLM watchlist species and 4 that are BLM sensitive 

species (Table J-2 in Appendix J).

The BLM monitors a list of 31 vascular plant species that are considered rare on the North Slope, 

including on the ARCP (Cortés-Burns et al. 2009). Based on the presence of appropriate habitats, there 

are 19 additional taxa on the BLM list not already documented as occurring in the program area in Table 

J-2 in Appendix J that could occur in the program area.

Nonnative and Invasive Plants

The spread of nonnative plants is limited on the North Slope of Alaska due to the short growing season, 

low summer temperatures, and the relative rarity of disturbed areas (Carlson et al. 2015). Historically, the 

region has been thought of as a low-risk area for invasive plant infestations. Disturbance vectors for 

transporting propagules15 to remote locations on the North Slope are still limited but are expected to 

increase with industrial development in remote areas, such as the program area. Vector pathways for 

invasive plants are closely tied to human disturbance, primarily at regional airport hubs, along road and 

highway corridors, and in areas with foot traffic (Carlson et al. 2015; ACCS 2018c). With a warming 

climate and an increase in commercial activity on the North Slope, damage caused by invasive plants is 

expected to increase in the coming decades (Carlson and Shephard 2007; Carlson et al. 2015).

A review of Alaska’s statewide invasive plant database, the Alaska Exotic Plants Information Clearinghouse 

(ACCS 2018c), revealed no documented occurrences of nonnative plant species in the program area. The 

search area was then expanded to the broader ARCP and Brooks Range foothills, where infestations were 

documented along the Dalton Highway and at Umiat (ACCS 2018c); documented nonnative species in the 

broader search area were Canada thistle (Cirsium arvense), narrowleaf hawksbeard (Crepis tectorum), herb 

Sophia (Descurainia sophia), white sweetclover (Melilotus albus), common dandelion (Taraxacum officinale), 

and foxtail barley (Hordeum jubatum). These infestations were associated primarily with disturbances, such 

as fill importation, or extraction associated with the construction of gravel roads and pads. 

According to the ecological risk analysis conducted by Carlson et al. (2015), none of the documented 

species listed above are regarded as a significant ecological threat. The species with the greatest ecological 

risk is thought to be Hordeum jubatum, which may be an Alaska native plant. It has been spreading rapidly 

through the state over recent decades in straw and agricultural seed (Carlson et al. 2015). Hordeum 

jubatum is a salt-tolerant species with extreme cold tolerance and is capable of invading a range of Coastal 

Plain ecosystems, including coastal-influenced plant communities. It thus has some potential to spread along 

with development in the program area.

Wetlands

The BLM used coarse-scale National Wetland Inventory (NWI) mapping for the North Slope of Alaska 

(USFWS 2018) to assess the extent of wetlands and wetland types in the program area. Most of the 

landscape in the program area is considered to be jurisdictional wetland (USFWS 2018), and NWI data 

 

15Any structure that can propagate a new plant, such as a shoot, root mass, or seed.
3. Affected Environment and Environmental Consequences (Vegetation and Wetlands)

3-68 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

indicate that at least 96 percent of the program area is classified as wetlands or waters of the US; the 4 

percent of the program area that is unmapped is also likely to consist of wetlands or waters (Table 3-16;

Map 3-11, Wetlands, in Appendix A). Upland areas that do not meet the three-parameter criteria to be 

classified as a wetland (Environmental Laboratory 1987; USACE 2007) likely are present, but detailed field 

observations and fine-scale mapping would be required to assess the extent of uplands in the program 

area. 

Table 3-16

Wetland Types Mapped in the Arctic Refuge Program Area by the National Wetland 

Inventory Program 

Wetland Class Area (Acres) Percent of Program 

Area

Estuarine and Marine Deepwater 71,300 5

Estuarine and Marine Wetland 9,700 1

Freshwater Emergent Wetland 1,258,300 83

Freshwater Forested/Shrub Wetland 98,000 6

Freshwater Pond 5,700 <1

Lake 12,300 1

Riverine 53,500 4

Unmapped 54,700 4

Total area 1,508,800 100

Source: USFWS 2018

Uplands are typically rare on the North Slope and limited to well-drained ridge crests and other exposed 

areas that are typically blown free of snow in the winter; these areas accumulate little moisture throughout 

the year (see the descriptions of dry dwarf shrub and bare ground types above).

Elsewhere, the combination of continuous permafrost, which impedes drainage, riverine flooding, tidal 

influences, and the flat and gently sloping or undulating landscape account for most of the 

hydrogeomorphic features driving wetland development in the program area. Isolated and possibly nonjurisdictional wetlands may be present in specific geomorphic locations; however, because of the broad 

extent of interconnected wetlands with subsurface hydrologic connectivity, the likelihood of isolated 

wetlands occurring is very small. As noted above, regarding quantifying uplands, a detailed field survey and 

fine-scale wetland map would be required in any area proposed for an oil or gas development project. It is 

at that stage at which the presence of any small occurrences of non-jurisdictional wetlands can be assessed.

In the NWI mapping, 83 percent of the acreage in the program area is classified as freshwater emergent 

wetland (Table 3-16); this includes the freshwater herbaceous marsh and herbaceous wet meadow types 

described in the Vegetation section above. Marine waters wetland types account for 5 percent of the 

program area and occur in the lagoons between the mainland and the barrier islands. Freshwater lakes and 

ponds comprise less than 2 percent of the program area, riverine wetlands cover another 4 percent, and 

other freshwater wetlands account for 6 percent.

The program area is largely undisturbed, and wetland structure and function are intact. Climate change 

poses the most significant threat to the stability of wetlands in the program area (BLM 2018a; USFWS 

2015a). As described below in the Climate Change section, climate change is generating a drying trend on 

the North Slope for lake, pond, and wetland habitats, and this is predicted to continue in the program 

area. 
3. Affected Environment and Environmental Consequences (Vegetation and Wetlands)

Coastal Plain Oil and Gas Leasing Program 3-69

Draft Environmental Impact Statement

Wetland Functions and Values

Most of the land cover types in the program area are likely to be jurisdictional wetlands subject to 

permitting under Section 404 of the Clean Water Act or Section 10 of the Rivers and Harbors Act. 

Because wetlands are ubiquitous in the program area, any development project proponent would find it 

difficult to avoid the loss of wetlands from fill. In such cases, under the mitigation rule of 2008 (33 CFR 

320(r)(1)), compensatory mitigation is required for the loss of wetland functions. To quantify the extent of 

mitigation required, wetland functions may be evaluated, and a value is assigned to each function so that 

project designers can avoid the most important wetlands and determine a compensation ratio if an in-lieu 

fee is required.

Wetland functions are the chemical, physical, and biological processes that occur in the ecosystem. 

Wetland values or ecosystem services are the benefits that a wetland provides to human communities and 

ecosystems. 

Statewide, Alaska has very few formally developed and regionally specific methods to systematically 

quantify wetland functions. Recently, however, the USACE developed a wetland conditional assessment 

method for the North Slope (Berkowitz et al. 2017). This method may rely on field data or be conducted 

remotely using off-site data. It assesses three functional groups: habitat, hydrology, and biogeochemical 

cycling along a gradient of anthropogenic disturbance. It standardizes the calculation of mitigation 

compensation metrics. The method is most suitable in areas where development has already occurred and 

may be useful only in the development phase; however, this is the first method to use a North Slopespecific land cover classification and assess regionally specific wetland conditions.

Previous wetland functional assessment methods evaluated a variety of the most commonly assessed 

functions for North Slope wetlands, including flood flow regulation, sediment nutrient and toxicant 

removal, erosion control and shoreline stabilization, organic matter production and export, threatened 

and endangered species support, avian and mammal habitat suitability, fish habitat suitability, educationalscientific-recreational-subsistence use, and soil thermal regime maintenance. In general, the functions that 

show the greatest variability among wetland types are the habitat functions supporting wildlife and fish 

species. This is because the measurable indicators of wetland function—the numbers of species and 

numbers of individual animals that use specific wetland or habitat types—can be wide ranging.

Relative to wetlands in temperate regions, North Slope wetlands tend to have low function for most of the 

hydrologic, biogeochemical, or social functions. This is because of the short, cold growing season, harsh 

winter conditions, remote location, low human population numbers, and the ubiquitous impermeable 

permafrost layer preventing groundwater flow. The most important functions tend to be related to wildlife 

habitat value and endangered species support. The most common wetland type (Freshwater Emergent 

Wetland, 83 percent of the program area) is comprised of multiple fine-scale wetland types, ranging from 

drier, well-drained saturated wetlands to permanently flooded marshlands. The wetter wetland types in 

this broad class are equivalent to the Herbaceous (Wet), Herbaceous (Marsh), and Herbaceous (WetMarsh) (Tidal) vegetation classes (Table J-1 in Appendix J). These provide nesting, brood-rearing, and 

migration staging habitat for a variety of avian species, and spawning and rearing habitat for fish where 

those types are next to fish-bearing waters.

Climate Change

Climate change is expected to alter vegetation and wetlands on the North Slope in the direction of more 

well-drained and drier habitat types characterized by a greater dominance of shrubs, and dwarf trees in 
3. Affected Environment and Environmental Consequences (Vegetation and Wetlands)

3-70 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

protected areas. In the reasonably foreseeable future, alterations to vegetation and wetlands from climate 

change would also occur as the activities described above contribute to cumulative impacts. Despite 

projections for increased precipitation, the longer growing season and increased temperatures due to 

climate change are predicted to result in greater evapotranspiration rates, which in turn are expected to 

produce landscape-scale drying; by mid-century, the landscape may be 10–12 percent drier on the Coastal 

Plain (USFWS 2015a). This drying would alter vegetation and shallow-water systems, such as palustrine 

wetlands, ponds, and lakes directly, and these wetlands and waterbodies are likely to be reduced in 

number and extent. These transitions may result in substantial changes in wildlife species assemblages, 

depending on the extent of habitat change (see Section 3.3.3, Birds, and Section 3.3.4). Coastal erosion 

would result in the continued loss of coastal vegetation and wetlands, and gradual reductions in the extent 

of the barrier island-lagoon system on the North Slope are also likely.

The longer growing season and increased summer temperatures are expected to promote the expansion 

of shrub vegetation in the program area, as has been found elsewhere on the North Slope (Tape et al. 

2006) and throughout Alaska. Warming and a longer growing season is also expected to promote the 

northward expansion of the ranges of some plant species more typically associated with the boreal forest, 

such as balsam poplar (Populus balsamifera) (USFWS 2015a).

Additionally, increasing soil temperatures could release stored carbon to the atmosphere, thus 

exacerbating warming (Sturm et al. 2001a) and further promoting the direct and indirect changes to 

vegetation and wetlands described above. The combined effects of the drying of wetlands and waterbodies 

and an increase in shrub plant cover would reduce the extent of sedge-dominated wetlands and lacustrine 

waterbodies that are used for nesting and brood-rearing by many waterbird and shorebird species.

Coastal erosion and the direct loss of coastal vegetation and wetlands on the North Slope also has 

increased due to climate change. Increasing ocean temperatures, sea level rise, and an increase in winddriven storm surges has resulted in a substantial increase in coastal erosion rates (Jorgenson and Brown 

2005). It is expected that increasing water temperatures, reduced sea ice, sea level rise, permafrost 

degradation, increased storm surges, and changes in river discharge and sediment transport rates (see 

drying trend noted above) would continue to alter coastal habitats. A recent analysis of data for the North 

Slope coastline from the Canadian border to Icy Cape indicates that although some areas show accretion, 

the mean values across the region and a substantial majority of the shoreline transects analyzed, including 

barrier islands, have been eroding between the 1940s and 2010s (Gibbs and Richmond 2017). Erosion 

rates along the Beaufort Sea coast also were substantially greater than along the coast of the Chukchi Sea.

Lastly, the degradation of permafrost and multi-year sea ice could release persistent organic contaminants 

and mercury to aquatic ecosystems and wetlands (Schiedek et al. 2007). 

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

vegetation and wetlands from on-the-ground post-lease activities
3. Affected Environment and Environmental Consequences (Vegetation and Wetlands)

Coastal Plain Oil and Gas Leasing Program 3-71

Draft Environmental Impact Statement

Potential impacts on vegetation and wetlands were evaluated for all areas available for development under 

each alternative, as identified in Table 2-2 in Chapter 2, and for areas of high, medium, and low HCP 

(Tables J-3 through J-8 in Appendix J). The quantification of potential impacts on specific vegetation and 

wetland types using a geographically explicit project footprint (the typical scenario for a proposed 

development) was not possible for this EIS because no on-the-ground actions have been authorized. 

Instead, the most vulnerable resources that could be affected were identified by calculating the 

proportions of each vegetation and wetland type occurring in each lease stipulation category and HCP 

zone. The hypothetical direct footprint for one anchor development oil field (consisting of a CPF, roads 

connecting to six satellite drill pads, a STP pad, and a 30-mile access road) was estimated at approximately 

750 acres. The anchor development footprint was buffered by 328 feet (comprising another 6,607 acres) 

to account for the area of indirect effects on vegetation and wetlands.

The effects of climate change described under Affected Environment above, could influence the rate or 

degree of the potential direct and indirect impacts.

Alternative A

Under Alternative A, no federal minerals in the program area would be offered for future oil and gas lease 

sales. Current management actions would be maintained and resource trends would continue, as 

described in the Arctic Refuge CCP (USFWS 2015a). There would be no direct or indirect impacts on 

vegetation or wetlands from post-lease oil and gas activities under Alternative A.

Impacts Common to All Action Alternatives

Exploration

Future seismic exploration is proposed to occur during winter, with direct surface impacts occurring by 

passage of camp trains on skis pulled by a tracked trailer directly over the snow-covered tundra surface 

(see Appendix B). Potential impacts on vegetation and wetlands typically include changes in plant 

community structure for altered hydrology or direct damage to aboveground structures, such as tussocks 

or woody stems and branches. Long-term studies have shown that the overall impact of seismic vehicle 

traffic on tundra is low, but impacts can still be measured up to 25 years after exploration (Jorgenson et al. 

2010). Seismic vibrator lines and camp train trails on the North Slope were found to be generally visible in 

summer vegetation for about 5 years after disturbance, and the longer-term impacts involved limited 

ground disturbance and ground subsidence where the trail became a wetter trough (Jorgenson et al. 2003).

Impacts affected drier, well-drained, woody shrub vegetation types to a greater degree than wetter types 

dominated by sedges. Studies on BMPs for winter off-road vehicle traffic suggest that the impacts described

above could be mitigated somewhat by using vehicles fewer less pounds per square inch and performing 

seismic operations later in the winter when there is more snow cover and soils are frozen deeper (Bader 

and Guimond 2004; Bader 2005). 

According to a long-term study on the effects of ice road construction and operation in the NPR-A, ice 

roads have a minimal effect on the vegetation, which would recover to pre-construction conditions after 

approximately 20 years. Similar to seismic train impacts, ice roads disturb the drier, shrub-dominated 

vegetation types to a greater degree than wetter graminoid-dominated communities. The damage was 

found to be due to the freezing of plant tissues in ice, in those species not adapted to inundation in water 

and then ice during winter, as well as the clipping of high microsites, such as raised tussocks that form in 

tussock tundra or shrub branches in low shrub vegetation types (Guyer and Keating 2005). BMPs include 

building ice roads along the wettest routes and avoiding the clipping of vegetation above the ice surface. 
3. Affected Environment and Environmental Consequences (Vegetation and Wetlands)

3-72 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

The most vulnerable wetland types to ice road construction and use are in the broad category of 

Freshwater Forested/Shrub wetlands.

Construction

The primary impact on vegetation and wetland types from construction is permanent loss of those types 

due to the placement of fill for the construction of roads, pads, and VSMs for pipeline footings. The 

removal of surface layers for gravel extraction in material sites also results in permanent loss of vegetation 

and wetlands. No vegetation or wetland types are more or less vulnerable to gravel fill, but the routing for 

roads and pads is preferentially located in drier vegetation types such as tussock tundra, herbaceous 

(mesic) tundra, and low shrub. Ice roads and pads also continue to be used during the construction phase 

to transport and stockpile materials. The effects of ice roads and pads would be the same as described in 

the Exploration section above.

During construction, vegetation and wetland plant community composition can be altered through the 

deposition of dust and gravel spray from vehicle traffic, alterations to drainage patterns from drifted snow, 

impounded drainages, the potential for introduction of invasive or noxious nonnative plants, and oil, water, 

and drilling mud spills to the tundra surface (see Section 3.2.11 for a discussion of spills). Dust fallout due 

to traffic on gravel road surfaces has been shown to occur up to 328 feet from the edge of the footprint 

(Myers-Smith et al. 2006). Dust particles may reduce plant growth by smothering the vegetation and may 

reduce wetland function by introducing pollutants. 

Gravel roads and pads tend to increase the occurrence of thermokarst next to the footprint edge, with 

ponded areas extending into the adjacent tundra and altering the vegetation and wetland plant community 

structure (Raynolds et al. 2014). Ponding also may occur if existing subsurface drainage is impeded at the 

edges of roads or if changes to patterns of snow drifting increases meltwater. 

Invasive species infestations are a growing threat to the relatively pristine vegetation and wetland types on 

the North Slope and in the program area. Gravel sources and vehicle tracks contaminated with invasive 

plant propagules have been shown to be the most likely way for invasive plants to be dispersed (Carlson 

and Shephard 2007). 

Operations

Impacts during future project operations typically would include all the effects described for construction, 

except for the placement of fill and gravel extraction.

Rare and Invasive Plants

Those rare vascular plant species with documented occurrences in the program area occur broadly across 

all vegetation types, with a few exceptions (see Affected Environment above). The available data for rare 

plants are not sufficient to determine the range of individual taxa across the program area; therefore, 

impacts on rare plant populations are assumed to be equivalent across all alternatives. 

Similarly, potential impacts from the introduction of invasive plants are assumed to be the same for all 

alternatives. This is because the exploration, construction, and operations activities that can increase the 

risk of invasive plant introductions are very likely to be the same for all alternatives.

Alternative B

The most common vegetation type across all areas available for lease under Alternative B is herbaceous 

(mesic) tundra, ranging from 16.4 percent to 39.9 percent of the areas open for leasing (Table J-3 in 
3. Affected Environment and Environmental Consequences (Vegetation and Wetlands)

Coastal Plain Oil and Gas Leasing Program 3-73

Draft Environmental Impact Statement

Appendix J). The exception is the NSO areas in the high HCP zone, where herbaceous (wet) tundra is 

more common than herbaceous (mesic) tundra and accounts for 22.4 percent of the area open for leasing. 

The NSO requirements under Alternative B restrict construction of permanent oil and gas facilities, 

except under circumstances when stream or river crossings are unavoidable; thus, the disturbances 

mentioned under Impacts Common to All Action Alternatives would likely occur throughout the NSO/high 

HCP areas but to a lesser extent than in the standard terms and conditions or TL areas. 

The NSO protections preferentially preserve wetter more vulnerable vegetation types common to 

riparian areas because impacts are limited to approved crossing areas and because well pads and central 

processing facilities may not be constructed. 

The TL areas and areas with only standard terms and conditions in Alternative B closely match the 

proportion of vegetation types throughout the entire program area (Table J-1 in Appendix J) and 

overall may be preferable for construction of gravels roads and pads. This is because they are dominated 

by drier types, such as tussock tundra and low shrub. The TL area (comprising inland areas of caribou 

calving and post-calving habitat) in the low HCP zone notably has the highest proportion of low shrub 

(32.1 percent of the area open for leasing; Table J-3 in Appendix J). The percentage of low shrub in this 

inland area is higher than the overall proportion in the full program area. 

The lease stipulations in the TL areas restrict construction between May 20 and July 20 to reduce 

disturbance to calving and post-calving caribou. This restriction, however, would not preserve vulnerable 

vegetation or wetland types because construction would be permitted outside the TL period and would 

still affect vegetation and wetlands. Because of the higher incidence of low shrub vegetation, potential 

winter seismic and ice road impacts, as described under Impacts Common to All Action Alternatives above, 

likely would be more pronounced in the TL area under Alternative B.

The predominant wetland type in all areas open for leasing under Alternative B is freshwater emergent 

(ranging from 42.4 percent to 96.3 percent of the areas available for leasing; Table J-4 in Appendix J). 

This broad category includes wetlands with a range of hydrologic conditions, from marsh to saturated 

classes. The wetter types occurring in the broad freshwater emergent class are often higher functioning 

wetlands but were not delineated separately in the NWI mapping used in this analysis. The NWI mapping 

provides information on high-value estuarine and marine deepwater wetlands and waters, which typically 

are high functioning as habitat for a variety of avian species that rely on estuarine wetlands and coastal 

lagoons during the post-breeding and fall migratory staging periods. The NSO areas in all HCP zones 

include a relatively high proportion of estuarine and marine habitats (Table J-4 in Appendix J). As 

described in the Affected Environment section above, the estuarine wetlands in the program area tend to be 

wetter saltmarsh habitats that are high value primarily for geese in the post-breeding and migratory staging 

periods. The high-value freshwater wetland habitats that are encompassed in the freshwater emergent 

wetland class (Table J-5 in Appendix J) have moderate protection through the construction restrictions 

along rivers and streams, but the high-value estuarine wetlands do not have similar protections under 

Alternative B. 

Alternative C

In general, the most common vegetation types in all areas available for lease under Alternative C are 

herbaceous (mesic), ranging from less than 0.1 percent to 37.4 percent of the areas open for leasing, and 

tussock tundra, ranging from less than 0.1 percent to 41.1 percent of the areas available for leasing (Table 

J-5 in Appendix J). The exception is the NSO area in the high HCP zone where herbaceous (wet) tundra 
3. Affected Environment and Environmental Consequences (Vegetation and Wetlands)

3-74 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

(24.6 percent of the area available for leasing), freshwater or salt water (29.4 percent), and sparse 

vegetation (12.0 percent) are the dominant broad-scale vegetation types (Table J-5 in Appendix J). 

The vulnerable wet tundra types in the NSO riparian areas under Alternative C are protected to a limited 

extent, depending on the specific design of an anchor oil field development and whether stream crossings 

are approved. Protections for barrier islands and selected coastal areas from impacts of barge landings and 

docks primarily apply to the sparse vegetation category, which is most likely comprised of barren 

gravel/sand beaches and dune geomorphic types.

The relative proportions of wetland types in the areas available for leasing under Alternative C generally 

are equivalent to the overall proportions occurring in the full program area, with freshwater emergent 

wetlands accounting for the greatest areal coverage (Table J-6 in Appendix J). The NSO requirements 

for Alternative C effectively protect high-value estuarine wetlands (see discussion under Affected 

Environment and Alternative B above).

Alternative D

Large areas of caribou calving habitat and springs and aufeis areas, especially in the southeastern portions 

of the program area, are not available for leasing under Alternative D (Table J-7 in Appendix J). Added 

restrictions for the NSO stipulation include larger setbacks for riparian areas, coastal areas, caribou calving 

habitat, polar bear denning areas, springs and aufeis areas, the Canning River delta and lakes, and the Mollie 

Beattie Wilderness boundary on the southern and eastern edges of the program area (see Table 2-2 in

Chapter 2). The added NSO restrictions, however, would provide limited protection to common or 

high-value vegetation types except for the Lease Stipulation 10, which does not allow development within 

3 miles of the southern and eastern boundaries of the program area where they are next to designated 

Wilderness. 

The most common vegetation types in all areas open to leasing under Alternative D are herbaceous 

(mesic), ranging from 4.7 to 60.6 percent of the areas available for leasing, and tussock tundra, ranging 

from 10.3 to 58.9 percent (Table J-7 in Appendix J). In the NSO/high HCP zone, the most common 

vegetation types are herbaceous (mesic) at 24.6 percent of the area, freshwater or salt water at 23.7 

percent, and herbaceous (wet) at 22.5 percent (Table J-7 in Appendix J). The area identified in Lease 

Stipulation 10 as NSO is farther inland and is dominated by relatively low-value tussock tundra. Lease 

Stipulation 8 includes TLs for caribou post-calving habitat but has no effect on the preservation of highvalue vegetation types occurring in that area. Similarly, the TLs for Alternative D outside of the CSU has 

no effect on the preservation of vulnerable vegetation types. Lease Stipulation 10 provides the only full 

protection for all vegetation types. This is because no development is allowed within the 3-mile setback 

from the Wilderness boundary (see Table 2-2 in Chapter 2). 

Most of the high-value estuarine and marine deepwater wetlands, as described above for Alternative B, 

occur in the NSO area. Outside of the NSO areas and the Wilderness boundary setback, the other lease 

stipulations for Alternative D would provide limited protection for the loss of wetlands from post-leasing 

oil and gas activities. 

Cumulative Impacts

Oil and gas development impacts are common on the North Slope, and any development resulting from 

lease sales in the program area would increase the occurrence and intensity of these common impacts. 

Such projects are likely in terrestrial environments in the future, as more oil resources are being 

discovered, especially to the west in the NPR-A, and those projects would affect vegetation and wetlands. 
3. Affected Environment and Environmental Consequences (Vegetation and Wetlands)

Coastal Plain Oil and Gas Leasing Program 3-75

Draft Environmental Impact Statement

In support of both oil and gas development projects and increased access for North Slope communities, 

impacts on vegetation and wetlands from surface transportation are anticipated to increase as the road 

system increases in size and more airstrips are constructed. To the extent that they would involve gravel 

fill, community development projects on the North Slope, such as airport improvements, roads and ports, 

telecommunication, and energy projects, also would increase impacts on vegetation and wetlands. The 

effects of climate change described under Affected Environment above, could influence the rate or degree of 

the potential cumulative impacts.

3.3.2 Fish and Aquatic Species

Affected Environment

Fish Habitat

There are three primary aquatic habitats available to marine, anadromous, and freshwater species in and 

next to the program area: the lagoon and nearshore brackish waters of the Beaufort Sea; the rivers, 

streams, and springs emanating from the Brooks Range or Arctic Coastal Plain16 (ACP) tundra; and lakes 

or ponds that are concentrated mostly near the Beaufort Sea coast. The quantity and distribution of these 

habitats throughout the program area are summarized in Table 3-17, Map 3-12, Fish Habitat and 

Distribution, and Map 3-13 in Appendix A.

As described in Section 3.2.10, freshwater habitat is limited in the program area; this is the case 

especially during the winter, when aquatic habitat is reduced to approximately 5 percent of that available 

during summer. This reduction in habitat results in fewer freshwater and anadromous fish species in the 

program area, relative to other parts of the ACP along the Beaufort and Chukchi Seas (USFWS 2015a) 

(Map 3-12 in Appendix A).

Table 3-17

Fish Habitat in the Program Area and Surrounding Area

Freshwater Streams

Total Anadromous 

Fish Habitat by 

Basin (Miles) a

Anadromous Fish 

Habitat in the Program 

Area (Miles) a

Streams in the 

Program Area 

(Miles) b

Aichilik River 51 1 –

Akutoktak River 13 13 18

Angun River 8 8 33

Canning River 125c46 41

Carter Creek 13 13 22

Hulahula River 73 27 27

Jago River 35 27 37

Katakturuk River 20 20 22

Kimikpaurauk River 4 4 5

Kogotpak River 12 12 20

Marsh Creek 1 1 20

Nataroarok Creek 11 8 21

Nularvik River 3 3 3

Okpilak River 43 31 33

Sikrelurak River 11 11 21

Siksik River 5 5 7

Staines River 18 18 18

 

16The Arctic Coastal Plain is a physiographic province that includes all of the North Slope of the Brooks Range 

north of the Foothills province. It extends across all of northern Alaska from the Chukchi Sea to the BS. 

(Wahrhaftig GIS 1965)
3. Affected Environment and Environmental Consequences (Fish and Aquatic Species)

3-76 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Freshwater Streams

Total Anadromous 

Fish Habitat by 

Basin (Miles) a

Anadromous Fish 

Habitat in the Program 

Area (Miles) a

Streams in the 

Program Area 

(Miles) b

Tamayariak River 26 26 29

West Canning River 15 15 15

Unnamed Stream Total 47 26 –

Total Streams 587 316 392

Other Waters Miles Acres

Total Lake Area b– 19,000

Unfrozen Lake Area d– 6,400

Coastline e593 –

Notes:

a Johnson and Blossom 2017. Data do not exist to quantify overwintering habitat by stream; the locations of overwintering 

habitat in the program area are depicted in Map 3-12 in Appendix A. 

b USGS GIS 2018. Data may conflict with Johnson and Blossom 2017; some streams may show fewer miles of stream than 

anadromous waters in the stream. These are the best available data for stream miles and anadromous fish habitat miles.

c

Includes Marsh Fork Canning River

d NSSI 2018. Dataset indicates the presence of liquid water, but not depth of water; thus, this data set overestimates potential 

fish overwintering habitat (unfrozen water may be range from a few inches to over 7 feet), though it is the best available 

information for this topic. Numbers are surface area of lakes with any portion unfrozen. 

e NOAA GIS 2018; USFWS 2015a

Lagoons and Nearshore Brackish Waters

Lagoons and shallow, brackish coastal waters are well understood to provide refuge/nursery habitat for 

juvenile fishes and for providing significant invertebrate prey for juvenile and adult fishes alike (Craig et al. 

1984; Dunton et al. 2006). The nearshore brackish and marine waters within the boundary of the Arctic 

Refuge, included the program area, are composed of a mix of open coastline, bays, and lagoons, bounded 

on the north by barrier islands. There are 16 bays and lagoons along the program area coastline, 

representing 593 miles of coastline and nearshore aquatic habitat potentially home to aquatic species (Map 

3-12 in Appendix A). During summer, these waters become brackish due to freshwater input from 

rivers along the ACP (Dunton et al. 2006; USFWS 2015a). Many of the inside barrier island lagoons are 

shallow and experience reduced currents and a small tidal flux of less than or equal to 1 foot, resulting in 

waters that are warmer and fresher than those outside the barrier islands. 

Summertime mixing of marine waters with freshwaters produces conditions favorable to many marine and 

anadromous fishes,17 as well as invertebrates (USFWS 2015a); however, by late fall the lagoons become 

saline again as freshwater input declines. As ice forms on the lagoons the water below becomes 

hypersaline and very cold, the result of ion exclusion during ice formation, restricted flow between the 

lagoons and the open sea beyond, and freezing point depression with greater salinity. These cold, 

hypersaline lagoon environments become unsuitable habitats for both anadromous and marine fishes 

during winter (USFWS 2015a). 

Rivers, Streams, and Springs 

The program area is underlain by continuous permafrost, which limits infiltration of surface water, 

resulting in a high ratio of stored water at the surface, rather than in the ground (USFWS 2015a). Data on 

these water resources are limited, with few datasets going back more than 5 years.

 

17Fish species that inhabit the ocean mostly but return to inland waters to spawn
3. Affected Environment and Environmental Consequences (Fish and Aquatic Species)

Coastal Plain Oil and Gas Leasing Program 3-77

Draft Environmental Impact Statement

All flowing surface waters in the program area drain to the Beaufort Sea. There are at least 10 major rivers 

and many smaller streams in the program area, though most flow only during summer, because of 

snowmelt, rainfall, perennial springs, and, in some cases, glacier melt (McCart 1980; Lyons and Trawicki 

1994; Rabus and Echelmeyer 1998; Kane et al. 2013; USFWS 2015a) (Map 3-12 in Appendix A). During 

winter, stream flow ceases due to freezing. The exception to this rule is in areas with perennial spring 

flow, which offer the only available overwintering habitat outside of summer (Kane et al. 2013; USFWS 

2015a) (Map 3-12 in Appendix A). Though there are 392 miles of streams in the program area, only 5 

percent (roughly 20 miles) are habitable in winter (Table 3-17). 

Lakes

A large portion of the program area is classified as wetlands, but lakes constitute very little of the total 

surface area of water for the region. Lake density from the Staines and Canning Rivers to the Aichilik 

River, which mark the western and eastern bounds of the program area, is lower than the ACP west of 

the Arctic Refuge (White et al. 2008; Arp and Jones 2009; USFWS 2015a). The central portion of the 

program area in particular has very few lakes. Most program area lakes are near the delta areas of the 

Canning, Sadlerochit, and Jago Rivers (Map 3-12 in Appendix A) (USFWS 2015a). 

These lakes vary in surface area from less than 1 acre to approximately 1,500 acres, though most are less 

than 12 acres (USFWS 2015a). Most are shallow and freeze solid during winter (Lyons and Trawicki 1994). 

Only a fraction of the program area lakes have a small volume of unfrozen water in winter because they 

are shallow (less than 7 feet) and freeze to the substrate (USFWS 2015a). The lakes with remaining liquid 

water at the end of winter (generally deeper than 7 feet) occur mostly in the Canning River delta; thus, fish 

overwintering habitat is extremely limited in area lakes. The total lake surface area is 22,100 acres, with 

only 6,400 acres available as potentially deep, overwintering water (Table 3-17; overwintering acres are 

likely overestimated). 

Fish Species

There are approximately 17 to 21 species of fish that use the program area regularly on a seasonal basis 

(Table 3-18); however, only Dolly Varden, round whitefish, burbot, ninespine stickleback, and arctic 

grayling overwinter in freshwater habitats in the program area (Table K-1 in Appendix K). Some species

are described as overwintering in other parts of the Arctic Refuge (USFWS 2015a), but they have not been 

confirmed in studies in the program area (USFWS 2015a); thus, a range of likely species is presented in this 

EIS, based on the best available information. It is also likely that additional marine species, which are not 

listed in Table 3-18, may use waters north of the program area (USFWS 2015a; BLM 2012). 

Round whitefish and burbot are present in the Canning River at the western boundary but not elsewhere 

in the program area (Fruge and Palmer 1994; USFWS 2015a). Dolly Varden are present in three resident 

freshwater populations—a resident dwarf form, a lake and spring form, and residual dwarf males of 

otherwise anadromous populations that stay in freshwater—and several anadromous populations (McCart 

and Craig 1973; USFWS 2015a). 

Arctic grayling occur in some lakes and in rivers with perennial springs (Fruge and Palmer 1994; USFWS 

2015a). Most of the anadromous species described in Table 3-18 use the nearshore marine area for 

migration or rearing. Various marine species also use the nearshore marine area, but only four are present 

in large numbers next to the program area (USFWS 2015a): fourhorn sculpin, arctic flounder, saffron cod, 

and arctic cod. Additional information on the life history attributes for fish of the program area are 

provided in Appendix K.
3. Affected Environment and Environmental Consequences (Fish and Aquatic Species) 

3-78 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement 

Table 3-18

Fish Species that May Use the Program Area 

FAMILY Common Name Scientific Name Freshwater Anadromous Marine

COTTIDAE: Sculpins Fourhorn 

Sculpin

Myoxocephalus 

quadricornis

- - +

GADIDAE: Cods Arctic Cod Boreogadus saida - - +*

Burbot Lota + - -

Saffron Cod Eleginus gracilis - - +*

GASTEROSTEIDAE: 

Sticklebacks

Ninespine 

Stickleback

Pungitius + + brackish -

OSMERIDAE: Smelts Rainbow Smelt Osmerus mordax - + -

PLEURONECTIDAE Arctic Flounder Pleuronectes glacialis - - +

SALMONIDAE: 

Salmonids

Arctic Char aSalvelinus alpinus + - -

Arctic Cisco b Coregonus autumnalis - + -

Arctic Grayling Thymallus arcticus + -

Broad Whitefish Coregonus nasus + + -

Chinook Salmon Oncorhynchus 

tshawytscha

- +* -

Chum Salmon O. keta - +* -

Dolly Varden Salvelinus malma + + -

Humpback 

Whitefish

Coregonus pidschian + + -

Lake Trout aSalvelinus namaycush + - -

Least Cisco Coregonus sardinella + + -

Pink Salmon Oncorhynchus 

gorbuscha

- +* -

Round 

Whitefish

Prosopium 

cylindraceum

+ - -

Source: BLM 2012; USFWS 2015a 

Notes: 

- = not applicable 

* Species with designated Essential Fish Habitat (EFH) in the program area 

a Species that may be extremely rare or unconfirmed as present in program area waters. 

b Some subsistence users have reported harvest take of Bering cisco (Coregonus laurettae), though this has not been confirmed, 

based on taxonomic features, such as gill raker count.

Aquatic Invertebrates 

Though data for aquatic invertebrates in the program area are limited, it is well understood that 

invertebrates provide the bulk of food resources for both fish and bird communities of the ACP (Howard 

et al. 2000). The most productive waters for invertebrates are in coastal marine environments, where 

benthic and pelagic organisms are plentiful and diverse. The distribution and density of invertebrates 

depend on the types and quantities of habitats, including sediment and vegetation types (Dunton and 

Schonberg 2000). In freshwater habitats, benthic invertebrates and zooplankton are most prevalent, with 

the former dominating food sources for fish (Howard et al. 2000). Terrestrial insects likely contribute to 

freshwater invertebrate food resources for fish. For a more complete understanding of aquatic 

invertebrate communities in the program area and the ACP, refer to The Natural History of an Arctic Oil Field

(Truett and Johnson 2000). 

Essential Fish Habitat 

The 1996 Sustainable Fisheries Act enacted additional management measures to protect commercially 

harvested fish species from overfishing. Measures were added to the Magnuson-Stevens Fishery 
3. Affected Environment and Environmental Consequences (Fish and Aquatic Species)

Coastal Plain Oil and Gas Leasing Program 3-79

Draft Environmental Impact Statement

Conservation and Management Act Reauthorization (16 USC 1801–1882), including one to describe, 

identify, and minimize adverse effects on EFH. Pacific salmon EFH in the program area includes both 

marine water and freshwater. Marine EFH for salmon extends 200 nautical miles from the coast, though 

recent data indicate that EFH for these species on the ACP could be refined to just freshwater habitats 

(Echave et al. 2012). Freshwater EFH consists of the lower reaches of some larger rivers (Map 3-13 in 

Appendix A). Because there is no available spawning habitat for these species, EFH does not extend to 

the upstream reaches of these rivers. Arctic cod and saffron cod EFHs include the coastal lagoon and 

marine waters next to the program area, but they may also extend into the lower reaches of larger rivers 

during summer. Additional relevant information on EFH for the Arctic, including the Beaufort Sea 

coastline, can be found in the NPR-A IAP/EIS (BLM 2012).

Climate Change

As discussed in BLM 2018a, climate change is affecting many variables that then affect aquatic species and 

habitats; such variables are precipitation, timing of ice formation, permafrost degradation, and changes to 

hydrologic functions and water quality, such as temperature and dissolved oxygen. Increasing temperature 

is expected to change climate patterns and lengthen the ice-free season, degrade permafrost, and increase 

evaporation, processes that contribute to surface water hydrology and may reduce (Laske et al. 2016) or 

increase (Stueffer et al. 2017) surface water connectivity. Reductions in connectivity from, for example 

drying of channels or ponds, may in turn reduce colonization opportunities for fish by limiting dispersal 

pathways and movement between habitats (Laske et al. 2016). This could change local species assemblages 

or species richness.

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

fish and aquatic species from on-the-ground post-lease activities

As a proxy for a geographically explicit project footprint, potential impacts on fish and fish habitat are 

described by types of available fish habitat, scarcity of those habitats in the program area, and importance 

of those habitats to aquatic species.

The effects of climate change described under Affected Environment above, could influence the rate or 

degree of the direct or indirect impacts.

Alternative A 

Alternative A (No Action Alternative) would not establish an oil and gas program for the leasing, 

development, production, and transportation of oil and gas in and from the Coastal Plain in the Arctic 

Refuge. Resource trends and management actions would continue as described in the Arctic Refuge CCP 

(USFWS 2015a). There would be no potential direct or indirect impacts on fish and aquatic species under 

Alternative A.
3. Affected Environment and Environmental Consequences (Fish and Aquatic Species)

3-80 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Impacts Common to All Action Alternatives

Post-oil and gas leasing activities that could affect fish and fish habitat would occur under all action 

alternatives, though their locations could vary. Potential effects on aquatic species and habitats are 

summarized here; locations that would incur more or fewer impacts are described by alternative in the 

following sections.

Direct Habitat Loss or Alteration

Activities with the potential to affect fish and aquatic species include the construction and operation of 

new gravel roads, gravel pads, airstrips, pipelines, culverts, bridges and barge landings or docks, and gravel 

mining.

Fill for infrastructure would directly and permanently remove aquatic habitat within the fill footprint. 

Gravel fill would likely not be placed in waterbodies due to practicability; however, fill placed near 

waterbodies could alter aquatic habitats and indirectly affect fish, as described below in Indirect Habitat 

Alteration. Bridge piers could be located in waterbodies or floodplains. A marine barge landing or dock 

could remove marine habitat. Potential direct aquatic habitat loss would be adverse and long term and 

would occur in the fill footprint.

Use of culverts could directly alter aquatic habitats by replacing substrates, banks, or both with metal pipe. 

This would adversely affect the habitat in the long term by removing the capacity of the fill footprint to 

contribute nutrients or organic matter to the waterbody.

Buried pipelines, such as the STP pipe, would alter marine sediments in the fill footprint due to trenching 

to bury the pipe. This would adversely affect the habitat in the short term by removing invertebrate food 

sources and potential algal cover in the trench footprint until the invertebrate and algal resources 

regenerate.

Because gravel is often most abundant in waterbodies, gravel may be mined in waterbodies and floodplains, 

which would alter aquatic habitats. Existing habitats would be adversely affected in the long term by the 

removal of substrate and the capacity of the mining footprint to contribute nutrients or organic matter to 

the waterbody. Water quality would also be degraded in the short term due to increased turbidity, which 

could lead to changes in dissolved oxygen or other water quality changes (see Section 3.2.10). Water 

depth would increase in the long term and could create new deep freshwater habitat for fish, as has been 

observed in other North Slope gravel mines (BLM 2012). Because deep habitats are limited in the program 

area, this could result in potential beneficial long-term effects for fish by creating new overwintering 

habitat.

Indirect Habitat Alteration: Dust and Gravel Spray

Activities associated with the post- leasing program that could cause potential dust and gravel spray effects 

include construction and operation of new gravel roads and gravel pads and vehicle traffic on gravel 

infrastructure.

Dust and gravel spray would be generated during future gravel placement, gravel compaction, and vehicle 

traffic on gravel roads and pads. Road dust accumulation is greatest within 35 feet of roads, but deposition 

may occur over a broader area. Roughly 95 percent of dust settles within 328 feet from the road surface 

(Myers-Smith et al. 2006; Walker and Everett 1987). Dust could increase turbidity in waterbodies next to 

roads and construction areas and could increase sediment and gravel inputs to existing substrates. This 

would have a long-term adverse effect on aquatic habitats and species by decreasing habitat quality, 
3. Affected Environment and Environmental Consequences (Fish and Aquatic Species)

Coastal Plain Oil and Gas Leasing Program 3-81

Draft Environmental Impact Statement

including through mobilization of possible contaminants specific to the underlying geology of gravel pits 

where sediment is mined. These sequestered chemicals or elements are not necessarily harmful 

themselves but could be harmful, in combination with other water chemistry attributes, such as pH.

Indirect Habitat Alteration: Flow Alteration and Fish Passage 

Post-leasing oil and gas activities that could affect flow alteration and fish passage include construction of 

ice roads, snow management activities, use of rolligons or other off-road vehicles for seismic surveys, 

maintenance, and the placement of bridge piers or piles in waterbodies.

Flow alteration can result from obstructions in the natural flow path, either by infrastructure or by 

compacted ice. Compacted ice over and surrounding waterbodies can delay ice melt and temporarily alter 

aquatic habitats. Compacted ice can change natural drainage patterns or cause water impoundments during 

spring break up. Delayed melt of ice roads or pads can also temporarily block fish passage, which can 

impede Arctic fish attempting to migrate from overwintering areas to feeding habitat during the early part 

of the open-water season. 

As discussed in BLM (2012), many fish move upstream during breakup to access productive feeding habitat 

or to reach locations only accessible during spring flooding. Energy reserves in spring are typically low for 

most fish and additional stress or delayed access to feeding habitats could have adverse impacts. A barrier 

to movement could alter migration patterns to lower quality feeding habitat and increase energetic 

demands, which could compromise survival. Ice compaction would temporary alter aquatic habitats near 

ice infrastructure or near where off-road activities would occur. This could have longer-term adverse 

effects on fish if their migration is annually delayed.

Bridge piers or piles could also alter flow due to ice blockage during spring break up. Effects would be the 

same as those described above for flow alteration due to ice compaction. 

Indirect Habitat Alteration: Water Quantity 

Post-lease oil and gas activities that could affect water quantity include water withdrawal from lakes or 

streams for ice roads, water supply, dust suppression, and other uses.

Water withdrawal from lakes can affect the amount of habitat available to overwintering fish, summer 

habitat accessibility, and habitat characteristics. Removal or compaction of snow can also increase the 

depth of freezing on lakes. As a result, the water quantity available in a lake during the winter can be 

greatly reduced. 

Because unfrozen freshwater in winter is scarce in the program area, any future withdrawal from these 

areas would have the most adverse effects on fish. These springs and deep lakes are sensitive areas, in part 

because there are so few of them that they limit the distribution of fish in the program area.

Indirect Habitat Alteration: Water Quality 

Activities that could affect water quality in the future include the following:

 Water withdrawal from lakes or streams for ice roads, water supply, dust suppression, and other uses

 STP discharge to marine waters 

 General construction in or near waterbodies

 Vehicle traffic on gravel infrastructure

 Gravel mining
3. Affected Environment and Environmental Consequences (Fish and Aquatic Species)

3-82 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Future water withdrawal from lakes in the winter could temporarily alter lake water chemistry (until 

spring breakup and recharge) by depleting oxygen, increasing solutes, and changing pH and conductivity. 

Reducing water quantity in a lake during the winter can increase the salinity of the water beneath the ice.

Construction or gravel mining that disturbs soils can increase sediment runoff, turbidity, and contaminant 

concentrations in streams. During future construction or mining, this would have a short-term adverse 

effect on aquatic habitats and species around or immediately downstream of soil-disturbing activities. 

Fugitive dust from vehicle traffic could also increase local turbidity in streams around gravel infrastructure. 

Dust effects on aquatic habitats and species would be long term and adverse.

Discharge of brine to the marine area from a potential STP could further increase salinity, particularly in 

the winter when freshwater may be frozen. Effects would be particularly pronounced if the discharge was 

in the brackish lagoon waters that are hypersaline in winter.

Disturbance or Displacement: Noise and Human Activity

Post-lease oil and gas activities that could cause effects related to noise and human activity include seismic 

surveys (use of vibroseis to image the subsurface), gravel mining (dredging or explosives), and pile driving 

for bridges or VSMs.

Seismic surveys generate increased sound pressures in waterbodies. The high-intensity acoustic energy 

produced by seismic surveys can damage auditory sensory hair cells in fish, reducing their ability to hear 

(McCauley et al. 2003; Popper 2003; Smith et al. 2004). Underwater shock waves can also injure the swim 

bladder and other organs and tissue, which could injure or kill fish. Increased sound pressures in unfrozen 

springs in winter could stress fish because they would not have alternate habitats where they could move 

to avoid effects; thus, seismic surveys could disturb, injure, or kill fish in unfrozen waterbodies (springs) in 

the winter. Vibroseis rigs operating on the ice overhead can create sound pressures great enough 

approximately 33 feet from the source to cause avoidance behavior (Greene 2000 and Nyland 2002, as 

cited in BLM 2012). Effects are further detailed in BLM 2012.

Noise generated by vehicles and machinery in the future could have potential local impacts on fish, such as 

stress-induced fleeing related to loud noises. The noise would be greatest during construction but would 

occur to a lesser degree throughout the program area. Because most construction would occur in the 

winter when waterbodies would have ice cover, noise effects on fish would be reduced during that time.

Injury or Mortality: Noise

Post-lease oil and gas activities that could affect fish and aquatic species from noise include seismic surveys 

(use of vibroseis to image the subsurface), gravel mining (dredging or explosives), and pile driving for 

bridges or VSMs.

As described above in Noise and Human Activity, noise can disturb fish, and, at higher dB or in greater 

intensity, it can injure or kill fish. Restricting seismic surveys to winter when waterbodies (except springs) 

are frozen and avoiding areas around springs would minimize effects on fish.

Pile driving can also create sound levels that affect fish. Assuming that piles would be installed in winter, if 

the bridge or VSM sites freeze to the bottom, the ice would diminish the sound, and the potential impact 

on fish in any adjacent overwintering habitats would be negligible.
3. Affected Environment and Environmental Consequences (Fish and Aquatic Species)

Coastal Plain Oil and Gas Leasing Program 3-83

Draft Environmental Impact Statement

Entrainment

Post-lease oil and gas activities that could cause effects related to entrainment include gravel mining and 

water withdrawal from lakes or streams or from marine waters, such as the STP.

Though injury or mortality of fish from entrainment or impingement at water intake could occur, the effect 

would be minimized by ROPs that ensure that intakes be screened. As is described in BLM 2012, it is 

unlikely that fish would be entrained in the water intake.

Contaminants

Post-lease oil and gas activities that could cause effects related to contaminants include potential spills from 

storage, use, and transport of waste and hazardous materials, potential spills from wells, pipelines, or other 

infrastructure, and mobilization of contaminants into aquatic or terrestrial systems from erosion, fugitive 

dust, and permafrost degradation. As described in detail in BLM 2012, spills can adversely affect aquatic 

habitats and species by exposing them to contaminants. Spills can injure or kill fish and effects can be long 

or short lived depending on the type, size, duration, and season of the spill. See Section 3.2.11 for more 

discussion of spills.

Alternative B

Under Alternative B, five streams described in Lease Stipulation 1 would have a 0.5-mile setback and five 

streams would have a 1-mile setback for surface development, though bridges, roads, and pipelines could 

still be built in the setbacks. Some streams would have no setbacks, and fish-bearing streams and other 

fish-bearing waterbodies would have a 500-foot setback. Most of the coastal areas would not have 

setbacks, but no development would be allowed in the coastal waters, lagoons, and barrier islands under 

any alternative; thus, effects on unprotected streams and coastal areas and the species that use them 

would be most pronounced under this alternative, and the types of impacts would be the same as those 

described under Impacts Common to All Action Alternatives. Overwintering habitat (springs) would be 

unprotected from both surface development beyond the 500-foot setback for fish-bearing waters and from 

water or ice withdrawal, which could affect the long-term survival and distribution of freshwater fish in the 

program area. Withdrawal of unfrozen water from lakes may be permitted. Alternative B would also have 

the most potential adverse effects on EFH since coastal areas and some anadromous streams would not be 

protected and could be developed.

Alternative C

Under Alternative C, the same select streams as Alternative B would have 0.5- to 1-mile setbacks for 

surface development, with similar exceptions for roads and pipelines; however, the Canning, Hulahula, and 

Okpilak River setbacks would be increased to 2 miles from the active floodplain, except where the 

Canning River floodplain is outside of the Arctic Refuge. Some streams would have no setbacks. As with 

Alternative B, fish-bearing streams and other fish-bearing waterbodies would have a 500-foot setback. 

There would be a 1-mile NSO setback from the coast (although exceptions would be allowed for various 

facilities, including docks and barge landings), and no development would be allowed in the coastal waters, 

lagoons, and barrier islands. As with Alternative B, no special protections are included in Alternative C for 

the critical springs in the areas offered for lease. Such springs are vital overwintering habitat for fish beyond

the 500-foot setback for fish-bearing waters; they are protected from surface development and from water 

or ice withdrawal; thus, long-term survival and distribution of freshwater fish in the program area could be 

affected. These lease stipulations are similar in magnitude of potential impact on fish and aquatic resources 

as under Alternative B, though greater protections are offered for select rivers and streams under 
3. Affected Environment and Environmental Consequences (Fish and Aquatic Species)

3-84 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Alternative C, and streams in the southeastern portion of the program area would be in areas not offered 

for lease.

Alternative D

Under Alternative D, 17 streams would have setbacks for surface development, although exceptions 

would be allowed for roads and pipelines. Setbacks for the Canning River east of the Arctic Refuge 

boundary and for the Aichikik and Okpilak river floodplains would be 3 miles; setbacks for the Hulahula 

River floodplain would be 4 miles; setbacks for the Sadlerochit and Jago River floodplains would be 1 mile; 

and the remaining 11 streams would have 0.5-mile setbacks. 

Permanent facilities would be prohibited within 0.5 mile of the ordinary high-water line of all waterbodies 

in the Canning River delta, which would protect most lakes in the program area. Additional 1- to 3-mile 

setbacks would be provided for four specific springs and aufeis areas, which would reduce potential effects 

on aquatic species and habitats, as described under Impacts Common to All Action Alternatives. There would 

be a 2-mile NSO setback from the coast, though exceptions would be allowed for barge landings, docks, 

and pipelines. No development would be allowed in coastal waters, lagoons, and barrier islands, as with all 

alternatives. Withdrawal of unfrozen water from lakes may be permitted.

Future gravel mining would not occur in the active floodplain or channel of the Canning, Sadlerochit, 

Hulahula, and Aichilik Rivers. Potential impacts on fish and aquatic species would be reduced under 

Alternative D, compared with Alternatives B and C, and would occur mostly in the western portion of the 

program area. Impacts would be predominantly indirect, such as in changes to hydrology associated with 

infrastructure outside river and lake buffers or where infrastructure crosses river corridors. Protecting 

spring habitat via TLs and NSOs would reduce the likelihood of disrupting groundwater that supports fish 

habitat.

Cumulative Impacts

Past and present actions in the program area have been limited and thus have had limited effects on aquatic 

species and habitats. Infrastructure developed for the community of Kaktovik may have indirectly affected 

or may be affecting aquatic habitats and species by contributing dust and gravel spray to streams, altering 

habitat by withdrawing water, and disturbing or displacing fish due to noise. Impacts from areawide seismic 

activities may change hydrology and water quality, potentially affecting fish habitat, if surface damage results 

in thermokarst and water channel formation. The effects of climate change described under Affected 

Environment above, could influence the rate or degree of the potential cumulative impacts.

Alternative A would have no cumulative impacts on aquatic species and habitats, but all action alternatives 

would incrementally contribute to potential cumulative impacts on fish and aquatic resources from postleasing oil and gas activities. 

3.3.3 Birds

Affected Environment

According to the USFWS (USFWS 2015a), 156 bird species have been recorded in the Arctic Refuge on 

the northern foothills of the Brooks Range, in the ACP (an area inclusive of the program area), and in 

adjacent marine waters (Table J-9 in Appendix J). Seventy of those species (45 percent) are confirmed 

breeders or permanent residents, or both; 11 are possible breeders, 40 have been recorded staging or 

migrating in the area (some also breed there), and 64 are casual, accidental, or rare visitors. 
3. Affected Environment and Environmental Consequences (Birds)

Coastal Plain Oil and Gas Leasing Program 3-85

Draft Environmental Impact Statement

With few exceptions, all birds in the program area are migratory and are present only during the summer 

breeding season, May to September, depending on species. Winter residents include small numbers of 

ravens and ptarmigan, dippers near open running water, and occasional gyrfalcons. The migration routes 

and wintering areas of ARCP birds encompass much of the North American and South American 

continents and central and southern Pacific islands; some species may winter in southern Africa, 

Australasia, Japan and China, and coastal Antarctica.

Shorebirds and passerines are the most abundant guilds of nesting birds on the ACP (Liebezeit et al. 2009). 

Waterfowl, loons, grebes, and cranes also use the ARCP in large numbers (Bart et al. 2013). Other bird 

groups present in lower numbers are larids (gulls, jaegers, and terns), raptors and owls, and seabirds. Many 

of the 156 species recorded are uncommon or rare; only 57 species are known to occur regularly in 

substantial numbers on the ARCP and are classified as fairly common, common, or abundant (Pearce et al. 

2018; Table J-9 in Appendix J). 

Additional seabirds occur along the marine vessel route to Dutch Harbor, Alaska, including Steller’s and 

spectacled eiders, which are discussed under Special Status Species, below (see Table J-10 in 

Appendix J).

The ARCP represents a substantial portion of the Beaufort Sea coastline in Alaska. Accordingly, it also 

supports a large number of birds during the important nesting, rearing, and migration staging periods. For 

these reasons, the ARCP and adjacent marine waters are recognized as important bird areas by the 

American Bird Conservancy, Audubon, and Birdlife International. Because the ARCP completely 

encompasses it, the program area is considered part of the important bird areas. Prior studies 

(summarized in USFWS 2015a) have demonstrated that at least several hundred thousand breeding and 

nonbreeding birds use the ARCP and program area during the short arctic summer. 

Although there are historical survey data for the ARCP, as described in USFWS and BLM (2018), detailed 

distribution and abundance data for the program area are lacking for many, and contemporary data are 

lacking for most bird species. In addition, much of the contemporary data were collected for only 1 or 2 

years, cover only a small portion of the program area, or were collected at low survey intensity. The 

program area contains far fewer water bodies, compared with sites farther west, such as Prudhoe Bay and 

the NPR-A. Because of this, many waterbirds and shorebirds are patchily distributed, which increases the 

difficulty in determining accurate abundance levels based on a small number of surveys.

A few bird species have been relatively well studied on the ARCP, such as golden eagles and fall-staging 

snow geese (summarized in USFWS 2015a), but detailed distribution and abundance data are lacking for 

many species. Information about the various bird species and species groups found in the program area is 

summarized below.

Special Status Species

Of the 156 species known to occur in the program area, 10 are recognized as BLM sensitive species (BLM 

2018b [in prep.]), 11 are USFWS birds of conservation concern (USFWS 2008a), and 44 are recognized as 

at-risk species by the ADFG (Table J-9 in Appendix J). Listings by the US Shorebird Conservation Plan 

Partnership, Partners in Flight, the International Union for Conservation of Nature (2018) Red List of 

Threatened Species, and Audubon Alaska are also included in Table J-9. At-risk species are those with a 

small population size or range, a declining population, or a population facing documented threats. At-risk 

rankings also incorporated the conservation concern listings prepared by other agencies and specialist 

groups focused on the conservation of Alaska birds (ADFG 2015). 
3. Affected Environment and Environmental Consequences (Birds)

3-86 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Steller’s eiders, the smallest of the four eider species, are tundra-nesting sea ducks. Their primary breeding 

range is in eastern Siberia, where they nest in wet tundra near freshwater ponds with and without 

emergents18 (Fredrickson 2001; Safine 2013, 2015; Graff 2016). The Alaska-breeding Steller’s eider, 

belonging to a larger Pacific population, was listed under the ESA as a threatened species in 1997 (62 FR 

31748–31757). Critical habitat was designated for Steller’s eiders in western Alaska, but no critical habitat 

was designated on the North Slope. Although the nesting distribution on the North Slope once extended 

eastward to Demarcation Bay, most Steller’s eiders nest in the Utqiaġvik area (Quakenbush et al. 2002). 

Although Steller’s eiders could occur in the program area, it would be unusual. The species is considered 

to occur only as a rare visitor in the program area (Table J-9 in Appendix J) and is not expected to nest 

that far east on the ACP.

The spectacled eider is a medium-sized eider, breeding on tundra in arctic and western Alaska and eastern 

Siberia and spending the rest of the year at sea, after young can fly (Petersen et al. 2000). The spectacled 

eider was listed as threatened in 1993, after a severe decline of the species on the Yukon-Kuskokwim 

Delta (58 FR 27474–27480). Critical habitat was designated in 2001 in Ledyard Bay in the Chukchi Sea and 

in other areas of western Alaska (66 FR 9146–9185). No critical habitat occurs in the program area. The 

spectacled eider breeds primarily on the Arctic coast from Point Lay and Utqiaġvik to the Sagavanirktok 

River (USFWS 1996). The spectacled eider is an uncommon breeder in the program area, and nests have 

been documented only on the Canning River delta (Latty, unpublished data). The program area is in a lowdensity region for pre-nesting spectacled eiders. ACP aerial surveys from 2012 to 2015 recorded low 

densities of pre-nesting spectacled eiders in those portions of the program area that were surveyed (0 to 

0.07 birds/square kilometer) (Map 3-14, Nest Sites, Observations, and Density of Pre-Nesting Spectacled 

Eider, in Appendix A). The distribution of nesting is unknown in the program area because extensive 

surveys have not been undertaken. Low numbers of spectacled eiders are expected to occur in the 

program area during the pre-nesting period, where suitable habitat is available. 

Waterbirds

As treated in this EIS, waterbirds on the ARCP are waterfowl, loons, grebes, and cranes. Thirty-seven 

species of waterbirds have been observed on the ARCP. Of these, 23 species are confirmed breeders or 

migrants (or both), and 14 are casual, accidental, or rare visitors (Table J-9 in Appendix J). The group of 

23 breeders/migrants includes 13 species of ducks, 4 geese, 3 loons, 2 swans, and 1 crane. Of these 23 

species, 3 are BLM sensitive species (BLM 2018b [in prep.]), 2 are USFWS birds of conservation concern 

(USFWS 2008a), and 4 are ADFG at-risk species (ADFG 2015) (Table J-9 in Appendix J). Waterbirds, 

especially ducks and geese, are an important subsistence resource for residents in Kaktovik (summarized in 

USFWS 2015a).

Seventeen waterbird species are fairly common, common, or abundant in the program area as either 

breeders or migrants: greater white-fronted goose, snow goose, brant, cackling goose, tundra swan, 

American wigeon, northern pintail, greater scaup, king eider, common eider, surf scoter, white-winged 

scoter, long-tailed duck, red-breasted merganser, red-throated loon, Pacific loon, and yellow-billed loon 

(Pearce et al. 2018). Since 1986, the USFWS has conducted annual aerial surveys of much of the ACP of 

Alaska to generate indices of breeding waterbird population size and trends over time (Stehn et al. 2013); 

however, prior to 2018 only about a quarter of the area was included, and it was surveyed at the lowest 

intensity, making estimates of waterbird abundance and distribution across the program area relatively 

unreliable.

 

18A water plant whose leaves and flowers appear above the surface
3. Affected Environment and Environmental Consequences (Birds)

Coastal Plain Oil and Gas Leasing Program 3-87

Draft Environmental Impact Statement

Breeding waterbirds generally arrive on the coastal plain of the North Slope in late May and June and begin 

nesting from late May through June (Johnson and Herter 1989). In addition to water body shorelines and 

islands, most waterbirds use a variety of wet and moist tundra habitats for nesting, often next to water 

(but see Common Eider below). After hatching in July and August, most waterbirds occupy lakes and ponds 

to rear their young, although geese and cranes graze in tundra wetlands. In the late summer, post-breeding 

and molting (temporarily flightless) waterbirds use coastal lagoons behind the barrier islands. Waterbirds 

continue to forage in the lagoons in the fall as they stage for the southward migration. Various migration 

routes and wintering areas are used by different species of waterbirds. Most waterfowl (swans, geese, 

ducks) migrate through the central continent to wintering areas across the continental US. 

Common Eider and King Eider

Common and king eiders are an important subsistence resource for North Slope residents. The USFWS 

conducts annual aerial surveys to estimate the number, distribution, and population trend of breeding 

common eiders in coastal habitats on the North Slope, including Arctic Refuge lands (summarized in 

USFWS 2015a) (Map 3-15, Post-Breeding and Fall Staging Common Eider, in Appendix A). Common 

eiders have been increasing in abundance on their barrier island breeding grounds in the Arctic Refuge 

since 1976, when only 14 nests were found. In a 2015 ground-based survey conducted across most Arctic 

Refuge barrier islands, over 800 common eider nests were found (Latty, unpublished data). Common 

eiders winter in coastal areas from the Aleutian Islands south to southern Alaska. Migration routes of 

common eiders in the Beaufort Sea are generally within 30 miles of shore, and routes are affected by the 

occurrence of open water leads in spring. Common eiders undertake a spectacular molt migration of 

several hundred thousand birds from the Beaufort Sea to coastal areas in western Alaska along the 

Chukchi sea coast. 

King eiders are abundant in the Beaufort Sea area, including the program area (Johnson and Herter 1989). 

They nest primarily in tundra wetlands, and low densities (0.3–0.8 nests/square kilometer) have been 

documented in the Arctic Refuge (Johnson and Herter 1989) (Map 3-16, Post-Breeding and Fall Staging

King Eider, in Appendix A). Barry (1974) estimated that about a million king eiders migrate into and 

through the Beaufort Sea area. Most of these birds nest on high arctic islands of Canada. Spring migrating 

king eiders come close to land only as they pass specific points, including Point Barrow and sites primarily 

in the Northwest Territories; offshore lead systems in pack ice are the primary determinant of routing and 

timing. King eiders undertake a spectacular molt migration from nesting areas to molting areas in the 

Chukchi and Bering Seas. As in spring, much of this migration occurs offshore and is most conspicuous at 

Point Barrow and Cape Bathurst in the eastern Beaufort Sea, which is much less conspicuous along much 

of the intervening coast (Johnson and Richardson 1982). King eiders are not abundant during fall surveys of 

coastal lagoons in the Arctic Refuge (Lysne et al. 2004).

Waterbird Use of Coastal Lagoons

Many waterbirds in the post-breeding period use the coastal lagoons behind the common barrier islands 

along the program area’s coast (Map 3-15, Map 3-17, Post-Breeding and Molting Surf Scoter, Map 3-18,

Post-Breeding and Molting Long Tailed Duck, and Map 3-19, Post-Breeding and Fall Staging Yellow-Billed 

Loon, in Appendix A). In aerial surveys of nearshore waters and barrier islands conducted during the 

early post-breeding period (early July 1999–2009), 17 waterbird species were recorded regularly (Dau and 

Bollinger 2009). The most abundant species recorded was surf scoter (average of 2,173 individuals), 

followed by long-tailed duck (average of 819 individuals), common eider (average of 593 individuals), and 

glaucous gull (average of 553 individuals) (from data summary by Pearce et al. 2018). In aerial surveys 

conducted later in the season (late July and early August 2002 and 2003), thousands more long-tailed ducks 
3. Affected Environment and Environmental Consequences (Birds)

3-88 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

were observed, with over 28,000 birds recorded in one year (Lysne et al. 2004). These data suggest that 

long-tailed ducks from a larger geographic area move to coastal lagoons in the Arctic Refuge in late 

summer and fall. 

During those same aerial surveys conducted in fall 2002 and 2003, up to 20, 28, 29, 33, and 41 percent of 

the yellow-billed loons, red-throated loons, long-tailed ducks, scaup, and Pacific loons, respectively, 

counted across the entire North Slope survey area were in the lagoons and nearshore areas along the 

Arctic Refuge coast. It is likely that many of the birds using lagoons along the Arctic Refuge coast during 

post-breeding nested to the east, particularly in northern Canada.

Snow Geese

Up to 325,000 snow geese of the Western Arctic Population use the ARCP as a staging area for fall 

migration (USFWS and BLM 2018) (Map 3-20, Frequency of Occurrence of Snow Goose Flocks with 

>500 Birds observed During Aerial Surveys, 1982-2004, in Appendix A). They come primarily from the 

large nesting colony on Banks Island and from much smaller nesting colonies on the North Slope and in 

western Canada to graze in upland and coastal tundra habitats (Hupp et al. 2002). The breeding population 

on Banks Island more than doubled, from 200,000 in the early 1990s to 500,000 in 2013 (Pacific Flyway 

Council 2013). The population breeding across the entire coastal plain of the North Slope also increased 

dramatically in that time (Burgess et al. 2017; Hupp et al. 2017). In the last surveys of staging snow geese 

on the ARCP conducted in 2004, 189,636 individuals were recorded (USFWS 2015a). If trends in staging 

reflect population trends in breeding areas, the number of geese staging in the program area was likely 

higher in recent years. Snow geese depend on this staging period to build energy reserves for their 

southward migration (Brackney and Hupp 1993). Following staging on the ARCP and areas east to the 

Canada border, snow geese migration takes birds south through Alberta and Manitoba and to wintering 

areas primarily in central California.

Shorebirds

Thirty-three shorebird species have been recorded on the ARCP, 21 of which are confirmed breeders or 

migrants or both, and 12 are casual, accidental, or rare visitors (Table J-9 in Appendix J). The group of 

21 breeders/migrants includes 16 sandpiper species, three plovers, and two phalaropes. As a group, 

shorebirds are of increasing conservation concern, as many species have been undergoing population 

declines over the past several decades. Of the 21 breeding/migrant shorebird species, 4 are BLM sensitive 

species (BLM 2018b [in prep.]), 4 are USFWS birds of conservation concern (USFWS 2008a), and 9 are 

ADFG at-risk species (ADFG 2015) (Table J-9 in Appendix J).

Seventeen shorebird species are fairly common, common, or abundant in the program area as either 

breeders or migrants: black-bellied plover, American golden-plover, semipalmated plover, upland 

sandpiper, whimbrel, ruddy turnstone, stilt sandpiper, sanderling, dunlin, Baird’s sandpiper, buff-breasted 

sandpiper, pectoral sandpiper, semipalmated sandpiper, western sandpiper, long-billed dowitcher, red-neck 

phalarope, and red phalarope (Pearce et al. 2018). 

Shorebirds arrive on the North Slope in mid-May through June. Most begin nesting in June, though a small 

number begin laying eggs in late May and into early July (Saalfeld and Lanctot 2015). Shorebirds use a wide 

range of aquatic, wet, and moist tundra habitats for nesting, often near bodies of water. Brown et al. 

(2007) conducted surveys of breeding shorebirds in June 2002 and 2004; they recorded 14 shorebird 

species and estimated that 230,000 shorebirds (95 percent confidence interval (CI) of 104,000 to 363,000) 

occupied the program area during the breeding season. 
3. Affected Environment and Environmental Consequences (Birds)

Coastal Plain Oil and Gas Leasing Program 3-89

Draft Environmental Impact Statement

Species richness and density typically were highest in coastal wetland and riparian habitats and near river 

deltas. Among wetland plots, densities were highest near the Canning River delta on the western edge of 

the program area. In a review of studies conducted across the entire North Slope, Johnson et al. (2007) 

determined that shorebirds were more abundant near the coast than farther inland and that species 

richness was highest to the west, in the NPR-A; however, several species were more common in the east, 

reflecting differences in distribution among individual species across the coastal plain of the North Slope. 

After hatching, most shorebirds use open tundra and shorelines to rear their young; as the young become 

flight capable, they begin to forage on the coast. In late July through September, shorebirds stage on ARCP 

river deltas for the fall migration to wintering areas in the Americas and Asia. Most of the deltas are used 

by large numbers of foraging shorebirds, with the Jago River delta being one of the most heavily used areas 

(summarized in USFWS 2015a and Pearce et al. 2018). Most of the shorebirds foraging in the river deltas 

in late summer and fall are juveniles hatched earlier in the summer. 

The data from birds marked with radio transmitters indicate that individuals that migrate via the Central 

Flyway use multiple river deltas as they gradually migrate eastward across the ARCP. Shorebirds continue 

migrating south to Central and South American coasts.

Larids

Larids on the ARCP are gulls, jaegers, and terns. Sixteen larid species have been recorded, 9 of which are 

confirmed breeders or migrants, or both, and 7 are casual, accidental, or rare visitors (Table J-9 in 

Appendix J). The 9 breeding/migrant species are pomarine jaeger, parasitic jaeger, long-tailed jaeger, ivory 

gull, Sabine’s gull, Ross’s gull, mew gull, glaucous gull, and arctic tern. None of these are BLM sensitive 

species (BLM 2018b [in prep.]), one is a USFWS bird of conservation concern (USFWS 2008a), and none 

are ADFG at-risk species (ADFG 2015) (Table J-9 in Appendix J). Three additional larid species (blacklegged kittiwake, glaucous-winged gull, and herring gull) occur along the marine vessel route to Dutch 

Harbor (Audubon Alaska 2017). 

Larids arrive on the North Slope roughly at the same time as shorebirds, in mid-May through June 

(Johnson and Herter 1989). They breed across the ARCP in a range of habitats, including open tundra 

(primarily jaegers), shores and islands on tundra lakes, and on the barrier islands (primarily gulls and terns). 

During the breeding season, the smaller gulls and terns generally feed on aquatic invertebrates and small 

fish, whereas jaegers largely prey on small mammals, birds, and eggs. 

The single larger gull species (glaucous gull) is omnivorous and can prey on small birds and eggs. Local 

residents report that glaucous gull populations on the ARCP have been increasing, and there is some 

evidence of increases in gull populations in the Arctic generally (National Research Council 2003). These 

increases could be due to global changes in their populations or increased human development in the area 

(Weiser and Powell 2010). There are numerous accounts of glaucous gulls foraging in North Slope landfills. 

Distribution maps from aerial surveys indicate that gulls tend to concentrate in the vicinity of human 

development on the coastal plain of the North Slope, including Kaktovik on the Arctic Refuge (summarized 

in USFWS 2015a).

Raptors

As treated in this EIS, raptors on the ARCP are eagles, hawks, falcons, and owls. Thirteen raptor species 

have been recorded on the ARCP, 6 of which are confirmed breeders or migrants, or both, and 7 are 

casual, accidental, or rare visitors (Table J-9 in Appendix J). The 6 breeding/migrant species are roughlegged hawk, golden eagle, gyrfalcon, peregrine falcon, snowy owl, and short-eared owl. None of these are 
3. Affected Environment and Environmental Consequences (Birds)

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Draft Environmental Impact Statement

BLM sensitive species or USFWS birds of conservation concern (BLM 2018b [in prep.]; USFWS 2008a), 

but 4 are ADFG at-risk species (ADFG 2015) (Table J-9 in Appendix J). Northern harriers are an 

uncommon summer resident and both northern harrier and merlin also may breed in the program area 

(USFWS 2015a). Golden eagles are protected under the Bald and Golden Eagle Protection Act. The arctic 

peregrine falcon subspecies, which breeds on the ARCP, was previously listed as endangered under the 

ESA, but it has been delisted (USFWS and NMFS 2014).

In the Arctic Refuge, nesting of raptors begins from late March to early May (Young et al. 1995). Some 

snowy owls winter on Arctic breeding grounds, but most arrive on the North Slope during April and May, 

with most egg laying in mid-May (summarized in Holt et al. 2015). The remaining raptors arrive and begin 

nesting in May and early June (Johnson and Herter 1989). 

Golden eagles nest almost exclusively in cliff habitats and, in the program area, they nest primarily in the 

Brooks Range foothills, as cliff habitat appropriate for eagles is rare elsewhere on the ARCP. Breeding 

golden eagles return to Alaska, presumably including the Arctic Refuge, from late February to mid-April, 

with nonbreeders arriving later (summarized in Kochert et al. 2002). Golden eagles are commonly 

observed on the ARCP in late June and early July, when calving and post-calving caribou herds are present; 

these are primarily subadult birds that are preying on or scavenging caribou calves (summarized in USFWS 

2015a). In a 1983–1985 study, golden eagles were the main predators of caribou calves on the calving 

grounds (Whitten et al. 1992; Griffith et al. 2002). It also appears that golden eagles from other regions in 

the state use northern Alaska, including the Brooks Range and ARCP. Eagles that hatched in the Alaska 

Range were found in the Arctic Refuge during at least two subsequent summers (summarized in USFWS 

2015a). 

Surveys on the ARCP were conducted on the Canning, Hulahula, and Kongakut Rivers in the 1990s and 

early 2000s to monitor cliff-nesting raptors (summarized in USFWS 2015a). Raptors nesting on cliffs along 

these rivers are golden eagles, peregrine falcons, gyrfalcons, and rough-legged hawks. In the program area, 

cliff nest habitats occur primarily in river corridors; in the surveyed areas the overall abundance of nesting 

raptors generally was found to be low.

The two owl species, snowy owl and short-eared owl, that breed on the ARCP are variable in abundance 

among years. As in other regions on the North Slope, both species are substantially more common as 

breeders in years of high vole or lemming abundance (Johnson and Herter 1989).

Landbirds

As treated in this EIS, landbirds on the ARCP include a diversity of species that are strongly dominated in 

abundance by passerines19 and ptarmigan. Fifty landbird species have been recorded on the ARCP, but 32 

of these are casual, accidental, or rare visitors; only 18 are confirmed breeders, permanent residents, or 

migrants (Table J-9 in Appendix J); this includes 16 passerines and 2 ptarmigan species. None of the 18 

breeding/migrant landbird species are BLM sensitive species or USFWS birds of conservation concern 

(BLM 2018b [in prep.]; USFWS 2008a), and 8 are ADFG at-risk species (ADFG 2015) (Table J-9 in 

Appendix J).

Most landbirds on the coastal plain of the North Slope are migrant species that arrive in mid-May through 

June and begin nesting shortly thereafter (Johnson and Herter 1989). The willow ptarmigan, rock 

ptarmigan, and common raven are year-round residents. By far the most abundant landbird species on the 

 

19Perching birds
3. Affected Environment and Environmental Consequences (Birds)

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ARCP is Lapland longspur, which nests throughout the area in wet and moist tundra habitats. Other 

relatively common species on the ARCP are rock ptarmigan (found throughout the area), willow 

ptarmigan (more common inland), common raven (found throughout the area), eastern yellow wagtail 

(most common in riparian areas), common and hoary redpoll (found throughout the area), snow bunting 

(more common on the coast), savannah sparrow (more common inland), and American tree sparrow and 

white-crowned sparrow (more common inland) (Pearce et al. 2018).

Seabirds

Seabirds occurring in marine waters next to the ARCP are fulmars, shearwaters, and alcids. Seven seabird 

species have been recorded in marine waters off the ARCP, but 5 of those species are casual, accidental, 

or rare visitors. Only the black guillemot occurs as a rare breeder on barrier islands, and the thick-billed 

murre as a rare migrant (Table J-9 in Appendix J). Of the 2 breeding/migrant seabird species, neither is 

a BLM sensitive species or USFWS bird of conservation concern (BLM 2018b [in prep.]; USFWS 2008a), 

and neither is an ADFG at-risk species (ADFG 2015) (Table J-9 in Appendix J).

Thirteen additional seabird species are present along the marine vessel route to Dutch Harbor, including 

alcids (auklets, murres, and puffins) and cormorants (Audubon Alaska 2017) (Table J-10 in Appendix J). 

The federally endangered short-tailed albatross may be present in southernmost portion of the route.

Climate Change

The changing climate has varied impacts on bird species, depending on the species considered and how 

dramatically the vegetation and hydrology are responding to the changes. Some bird species could benefit 

from longer breeding seasons and expansion of shrub and coastal habitats, while others could lose habitat, 

food, or prey, and could experience seasonal mismatches in breeding and plant/insect phenology. 

Climate change is expected to increase temperatures, increase precipitation, and lengthen the snow-free 

season (see Section 3.2.1). Summer temperatures above freezing could occur for 6 weeks longer by 

2099 (SNAP 2011). Warmer temperatures and earlier snowmelt would likely change the timing of seasonal 

events on the North Slope, but it is unclear how bird populations would respond. For birds, climate 

change would affect phenology (seasonal timing of events), habitat and forage availability, and range 

expansion. 

It is unclear whether some or all birds would be able to arrive earlier to take full advantage of an earlier 

and longer breeding season; however, a delay in freeze-up in fall should be advantageous to the slowgrowing young of such species as loons and swans, which are not always flight capable by time of freeze-up. 

With earlier thaws and snowmelt, insect populations would hatch earlier (McKinnon et al. 2012). Some 

species of insect-feeders (shorebirds and songbirds) can initiate nests earlier with early snowmelt, whereas 

others (jaegers, common eiders, and raptors) do not; however, it is unclear if birds relying on insects to 

feed their young (songbirds and shorebirds) could adapt to hatch at the optimum time as insect hatch 

continues to advance (Grabowski et al. 2013). Plant biomass is predicted to increase with warmer 

temperatures, but forage quality is seasonal. Mismatches in insect abundance and forage quality with timing 

of bird reproduction would likely have adverse effects on growth rates of young of some species (Dickey 

et al. 2008; McKinnon et al. 2012). 

Avian habitat is likely to change slowly with climate change, except for coastal areas subject to erosion and 

deposition (see below). Waterbodies in the program area may shrink, depending on the balance of 

precipitation, evapotranspiration, and drainage from thermokarsting and a deeper active layer in soils. 
3. Affected Environment and Environmental Consequences (Birds)

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Some shorebirds (particularly phalaropes), waterfowl, and loons could face reduced availability or quality of 

nesting and brood-rearing habitats (Martin et al. 2009). 

Increases in shrubs and trees have been documented (Sturm et al. 2001b; Tape et al. 2006) and are 

expected to continue with increasing summer temperatures. If available wet sedge and graminoid meadows 

are reduced by invading shrubs and decreasing moisture, it may result in shifts in the breeding bird 

community. Shrub- and tree-nesting birds (passerines, such redpolls, sparrows, and thrushes) may become 

more numerous, and tundra nesting birds (longspurs, savannah sparrows, shorebirds, geese, and eiders) 

may decline. With a longer breeding season and increases in shrub and tree cover, breeding species more 

typical of boreal forest areas to the south may extend their ranges northward and possibly compete with 

current tundra breeders for resources. 

Coastal habitats are likely to change quickly with increased water temperature, reduced sea ice, rising sea 

level, and increasing storm surges and wave action. Erosion of barrier islands and ice-rich coastlines from 

mechanical process and thawing can happen rapidly; current rates of loss along the Beaufort Sea coastline 

is 6.5 to 59 feet per year (see Martin et al. 2009 for review). 

River deltas may grow from deposition of sediment, while barrier islands, which form the lagoon areas 

important to post-breeding birds, may be losing area to storm surges, while accreting less material from 

ice-push events in the future. Erosion of coastal shorelines could increase inundation of tundra by salt 

water; the resulting salt-killed tundra may be colonized by salt-tolerant species and develop into salt marsh, 

a rare but important post-breeding habitat for geese (Flint et al. 2003). 

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms,

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

birds from on-the-ground post-lease activities.

Potential impacts of oil development on birds are four primary categories of effects: habitat loss and 

alteration, disturbance and displacement (including alteration of behavior), injury and mortality, and 

attraction of predators and scavengers (including both mammals and birds) to human activity or facilities, 

with subsequent changes in predator abundance (Eberhardt et al. 1982; Truett et al. 1997; Burgess 2000; 

Stickney et al. 2014). The season in which activities occur would either moderate or accentuate the effects 

on birds. Winter activities would affect few species and low numbers of year-round residents. Summer 

activities would affect breeding birds during the nesting, brood-rearing, molting, and fall migration-staging 

seasons, when many species are present in high numbers and potential population-level consequences of 

impacts are greatest.

Although many future activities, such as vehicle traffic, would occur during exploration, construction, 

drilling, and operations of a development project, the potential intensity of impacts on birds differs among 

phases. Exploration occurs during winter and would have little direct effect on birds; indirect effects would 

occur only from ice roads and rolligon traffic on vegetation and terrain surfaces and impacts on habitat 
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quality from water removal. Human-caused disturbance and displacement would peak during the 

construction phase, which involves the largest number of people, temporary construction camps, and the 

highest levels of vehicle, machinery, heavy-haul equipment, and aircraft traffic. Habitat loss also would peak 

during construction, including the building of ice roads to support gravel extraction, gravel hauling, gravel 

road and pad construction, bridge construction, and pipeline construction. 

Future barging and in-field transport of CPF modules would occur early in the construction phase of any 

development project and would also affect birds through habitat loss and disturbance. The drilling phase of 

a development project would require less personnel and traffic than during construction, but still higher 

levels than during operations. Air traffic and vehicle traffic would peak during construction and drilling 

because personnel numbers peak during construction and materials transport during drilling. Traffic rates 

would be lower during operations.

Schedules of development projects in the program area are unknown, but foreseeable hypothetical 

scenarios indicate extensive overlap of exploration, construction, drilling, and operation phases of 

potentially several different projects with different operators. In terms of impacts on birds, activities and 

areas affected would increase until the limit of 2,000 acres of surface disturbance is reached in years or 

perhaps decades after initial project construction. These activities would be dispersed in different parts of 

the area available for lease over that period.

For most actions, potential impacts can be described only qualitatively, either because resource and impact 

data are unavailable or because project-specific details are uncertain or unknown at the time of this 

preliminary analysis; however, for some habitat impacts and for some types of behavioral disturbance, 

semiquantitative estimates of areas affected are possible, with some assumptions regarding the likely 

configuration of a development project. 

Potential direct effects resulting from future on-the-ground actions on avian habitats would occur in the 

footprint of gravel fill, whereas indirect effects on habitat would occur at varying distances, depending on 

the source. Fugitive dust, gravel spray, thermokarsting, and impoundments may affect soils and vegetation 

up to 328 feet from roads and pads (see Section 3.3.1). Disturbance and displacement could occur over 

a larger area. When estimating the incidental take of spectacled eiders that would be caused by the 

construction and operation of oilfield infrastructure, the USFWS considers the direct loss of habitat due to 

gravel fill plus indirect loss in an adjacent zone of influence (estimated to be 656 feet wide), where 

disturbance could prevent spectacled eiders from nesting. Implicit in this method of estimating impacts is 

the assumption that displaced pairs would not move and nest successfully elsewhere. 

Using the schematic anchor-field footprint,20 the BLM calculated estimates of the area within 328 feet, for 

impacts of dust fallout, gravel spray, thermokarsting, and impoundments, and within 656 feet for impacts of 

disturbance and displacement. Using these standardized footprints and extrapolating to a 2,000-acre 

maximum gravel footprint, the BLM estimated total acres indirectly affected by habitat alteration and by 

disturbance and displacement and then compared these areas with areas available for lease under each 

action alternative. The effects of climate change described under Affected Environment above, could 

influence the rate or degree of the potential direct and indirect impacts.

 

20One CPF and 6 radiating 8-mile access roads to 6 drill pads, including an STP pad and a 30-mile access road, 

totaling 750 acres
3. Affected Environment and Environmental Consequences (Birds)

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Draft Environmental Impact Statement

Alternative A

Under this alternative, current management actions would be maintained, and resource trends would 

continue, as described in the Arctic Refuge CCP (USFWS 2015a). No direct or indirect impacts on birds 

from post-leasing oil and gas activities would occur under Alternative A.

Impacts Common to All Action Alternatives

The following actions and types of potential effects would be common to all action alternatives, but the 

avian resources affected (e.g., total area, specific habitats, bird species, and bird densities) would vary based 

on the location of facilities in each action alternative. 

Habitat Loss and Alteration

Habitat would be temporarily altered from future winter ice roads and pads. Ice road alignments are 

unavailable for calculating areas affected, but proposed use of ice roads is extensive under all action 

alternatives, including an annual ice road between the program area and the Prudhoe Bay/Deadhorse road 

system. Ice roads and pads can interfere with natural drainage of spring runoff; additional habitat alteration 

can occur through vegetation damage, including reduced live and dead cover due to crushed standing plant 

cover, stem and blade breakage, compaction, freezing, and physical damage (see Section 3.3.1). Although 

recovery of sedges, grasses, and forbs may occur in two to three growing seasons (Pullman et al. 2005), 

tussocks and woody shrubs often take longer to recover (Yokel et al. 2007). 

Vegetation damage is most severe and takes longer to recover in well-drained areas, including moist 

tundra and shrub habitats, which support higher densities of passerines, ptarmigan, and some shorebirds, 

like whimbrel and American golden-plover. In contrast, aquatic and wet tundra habitats, which are favored 

by most waterbird species (Derksen et al. 1981; Johnson et al. 2003, 2005, 2007), generally are damaged 

less by ice roads and recover more quickly (Guyer and Keating 2005; Pullman et al. 2005). Habitat 

alterations from ice roads are likely, and their impacts would be short to long term, depending on the 

types of vegetation affected and whether routes and pad sites are reused in multiple years. 

Water source lakes may include those used by a variety of birds. Future drawdowns may change the 

abundance and distribution of foods on which birds rely. Drawdowns may also affect shorelines, degrading 

habitat for a variety of waterbirds and shorebirds. For example, lower water levels could eliminate 

important nesting sites on islands and peninsulas and may reduce fish prey, with particular impacts on 

breeding Pacific and red-throated loons. Although water withdrawals would be limited to permitted lakes 

and to permitted percentages of total lake volume to protect resident fish, water withdrawals could cause 

lower lake levels and exceed natural recharge (see Section 3.2.10). 

Withdrawing water from under ice could affect water chemistry and turbidity and possibly result in some 

fish mortality and impacts on aquatic invertebrate communities (see Section 3.3.2, Fish and Aquatic 

Species). Drawdowns may cause fish mortality, and lack of fish would make such lakes unsuitable for 

breeding loons. The long-term loss of nesting lakes would have potential population consequences for 

loons, primarily for Pacific and red-throated loons; yellow-billed loons in the Arctic Refuge nest primarily in 

the northern foothills of the Brooks Range and outside of the program area. 

Gravel would be mined in the future during winter at several unidentified material sites and transported 

over gravel roads or ice roads or both. Reclamation would consider gravel’s potential use for enhancing 

fish and wildlife habitat. Some pits remaining from excavation would be used as water sources during 

drilling and operations. Avian habitats would be lost to material sites, but rehabilitated sites would likely be 

used by some species of nonbreeding, breeding, and brood-rearing waterbirds. The potential habitat loss 
3. Affected Environment and Environmental Consequences (Birds)

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or alteration from gravel excavation would affect up to 320 acres of surface disturbance; the impact on 

birds would be long term and somewhat ameliorated by reclamation plans (i.e., terrestrial breeding 

habitats could be replaced by aquatic habitats).

Future construction of gravel pads and roads would result in potential; long-term direct loss of habitat and 

indirect alteration of habitat. Direct losses from gravel coverage (up to 2,000 acres allowable) would last as 

long as development projects are active, or until gravel is partially removed from retired roads and pads to 

restore some habitat features; this is estimated to be 85 years after the first lease sale before all facilities 

described in the hypothetical development scenarios are abandoned and reclaimed. 

Potential indirect habitat modification would result from fugitive dust (i.e., dust shadow) and gravel spray, 

changes in drainage resulting in impoundments and vegetation desiccation, thermokarsting, and delayed 

melt of snow in snow drifts or berms created by snow removal. Fugitive dust would generally affect the 

largest area, extending as much as 328 feet from gravel roads (see Section 3.3.1; Walker and Everett 

1987). 

Using a hypothetical schematic drawing of a standardized anchor field (one CPF and 6 radiating 8-mile 

access roads to 6 drill pads, one STP pad, and a 30-mile access road, totaling 750 acres), the area within 

328 feet for impacts of dust fallout, gravel spray, thermokarsting, and impoundments was estimated to be 

about 6,607 acres. The actual area potentially affected would depend entirely on the configuration of 

roads, but these numbers indicate that indirect impacts of gravel roads and pads would affect an additional 

area about 7 to 8 times larger than the gravel footprint. 

Potential effects on waterbirds would be minimized by using the shortest road routes and smallest pads 

and by placing gravel in uplands and well-drained habitats composed of moist and shrub tundra. Such 

habitats support higher densities of landbirds and impacts on these species could be greater as a result. 

Habitat alteration caused by fugitive dust, thermokarsting, and water impoundments intensifies with time. 

As dust and gravel spray accumulate, vegetation is slowly affected, and thermokarsting deepens or spreads. 

Potential loss and alteration of habitat from direct effects of gravel deposition and indirect effects of dust, 

thermokarsting, and impoundments would be long term and would occur over about 17,000 acres (2,000 

acres total gravel footprint plus approximately 15,000 acres within 328 feet), or about 1 percent of the 

program area (1,563,500 acres). For some species of tundra nesting birds, habitat loss due to gravel 

placement redistributes individual nesting pairs to adjacent similar habitats (Troy and Carpenter 1990; 

Johnson et al. 2003).

Future screeding for barge access would result in short-term (one season) habitat modification in the 

affected lagoon just prior to each barge arrival. Each potential CPF module is expected to be shipped on 

two barges, CPFs would be built at 10- to 15-year intervals, and up to three could be active at any one 

time. Screeding would modify the sea floor in shallow water. The area of potential screeding and 

redistribution would likely be lost in the short term to benthic feeding birds and would create a sediment 

plume that could disrupt feeding by non-breeding, post-breeding, and staging birds. Although high numbers 

of birds use the lagoons, they are highly mobile and likely would be able to move to adjacent similar areas 

if necessary.

Long-tailed ducks made up 80 percent of the birds on surveys during late summer and fall in nearshore 

waters of the Beaufort Sea (Fischer et al. 2002). Other species included many of those potentially breeding 

in the program area, plus common eiders and scoters. Potential habitat alteration in the area is expected 
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to be brief, occurring only during screeding and vessel travel. Habitat alteration impacts from screeding are 

expected to be of short duration and would occur in localized areas.

Disturbance and Displacement

The impact of disturbance refers to behavioral and potential physiological reactions to perceived disturbing 

stimuli, which may be visual or aural. Displacement occurs when the organism moves to another site or 

area that is free from the disturbing stimulus. For example, alert postures, concealment postures, and 

escape all are potential behavioral reactions and may or may not be accompanied by changes in heart rate, 

endocrine states (including stress), and increased energy expenditure. For nesting birds, displacement is 

less available as an option than it would be for non-nesting birds that are not attached to a nest site. Many 

types of human activities in bird habitats would result in either disturbance or displacement of birds. 

Future gravel transport and placement and pipeline construction would take place in winter from ice roads 

and, after initial construction, from existing gravel roads. Traffic and machinery related to winter 

construction could cause disturbance, behavioral alterations, and displacement to resident wintering birds. 

In the event that ice road use is permitted into April, some early arriving breeding birds could also be 

affected, primarily golden eagles and snowy owls. Although winter construction activity would involve 

more traffic and machinery than other phases, potentially resulting in higher levels of disturbance and 

displacement, only small numbers of only a few bird species are resident during winter, and none are 

breeding. Winter construction therefore would potentially affect small numbers of non-breeding birds 

during the construction phase of a development project.

Future construction activities during summer would occur on gravel roads and pads, which could cause 

short-term behavioral changes or displacement of breeding birds. Summer construction would involve 

gravel grading and compacting, module and pipeline hookups, and construction of the camp, operations 

center, and CPF. Summer construction would have higher levels of machine, heavy equipment, and vehicle 

traffic and more human activity than during drilling or operations, thus higher rates of disturbance-caused 

behaviors and displacement of birds. During drilling and operations, similar types of disturbance and 

displacement would continue, and additional helicopter, boat, and human activity likely would occur 

associated with pipeline inspection and maintenance, surveying, cleanup, and spill prevention and response 

activities, such as equipment deployment and maintenance and boom placement on waterways. 

Human-caused disturbance could cause behavioral changes in birds, ranging from alert postures to flush or 

flight behaviors (Murphy and Anderson 1993; Johnson et al. 2003; Livezey et al. 2016). At low levels, 

disturbance could increase the occurrence of concealment postures, interfere with resting and feeding 

activities, and increase energetic costs. At higher levels, escape behaviors could affect reproduction 

through increased absences from nests and nest abandonment, thereby increasing the likelihood of 

predation leading to nest failure (Uher-Koch et al. 2015; Stien and Ims 2015) or disintegration of broods 

and chick predation. Although foot traffic on the tundra would be uncommon with most development 

activities, reduced productivity due to disturbance by foot traffic is the most consistently reported effect of 

human presence at nesting sites (Meixell and Flint 2017). Human disturbance can lead to displacement of 

breeding birds (Johnson et al. 2003), which may or may not affect reproduction. Studies of bird responses 

to human disturbance in oilfields indicate that responses vary among species, by season and breeding 

status, by type of human disturbance, and by distance to the source of disturbance (Anderson et al. 1992; 

Murphy and Anderson 1993; Johnson et al. 2003, 2008). 

As discussed previously, for assessment of potential effects of disturbance and displacement by future road 

traffic, the area was calculated within 656 feet of roads, pads, and pipelines as a conservative estimate of 
3. Affected Environment and Environmental Consequences (Birds)

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the area affected by disturbance and displacement for all species of birds. This overestimates the area of 

disturbance for nesting shorebirds and passerines, which respond at very close distances (43 to 72 feet; 

Livezey et al. 2016); however, it likely underestimates the area for more sensitive birds, such as nesting 

tundra swans (at least 1,640 feet or more; Monda et al. 1994).

Future disturbance and displacement could affect nesting within 0.8 miles of active roads (Johnson et al. 

2003). Liebezeit et al. (2009) reported a decrease in nest survival of passerines within 3.1 miles of oilfield 

facilities. A review of literature on reported distances from various motorized and nonmotorized human 

activities, at which nesting birds initially respond and take flight, found all species studied reacted and 

flushed at mean distances of less than or equal to 656 feet, except for falcons, hawks, and eagles; these 

species reacted at greater distances to some disturbance types (Livezey et al. 2016). Fall migration-staging 

flocks may also be subject to disturbance and displacement, such as shorebirds in river deltas, molting longtailed ducks and other birds in lagoons, and snow geese in tundra habitats. 

As for estimating potential habitat impacts, above, a drawing of a hypothetical anchor field was used to 

estimate the area within 656 feet for impacts of disturbance and displacement. The actual area affected 

would depend entirely on the configuration of roads, but with a standardized footprint of 750 acres, an 

additional 11,820 acres of tundra within 656 feet was calculated, an additional area about 15 to 16 times 

larger than the gravel footprint. With a 2,000-acre gravel footprint at peak development, disturbance and 

displacement of breeding birds in tundra habitats could occur over about 31,000 acres, or about 2 percent 

of the program area (1,593,500 acres). Potential impacts of disturbance and displacement by summertime 

construction and operations would be long term and may affect nesting success for some birds near 

facilities; however, they are unlikely to affect regional or global population sizes or nesting densities of 

breeding birds. 

Future screeding and barging would be required to transport modules to Camden Bay early in the 

construction period of each development project. This could displace and disturb normal behavior of birds 

in the nearshore marine environment. Both screeding and barging would involve slow-moving vessels (7 

knots for barges) and would produce noise and visual disturbance. Boat operations for other activities may 

also occur. 

Many seabird species use the nearshore and lagoon waters of the Beaufort Sea, which attracts them 

because of its shallow water for feeding and protection from wind and waves (Flint et al. 2004). Long-tailed 

ducks make up about 80 percent of the birds in nearshore waters of the Beaufort Sea (Fischer et al. 2002) 

and are the predominant bird in the lagoon system. The long-tailed duck molt period, when the ducks are 

flightless, begins in mid-July and ends by early September; this is also the period of highest lagoon use by 

most other species. 

Lysne et al. (2004) recorded over 23,000 long-tailed ducks along the Arctic Refuge coast during a survey in 

late summer 2003. They also reported a substantial portion of yellow-billed loons, red-throated loons, 

scaup, and Pacific loons counted during the entire Alaska North Slope survey, which was done along the 

Arctic Refuge coast during some years. Johnson (1982) reported displacement of long-tailed ducks in 

response to aircraft, boats, and human disturbance. Schwemmer et al. (2011) reported ship traffic affected 

flight reactions in sea ducks and the distribution of loons. Flint et al. (2004) reported that molting longtailed ducks using lagoons in the Beaufort Sea had low but variable fidelity to sites inside barrier islands, 

averaging 39 percent. Sites were occupied consistently, but turnover of individuals was high as flightless 

ducks moved among sites. Site fidelity was not clearly affected by seismic surveys and little evidence was 
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found for disturbance-related displacement of individuals (Flint et al. 2004); aerial surveys did not find a 

difference in density of long-tailed ducks between industrial and control sites (Fischer et al. 2002). 

Potential displacement and disturbance of birds from future screeding and barging would be short term 

and would occur in a relatively small area; other boating activities may also be short term but may occur 

over a broad area and for the duration of a development project. Additional low levels of disturbance and 

displacement of seabirds could occur along the marine vessel route between the ARCP and Dutch Harbor, 

Alaska.

All types of air traffic could disturb and displace both breeding and non-breeding birds. Air traffic 

supporting any future development project in the program area would include aircraft carrying passengers 

and supplies to the airport in Deadhorse and helicopter support primarily during summer. Use of the 

Deadhorse airport, which is the primary hub for the North Slope oil industry, would increase both for 

passenger and freight flights. It is expected that the additional use of the Deadhorse airport would add to 

disturbance levels there, although traffic levels already are high. Potential impacts on birds would be long 

term but would be restricted to the area of the airport in Deadhorse; however, birds in this area already 

experience high levels of disturbance due to current aircraft traffic and airport activities.

Under all action alternatives, helicopters would be used in the future to support ice road layout, survey, 

and summer cleanup and possibly for spill-response equipment deployment and maintenance. These 

activities usually take place in July or early August and last approximately 4 weeks, with daily helicopter 

traffic during that time, involving departures from the helipad and landings at various tundra locations. 

Helicopter flights during July and August would occur during nesting, brood-rearing and molting, and fall 

migration-staging periods for most of the species in the program area. Helicopter landings on tundra could 

cause displacement from nests and separation of broods, which could allow predators to take eggs or 

chicks and thus reduce reproductive output. As young grow and become more mobile or even flight 

capable, helicopter landings and low-level flights would cause escape movements or flight behavior and 

interfere with feeding and resting; however, such effects are usually very short term. The intensity of 

impacts of helicopter flights would vary, depending on number of landings on tundra, landing locations, and 

seasonal timing. Impacts would occur during all development phases and would be extensive in geographic 

scope. 

Air traffic could disturb and displace staging snow geese that visit the eastern coastal plain of the North 

Slope in large numbers in late August and September of most years. As many as 325,760 snow geese have 

been documented using the ARCP, including the program area and east to the Canada border, for several 

weeks, foraging for cottongrass and equisetum in both coastal and upland habitats and building energy 

reserves needed for fall migration (Kendall 2006). They are easily disturbed by aircraft and other human 

intrusions during staging, making them vulnerable to displacement and potentially significant impacts. Davis 

and Wisely (1974) documented flushing distances of staging snow geese on the North Slope up to 8 miles 

from overflying aircraft. Mean distances of flushing for various types of overflights ranged between 1.2 and 

2.5 miles and durations averaged between 5 and 6 minutes, depending on overflight category, such as 

aircraft and altitude. Boothroyd (1985) found similar results and that staging snow geese were the 

waterfowl species in their area most sensitive to aircraft overflights.

Mortality and Injury

Vehicle and aircraft traffic and tall structures, including communication towers and drill rigs, pose collision 

hazards that could kill or injure birds. Little information is available on rates of mortality or injury from 

collisions in the North Slope oilfields. Collisions with vehicles and aircraft would probably be correlated to 
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bird densities and traffic rates. Collisions might increase during breeding, when birds are less focused on 

hazards, and during brood-rearing, when flightless birds would be crossing roads. Reduced speed limits and 

driver awareness of seasonal bird vulnerability could reduce collision risk from vehicles. 

Collisions with tall structures increase with tower height, bright lighting, and the presence of guy wires 

(Manville 2005; Gehring et al. 2011). Weather conditions, such as fog, rain, and low light, increase collision 

mortality of common eiders at towers and transmission lines (MacKinnon and Kennedy 2011). On the 

North Slope, birds often migrate at low altitudes and in foggy conditions; migrating eiders averaged 40 feet 

aboveground level at Point Barrow (Day et al. 2002). BMPs of eliminating guy wires, reducing tower 

heights, and shielding lighting would reduce the risk of collisions with facilities in the program area. 

Collisions with vehicles, aircraft, or structures in the future would likely injure or kill birds. Although the 

risk of collisions is low, the consequences are high, resulting in serious injury or death. Collisions would be 

expected to occur annually in small numbers, but mortalities could be serious if flocks of birds of 

conservation concern are involved. The potential impacts of collisions are short term, infrequent, and 

seasonal in but would occur throughout the life of any development project and would be restricted to 

roads and facilities. 

Oil spills and other releases of contaminants pose risks of injury or death to birds. During future 

exploration and construction, the primary potential for release would be accidental spills from vehicles, 

storage tanks, marine barges and docks, aircraft, and equipment during transport or fueling and during 

pipeline hydrotesting (see Section 3.2.11). Most potential spills would involve refined oils, antifreeze, or 

salt water used in hydro-testing. Crude oil spills would not be a risk during construction. During drilling 

and operation, there may be risks of larger spills, due to well blowout or pipeline failure. 

Small spills are likely, medium-sized spills are possible, and large and very large spills are unlikely. Most spills 

would be fewer than 100 gallons and would be restricted to ice or gravel roads and pads, never reaching 

the tundra. Oil spills on tundra or in water are extremely rare, as are large spills of greater than 10,000 

gallons. Spill containment at strategic points on waterways would likely keep oil from flowing downstream 

into lagoons. Nonetheless, if oil escaped, many species would be vulnerable. 

Potential salt-water spills would not be toxic to birds but would likely kill vegetation in the spill zone and 

thus alter habitat. Somewhat larger spills, such as tanker truck spills of fewer than 10,000 gallons could 

reach tundra and contaminate a few birds, nests, and eggs or their habitat and forage, or they could reach 

streams or lakes, which would spread the effect farther and affect more birds and bird habitats. Potential 

marine spills would likely be very small to small, fewer than 100 gallons, would be localized to docking 

facilities, and would have a very low to low frequency of occurrence. Medium to very large spills in the 

ocean would be possible but very unlikely, requiring a vessel to run aground or somehow have 

containment compartments breached. This could occur in the shipping lanes leading to the docking or STP 

pads. 

Small spills would be short term and of several acres or fewer on land. This is because they are usually 

contained on gravel pads and roads. Marine spills would have similar probabilities for similar volumes, but 

they would occur only during screeding and barging of CPF and STP modules. Large spills would be more 

extensive, with cleanup activities lasting days to weeks, and could pose contamination risk to large 

numbers of molting, feeding, or migrating birds. 
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Attraction to Human Activities and Facilities

Future oil development projects in the program area would likely increase the numbers of scavengers and 

predators in the area, beginning in the construction phase and continuing through operations. Effective 

food and garbage control, wildlife interaction plans, and personnel training should minimize the attraction 

of predators to oilfield facilities; however, the potential for development to attract scavengers and 

predators is a concern in part because increased predator abundance can decrease productivity and 

increase mortality of nesting birds (Truett et al. 1997; Johnson et al. 2010). Liebezeit et al. (2009) detected 

reduced nest survival among Lapland longspurs from predation up to 3.1 miles from oilfield infrastructure. 

Both birds and mammals may be attracted to human activities. Two avian predators, glaucous gulls and 

common ravens, are attracted to human food (Day 1998; National Research Council 2003), and 

populations of these species have increased on the coastal plain of the North Slope (Stehn et al. 2013). On 

the North Slope, ravens and, to a lesser degree, peregrine falcons, gyrfalcons, and rough-legged hawks nest 

on human-made structures, including buildings, elevated pipelines, bridges, towers, drill rigs, and wellheads 

(Ritchie 1991; Frost et al. 2007; Powell and Backensto 2009; Sanzone et al. 2010). Some species of 

songbirds (e.g., snow buntings, common redpolls) also are attracted to human structures for nest sites. 

The potential impact of attracting birds to facilities would vary, depending on the species attracted and 

their predatory effect on species of concern (for example, threatened species) and the duration extending 

longer than 5 years. This would affect most of the program area, as predators are far-ranging.

Foxes and bears also prey on birds and their eggs and are attracted to areas of human activity, where they 

readily feed on garbage and handouts (Eberhardt et al. 1982; Follmann and Hechtel 1990; Savory et al. 

2014). Arctic foxes in oil-development areas occur at higher densities and experience reduced population 

fluctuations, compared to foxes in undeveloped regions, increasing potential levels of predation of nesting 

birds and their eggs (Eberhardt et al. 1983; Burgess 2000). Foxes also use human structures (gravel berms 

and empty pipes) for denning and shelter (Eberhardt et al. 1983; Burgess et al. 1993). Future development 

projects would attract foxes throughout the year and grizzly bears in summer and fall. 

Alternative B

In Alternative B, the entire program area is available to lease. Alternative B includes 359,400 acres 

designated NSO to protect nearshore marine, lagoon, and barrier islands and to protect rivers and 

streams, although barge landings, docks, pipelines, and road crossings would be allowed. These restrictions 

offer some protection to birds in riparian areas by limiting potential habitat loss and alteration and 

disturbance and displacement. Important waterbird habitats in the Canning River delta and adjacent lakes 

district are included in this NSO.

In addition, Alternative B includes 721,200 acres of caribou calving habitat in which construction activity 

using heavy equipment would be halted between May 20 and June 20. In the same area, road and air traffic 

restrictions would be applied when caribou are present. These areas also would offer negligible protection 

to birds from limiting future disturbance and displacement by stopping traffic, but only when caribou are 

present.

The most abundant vegetation types in the program area are herbaceous (mesic) (31 percent total cover), 

tussock tundra (26 percent), herbaceous (wet) (16 percent), and low shrub (15 percent). Freshwater or 

salt water (primarily salt water, as all lagoons are included) comprises 9 percent, and no other vegetation 

type comprises more than 2 percent of the program area. Breeding birds use all these vegetation types, 

but the greatest abundance and species richness of nesting birds, and potentially greater direct and indirect 
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habitat and disturbance-related impacts, would occur in wetter habitats and in more coastal and delta 

habitats. 

Areas available for lease under Alternative B are 427,900 acres in the area of high HCP, 658,200 in 

moderate HCP, and 477,100 in low HCP. Areas of high, medium, and low HCP have similar cover by 

vegetation types overall, although areas of medium and low HCP include greater proportions of inland 

habitats. This is reflected in an increase in occurrence of more well-drained tussock tundra and low shrub 

and decreasing occurrence of herbaceous (mesic) and freshwater or salt water (again almost entirely salt 

water) (see Section 3.3.1). Also, two relatively high-quality bird habitats, herbaceous (marsh) and 

herbaceous (wet-marsh) (tidal) occur primarily in areas of high HCP in the program area. 

Assuming a maximum of 2,000 acres of facility footprints (excludes material sites), potential long-term loss 

and alteration of habitat from direct effects of gravel deposition and indirect effects of dust, 

thermokarsting, and impoundments under Alternative B would occur over 1 percent of the entire 

program area. Potential disturbance and displacement of breeding birds in tundra habitats could occur over 

about 2 percent of the area available for leasing.

Alternative C

In Alternative C, the entire program area is open to lease, but 932,500 acres are subject to NSO to 

protect rivers and streams, nearshore marine lagoon and barrier islands, coastal areas (within 1 mile of the 

coast), and caribou calving habitat. Exceptions would be made for roads, pipelines, barge landings, and 

docks, but not in 606,200 acres of caribou calving habitat, where no surface occupancy would be allowed. 

Alternative C includes some larger setbacks than Alternative B for riparian areas and is, therefore, 

somewhat more protective of avian habitats in riparian areas. The area closed to surface occupancy to 

protect caribou calving habitat comprises entirely inland habitats and nearly all in the area of Low HCP. 

Although protective of birds, this closure affects mainly drier and inland habitats that are more important 

for landbirds, including passerines, ptarmigan, and some shorebirds, like whimbrel and American goldenplover. Fall staging snow geese are an important exception, as the area closed to leasing overlaps 

extensively with areas historically used by the largest numbers of fall staging snow geese in the program 

area. 

The coastal and riparian setbacks in Alternative C would protect important bird habitat, although as 

described above, future roads and pipelines would be allowed, including docking pads and the STP in the 

coastal setback. Alternative C also includes an additional 317,100 acres subject to TLs, including 115,000 

acres of caribou calving habitat (restrictions May 20 to June 20) and 985,500 acres of caribou post-calving 

habitat (restrictions 15 June to 20 July) in which traffic controls would be implemented when caribou are 

present. NSOs and TLs to protect caribou habitat would offer negligible protection to breeding birds, 

again primarily in inland and drier habitats; however, lower levels of aircraft traffic in NSO areas would 

result in much lower potential for disturbance and displacement of staging snow geese, by comparison 

with Alternative B.

With Alternative C, potential long-term loss and alteration of habitat from direct and indirect effects of 

gravel deposition would be similar to Alternative B (the entire area is available for leasing) and would 

occur over approximately 1 percent of the area available for leasing; disturbance and displacement could 

occur over about 2 percent of the area available for leasing.
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Alternative D

In Alternative D, 476,600 acres are closed to leasing to protect caribou calving habitat, and an additional 

49,900 acres are closed to leasing to protect springs and aufeis locations. An additional 910,600 acres 

would be subject to NSO to protect rivers and streams: the Canning River delta and adjacent lakes; 

springs and aufeis; nearshore marine, lagoon, and barrier islands; polar bear denning habitat; caribou calving 

habitat’ the coastal zone (within 2 miles of the coast); and the wilderness boundary (3 miles from 

wilderness boundary). Exceptions would be made for roads, pipelines, barge landings, and docks; however, 

there would be no exceptions in 526,300 acres not offered for lease (calving habitat and springs/aufeis) or 

in an additional 244,600 acres of calving habitat subject to NSO. 

An additional 264,300 acres of caribou post-calving habitat would be subject to CSU, meaning no CPFs 

allowed with other infrastructure (roads, pads, airstrips, and pipelines) not to exceed 100 acres per 

township or 510 acres total. Alternative D includes some larger setbacks than Alternatives B or C for 

riparian areas and is, therefore, somewhat more protective of avian habitats in riparian areas. 

All these no lease areas, NSO areas, and CSU areas would potentially reduce impacts on birds. As with 

Alternative C, nearly all of the area closed to leasing are in the area of low HCP and in inland and drier 

habitats that are important to landbirds and some shorebirds and are used extensively by fall staging snow 

geese; however, the various NSO areas with Alternative D would be protective to many important avian 

habitats, including riparian and stream habitats, Canning River delta water bodies and wetlands, lagoon and 

barrier island habitats, and coastal habitats. Setbacks for springs and aufeis with Alternative D would 

provide some protection to several specific sites that are important providers of surface water during 

summer and thus very important to tundra birds.

Alternative D also includes TLs on activities in some areas, some of which would be potentially beneficial 

to birds. These TLs to protect caribou would provide negligible protection to birds, primarily in inland 

habitats that are important for landbirds, including passerines and ptarmigan, and some shorebirds.

Although protective of all birds, areas closed to leasing and adjacent areas with NSO or CSU restrictions 

that are intended to protect caribou habitat under Alternative D also overlap extensively with areas 

known to be used intensively by fall-staging snow geese. Lower levels of future aircraft traffic in these areas 

would result in reduced disturbance and displacement of staging snow geese. As mentioned above, air 

traffic and other disturbances would likely be low in areas used by the largest numbers of staging snow 

geese in the southeast portion of the program area, which is closed to leasing with Alternative D; 

however, potential disturbance and displacement of staging snow geese also would occur during fall in 

areas north and west of protected calving habitat. These areas are used by large numbers of staging snow 

geese in fall, and the TLs to protect caribou would not be protective. Fall-staging snow geese occur 

throughout these areas and air traffic and other activities there likely would result in potential disturbance 

and displacement.

Under Alternative D, potential long-term loss and alteration of habitat from direct and indirect effects of 

gravel deposition would occur over approximately 1.6 percent of the area available for leasing (1,037,200 

acres). Disturbance and displacement could occur over about 3 percent of the area available for leasing.

Cumulative Impacts

Past, present, and reasonably foreseeable oil and gas development impacts would be common to the 

impacts described for developments pursuant to the program area lease sales. They would increase the 
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occurrence and intensity of these common impacts. Such projects are likely in both terrestrial and marine 

environments and would affect birds in both. 

The National Research Council (NRC 2003) identified higher predator densities and increased predation 

on nests as the most apparent effect of oil development on birds. Transportation activities are anticipated 

to increase in support of both oil and gas development projects and of coastal villages, along with increases 

in research and recreational transportation. Increased transportation would include overland movement as 

the road system increases in size, barge and boat traffic, and passenger and cargo air traffic. Future surface, 

boat, and air traffic would result in increasing levels of disturbance of birds. Subsistence activities involving 

bird hunting and egg harvesting would continue with similar types of activities and areas used. 

If residents of adjacent villages are allowed access to roads, harvest of birds may increase. Future 

subsistence activities and scientific research are unlikely to negatively affect bird populations. Recreation 

and tourism could negatively affect birds, depending on locations and seasons, intensity, and types of 

transport. Air-based sightseeing could cause widespread disturbance, as could adventure cruise ships. 

Community development projects, such as airport improvements, roads and ports, telecommunication, 

and energy projects, all would affect local birds in the vicinity of such communities but would result in 

small increases in impacts on bird populations. The effects of climate change described under Affected 

Environment above, could influence the rate or degree of the potential cumulative impacts. Alternative A 

would have no cumulative impacts on birds from post-leasing oil and gas activities.

3.3.4 Terrestrial Mammals

Affected Environment

Thirty-nine species of terrestrial mammals are known or expected to occur in the Arctic Refuge, 18 of 

which occur regularly on the Coastal Plain physiographic province in the Arctic Refuge (MacDonald and 

Cook 2009; USFWS 2015a; Table J-11 in Appendix J). The occurrence and distribution of terrestrial 

mammals in the program area have been described in detail previously (Clough et al. 1987; Douglas et al. 

2002; USFWS 2015a; Pearce et al. 2018); those discussions are incorporated here by reference, and 

relevant information is summarized below, supplemented with updates from more recent research.

Special Status Species

None of the terrestrial mammals in the program area are listed under the federal ESA. (Polar bears do 

occur on land in the program area, but they are discussed in Section 3.3.5). In 2010, the BLM (2010) 

added to its list of sensitive species the Alaska tiny shrew (Sorex yukonicus, which has since been reclassified 

as the Holarctic least shrew, S. minutissimus; Hope et al. 2010; Bradley et al. 2014). 

To date, one specimen of the Holarctic least shrew has been captured in the mountains of the Arctic 

Refuge, south of the program area, at the confluence of the Canning and Marsh Fork Rivers.21 A previous 

report of this species from the Canning River delta in 2004 (MacDonald and Cook 2009; USFWS 2015a) 

was based on a misidentified specimen (University of Alaska Museum of the North, number 85499). It was 

subsequently identified correctly as a barren ground shrew (S. ugyunak).

22

Caribou

Caribou are the most abundant large mammals in the program area and are an important subsistence 

resource for Iñupiaq and Gwich'in hunters. They also are important for harvest by other hunters who do 

 

21A. G. Hope, Kansas State University, personal communication

22A. G. Hope, Kansas State University, personal communication
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

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not live in the refuge and for nonconsumptive uses, such as tourism and wildlife viewing. Because caribou 

exhibit high fidelity to calving grounds, the ADFG defines herds based on their use of calving grounds. 

Four herds of barren-ground caribou occur in Arctic Alaska: (proceeding from west to east) the Western 

Arctic herd, the Teshekpuk herd, the CAH, and the PCH. These four herds differ in their use of seasonal 

ranges, especially during the calving, insect-relief, and winter seasons (Russell et al. 1993; Murphy and 

Lawhead 2000). The program area is primarily used by the PCH and the CAH and is far to the east of the 

Western Arctic herd range (Dau 2015; Joly and Cameron 2017). The program area is outside the primary 

range of the Teshekpuk herd, although an estimated 5,000–10,000 caribou of the Teshekpuk herd moved 

into the northern portion of the Arctic Refuge in the fall of 2003 (Person et al. 2007; USFWS 2015a); that 

unprecedented movement was highly unusual and has not been repeated. 

Caribou in the PCH give birth in the program area during most years and use the Coastal Plain and ridges 

in the adjacent foothills and mountains for relief from insect harassment during summer, a period when 

some CAH caribou also use the program area. For these reasons, this discussion focuses on the PCH and 

CAH. 

Herd Sizes and Trends

The PCH was estimated to number about 100,000 animals in 1972 and increased to 178,000 in 1989, 

before declining to 123,000 animals in 2001 (Caikoski 2015). Due to unsuitable conditions of weather and 

herd distribution, another census could not be conducted until 2010, when the herd was estimated at 

169,000 animals. It increased to 197,000 animals by 2013 and reached a herd size of 218,000 animals in July 

2017 (Figure 3-5, Population Size of Three Caribou Herds in Arctic Alaska, 1977-2017, in Appendix A; 

Caikoski 2015; ADFG 2018a). Although population dynamics are complex, population growth of the PCH 

has been correlated with phases of the arctic oscillation (an index of oceanic temperature and sea-level 

pressure over the Arctic Ocean), which may affect snowfall and summer growing conditions (Joly et al. 

2011).

The CAH was estimated at approximately 5,000 animals when it was first described as a separate herd in 

the mid-1970s. The herd grew to its estimated peak of 68,000 animals by July 2010, then declined steeply 

to 23,000 by July 2016; the most recent estimate was 28,000 individuals in 2017 (Figure 3-5 in Appendix 

A; Lenart 2015a, 2018; ADFG 2017). The herd decline between 2010 and 2016 was thought to be due to 

high adult mortality and to the emigration of some CAH caribou to the PCH and Teshekpuk herd (ADFG 

2017). 

Life History and Habitat Use 

Caribou behavior and habitat use in northern Alaska vary substantially on a seasonal basis (Russell et al. 

1993; Murphy and Lawhead 2000). This is because caribou efficiently travel long distances (Fancy and 

White 1987) to maximize access to areas of accessible, nutritious forage plants, to minimize the risk of 

predation, and to limit their exposure to insect harassment.

Caribou of the PCH and CAH generally spend the winter in or south of the Brooks Range (Griffith et al. 

2002; Lenart 2015a; Nicholson et al. 2016), where the winter ranges of the two herds often overlap 

substantially, although some CAH caribou winter north of the Brooks Range in some years (Lenart 2015a; 

Nicholson et al. 2016). Many PCH animals migrate to winter range in the Yukon. During winter, the 

availability of lichens and other winter forage is influenced strongly by snow depth, snow hardness, and ice 

(Collins and Smith 1991). Winter snow depth is negatively related to population growth (Aanes et al. 
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2000), calf birth mass (Adams 2005), and birth rate (Ferguson and Mahoney 1991). Deep winter snow may 

delay the timing of births and reduce birth rates for a year (Adams and Dale 1998a, 1998b).

In spring, pregnant females migrate northward to calving grounds ahead of non-pregnant females, with 

males arriving later, after most calving is complete (Russell et al. 1993; Murphy and Lawhead 2000). Spring 

migration tends to coincide with snowmelt, and caribou often calve farther south when snowmelt is 

delayed (Carroll et al. 2005) or, in the case of the PCH, farther east (Griffith et al. 2002). In northern 

Alaska, most adult females older than 2 years of age give birth to a single calf in late May or early June. 

Caribou calving grounds in Arctic Alaska are in areas with few predators and with abundant, early 

emerging forage plants (especially tussock cotton grass, Eriophorum vaginatum), which are high in protein 

and are highly digestible (Kuropat 1984; Griffith et al. 2002; Johnstone et al. 2002). Use of the Coastal Plain 

during summer appears to extend the period when caribou can find forage with adequate digestible 

nitrogen (Barboza et al. 2018). 

The calving grounds of the PCH and CAH are near coastal mosquito-relief habitat, requiring relatively 

short movements once mosquitoes become active (Walsh et al. 1992; Murphy and Lawhead 2000; 

Nicholson et al. 2016). During the summer insect season (late June to mid-August), caribou are harassed 

heavily by mosquitos (Aedes spp.) and parasitic oestrid flies (warble fly, Hypoderma tarandi; nose-bot fly, 

Cephenemyia trompe). The longest distances traveled per day throughout the entire year typically occur in 

July, when mosquito harassment peaks (Fancy et al. 1989; Prichard et al. 2014; Dau 2015). In response to 

severe mosquito harassment, caribou form large groups and move to relief habitat near the coast or to 

remnant snowfields, patches of aufeis, and mountain ridges farther inland, where temperatures are lower 

and wind speeds are higher (Downes et al. 1986; Walsh et al. 1992; Murphy and Lawhead 2000; Yokel et 

al. 2011; Wilson et al. 2012).

Oestrid flies emerge in July and exert strong effects on caribou behavior and body condition (Murphy and 

Lawhead 2000; Hughes et al. 2009). In response to fly harassment, large caribou herds break up and 

disperse widely in small groups, seeking relief in unvegetated habitats, such as river bars, dunes, drainedlake basins, pingos,23 and ridgetops. In areas of northern Alaska with industrial development, caribou often 

use elevated sites on gravel roads and pads and in shaded areas under buildings and pipelines when flies are 

active (White et al. 1975; Pollard et al. 1996; Murphy and Lawhead 2000). Hot summers with severe insect 

harassment can substantially decrease caribou conditions in fall, causing them to enter the winter in poor 

condition (Helle and Tarvainen 1984; Colman et al. 2003; Weladji et al. 2003; Couturier et al. 2009) and 

potentially leading to lower productivity (Cameron and Ver Hoef 1994). 

During late summer and fall, caribou feed heavily to restore body reserves before the onset of winter 

(Haskell and Ballard 2004; Gustine et al. 2017). The birth rate for female caribou in spring is strongly 

related to body mass in the previous autumn (Cameron and Ver Hoef 1994; Cameron et al. 2000). On the 

range of the CAH, the length of the growing season has increased by 15 to 21 days as the climate warmed 

between 1970 and 2013 (Gustine et al. 2017); despite a 9- to 10-day increase in the fall growing season 

during that period, no significant change in seasonal forage quality was evident. Caribou migration to 

winter ranges in the fall coincides with the breeding season (rut) in October, a period when male caribou 

experience high energy demands. In one study, adult males lost 23 percent of body protein and 78 percent 

of body fat during the rut (Barboza et al. 2004).

 

23A dome-shaped hill formed in a permafrost area when the pressure of freezing groundwater pushes up a layer of 

frozen ground
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Compared with the conditions experienced by other arctic migratory herds, the range of the PCH has 

warm spring conditions and cool moist summers, which likely result in longer periods of high plant quality 

and lower mosquito harassment (Russell and Gunn 2017). The winter range has relatively high snow 

depths, but diverse terrain provides a wide range of wintering locations. PCH animals accumulate less back 

fat and get pregnant at higher fall body weights (indicating lower productivity) than other herds, but 

pregnancy rates change less dramatically with changing fall body weights (indicating lower vulnerability). 

The PCH has had a more stable population size than other herds in recent decades (Russell and Gunn 

2017; Fauchald et al. 2017). 

PCH Use of the Program Area

Caribou use of the program area varies greatly throughout the year. The principal use by the PCH occurs 

in the spring and summer, during spring migration and the calving, post-calving, and insect seasons (Map 3-

21, Seasonal Distribution of the Porcupine Caribou Herd, in Appendix A). The PCH give birth from the 

northern portion of the Arctic Refuge into northern Yukon, and the extent of use of those areas varies 

substantially among years (Map 4-9 in USFWS 2015a; Map 3-21 in Appendix A). 

Four terms are used to describe the use of calving grounds by caribou, as follows (Russell et al. 2002): 

 Annual calving ground—the calving ground for a particular year

 Extent of calving—the outer perimeter of all known annual calving grounds

 Annual concentrated calving area—the area of relatively high use in an annual calving ground

 Extent of concentrated calving—the outer perimeter of all known annual concentrated calving 

areas

Between 1983 and 2001, the annual percentage of PCH females calving in the ANILCA 1002 Area 

(essentially the program area) averaged 42.7 percent. It was highest in years with early spring conditions 

(as measured by the Normalized Difference Vegetation Index [NDVI] calculated from satellite imagery 

during calving; Griffith et al. 2002). In 8 of the 12 years from 2000 to 2011, the annual concentrated calving 

areas occurred in the Yukon or near the Yukon-Alaska border, largely outside the program area (USFWS 

2015a). The PCH calved predominantly in the Yukon in 2012/2013 (Caikoski 2013, 2015) but 

predominantly in Alaska between 2014 and 2017, and calving was widely dispersed in 2018 (Caikoski 

2015).24 In 2017, much of the PCH concentrated calving area was west of the Sadlerochit River.25

The annual calving grounds were in areas with higher rates of increase in NDVI, which is thought to 

indicate higher quality forage. The annual concentrated calving areas in those annual calving grounds were 

characterized by higher forage biomass, as measured by NDVI (Griffith et al. 2002). PCH caribou feed 

primarily on immature flowers of tussock cottongrass early in June, in wet sedge meadows, herbaceous 

tussock tundra, and riparian vegetation types; then later in June they forage primarily on willows and 

herbaceous plants (Griffith et al. 2002; Johnstone et al. 2002).

Between 1983 and 1985, PCH calf mortality during June averaged 29 percent, and 61 percent of that 

mortality was due to predation, primarily by golden eagles, grizzly bears, and wolves. Predation rates and 

predator densities were higher in the foothills south of the program area (Whitten et al. 1992; Young and 

 

24Caikoski, Jason. Personal communication. Phone call from Jason Caikoski, ADFG to Alex Prichard, ABR Inc on 

September 11, 2018 regarding annual calving distribution of the Porcupine Caribou Herd.

25Caikoski, Jason. Personal communication. Phone call from Jason Caikoski, ADFG to Alex Prichard, ABR Inc on 

September 11, 2018 regarding annual calving distribution of the Porcupine Caribou Herd.
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

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McCabe 1997), and calf survival was lower for calves born in the foothills (Griffith et al. 2002). Mean 

annual calf survival was higher when the forage biomass at peak lactation (estimated by NDVI on June 21) 

was higher (Griffith et al. 2002); hence, calving grounds for the PCH varied annually, at least in part due to 

spring weather and vegetation growing conditions; calving location and vegetation growing conditions 

appear to affect calf survival. The USFWS (2015a) concluded that, due to the annual variability in the 

calving area, the PCH needs a large region from which to select the best conditions for calving in a given 

year.

During the post-calving season (last week of June and first week of July), most locations of PCH caribou 

were in the program area, and PCH caribou moved west toward the program area, even if they calved 

outside of it (Griffith et al. 2002). 

PCH caribou may use both coastal areas and inland ridgetops for insect relief (Walsh et al. 1992; USFWS 

2015a). During the summer insect season (July 7–August 14) in the years before 2000, caribou spread out 

across the Coastal Plain and in the Brooks Range in Alaska and Yukon, with few remaining in the program 

area (Map 3-21 in Appendix A; Griffith et al. 2002). After 2000, PCH caribou generally left the Coastal 

Plain by the end of June (USFWS 2015a). Most PCH caribou move out of the program area by mid to late 

summer.

CAH Use of the Program Area

Females in the CAH calve in two areas west of the Arctic Refuge: one south and southwest of the 

Kuparuk oilfield, between the Colville and Kuparuk Rivers, and the other between the Sagavanirktok and 

Canning Rivers in an area with little development (Map 3-22, Seasonal Distribution of the Central Arctic 

Herd, in Appendix A). Since construction of the Alaska North Slope oilfields, the CAH has been exposed 

to some level of development for about 40 years (Cameron et al. 2005). During most years since 2004, a 

portion of the CAH has moved through the program area during the summer insect season (Map 3-22 in

Appendix A; Lenart 2015a; Nicholson et al. 2016; Prichard et al. 2017).

Coastal movements by large groups of caribou occur during periods of mosquito harassment, with caribou 

typically moving into the wind (which tends to be easterly); however, those groups tend to break up and 

disperse when oestrid flies become the dominant insect pests (Murphy and Lawhead 2000). 

The number of CAH animals using the program area varies annually, likely in response to weather 

conditions and the resulting levels of insect harassment and longer time scale shifts in CAH summer 

movement patterns.

Muskox

This native species became extinct in Alaska in the nineteenth century; the history, distribution, and habitat 

preferences of muskoxen were described previously (BLM 2012, Section 3.3.6.2, page 293; USFWS 2015a). 

The current population in northeastern Alaska was reestablished by translocation when 64 animals from 

Greenland stock were released at Barter Island and the Kavik River in 1969 and 1970 (USFWS 2015a). As 

their numbers increased, they expanded westward on the ACP to the Colville River drainage and eastward 

across the international border to the Babbage River in northern Yukon. 

The population in northeastern Alaska and northwestern Canada was estimated at 700–800 animals in the 

mid-1990s, but it subsequently declined to approximately 300 animals from 2007 to 2014; about 200 were 

located west of the Arctic Refuge and 100 were located east of it in northern Yukon (Lenart 2015b; 

Arthur and Del Vecchio 2017). The decline was especially steep in the Arctic Refuge, where only one 
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muskox was observed in 2006. A group of fewer than 20 animals, which moved back and forth across the 

Canning River, was the only group using any part of the Arctic Refuge from 2009 to 2015 (Lenart 2015b). 

Predation by grizzly bears accounted for 58 percent of calf mortality and 62 percent of adult mortality 

from 2007 to 2011 (Arthur and Del Vecchio 2017).

Moose

The program area is near the northern extent of moose range, but moose are found in low numbers on 

the ACP where suitable forage plants occur, primarily in riverine habitats dominated by willow shrubs 

(Lenart 2014; USFWS 2015a). Late-winter aerial surveys in 2014 found only 22 moose in a series of 

drainages that included the program area, a sharp decrease from the fairly stable number of 47–61 moose 

found in the same survey area from 2002 to 2010 (Lenart 2014). Moose exhibit large fluctuations in 

population size on the North Slope but appear to be expanding their range farther onto the North Slope 

in response to climate warming and corresponding northward expansion of tall shrubs (Tape et al. 2016). 

Carnivores

Three large- to medium-sized terrestrial carnivores—grizzly bear, wolf, and wolverine—inhabit the Arctic 

Refuge, occurring in lower densities on the coastal plain of the North Slope than father inland in the 

foothills and mountains (Young et al. 2002). The USFWS (2015a) summarized information on these 

species. 

Grizzly bears and wolves are important predators of caribou and other ungulates. Grizzly bears occupy 

dens during winter dormancy, whereas wolves and wolverines remain active year-round. Grizzly bear

density in Game Management Unit (GMU) 26C, which covers much of the program area, was estimated to 

be 3.8 bears per 100 square miles in 1993 (Lenart 2015c). Due to the distribution of suitable landforms 

and substrates, wolf den sites are more common in the foothills and mountains than on the coastal plain of 

the North Slope (Young et al. 2002; USFWS 2015a). Wolf density in GMU 26C was estimated to be 5.7–

8.3 per 1,000 square miles in the 1980s (Garner and Reynolds 1986; Caikoski 2012).

Two species of foxes and two species of weasels inhabit the program area, all which feed on small 

mammals year-round and on birds and their eggs when available during summer. Arctic foxes inhabit the 

Coastal Plain during the summer denning season to rear pups but move long distances to forage 

extensively on sea ice during winter (Pamperin et al. 2008), although arctic foxes may have a significantly 

reduced winter range and higher survival rates in areas with access to anthropogenic food sources near 

development (Pamperin et al. 2008; Lehner 2012). Red foxes are not known to inhabit sea ice and are 

increasing in numbers on the ACP, in concert with climate warming and increased availability of human 

food sources in industrial areas (Savory et al. 2014; Elmhagen et al. 2017). Red foxes are aggressive toward 

arctic foxes and would kill or otherwise displace them from den sites (Pamperin et al. 2006; Stickney et al. 

2014). 

All species of terrestrial carnivores can be attracted to areas of human activity if food or rotting waste are 

improperly handled or disposed of. This can lead to habituation and food-conditioning, thus increasing the 

risk of injury or mortality to humans or the carnivores themselves (Burgess 2000; Shideler and Hechtel 

2000). Increasing predator populations, with the associated higher predation rates on prey populations 

(especially migrant birds), has been a perennial concern around the North Slope oilfields (Day 1998).

Small Mammals

Small mammals provide important prey resources for predatory mammals and birds in the region, and 

arctic ground squirrels are especially important prey for grizzly bears and foxes (Babcock 1986). Arctic 
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

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ground squirrels hibernate during winter, whereas lemmings, voles, and shrews remain active under the 

snow cover. Most species of small mammals exhibit cyclical population fluctuations, which have 

pronounced effects on local ecological systems (USFWS 2015a). Similar to moose, snowshoe hares appear 

to be expanding their range farther onto the ACP in response to climate warming and corresponding 

northward expansion of tall shrubs (Tape et al. 2015). Beavers also are expanding their range into parts of 

Arctic Alaska and the northern Yukon (Tape et al. 2018).

Climate Change

Caribou body condition and population fluctuations have been found to be influenced by large-scale 

climate oscillations, such as the Arctic Oscillation (Griffith et al. 2002; Joly et al. 2011; Mallory et al. 2018). 

Climate change is expected to increase temperatures, increase precipitation, and lengthen the snow-free 

season (see Section 3.2.1). Summer temperatures above freezing could occur for 6 weeks longer by 

2099 (SNAP 2011). Climate change in the Arctic is predicted to have multiple, sometimes counteracting, 

effects on barren-ground caribou (Martin et al. 2009; Albon et al. 2016; Mallory and Boyce 2017). 

Vegetative biomass in the arctic has generally increased since 1984, although the increase in Alaska has 

been lower than the increase in eastern Canada (Ju and Masek 2016). An increase in shrub cover and a 

decline in lichens growing on soil has been documented in the western Canadian Arctic (Fraser et al. 

2014). 

A longer snow-free season can increase access to forage (Cebrian et al. 2008; Tveraa et al. 2013), but 

warmer summers could increase insect harassment (Weladji et al. 2003), increase the incidence of 

parasites, and speed the annual decline in forage quality (Gustine et al. 2017). Changes in vegetation 

composition could result in increased abundance of shrubs and deterioration of forage quality (Fauchald et 

al. 2017). Increased moose densities could increase predator densities and alter predator distributions. 

Changes in winter precipitation could change access to forage and energetic demands for cratering 

through snow. Increases in rain-on-snow events could greatly decrease access to winter forage (Hansen et 

al. 2011; Albon et al. 2016; Loe et al. 2016). Changes in timing of snowmelt and vegetation growth could 

create a phenological mismatch26 between timing of calving and the emergence of highly nutritious forage 

(Post and Forchhammer 2008). Gustine et al. (2017) found no evidence of a spring nourishment mismatch 

for caribou in Alaska but suggested that one may occur in fall with increased warming. If mosquitos emerge 

closer to calving, it could result in a higher rate of separation of calves, poorer body quality of maternal 

caribou, and higher calf mortality. Earlier melting of ice and snow and earlier river breakup could alter the 

timing or difficulty of caribou migrations (Sharma et al. 2009; Leblond et al. 2016).

Climate change is also likely to result in a northward expansion of some mammal species, such as moose, 

beaver, and snowshoe hare; a potential increase in red foxes due to warming could cause a decline in 

arctic foxes. Some species with low reproductive output in the Arctic, such as grizzly bears, may benefit 

from increased productivity and a more diverse prey base. 

Because climate change could involve both adverse and beneficial effects on caribou, it is not possible to 

predict the impacts on the PCH and CAH; however, climate change could affect caribou demographics as 

well as habitat use and introduce additional uncertainty into projections of impacts due to development. 

 

26The phenomenon of food and habitat being available at different times than those to which the species was 

formerly cued.
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The PCH calving distribution varies with the onset of spring seasonal changes and is typically farther west 

during warmer springs (Griffith et al. 2002); hence, climate warming could result in more frequent calving 

in the program area or a western shift in concentrated calving areas. Development alternatives that limit 

development to a smaller portion of previously used PCH calving grounds would allow caribou greater 

flexibility to adapt to changing conditions. Infrastructure to support development in the program area may 

facilitate additional development west of the program area, potentially altering the behavior and 

movements of CAH caribou. It could also result in demographic impacts, although at much higher levels of 

interaction than currently observed (Murphy et al. 2000).

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

terrestrial mammals from on-the-ground post-lease activities.

Post-lease activities in the program area have the potential to affect terrestrial mammals through habitat 

loss and alteration, behavioral disturbance and displacement, and injury or mortality as a result of oil and 

gas exploration and development (Table 3-19). The impacts of oil and gas development on caribou have 

been summarized in various reviews, along with appropriate mitigation measures (Shideler 1986; Cronin et 

al. 1994; Murphy and Lawhead 2000; Lawhead et al. 2006), which are incorporated here by reference and 

are summarized below. Because specific project plans are not available for analysis, the areas available for 

leasing with and without restriction under each alternative were summarized in relation to the available 

data on terrestrial mammal distribution and in relation to predicted oil potential. The effects of climate 

change described under Affected Environment above, could influence the rate or degree of the potential 

direct and indirect impacts.

Alternative A

Under this alternative, current management actions would be maintained, and resource trends would 

continue, as described in the Arctic Refuge CCP (USFWS 2015a). There would be no direct or indirect 

impacts on terrestrial mammals from post-lease oil and gas activities under Alternative A.

Impacts Common to All Action Alternatives

Seismic Exploration

Future seismic exploration is expected to occur in all portions of the program area that are open to lease 

sales. It has the potential to affect terrestrial mammals by eliminating below snow habitat for small 

mammals, reducing forage availability during winter through compaction of snow and underlying 

vegetation, and disturbing denning grizzly bears and muskoxen. Occupied dens of grizzly bears detected 

during den surveys would be avoided by at least one half-mile, although complete detection of dens is 

unlikely (Amstrup et al. 2004a). The program area is used very little by caribou during winter (Clough et al. 

1987; Porcupine Caribou Technical Committee 1993; Ryder et al. 2007), so direct impacts on that species 
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

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Table 3-19

Summary of the Type, Context, and Duration of Potential Effects of Oil and Gas 

Exploration, Construction, and Drilling and Operations on Terrestrial Mammals

Project 

Component Potential Effect Type Context Duration

Seismic 

exploration

Elimination of under-snow habitat for small mammals Adverse Site-specific Short-term

Disturbance of active or denning mammals during 

winter

Adverse Local Short-term

Change in phenology or damage to forage plants Adverse/ 

beneficial

Site-specific Short-term/

long-term

Gravel and 

pipeline 

infrastructure

Habitat loss from gravel fill placement Adverse Site-specific Long-term

Habitat alteration due to drifted snow, gravel spray, 

and dust deposition adjacent to gravel infrastructure

Adverse Local Long-term

Early snowmelt due to dust deposition Beneficial Local Long-term

Displacement of caribou from infrastructure during 

calving

Adverse Planning 

area-wide

Long-term

Attraction of caribou to roads and gravel pads during 

oestrid fly harassment

Beneficial Local Long-term

Disturbance and altered behavior due to noise and 

activities associated with construction and drilling 

and operation

Adverse Local Long-term

Alteration of normal movement patterns and 

fragmentation of habitat due to roads and pipelines

Adverse Local Long-term

Injury or mortality of large mammals due to vehicle 

strikes on gravel roads

Adverse Site-specific Long-term

Injury or mortality of small mammals due to vehicle 

strikes on gravel roads

Adverse Site-specific Long-term

Contamination of roadside forage due to dust Adverse Local Long-term

Injury or mortality of small mammals in subterranean 

burrows 

Adverse Site-specific Long-term

Ice roads and 

pads

Habitat alteration due to drifted snow, delayed ice 

melt, vegetation compression, and hydrologic 

alteration from ice roads

Adverse Local Short-term

Displacement from ice roads and ice pads due to 

noise and activity

Adverse Local Short-term

Injury or mortality due to vehicle strikes on ice roads Adverse Site-specific Short-term

Injury and mortality of small mammals in under-snow 

habitats 

Adverse Site-specific Short-term

Gravel Mine Habitat loss due to gravel mining Adverse Site-specific Long-term

Habitat alteration from dust, water displacement, and 

hydrologic alteration at gravel mine

Adverse Local Long-term

Displacement from gravel mine due to noise and 

activity

Adverse Local Long-term
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

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during that time frame would be negligible. Potential localized disturbance of the small number of 

muskoxen along the western boundary of the program area could result from seismic exploration activities 

in areas of High HCP.

Potential indirect effects of seismic exploration would include short-term compaction of snow cover in 

foraging habitats for herbivores. The timing of snowmelt during the spring following seismic exploration 

would change as a result of snow compaction and changes in snow drifting. Delayed snowmelt in the spring 

could decrease forage available to caribou and other herbivores, but could also extend the time when 

highly nutritious, early growth forage is available after snowmelt. Some potential habitat alterations and 

long-term damage to forage plants for herbivores, such as riparian willow shrub is also likely to occur, as 

described in the Section 3.3.1.

Construction

All action alternatives could result in up to 2,000 acres of direct surface impact from future placement of 

gravel infrastructure on leased land, in addition to gravel mines and associated development on adjacent 

land owned by Alaska Native corporations in the program area, but not subject to PL 115-97. The amount 

of future construction activity is expected to be similar across action alternatives, although the spatial 

distribution and extent of the activities would differ, as described separately for each alternative later in 

this section. 

Using the hypothetical schematic anchor-field footprint (one CPF and 6 radiating 8-mile access roads to 6 

drill pads, including an STP pad and a 30-mile access road, totaling 750 acres), the BLM calculated estimates 

of the area within 2.49 miles for potential displacement of calving caribou. Using these schematic footprints 

and extrapolating to a 2,000-acre maximum gravel footprint, it estimated the total acres of potential 

disturbance and displacement is 633,000 acres; however, this number would vary with different road and 

pad scenarios, and some portion of this area could be overlapping the buffer from other development, 

outside of the program area, or in the ocean. This potential displacement area is compared with areas 

available for lease under each alternative.

During winter, future construction activities would affect mammals that are active all year or are denning 

in the area. Future summer construction activities could potentially disturb all mammal species using the 

area in that season. Increased disturbance could result in increased energetic costs, decreased time spent 

foraging, or displacement from preferred habitat. 

Future construction activities would result in potential loss and alteration of terrestrial mammal habitats 

due to gravel placement for roads, pads, and airstrips, as well as from gravel extraction from mine sites. 

Habitat loss would reduce forage availability for herbivorous terrestrial mammals. For most terrestrial 

mammals, foraging habitat is abundant across the program area. Habitat loss also would eliminate denning 

and burrowing habitat for some species of small mammals, but the availability of denning habitat does not 

appear to be a limiting factor for those species. Gravel fill occasionally may be used for artificial den sites 

by small numbers of bears and foxes.

Injury and mortality of terrestrial mammals is possible as a result of potential vehicle strikes on gravel 

roads and ice roads during construction. Caribou and other mammals attracted by early vegetation 

greening along gravel roads during spring snow melt would be at increased risk of injury or mortality. 

Caribou move unpredictably during the oestrid fly season and often use gravel roads and pads as travel 

routes and as relief habitat, substantially increasing the risk of vehicle-related injury and mortality during 

that period. Small mammals in under-snow burrows may be killed because of gravel placement, gravel 
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

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mining, and ice road construction during winter, or they may be killed by vehicles while crossing roads. 

Humans may haze bears and foxes attracted to infrastructure or, in extremely rare situations, may kill 

them in defense of life or property.

Potential indirect impacts on terrestrial mammals would include habitat alteration, fragmentation, and loss 

of use because of disturbance and displacement. Habitat near gravel infrastructure is likely to be affected 

by physical alteration caused by dust deposition, gravel spray, thermokarst, flow alteration, and 

impoundments. The magnitude of these impacts varies, depending on species, habitat type, volume of 

ground ice, and hydrologic regime (Brown and Grave 1979; Walker et al. 1987). Habitat alteration would 

reduce local forage availability for herbivorous mammals, such as caribou, muskox, moose, and some small 

mammals. Snowdrifts along roads would reduce the availability of winter forage locally for herbivores and 

delay its availability in the spring. Deposition of fugitive dust on snow, caused by vehicle traffic on gravel 

roads, would lead to early snowmelt and green-up in affected areas, attracting some caribou in spring 

before calving and increasing access to early emerging forage. 

Few data are available on the effects of noise and light on caribou. Tyler et al. (2018) suggested that 

caribou may avoid power lines in winter due to their ability to detect light in the ultraviolet range. Noise 

and light associated with vehicles, aircraft, and other human activity is likely to increase the level of 

disturbance associated with those activities, which could result in negative effects on terrestrial mammals, 

due to increased disturbance, altered behavior, and displacement.

Vegetation damage from future ice-road construction could reduce the abundance and quality of forage for 

terrestrial mammals, particularly caribou. The compaction of vegetation could reduce concealing cover for 

small mammals. Although some habitat damage would result from the use of ice roads and pads because

the ice road is temporary, the long-term impacts would be considerably less than those associated with 

gravel roads and pads. Tussock tundra and sedge/grass meadow are preferred cover classes for caribou. 

Moose generally prefer tall shrub and riverine landcover types. Drier habitat classes are preferred by arctic 

ground squirrels and denning foxes. Many other terrestrial mammals in the program area are opportunistic 

and do not have restrictive habitat preferences (Table J-1 in Appendix J).

Disturbance by future vehicle traffic, structures, and construction activities, including blasting associated 

with gravel mining, causes a variety of potential impacts on the behavior and movements of terrestrial 

mammals. Some species, particularly bears and foxes, may be attracted to areas of human activity in the 

program area due to the availability of food or shelter. An increase in red foxes due to human food 

sources could result in a decline in arctic fox densities. Construction may disturb grizzly bears in dens that 

are not found by preconstruction denning surveys.

Potential behavioral effects of disturbance on caribou include displacement of maternal caribou during 

calving and early lactation (late May to late June), deflection and delays in caribou movements across roads 

and pipelines during the summer insect season (late June to mid-August), and potentially during spring and 

fall migrations for the smaller numbers of caribou present in those seasons. Potential disturbance could 

result in behavioral responses, such as reduced foraging rates, increased movements, and energetically 

costly flight responses, potentially displacing animals from suitable habitat (Shideler 1986; Cronin et al. 

1994; Murphy and Lawhead 2000; Murphy et al. 2000).

Under all alternatives, terrestrial mammals are more prone to displacement from areas with consistently 

high levels of activity, such as near CPFs, airstrips, and busy sections of trunk roads. The most common 

disturbing stimulus associated with roads is vehicle traffic; 15 vehicles per hour or more has been shown 
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

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to deflect caribou movements and delay road crossings, even in the absence of pipelines (Curatolo and 

Murphy 1986; Cronin et al. 1994). Studies of CAH caribou have demonstrated that behavioral reactions 

are most common when caribou are within 656 feet of roads, but the strongest reactions, as measured in 

displacement distance, occur in response to humans on foot (Curatolo and Murphy 1986; Lawhead et al. 

1993; Cronin et al. 1994).

Experience in existing northern Alaska oil fields indicates that caribou and other terrestrial mammals may 

habituate to low-level constant noise and oilfield activities on roads and pads (maternal caribou with young 

calves, being a notable exception). PCH caribou have had much less exposure to human development and 

activities than have CAH caribou, however, so they would be expected to have stronger reactions to 

infrastructure than CAH caribou for some years. Some indication of habituation to infrastructure by PCH 

caribou during winter has been reported (Johnson and Russell 2014).

Research in the Kuparuk and Milne Point oilfields on the central North Slope has demonstrated that, 

during and immediately after calving, maternal caribou with young calves tend to avoid areas within at least 

1,640–3,281 feet of active roads and pads (Johnson and Lawhead 1989; Cronin et al. 1994), and as far as 

1.25 to 2.5 miles (Dau and Cameron 1986; Lawhead 1988; Cameron et al. 1992; Cronin et al. 1994; 

Nellemann and Cameron 1996; Lawhead et al. 2004). 

Studies of open-pit mines have recorded more extensive displacement of Bathurst caribou with a zone of 

influence extending 6.8–8.7 miles (Boulanger et al. 2012). A level of displacement of up to 2.49 miles 

observed at existing North Slope oil fields would be expected in the program area with similar 

development and mitigation design. Displacement lasts from calving (late May to mid-June) up to when 

calves are approximately 3 weeks of age (Lawhead et al. 2004; Haskell et al. 2006), corresponding to the 

calving and post-calving periods for the PCH (Map 3-21 in Appendix A). 

Of the 1,563,500 acres in the program area, 728,300 acres (49.0 percent) are in areas used for annual 

calving grounds of the PCH at least 40 percent of years; 882,500 acres (59.4 percent) are in areas used for 

annual calving grounds of the PCH at least 30 percent of years; and 1,031,400 acres (69.4 percent) are in 

areas used for annual calving grounds of the PCH at least 20 percent of years (Table J-15 in Appendix 

J). All of the area in the annual calving grounds of the PCH (at least 30 percent of years) is thought to have 

low or medium HCP (Map 3-21 in Appendix A). 

Although several potential demographic impacts of development on CAH caribou have been reported 

(Cameron et al. 2005; Arthur and Del Vecchio 2009), the CAH increased in size between 1978 and 2010 

before declining in size between 2010 and 2016 (Lenart 2015a). The patterns of CAH demography 

following development should be applied to the PCH with caution for several reasons: movements and 

demography of the PCH are different from the CAH, concentrated calving density of the PCH is much 

higher than the CAH, and areas next to the PCH calving grounds contain less high-quality forage and 

higher predator densities and exhibit more topographic relief than do the current PCH calving grounds 

(Clough et al. 1987; Griffith et al. 2002).

If future development causes large-scale displacement of the PCH from the calving grounds in the program 

area, the calving distribution would most likely shift to the east or southeast (Griffith et al. 2002) and 

displacement would be most likely to occur in years of early snowmelt when the PCH is more likely to 

calve in the program area in the absence of development (Griffith et al. 2002). Comparison of mean annual 

survival rates of PCH calves during June 1985 and between 1987 and 2001 showed that calf survival was 

lower in years when higher proportions of calves were born off the coastal plain and when less vegetative 
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biomass (based on NDVI) occurred on the annual calving ground at the time of peak lactation (June 21; 

Griffith et al. 2002). Using this model and previous hypothetical development scenarios (Scenarios 2–5 

from Tussing and Haley 1999) and assuming that the calving distribution would be displaced 2.49 miles 

from development, Griffith et al. (2002) predicted that calf survival would decline linearly with the distance 

that the annual calving ground was displaced and predicted an 8 percent decline in annual calf survival if 

there were full development of the ANICLA defined 1002 Area, essentially the current program area. This 

predicted decline in mean annual calf survival during June would have been large enough to halt herd 

growth, based on random population simulations of the PCH (Walsh et al. 1995). This analysis assumed no 

change in the shape of the calving distribution. It was developed from annual comparisons of mean calf 

survival but has not been tested for a spatial shift in calving in a given year. An eastward shift in the calving 

distribution would move the calving distribution into areas with higher predator densities (Young et al. 

2002), into areas with lower quantity and quality of common caribou forage species, and into lower 

proportions of the preferred tussock tundra and moist sedge-willow tundra vegetation types (Jorgenson et 

al. 2002). 

Large aggregations of PCH and CAH moving in midsummer through the program area during periods of 

mosquito harassment would have to navigate any infrastructure they encounter. Caribou may expend 

more energy, take more time, or exhibit reduced crossing success where traffic rates exceed 15 vehicles 

per hour and pipelines are within 300 feet of roads (Curatolo and Murphy 1986; Cronin et al. 1994; 

Murphy and Curatolo 1987; Johnson and Lawhead 1989; Lawhead et al. 1993); however, the 7-foot 

minimum height at VSMs and placement of elevated pipelines at least 500 feet from adjacent roads have 

been found to be adequate to maintain caribou passage in the oilfields west of Prudhoe Bay (Cronin et al. 

1994; Lawhead et al. 2006). During the oestrid fly season (mid-July to mid-August) elevated gravel roads 

and pads and shaded areas under buildings and pipelines may provide relief from insect harassment 

(Curatolo and Murphy 1986; Cronin et al. 1994; Noel et al. 1998).

The presence of roads and pipelines in the program area could also delay and deflect movements during 

spring and fall. Research has found varied responses of caribou to roads during such migrations. 

Approximately 30 percent of collared female caribou (8 of 24 individuals) encountering the Red Dog Mine 

road in northwestern Alaska during fall migration experienced long delays in crossing the road corridor, 

with the delays of these “slow crossers” averaging 11 times longer than those of “normal crossers” (33.3 

days vs. 3.1 days; Wilson et al. 2016). Wild reindeer (the same species as caribou) in Norway were delayed 

approximately 5 days during spring migration at a highway corridor experiencing high levels of human 

activity, but when human activity was low during fall migration, the road did not appear to pose an 

obstruction (Panzacchi et al. 2013). Similar delays have not been observed in caribou in the existing North 

Slope oil fields, where most movements occur during the summer insect season when movement rates 

and motivation to cross are much higher (Cronin et al. 1994; Murphy and Lawhead 2000). Caribou 

crossing success in the program area would vary by season, behavioral motivation, level of habituation, and 

human activity levels. Alteration of the timing of fall migration could affect some subsistence hunters by 

delaying access until caribou bulls are in rut and are no longer selected by subsistence hunters.

Aircraft noise during take-offs and landings could result in the inability of nearby terrestrial mammals to 

hear biologically important sounds, such as predators, prey, or interspecific communication (Barber et al. 

2010) and could lead to increased stress levels near the airstrip. Low-level aircraft may cause flight 

responses or temporary changes in caribou behavior (Maier et al. 1998; Reimers and Colman 2006), which 

could temporarily deflect or alter caribou behavior, potentially affecting hunting activities and hunting 

success for subsistence hunters (as described in Section 3.4.3, Subsistence Uses and Resources). 
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Most program-related aircraft operators would maintain minimum flight altitudes to reduce disturbance of 

wildlife and subsistence hunters. In addition, habituation appears to lower the response of caribou to 

aircraft activity (Valkenberg and Davis 1985). Some of the limited research on aircraft disturbance on 

caribou involved military jets. Military jets are louder than the typical aircraft likely to use the program 

area, but they are also faster, potentially resulting in more intense disturbance for a shorter duration. 

Although the effects of military aircraft on caribou behavior may differ somewhat from the effects of more 

typical aircraft using the program area, these studies provide useful information on the range of caribou 

behavior likely to be encountered. Maier et al. (1998) found that caribou responses to low-level military jet 

overflights were low in late winter, moderate in midsummer, and strongest during post-calving, with 

females accompanied by young showing the strongest responses. During the post-calving season, caribou 

subjected to direct overflights at low altitudes by military jets moved farther and were more active than 

animals that were not overflown. Lawler et al. (2005) found that responses to military overflights during 

calving were variable but generally mild, and overflights did not result in higher calf mortality or increased 

movements of cow/calf pairs. 

All alternatives would be subject to ROP 23 and portions of ROP 34. ROP 23 incorporates oilfield design 

specifications that have been found to minimize disruptions to caribou movements in existing oilfields 

(Shideler 1986; Cronin et al. 1994; Murphy and Lawhead 2000; Lawhead et al. 2006). These include 

requirements relating to pipeline height, pipeline road separation distance, road and pipeline orientation, 

caribou crossing ramps, and pipeline coating, and would require a vehicle management plan to be 

developed. ROP 34 requires an aircraft use plan and would place limits on aircraft altitude and landings 

near known subsistence hunting camps and cabins and in the PCH calving area (all action alternatives) and 

the PCH post-calving area (Alternative D only). 

Development Drilling and Operations

Given the 2,000-acre limit on gravel placement, the amount of activity during future development drilling 

and operations is expected to be similar among alternatives, although the spatial distribution and extent of 

the activity would differ among the alternatives, as described separately below.

Many of the same impacts that occur during construction would persist throughout future drilling and 

operation, although some activities, such as gravel hauling, gravel fill placement, pipeline construction, 

would end and others, such as vehicle and air traffic volume, would continue at a lower frequency. Drill 

rigs and associated activity would introduce additional noise disturbance. Because of the relative levels of 

activity associated with each phase, the potential impacts during development drilling would be greater 

than during operations after drilling ceases.

The potential effects of habitat loss are long term and would continue throughout drilling and operations. 

Additional habitat alterations from the impacts of snowdrifts, dust, thermokarst, and ponding would 

continue during operations. Accidental oil discharges in the program area may affect terrestrial mammals, 

depending on the location and size of the spills (see Section 3.2.11). During exploration and 

construction, the primary releases would be accidental spills from vehicles, storage tanks, marine barges 

and docks, aircraft, and equipment during transport or fueling and during pipeline hydrotesting; however, 

the frequency of spills would be limited by BMPs.

Most potential spills would be fewer than 100 gallons and restricted to ice or gravel roads and pads, never 

reaching the tundra, but larger tundra spills are possible. Disturbance from human activities and traffic on 

roads, pads, and airstrips would continue through drilling and operations; however, the frequency of 

disturbance would decline during operations, in comparison with construction and development drilling. 
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

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Throughout future drilling and operations, the assumption is that maternal female caribou with young 

calves would continue to avoid active infrastructure by up to 2.49 miles and that caribou moving through 

the program area during the post-calving and insect seasons could experience delays and deflections when 

encountering roads and pipelines. 

Vehicles are likely to strike small numbers of mammals throughout future drilling and operations, although 

a vehicle management plan (ROP 23) would be required and may lower the incidence of vehicle strikes. 

Dust generated during future creation of and travel on gravel roads may add toxic metals to roadside 

vegetation that mammals forage (Walker and Everett 1987; Shotyk et al. 2016; Knight et al. 2017).

Alternative B

Seismic Exploration

Alternative B would open the entire program area to lease sales, and seismic activity could occur 

throughout the program area. Approximately 500 line miles of seismic data are expected to be collected, 

with receiver lines spaced 330 to 1,320 feet apart. Seismic activity could have potential impacts on 

terrestrial mammals, such as destruction of under-snow small-mammal habitat, disturbance of denning 

mammals, crushing of forage species, alteration of snowmelt timing.

Construction

Under this alternative, surface occupancy would be excluded from areas within 0.5 and 1 mile of selected 

river corridors (Lease Stipulation 1); this would limit disturbance on some potentially important PCH 

calving areas. Although they did not test specifically for selection of riverine areas, Young and McCabe 

(1998) found that the mean distance from rivers was closer than expected for calving PCH caribou but not 

for grizzly bears in their 1002 study area. Wilson et al. (2012) found that female Teshekpuk Herd caribou 

avoided riverine habitats at both the landscape and patch scale of selection during calving. Jakimchuk et al. 

(1987) found that female CAH caribou avoided riverine habitat during calving, while males selected riverine 

habitats during that period, although use of riparian areas was partially confounded with industrial 

development in one river corridor. 

Future development along coastal areas could hinder coastal movements of CAH and PCH animals during 

midsummer periods of mosquito harassment. Alternative B requires an impact and avoidance and 

monitoring plan to mitigate effects on wildlife along coastal areas (Lease Stipulation 9) but does not limit 

infrastructure in coastal areas.

Under Alternative B, 289,600 acres would be closed to surface occupancy. The 633,000 acres of potential 

PCH calving displacement area (based on a displacement of 2.49 miles) would affect up to 52.9 percent of 

the remaining area, although some of this buffer area would likely fall into the locations with NSO or out 

of the program area (Map 3-23, Porcupine Caribou Herd, Alternatives B, C, D1, and D2, in Appendix 

A).

Alternative B would suspend major construction activities and place limits on vehicle traffic and vehicle 

speeds in the PCH primary calving habitat area (Lease Stipulation 7 and ROP 23) during the calving period 

(May 20 to June 20). 

Density of infrastructure as well as such activity as vehicle traffic, aircraft, and human foot traffic affects 

caribou use of calving areas (Curatolo and Murphy 1986; Nellemann and Cameron 1998; Cameron et al. 

2005). Some level of displacement of calving caribou has been shown to occur even with low levels of 

traffic (Dau and Cameron 1986; Lawhead 1988, Lawhead et al. 2004), while caribou avoidance of roads in 
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

3-118 Coastal Plain Oil and Gas Leasing Program

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other seasons appears to be positively related to the intensity of the disturbance (Leblond et al. 2013). As 

a result, the limitations on vehicle and aircraft use and construction activity outlined in the Lease 

Stipulation 7, ROP 23, and ROP 34 would lower the frequency and intensity of caribou disturbance. Future 

infrastructure development, even with low levels of human activity in the area of concentrated calving for 

the PCH, could lead to displacement of calving caribou and decreased calf survival or a decline in caribou 

body condition, as described above. 

The PCH calving habitat area would not be subject to specific lease stipulations after June 20, although the 

area is used extensively by the PCH during the post-calving period (PCTC 1993); it would still be subject 

to the limitations in ROP 23 and ROP 34. As a result, some potential impacts on caribou distribution and 

movements may occur in this area during the post-calving period, although caribou exhibit less 

displacement from properly designed infrastructure during the post-calving period, compared with the 

calving period.

A total of 9.4 percent of the preferred Tussock Tundra land-cover type in the program area would be off 

limits to lease sales or surface occupancy (Table J-3 in Appendix J). Of the high use PCH calving area 

(used in greater than 40 percent of years), Alternative B would place 135,500 acres (18.6 percent) off 

limits to lease sales or surface occupancy, place TLs on 564,900 acres (77.6 percent) and leave 27,900 

acres (3.8 percent) subject only to standard terms and conditions (Table J-12 in Appendix J). 

Of the high use PCH post-calving area (used in greater than 40 percent of years), Alternative B would 

place 113,700 acres (20.4 percent) off limits to lease sales or surface occupancy. It would place TLs on 

371,300 acres (66.5 percent) and leave 73,500 acres (13.2 percent) subject only to standard terms and 

conditions (Table J-13 in Appendix J). 

Alternative B would place an area predicted to contain 0.27–1.65 percent of the CAH during different 

seasons off limits to lease sales or surface occupancy, place TLs on an area predicted to contain 0.05–0.78 

percent of the CAH during different seasons and use only standard terms and conditions in an area 

predicted to contain 0.76–4.45 percent of the CAH during different seasons (Table J-14 in Appendix J). 

Because these percentages represent seasonal averages, the percentage of the CAH moving through these 

areas during a season may be substantially higher; hence, much of the seasonally important areas for the 

PCH in the program area are open to surface occupancy but subject to TLs under Alternative B; the 

potential impacts of this alternative on caribou would depend, in large part, on how well these TLs avoid 

displacement of calving caribou and impediments to caribou movements during other times of year when 

caribou are present. 

Drilling and Development Operations

Potential impacts under Alternative B during the drilling and operations phase would be similar to the 

construction phases. Many of the same impacts that occur during construction would persist throughout 

drilling and operation, although some activities, such as gravel hauling, gravel fill placement, and pipeline 

construction, would end and others, such as vehicle and air traffic volume, would continue at a lower 

frequency. These potential impacts would be long term, lasting for at least the period of development and 

range in extent from the area of the gravel footprint to within 2.49 miles of infrastructure, as described 

above.
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

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Draft Environmental Impact Statement

Alternative C

Seismic Exploration

Alternative C would not allow surface occupancy on 606,200 acres of the PCH primary calving habitat 

area (Lease Stipulation 7); however, seismic activity could occur over the entire program area with 

potential impacts on terrestrial mammals, as described above, such as destruction of under-snow small 

mammal habitat, disturbance of denning mammals, crushing of forage species, alteration of snowmelt 

timing.

Construction

Under Alternative C, 858,000 acres (57.7 percent of the program area) would not allow surface 

occupancy. The potential 633,000 acres of PCH calving displacement (based on a displacement of 2.49 

miles) would affect up to 100 percent of the remaining area, although some of this buffer area would likely 

fall into the locations with NSO or out of the program area. Because there would be no change from 

Alternative A, no potential impacts are expected in these areas under Alternative C.

Alternative C would close the areas within 0.5 to 2 miles of selected rivers (Lease Stipulation 1) and 

606,200 acres of PCH calving habitat to surface occupancy (Lease Stipulation 7). This could limit potential 

impacts on caribou in potentially important calving areas. as described above.

Alternative C would suspend major construction activities and place limits on vehicle traffic and vehicle 

speeds in the remaining 115,000 acres of the PCH primary calving habitat area (Lease Stipulation 7) from 

May 20 to June 20 and would require sections of road to be evacuated whenever large caribou crossings 

appear to be imminent in the PCH post-calving habitat area (Lease Stipulation 8) between June 15 and July 

20. The limitations on vehicle and aircraft use and construction activity outlined in Lease Stipulation 7, 

Lease Stipulation 8, ROP 23, and ROP 34 would lower the frequency and intensity of caribou disturbance 

in this area; however, some level of displacement of calving caribou has been shown to occur even with 

low levels of traffic (Dau and Cameron 1986; Lawhead 1988, Lawhead et al. 2004).

Alternative C would not allow wells or CPFs within 1 mile of the coast (Lease Stipulation 9). PCH and 

CAH form large, fast-moving aggregations along the coast in response to mosquito harassment. This lease 

stipulation would lower the potential for infrastructure to hinder these movements. Pipelines and roads 

could still be allowed by the BLM Authorized Officer, but with proper design, caribou are generally able to 

navigate these structures, especially following habituation and with low levels of vehicle traffic (Cronin et 

al. 1994; Murphy and Lawhead 2000, Lawhead et al. 2006).

Forty-two percent of the Tussock Tundra land cover type in the program area would be off limits to lease 

sales or surface occupancy (Table J-5 in Appendix J). Of the high use PCH calving area (area used in 

greater than 40 percent of years), Alternative C would place 631,100 acres (86.7 percent) off limits to 

surface occupancy, would place TLs on 83,400 acres (11.5 percent), and would leave 13,700 acres (1.9 

percent) subject to only standard terms and conditions (Table J-12 in Appendix J). 

Of the high use PCH post-calving area (used in greater than 40 percent of years), Alternative C would 

place 450,400 acres (80.6 percent) off limits to surface occupancy, would place TLs on 108,000 acres (19.3 

percent), and would leave 108,000 acres (0.02 percent) subject to only standard terms and conditions 

(Table J-13 in Appendix J). 

Alternative C would place an area predicted to contain 0.4–2.54 percent of the CAH during different 

seasons off limits to surface occupancy, would place TLs on an area predicted to contain 0.21–1.36 percent 
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

3-120 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

of the CAH during different seasons, and would use standard terms and conditions in an area predicted to 

contain 0.39–2.68 percent of the CAH during different seasons (Table J-14 in Appendix J). Because 

these percentages represent seasonal averages, the percentage of CAH animals moving through these 

areas during a season may be substantially higher. 

Much of the seasonally important areas for the PCH in the program area is closed to surface occupancy 

under Alternative C; however, a smaller percentage of the area and some concentrated calving areas used 

in less than 40 percent of years are subject to TLs or to only standard terms and conditions, except those 

that apply to all alternatives (ROP 23 and ROP 34). The potential impacts of this alternative on caribou 

would depend on how well the area off limits to surface occupancy captures the preferred calving area for 

the PCH, how well these TLs and ROPs avoid displacing calving caribou in areas with surface occupancy, 

and how well it minimizes impediments to caribou movements during other times of the year. 

Drilling and Development Operations

Additional potential impacts under Alternative C during the drilling and operations phase would be similar 

to the construction phases. Many of the same impacts that occur during construction would persist 

throughout drilling and operation, although some activities, such as gravel hauling, gravel fill placement, and 

pipeline construction, would end and others, such as vehicle and air traffic volume, would continue at a 

lower frequency. These potential impacts would be long term, lasting for at least the period of 

development and range in extent, from the area of the gravel footprint to within 2.49 miles of 

infrastructure, as described above; however, the areas of NSO would have no additional impact relative to 

Alternative A.

Alternative D

Seismic Exploration

Alternative D would close 476,600 acres of the PCH primary calving habitat area to lease sales; however, 

seismic activity could occur over the entire program area, with potential impacts on terrestrial mammals, 

as described above, such as destruction of under-snow small mammal habitat, disturbance of denning 

mammals, crushing of forage species, alteration of snowmelt timing. This alternative would prohibit winter 

activity within 1 mile of polar bear denning habitat (Lease Stipulation 5), an area that would likely also 

include some grizzly bear dens, due to similar habitat preferences.

Construction

Alternative D would close to lease sales or to surface occupancy those areas within 0.5 to 4 miles of 

selected rivers (Lease Stipulation 1), areas of the Canning River delta (Lease Stipulation 2), areas within 1 

to 4 miles of selected springs and aufeis, the area within 3 miles of the east bank of the Canning River 

(Lease Stipulation 3), all 721,200 acres of the PCH primary calving habitat area (Lease Stipulation 7), and 

areas within 3 miles of the wilderness border (Lease Stipulation 10). Because there would be no change 

from Alternative A, no impacts are expected in these areas for Alternative D. The limits on surface 

occupancy near rivers and on the Canning River delta would ensure that development would not hinder 

caribou movements in these areas. The Canning River delta is used by large numbers of CAH caribou

during midsummer in some years (Table J-14 in Appendix J), and one muskox group has often used it in 

recent years; limiting infrastructure in this area would limit alterations to the movements of this group.

Alternative D would not allow CPFs in the PCH post-calving habitat area and would limit total 

infrastructure density in this area (Lease Stipulation 8). Sections of road would also be evacuated whenever 

large crossings of caribou appear to be imminent in this area (Lease Stipulation 8). The density of 
3. Affected Environment and Environmental Consequences (Terrestrial Mammals)

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Draft Environmental Impact Statement

infrastructure affects caribou use of an area during calving and creates additional barriers for caribou 

movements during summer (Nellemann and Cameron 1998; Cameron et al. 2005); hence, limits on the 

density of development should improve caribou movement through the area. 

Under Alternative D1,158,700 acres (77.9 percent of the program area) would be closed to lease sales or 

have NSO restrictions. The potential 633,000 acres of PCH calving displacement (based on a displacement 

of 2.49 miles) is larger than the 328,600 acres of the program area remaining open to surface occupancy. 

Alternative D2 would limit major construction (Lease Stipulation 6) from May 20 to July 20. Sections of 

road would also be evacuated whenever large crossings of caribou appear to be imminent in the postcalving area (Lease Stipulation 8). These limits would lower the probability of displacement of caribou 

during calving and lower the frequency of delays in caribou movements or caribou disturbance during 

summer. Traffic volumes of 15 vehicles per hour or more have been shown to deflect caribou movements 

and delay road crossings, even in the absence of adjacent pipelines (Curatolo and Murphy 1986; Cronin et 

al. 1994). 

Alternative D would not allow wells or CPFs and would restrict vessel activity within 2 miles of the coast 

(Lease Stipulation 1). PCH and CAH caribou form large, fast-moving aggregations along the coast in 

response to mosquito harassment; hence, this lease stipulation would lower the potential for 

infrastructure to hinder these movements. Pipelines and roads could still be allowed by the BLM 

Authorized Officer; however, with proper structure design, caribou are generally able to navigate them, 

especially following habituation and with low levels of vehicle traffic (Cronin et al. 1994; Murphy and 

Lawhead 2000, Lawhead et al. 2006).

A total of 66.5 percent of the Tussock Tundra land cover type in the program area would be off limits to 

lease sales or surface occupancy (Table J-7 in Appendix J). Of the high use PCH calving area (used in 

greater than 40 percent of years), Alternative D1 would place 714,000 acres (98.0 percent) off limits to 

lease sales or surface occupancy, would control surface use in 5,400 acres (0.1 percent), and would use 

only standard terms and conditions on the remaining 8,900 acres (1.2 percent; Table J-12 in Appendix 

J). Alternative D2 would place 714,000 acres (98.0 percent) off limits to lease sales or surface occupancy, 

would control surface use in 5,400 (0.7 percent), and would place TLs on 8,900 acres (1.2 percent; Table 

J-12 in Appendix J).

Of the high use PCH post-calving area (used in greater than 40 percent of years), Alternative D1 would 

place 501,500 acres (89.8 percent) off limits to lease sales or surface occupancy and would control surface 

use in or use only standard terms and conditions on the remaining 56,800 acres (10.2 percent; Table J-13

in Appendix J). Alternative D2 would place 501,500 acres (89.8 percent) off limits to lease sales or 

surface occupancy and would control surface use or place TLs in the remaining 56,800 (10.2 percent) 

(Table J-14 in Appendix J).

Alternative D would place an area predicted to contain 0.64–3.84 percent of the CAH during different 

seasons off limits to lease sales or surface occupancy, would control use in an area predicted to contain 

0.13–0.81 percent of the CAH during different seasons, and would use standard terms and conditions 

(Alternative D1) or TLs (Alternative D2) on an area predicted to contain 0.27–1.92 percent of the CAH 

during different seasons (Table J-14 in Appendix J). Because these percentages represent seasonal 

averages, the percentage of CAH animals moving through these areas during a season may be substantially 

higher. 
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Based on the previously recorded calving distribution, most of the seasonally important areas for the PCH 

in the program area are closed to surface occupancy under Alternative D, but some concentrated calving 

areas used in less than 40 percent of years would be subject to only standard terms and conditions 

(Alternative D1) or TLs (Alternative D2); hence, in the absence of large shifts in calving distribution, little 

displacement of calving PCH caribou is expected during most years. Additional areas closed to surface 

occupancy would provide additional options for calving caribou to select areas away from infrastructure.

Drilling and Development Operations

Additional potential impacts under Alternative D during the drilling and operations phase would be similar 

to the construction phases. Many of the same impacts that occur during construction would persist 

throughout drilling and operation, although some activities, such as gravel hauling, gravel fill placement, and 

pipeline construction) would end and others, such as vehicle and air traffic volume, would continue at a 

lower frequency. These potential impacts would last for at least the period of development and would 

range in extent from the area of the gravel footprint to within 2.49 miles of infrastructure, as described 

above; however, the areas of NSO would have no additional impact relative to Alternative A.

Cumulative Impacts

Subsistence hunting of caribou has probably occurred in the program area for millennia (USFWS 2015a). 

Most terrestrial mammals in the program area currently have little interaction with infrastructure. There is 

permanent development associated with the community of Kaktovik as well as use of the area by 

subsistence hunters, hunters from outside the NSB, scientists, and recreationists. Far-ranging species such 

as caribou may encounter the Dempster Highway and other development in the Yukon (Johnson and 

Russell 2014), communities south of the program area, or oil and gas development west of the program 

area. Caribou of the CAH have had some interaction with oil and gas development for approximately 40 

years. 

The use of roads by local hunters to achieve summer and winter access to subsistence hunting areas may 

alter the distribution of hunting in the area and could further displace caribou and other mammals away 

from gravel roads, potentially delaying habituation; however, hunting is allowed along most roads in Alaska, 

including some roads that bisect caribou herd ranges (Boertje et al. 2012). To a lesser extent, roads may 

also be used by non-subsistence hunters and recreationists in summer and winter. The effects of climate 

change described under Affected Environment above, could influence the rate or degree of the potential 

cumulative impacts.

3.3.5 Marine Mammals

Affected Environment

All marine mammals found in US waters are protected under the MMPA, as amended (16 USC 1631 et 

seq.). Some species receive additional protection under the ESA (16 USC 1531 et seq.). Whales, seals, and 

porpoises are managed by the NMFS, whereas polar bears and walruses are managed by the USFWS. The 

NMFS and USFWS stock assessment reports (SARs) contain detailed information on the status, seasonal 

distribution, abundance, and life history of marine mammals in the Beaufort Sea. NMFS publishes current 

SARs for whales, seals, and sea lions (Muto et al. 2018; www.nmfs.noaa.gov/pr/sars) and the USFWS 

publishes current SARs for Pacific walrus and polar bear (www.fws.gov/alaska/fisheries/mmm/stock). 

Additional information on polar bears and Pacific walrus can be found in the Beaufort Sea ITR Final Rule 

(81 FR 52276). Further, the Final EIS on Effects of Oil and Gas Activities in the Arctic (NMFS 2016a) 

provides detailed descriptions of marine mammal population status and trends, distribution, seasonal 
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migration and movements, habitat use, reproduction and growth, survival, and mortality. These documents 

are incorporated into this EIS by reference.

Nine species of marine mammals have been recorded in marine waters within 5 nautical miles of the 

program area (Table 3-20). The bowhead whale is listed as endangered under the ESA, and the polar 

bear and bearded and ringed seals are listed as threatened. 

Table 3-20

Marine Mammal Species Occurring within 5 NM of the Arctic Refuge Coastline and 

Their Status in the Program Area

Common Name Scientific Name Status Occurrence3

Bowhead whale Balaena mysticetus Endangered1 Common

Beluga Delphinapterus leucas Depleted2 Common

Gray whale Eschrichtius robustus Depleted2 Casual

Harbor porpoise Phocoena Protected2 Casual

Bearded seal Erignathus barbatus Threatened1Fairly common

Ringed seal Phoca (Pusa) hispida Threatened1 Common

Spotted seal P. largha Protected4Fairly common

Pacific walrus Odobenus rosmarus Protected2 Casual

Polar bear Ursus maritimus Threatened1 Common

Source: ASAMM 2017; Muto et al. 2018

1Under the ESA (ESA-listed species are considered depleted under the MMPA).

2Under the MMPA.

3Common = recorded in every year; fairly common = recorded in most years; uncommon = recorded once every 3–5 years; 

rare = in its normal range but recorded less than every 5 years; casual = beyond its normal range, further observations unlikely. 

Occurrence is based primarily on data from the Aerial Surveys of Arctic Marine Mammals Program funded by BOEM and 

National Oceanic and Atmospheric Administration (NOAA).

4The Bering distinct population segment (DPS) uses the program area and is not listed under the ESA (the Southern DPS is 

listed as threatened but does not occur in the program area).

Table 3-21 lists additional species of marine mammals that may be encountered in the Bering and 

Chukchi Seas by post-lease oil and gas activity vessel traffic from Dutch Harbor to the program area 

(Figure 3-6, Marine Barge Route—Dutch Harbor to Program Area, in Appendix A). Species currently 

listed as threatened or endangered under the ESA are fin, humpback, and right whales, Steller sea lions, 

and sea otters. The discussion below focuses on the ESA-listed species and the beluga whale, which occurs 

commonly nearshore and is of interest for subsistence harvest. Narwhals (Monodon monoceros) and 

hooded seals (Cystophora cristata) are considered extralimital to the program area and are not discussed in 

this EIS. 

Polar Bear

Distribution

Polar bears have a circumpolar distribution in the Northern Hemisphere. In Alaska, they occur most 

commonly within 200 miles of the coast of the Arctic Ocean (Amstrup and DeMaster 1988). Nineteen 

subpopulations (stocks) of polar bears have been identified throughout their range, ranging from several 

hundred to several thousand animals each and, in the latest estimate, totaling approximately 26,000 

individuals range wide (95 percent CI = 22,000–31,000; Wiig et al. 2015; Durner et al. 2018).
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Table 3-21

Additional Marine Mammal Species Occurring Along Vessel Transit Routes 

in the Bering and Chukchi Seas

Common Name Scientific Name Status

Steller’s sea lion (Western DPS) Eumetopias jubatus Endangered2

Ribbon seal Histriophoca fasciata Protected1

Northern sea otter (Southwest Alaska DPS) Enhydra lutris Threatened2

North Pacific right whale Eubalaena japonica Endangered2

Minke whale Balaenoptera acutorostrata Protected1

Blue whale B. musculus Endangered2

Fin whale B. physalus Endangered2

Humpback whale (Western North Pacific DPS) Megaptera novaeangliae Endangered2

Gray whale (Western North Pacific DPS) Eschrichtius robustus Endangered2

Pacific white-sided dolphin Lagenorhynchus obliquidens Protected1

Killer whale Orcinus orca Protected1

Harbor porpoise Phocoena Protected1

Dall’s porpoise Phocoenoides dalli Protected1

Sperm whale Physeter catodon Endangered2

Baird’s beaked whale Berardius bairdii Protected1

Stejneger’s beaked whale Mesoplodon stejnegeri Protected1

Cuvier’s beaked whale Ziphius cavirostris Protected1

Source: NOAA 2018; Muto et al. 2018

1Under the MMPA

2Under the ESA; listed species are considered depleted under the MMPA

Bears from three stocks occur in US waters off Alaska: the Northern Beaufort Sea stock, the SBS stock, 

and the Chukchi Sea stock (Bethke et al. 1996; Amstrup 2003a; Amstrup et al. 2004a; Schliebe et al. 2006; 

Obbard et al. 2010; Durner et al. 2018). The SBS stock is the subpopulation most likely to occur in the 

program area, so the analyses below focus on this stock. Based on the distribution and characteristics of 

sea ice and corresponding population movements (Amstrup et al. 2007), SBS bears either move with the 

retreating ice or abandon it to spend the summer on land (Durner et al. 2009).

The SBS stock ranges over an expansive area, extending from Icy Cape and Point Hope on the Chukchi 

Sea coast of Alaska eastward to Cape Bathurst in the Northwest Territories of Canada, and seaward at 

least 185 miles from the coast (Amstrup 2000, 2002; Bethke et al. 1996; Brower et al. 2002; Schliebe et al. 

2006). The core activity area of the SBS stock encompasses a considerably smaller region from Herschel 

Island, Yukon, to Point Barrow, Alaska, and seaward about 85 miles (Amstrup 2000); thus, the program 

area is in the core activity area of the SBS.

Species Status

The USFWS listed the polar bear as a threatened species under the ESA in May 2008 (73 FR 28212). The 

ESA listing decision was based on the rapidly diminishing sea-ice cover and thickness in the Arctic Ocean 

due to climate change, primarily during summer (73 FR 28212; Durner et al. 2009). 

The continuing loss of sea ice was judged to put polar bears at risk of becoming endangered throughout 

their range in the foreseeable future. Subsequent modeling analyses predict that declining sea ice cover 

risks significant declines in polar bear populations within three generations (35–41 years; Regehr et al. 

2016). Considerable research has focused on changes in population status and survival because of 

diminishing sea ice habitat. Regehr et al. (2010) documented decreases in vital rates of the SBS stock, 
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including survival and breeding rates, corresponding to increases in the number of ice-free days per year in 

waters over the Beaufort Sea continental shelf (including waters adjoining the program area). 

The best available analyses suggest that the SBS stock is declining (Obbard et al. 2010; Bromaghin et al. 

2015; USFWS 2017). The estimated population size of the SBS stock was approximately 900 bears in 2010 

(90 percent CI = 606–1,212; Bromaghin et al. 2015). The authors noted, however, that suspected biases 

may have affected the abundance estimate, which represents a significant reduction from previous 

estimates of approximately 1,800 in 1986 (Amstrup et al. 1986) and 1,526 in 2006 (Regehr et al. 2006). 

Furthermore, analyses of over 20 years of data on the size and body condition of bears in the SBS stock 

demonstrated declines for most sex and age classes and significant negative relationships between annual 

sea ice availability and body condition (Rode et al. 2010). The estimate of 900 bears is currently used for 

management purposes by the USFWS (USFWS 2017).

Human activities that can affect polar bears are regulated by the USFWS under both the MMPA and ESA, 

with the former law taking precedence in the permitting process regarding incidental take. The principal 

mechanism for regulating human activities in regard to polar bears are incidental take authorizations, 

generally in the form of ITRs. These regulations allow industry operators to unintentionally take small 

numbers of polar bears provided that it results in negligible impacts on the species and does not have an 

unmitigable adverse impact on the availability of the species for subsistence use by Alaska Natives. 

ITRs also include measures to avoid and minimize bear conflict with humans. Upon issuance of a LOA by 

the USFWS, trained personnel are allowed to haze or otherwise take polar bears under specific 

circumstances involving the protection of human life. The USFWS has voluntary deterrence guidelines (75 

FR 61631) to deter polar bears without causing injury or death, focusing on passive measures intended to 

prevent bears from gaining access to property or people, such as fencing, gates, skirting, exclusion cages, 

and bear-proof garbage containers, as well as on preventive measures to discourage bears from interacting 

with property or people, such as acoustic devices for auditory disturbance and vehicle or boat deterrence. 

Oil and gas activities in the Alaska Beaufort Sea currently are subject to ITRs until August 2, 2021 (81 FR 

52276); however, the program area is not included in the geographic region of the current ITRs.

Polar bear harvesting is legal for Alaska Natives under the MMPA. Polar bear harvests in the southern 

Beaufort Sea are managed through the Iñupiat–Iñuvialuit Agreement, a voluntary Native-to-Native 

agreement between the US and Canada (Nageak et al. 1991). For the 10-year period from 2006 through 

2015, an average of 19 bears per year were removed from the US portion of the SBS stock, averaging 50 

percent males, 27 percent females, and 22 percent unreported sex (USFWS 2017). 

Population Movements

Polar bears of the SBS stock range over large areas, with annual activity areas of collared individuals ranging 

from 2,805 to 230,426 square miles (Amstrup et al. 2000). They are transient throughout the nearshore 

areas of the Beaufort Sea coast, including the program area. The largest monthly movements occur during 

early winter and the smallest in early spring; females with cubs move less and cover smaller areas than do 

males and other age classes. Movements are increasing as sea-ice cover diminishes. From 1979 to 2006, 

collared female polar bears moving from the pack ice to denning areas onshore experienced an average 

increase in travel distance of 3.7 miles per year (Bergen et al. 2007).

Polar bears typically use land only during late summer, autumn, and the maternal denning season in winter; 

besides denning females, adult females with and without cubs, subadults, and adult males all come ashore. 

Polar bears begin to appear on the mainland and barrier islands in July and August, during the open-water 
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period (Miller et al. 2006; Schliebe et al. 2008). As seasonal and pack ice cover spreads southward in the 

late fall and winter, polar bears move with it, appearing along the Beaufort Sea coast (Amstrup et al. 2000), 

although some may remain on pack ice all year, if there is continuous access to prey (Stirling 2009). 

The number of bears observed on coastal surveys in the fall was significantly related to the distance of pack 

ice from shore (Schliebe et al. 2008; Wilson et al. 2017). Except for pregnant females that remain to den, 

bears using land begin to leave when sea ice develops, usually by late October (Schliebe et al. 2001; 

Kalxdorff et al. 2002). Rapid environmental changes from lengthening of the ice-melt season and diminished 

sea ice cover has increased the bears’ use of terrestrial habitats: the percentage of collared female SBS 

bears coming ashore tripled over 15 years since the late 1990s, with bears arriving onshore earlier, staying 

longer, and departing later (Atwood et al. 2016). The mean duration of the open-water period increased 

by 36 days in that period, and the mean length of stay increased by 31 days.

It has been known for a long time, as stated by several Alaska Native informants (in USFWS 1995), that 

polar bears become increasingly abundant on the mainland and barrier islands during the open-water 

season in late summer and the fall subsistence whaling season. USFWS biologists flew 53 aerial surveys 

along the entire Beaufort Sea coast between Point Barrow and the Canada border in fall 2000 to 2014, 

averaging 64 bears per survey and recording a maximum of 156 bears on a single survey in August 2012 

(Wilson et al. 2017). On average, 4 to 8 percent of the bears in the SBS stock were observed on land per 

survey (Schliebe et al. 2008). Most sightings on those coastal surveys (82 percent) were recorded on 

barrier islands, with 11 percent on the mainland and 6 percent on landfast ice (74 FR 56068). 

Peak numbers of polar bears observed on land generally occurred in late September and early October 

(USFWS 1995; Schliebe et al. 2001, 2008; Kalxdorff et al. 2002). Bear numbers onshore have increased in 

autumn in certain locations, with the greatest concentrations occurring at Barter Island, Cross Island, and 

Point Barrow, where bears feed on bone piles of butchered bowhead whales taken during the autumn 

subsistence hunt (Miller et al. 2006; Schliebe et al. 2008; Atwood et al. 2016; Lillie 2018). Genetic analysis 

of hair-snare samples estimated that as many as 146 individuals (standard error = 21), representing 

approximately 16 percent of the most recent SBS stock estimate, visited the whalebone pile in Kaktovik in 

2012 (Lillie 2018). The number of polar bears onshore is related to sea ice dynamics, although the 

distribution of bears onshore was most strongly influenced by the availability of food from subsistence 

whaling (Wilson et al. 2017). 

Life History

Polar bears are large, long-lived (29–32 years), opportunistic hunters that feed primarily on ringed and 

bearded seals but also on beached carcasses of marine mammals (whales and walrus) (Smith 1980; 

Amstrup 2003a; Schliebe et al. 2006; Miller et al. 2006). Adult males and non-pregnant females are active 

all year. Mating occurs from March to late May. Pregnant females construct and enter snowdrift natal dens 

in October or November (Amstrup and Gardner 1994) and give birth in late December or early January. 

Mothers and cubs emerge from natal dens in late March or April, when the cubs are 3 to 4 months old 

(Lentfer and Hensel 1980; Amstrup and Gardner 1994; Smith et al. 2007). The cubs remain near the dens 

for up to 2 weeks (Smith et al. 2007) as they adapt to outside temperatures. Cubs usually stay with their 

mothers until they are 1.5 to 2.5 years old (Stirling et al. 1975). Females breed again at about the same 

time they separate from their young, resulting in a breeding interval of females that successfully wean cubs 

of 3 years or longer.
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Critical Habitat

The USFWS designated critical habitat for polar bears in Alaska in 2011 (75 FR 76086). Three units of 

critical habitat (all of which occur in the program area; Map 3-24, Polar Bear Habitat, in Appendix A) 

were designated, corresponding to the following primary constituent elements of critical habitat described 

in the final rule: 

 Sea-ice habitat, used for feeding, breeding, denning, and movements, in US territorial waters

 Terrestrial denning habitat, on land along the northern coast of Alaska, with characteristics 

suitable for capturing and retaining snow drifts of sufficient depth to sustain maternal dens through 

winter, occurring within 20 miles of the coast between the US-Canada border on the east and the 

Shaviovik and Kavik Rivers on the west (including the program area), and within 5 miles of the 

coast from the Shaviovik and Kavik Rivers west to Point Barrow

 Barrier island habitat, used for denning, refuge from human disturbance, and movements along the 

coast for access to denning and feeding habitats, comprising barrier islands and associated 

mainland spits, along with the water, ice, and terrestrial habitat within 1 mile of those features, 

designated as a no-disturbance zone

Critical habitat excludes human-made structures and the land on which they are located, as well as seven 

specific areas consisting of the communities of Utqiaġvik and Kaktovik and five US Air Force radar sites 

(Point Barrow, Point Lonely, Oliktok Point, Bullen Point, and Barter Island).

Habitat Use

Polar bears are strong swimmers but rely principally on the availability of sea ice habitats to roam, hunt, 

breed, den, and rest. Up to 37 percent of adult females have been estimated to use land in the summer but 

spending an average of 56 days onshore (Atwood et al. 2016). Given that adult males and subadult bears of 

both sexes cannot be collared to track their movements, it is not clear what proportion of those bears use 

land; however, it is clear that they also use land in the summer and autumn (Miller et al. 2015). 

Preferred habitats are in the active seasonal ice zone that overlies the continental shelf and associated 

islands and in areas of heavy offshore pack ice (Stirling 1988; Durner et al. 2004, 2009). Adult males usually 

remain there, rarely coming ashore (Amstrup and DeMaster 1988). Habitat use changes seasonally with 

the formation, advance, movement, retreat, and melt of sea ice (Amstrup et al. 2000; Ferguson et al. 2000; 

Durner et al. 2004, 2009; Schliebe et al. 2008). During winter and spring, polar bears tend to concentrate 

in areas of ice with pressure ridges, at floe edges, and on drifting seasonal ice at least 8 inches thick (Stirling 

et al. 1975, 1981; Schliebe et al. 2006); the greatest densities occur in the latter two categories, 

presumably because those habitats provide greater access to seals. Use of shallow water is greatest in 

winter, in areas of active ice with shear zones and leads (Durner et al. 2004). Use of landfast ice increases 

in spring during the pupping season of ringed seals. Multiyear ice is selected in late summer and early 

autumn as the pack ice retreats to its minimal extent (Ferguson et al. 2000; Durner et al. 2004).

Maternal Denning

The southern Beaufort Sea is an area of widespread, low-density denning by maternal polar bears 

(Amstrup 2003b; Schliebe et al. 2006). The total number of maternal dens occupied annually by females of 

the SBS stock has been estimated at 140 to 240 (Amstrup and Gardner 1994; 75 FR 76099). 

Notable shifts in the distribution of maternal dens in northern Alaska were documented by comparing 124 

den locations used by 85 collared SBS bears between 1985 and 1994 and between 1997 and 2004, 
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documenting a landward and eastward shift in maternal denning along the Beaufort Sea coast (Fischbach et 

al. 2007). The proportion of dens on drifting sea ice decreased from 62 percent in the early period to 37 

percent in the later period, and proportionately fewer dens occurred on pack ice in the western Beaufort 

Sea in the later period. Although female polar bears do not show fidelity to specific den locations, they 

tend to den on the same substrate (sea ice or land) from year to year and may return to the same general 

area to den (Amstrup and Gardner 1994; Amstrup 2003b; Schliebe et al. 2006; Fischbach et al. 2007). 

Fischbach et al. (2007) noted that more females shifted from sea ice to land during both periods studied 

and that females in the later period showed greater fidelity to land for denning. 

This increasing trend of more bears denning on land has continued (Olson et al. 2017). The use of denning 

substrate (sea ice or land) is significantly related to where bears occur in autumn. Pregnant polar bears in 

the SBS stock that spent 25 days or more on land in autumn all subsequently denned on land (Olson et al. 

2017). Between 1985 and 2013, the percentage of SBS females denning on land increased from 34 to 55 

percent, linked to sea ice declines. Terrestrial Denning Critical Habitat overlaps 77 percent of the program 

area of the Arctic Refuge (USFWS 2010), and 38 percent more potential maternal denning habitat is 

available in the program area than in the region immediately west of it (Durner et al. 2006). 

Polar bears have been shown to den in the program area with greater frequency than expected, based on 

available habitat (Amstrup 1993). From 2000 to 2010, 22 percent of the known maternal dens of the SBS 

stock occurred in the program area (Durner et al. 2010); thus, the program area has been shown to be an 

important area for maternal denning and would likely increase in importance as the percentage of bears 

denning on land increases with continuing sea-ice loss (Olson et al. 2017). 

Because of bears’ greater proximity to settlements, industrial sites, and other coastal areas of human 

activity, dens on land and landfast ice are more vulnerable to disturbance by human activity than are dens 

on sea ice. A few records of female polar bears denning successfully in snow drifts near oil infrastructure 

have been recorded since development began in the oilfields along the central Beaufort Sea coast.

Pregnant polar bears denning in terrestrial habitats excavate maternal dens in compacted snow drifts next 

to coastal banks of barrier islands and mainland bluffs, river, stream, and lake banks, and other areas with 

suitable topographic relief (Amstrup and DeMaster 1988; Durner et al. 2001, 2003, 2006). In the program 

area, 46 maternal dens have been documented in terrestrial habitats, 18 of which were located between 

the Katakturuk and Sadlerochit River drainages in the central portion of the program area; 12 other dens 

were found on sea ice within 5 miles of the program area and in the Arctic Refuge south of the program 

area (Map 3-24 in Appendix A). 

The dens in this sample were found using a variety of methods; most were found by radio-tracking bears 

collared with very high frequency radio collars or satellite transmitters from 1989 to 2010, whereas others 

were found through opportunistic encounters or dedicated searches from as early as 1913 to as recently 

as 2010 (Durner et al. 2010). Based on the estimated population of the SBS stock, the proportion of adult 

females in the population, the breeding probability of adult females, the proportion of dens on land, and 

the proportion of historical dens in the program area, approximately 19 female bears may den in the 

program area annually.27

 

27Wilson, Ryan. Personal communication. Phone conversation, BLM to USFWS on October 19, 2018 regarding 

polar bear denning activity in the Coastal Plain.
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The most important characteristic of maternal denning habitat is the presence of topographic features of 

sufficient height and slope to catch blowing snow and form persistent drifts in early winter, with at least 

4.3 feet of vertical topographic relief and steep slopes (mean 40°, range 15.5–50°) (Amstrup and DeMaster 

1988; Durner et al. 2001, 2003, 2006). Biologists characterized and mapped landscape features (bankhabitat segments) considered to provide suitable maternal denning habitat along the Alaska Beaufort Sea 

coast, from the NPR-A to the Canada border (Durner et al. 2001, 2003, 2006, 2013; Map 3-24 in 

Appendix A). Aerial imagery showed that approximately 1,815 miles of bank habitats were delineated by 

Durner et al. (2006) in the program area. Since then, synthetic aperture radar also has been used to detect 

suitable denning habitat, producing similar results (Durner and Atwood 2018). 

Other researchers recently developed a three-dimensional spatial model, integrating snow physics, 

weather data, and a high-resolution digital elevation model, to predict the occurrence of potential denning 

habitat along the Beaufort Sea coast (Liston et al. 2015). All of these techniques provide fine-scale results 

to focus aerial surveys of denning habitat using thermal imaging equipment (forward-looking infrared 

radiometry [FLIR]). This method is the most suitable for searching large areas for maternal dens in advance 

of seismic exploration or other potentially disturbing activities (York et al. 2004; Owyhee Air Research 

2018).

Bowhead Whale

Bowhead whales transit past the program area during spring (April–June) and fall (September and 

October) migration, traveling along the shelf break and coming close to shore to feed (Quakenbush et al. 

2010; Citta et al. 2015; Map 3-25, Bowhead and Beluga Whale Sightings, in Appendix A). They may 

occur in the program area throughout the open-water season. Bowhead whales were listed as endangered 

under the predecessor of the ESA in 1973, but no critical habitat has been designated. The decline in 

extent and duration of sea ice over the past 40 years has coincided with an increase in harvest by residents 

of Kaktovik, who harvested 1–2 whales per year from 1973 to 1994 and 2–4 whales per year from 1995 to 

2016 (Koski et al. 2005; Suydam and George 2018). The Western Arctic population of bowhead whales 

increased at a rate of 3.2–3.7 percent from 1978 to 2011 (Schweder et al. 2009; Givens et al. 2013), and 

the current population estimate is 16,820 individuals (95 percent CI: 15,176–18,643; Givens et al. 2016)

Beluga Whale

Beluga whales in Arctic Alaska belong to the Beaufort Sea (BS) and the Eastern Chukchi Sea (ECS) stocks 

(Muto et al. 2018). They use waters in the eastern Beaufort Sea but stay farther offshore than bowhead 

whales, typically beyond the shelf break (Hauser et al. 2014). Spring migration eastward through the 

Beaufort Sea is stock-specific, with BS stock migrating in spring and ECS stock migrating in summer. The 

main fall migration corridor of belugas is over 54 NM north of the coast; however, they do occasionally 

approach shallow water in coastal areas, such as lagoons and river deltas, to molt or feed (Suydam 2009). 

Belugas have been recorded within 5 NM of the program area in the lagoons (Map 3-25 in Appendix A) 

and are sometimes harvested by Kaktovik residents. The population estimate for the ECS stock is 

approximately 20,000 belugas (Lowry et al. 2017). Although the BS stock was estimated to be 

approximately 39,000 whales, based on 1996 information, there is currently no recent reliable population 

estimate available for the BS stock (Muto et al. 2018); however, trend data suggest that the stock is at least 

stable (Harwood and Kingsley 2013).
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Other Whales

Whale species that may be encountered by vessels in transit from Dutch Harbor to the Beaufort Sea are 

described in the EIS for the Liberty development project (BOEM 2018b), incorporated here by reference. 

In addition to the species listed above, sub-arctic whales that could be encountered during vessel transit 

are blue, fin, humpback, minke, North Pacific right, sperm, and killer whales. Blue whales are present in 

Alaska waters only during their non-breeding season and would be found in the open waters near the 

Aleutian Islands and the Bering Sea. Fin whales are present in both the Bering and Chukchi Seas in the 

summer, with greater numbers in the Bering than the Chukchi Sea (Muto et al. 2018). Individual humpback 

whales from the Western North Pacific Stock could occur in the Bering Sea and possibly in parts of the 

Chukchi and Beaufort seas (Muto et al. 2018), although sightings are rare. Minke whales are believed to be 

migratory summer residents of the Chukchi and Bering Seas, and move south of the Bering Sea to 

overwinter. North Pacific right whales are considered the rarest of all large whale species and among the 

rarest of all marine mammal species. Critical habitat was designated for the eastern North Pacific right 

whale in 2008 (73 FR 19000) in the Bering Sea, based on geographic coordinates where they have been 

consistently sighted in spring and summer.

Ringed Seal

Ringed seals are year-round residents in the Beaufort Sea (Muto et al. 2018). They use sea ice as a platform 

for pupping in the winter and early spring, molting in early summer, and resting throughout the year (Kelly 

1988). Ringed seals can be found in the nearshore areas during the summer and winter (Williams et al. 

2002). Optimal wintering areas for ringed seals in the Beaufort Sea are generally in waters 32–115 feet 

deep; however, under-snow seal structures have been found in waters depths of 5–10 feet in the central 

Beaufort Sea (Williams et al. 2006), indicating that a small number of seals could use portions of the 

program area.

The decline in extent and duration of sea ice cover is the primary conservation concern leading to their 

listing as threatened under the ESA in 2012. During the summer, ringed seals forage along ice edges 

offshore and in productive open water (Harwood et al. 2015), including waters within 5 NM of the 

program area (Map 3-26, Seal Sightings, in Appendix A). The population trends and status of this stock 

are currently unknown (Muto et al. 2018), but there are indications that ocean conditions have been 

favorable for ringed seals recently: ringed seals near Kaktovik are growing and maturing faster and at a 

younger age now than 30 years ago (Quakenbush et al. 2011).

Bearded Seal

Bearded seals are associated with offshore pack ice throughout the year, remaining close to the ice edge 

for as long as the ice is available. They use ice as a platform for breeding, pupping, molting, and resting. In 

summer, bearded seals may use nearshore areas of the Beaufort Sea (Map 3-26 in Appendix A), and 

occasionally haul out on land (Muto et al. 2018). The primary conservation concern for this species is the 

ongoing and projected loss of sea ice cover (Cameron et al. 2010), which led to their listing as threatened 

under the ESA in 2012. 

No reliable population estimate and no reliable data on trends of population abundance are available for 

the entire Alaska stock of bearded seals (Muto et al. 2018). The most recent abundance estimate for 

bearded seals in US waters (299,174 individuals; 95 percent CI: 245,476–360,544) applies only to the 

Bering Sea (Conn et al. 2014). Residents of Kaktovik hunt bearded seals as part of their subsistence 

activities, but seals are not considered a primary food source (Clough et al. 1987). Bearded seals are 

expected to occur within 5 NM of the program area.
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Other Marine Mammals

Pinniped species that may be encountered by vessels in transit from Dutch Harbor to the Beaufort Sea are 

described in the EIS for the Liberty development project (BOEM 2018b), incorporated here by reference. 

Steller sea lions typically occur in coastal areas of the North Pacific and Bering Sea, and are commonly 

encountered by vessels traveling in and out of Dutch Harbor and near the Pribilof Islands where large 

breeding rookeries occur. Spotted seals are widely distributed on the continental shelf of the Bering, 

Chukchi, and Beaufort seas, with pupping and breeding occurring primarily south of Bering Strait (Boveng 

et al. 2009). While extralimital near the program area, Pacific walruses are common in the Bering and 

Chukchi seas and occasionally range into the Beaufort Sea (Fay 1982; Garlich-Miller et al. 2011). The 

Southwest Stock of northern sea otters may be encountered by barges near Dutch Harbor, but probably 

not in offshore areas.

Climate Change

Climate change is a global issue affecting marine mammals in the program area (see Section 3.2.1). 

Climate warming is expected to be most dramatic in the Arctic, with rates of warming nearly twice that 

experienced globally (ACIA 2005; Wendler et al. 2014). The effects of these global trends are complicated; 

yet the forecast models—based on current trends—that have been constructed to examine the likely 

effects on marine mammal habitats point to dramatic declines in the extent and thickness of arctic sea-ice 

cover. This has serious implications for the future of such species as polar bears and ice seals (Durner et 

al. 2009; Cameron et al. 2010; Kelly et al. 2010; Regehr et al. 2016). 

Climate change in the Arctic is a rapidly growing concern, especially for the marine environment. Increased 

air and sea temperatures, longer periods of open water with an earlier onset of melting and later onset of 

freeze-up, increased rain-on-snow events, warm water intrusion, and changing atmospheric wind patterns 

are contributing to overall reduction and changes in sea ice (Kovacs et al. 2011; Chapin et al. 2014). The 

greatest concern for marine mammals in the reasonably foreseeable future is the continued Arctic 

warming trend and the resulting deterioration of sea ice conditions that are necessary for ice-dependent 

species and their prey. 

Arctic sea ice is changing in the extent of geographic coverage, thickness, age, and timing of melt and is one 

of the most pronounced changes currently occurring, at rates higher than previously predicted. Analysis of 

long-term data sets show substantial decreases in both extent (area of ocean covered by ice) and thickness 

of sea ice cover during the past 30 years (Post et al. 2013; Wendler et al. 2014). These trends are 

projected to continue, possibly resulting in loss of summer sea ice by mid-century (Chapin et al. 2014) and 

suggesting that all ice-dependent species may experience conditions that could result in declines of food 

availability and foraging and breeding habitat. 

The ongoing declines in the extent and duration of sea-ice cover present the greatest source for possible 

population-level impacts on marine mammals over the next 20 years, although the impacts are not entirely 

clear. Bowhead whales appear to be in better body condition in years of light ice cover (George et al. 

2015) and the Western Arctic stock is so far adapting to change in ice cover, as demonstrated by their 

consistent population increase (Givens et al. 2013; Muto et al. 2018); the long-term effect of reductions of 

sea ice on bowhead populations is not known (George et al. 2015). 

The broad distribution, diverse diet, and ability to haul out on land or ice suggest that ringed seals may be 

resilient to changes in sea ice availability (NMFS 2013). Bearded seals are more strongly associated with sea 
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ice available over shallow benthic habitat that is suitable for feeding, suggesting they may be less resilient to 

reduced sea-ice cover (NMFS 2013).

Recent shifts in distribution and habitat use by polar bears in the Beaufort and Chukchi Seas are likely 

attributable to loss of sea ice habitat. The greatest declines in optimal polar bear habitat are expected to 

occur in those areas where reduced habitat would likely reduce polar bear populations (Durner et al. 

2009; Regehr et al. 2016). 

The increasing difficulty for polar bears dealing with ecological changes, resulting from declining sea ice 

cover related to climate change has led to behavioral changes, as follows:

 Increased frequency of long-distance swimming by collared bears (Durner et al. 2011)

 Observations of swimming bears and dead bears in open water (Monnett and Gleason 2006; 

Schliebe et al. 2006)

 Polar bear predation and cannibalism (Amstrup et al. 2006a)

 Unusual predation behavior (Derocher et al. 2000; Brook and Richardson 2002; Stirling et al. 

2008)

 Increased time spent onshore (Atwood et al. 2016; Wilson et al. 2017)

Polar bears of the SBS stock experienced twice as many days of reduced sea ice from 2008 to 2011 than 

did those of the Chukchi Sea stock. Despite similar diets, SBS bears were smaller and in poorer condition 

and exhibited lower reproduction, and twice as many were fasting in spring (Rode et al. 2014). Consuming 

terrestrial foods is judged to be insufficient to offset the loss of ice-based hunting. 

Given the high metabolic demands and increased movements of polar bears, cascading negative effects on 

polar bear populations are predicted as sea ice declines and the availability of high-energy prey decreases 

(Rode et al. 2015; Pagano et al. 2018). The increased frequency of female SBS polar bears denning on land 

now rather than on pack ice was attributed to reductions in stable old ice, increases in unconsolidated ice, 

and lengthening of the melt season (Fischbach et al. 2007; Olson et al. 2017). 

Another result of climate change is increasing delays in formation of sea ice in the fall, forcing more bears 

to spend more time on land where they have difficulty catching prey and spend longer periods fasting and 

increasing the chance of interactions with humans, which increases the risk of bears being killed in defense 

of life or property (Amstrup 2000; Whiteman et al. 2015). 

The warming temperatures and increased precipitation year-round and longer growing seasons that are 

predicted to occur in the future may have negative implications for the stable conditions required for 

maternal denning by polar bears, especially if warm temperatures prevent snow cover of sufficient depth 

from accumulating early in the denning season. Population-level effects of sea-ice loss have been observed 

in polar bears at the southern edge of their range in western Hudson Bay, and models predict decreased 

survival (including breeding rates and cub litter survival) of polar bears in the SBS population with reduced 

sea-ice coverage (Regehr et al. 2010; Hunter et al. 2010). Reduced body size and cub recruitment in polar 

bears have been documented in years when sea ice availability was reduced (Rode et al. 2010). 

Range expansion of subarctic and temperate species into the Beaufort and Chukchi Seas has been 

observed in recent years and is likely to continue with changing arctic conditions. Increased observations 

of gray whales, humpback whales, and fin whales in the northeastern Chukchi Sea and gray and humpback 

whales in the western Beaufort Sea is a relatively recent phenomenon (Clarke et al. 2015). Thus far, 
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potential range expansion into the Beaufort Sea has been limited, but sightings appear to be increasing 

slowly. Range expansion by more temperate species raise the possibility of resource competition with 

arctic species (ACIA 2005). Other risks to arctic marine mammals induced by climate change include 

increased risk of infection and disease with improved growing conditions for disease vectors and from 

contact with nonnative species, increased pollution through increased precipitation transporting river 

borne pollution northward and increased human activity through shipping and offshore development 

(ACIA 2005; Huntington 2009; Hauser et al. 2018).

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

marine mammals from on-the-ground post-lease activities.

The Final EIS on Effects of Oil and Gas Activities in the Arctic (NMFS 2016a) provides detailed descriptions 

of potential impacts of petroleum-related industrial activities on marine mammal populations, including 

seismic exploration and drilling activities. That analysis is incorporated here by reference. The effects of 

climate change described under Affected Environment above, could influence the rate or degree of the 

potential direct and indirect impacts.

Alternative A

Under this alternative, current management actions would be maintained, and resource trends would 

continue, as described in the Arctic Refuge CCP (USFWS 2015a). There would be no direct or indirect 

impacts on marine mammals under Alternative A from post-lease oil and gas leasing activities.

Impacts Common to All Action Alternatives

The following potential actions and environmental consequences would be common to all action 

alternatives, although the extent of activities allowed and the areas affected would differ somewhat under 

each alternative, as described later in this section. All the action alternatives would affect large areas of the 

designated terrestrial-denning unit of critical habitat for polar bears; any facilities constructed within 20 

miles of the coast would be located in that critical habitat unit.

Habitat Loss and Alteration

POLAR BEAR

For polar bears, direct loss or alteration of maternal denning habitat would potentially result from gravel 

mining, gravel and ice road construction, changes in natural drainage patterns (impoundment), and off-pad 

snow disposal. The permanent, direct loss of polar bear habitat as a result of oil and gas leasing-related 

activities would primarily involve the terrestrial-denning unit of critical habitat (Map 3-24 in Appendix 

A) and constituting 77 percent (1,222,300 acres) of the program area. At 4.8 percent (76,600 acres) and 

0.1 percent (1,400 acres), respectively, the areas of the sea ice and barrier island critical habitat units 

potentially affected by program-related activities would be much smaller. Even though the overall 

proportion of Barrier Island Critical Habitat in the program area is not large, it receives a 
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disproportionately high level of use by polar bears (Wilson et al. 2017); thus, program-related activities 

affecting that habitat could have a larger impact on polar bears than is indicated on the basis of 

proportional representation.

It is important to note that not all portions of the terrestrial-denning unit of critical habitat represent 

suitable maternal denning habitat, however, because of local topography and the distribution of suitable 

habitat characteristics across the landscape. Specifically, potential maternal denning habitat (Durner et al. 

2001, 2006; Map 3-24 in Appendix A) covers an estimated total of 1,769 miles and 4,700 acres 

(assuming an average segment width of 21 feet; Durner et al. 2001) among the three zones of estimated 

HCP, constituting the high-priority area that would need to be searched in den surveys before exploration 

or development activities occur (Table 3-22). To date, the occurrence of maternal dens has been 

disproportionately high in the high-potential zone, where 54 percent of known dens occurred in 30 

percent of the potential habitat mapped. In contrast, the occurrence of dens in the low-potential zone has 

been disproportionately low, with only 4 percent of known dens occurring in 24 percent of the potential 

habitat. The occurrence of dens in the medium-potential zone has been proportional to the amount of 

potential habitat.

Table 3-22

Number of Documented Dens and Extent of Potential Terrestrial Denning Habitat for 

Maternal Polar Bears within the Three Zones of Estimated HCP in the Program Area

Hydrocarbon 

Zone

Number of 

Dens

Habitat Metrics

Total Length of BankHabitat Segments (miles)Estimated Area of BankHabitat Segments (acres)

High 25 (54%) 527 (30%) 1,400 (30%)

Medium 19 (41%) 799 (45%) 2,100 (46%)

Low 2 (4%) 442 (25%) 1,100 (24%)

Total 46 1,769 4,600

Notes:

Bank-habitat segments mapped by USGS (Durner et al. 2006); see Map 3-24 in Appendix A.

Acreage estimates assume an average width of 21 feet per mapped segment of bank habitat (Durner et al. 2001) and are 

rounded to the nearest 100 acres.

Temporary loss or alteration of polar bear denning habitat would potentially result primarily from the 

construction of ice roads and pads, which persist for one winter season. The effects of ice placement in 

potential denning habitat would be temporary until the ice road or pad thawed during spring melt, 

although annual reconstruction in the same location would result in perennial loss of use of the specific 

bank-habitat segment affected. Because ice placement would not affect the topographic characteristics that 

create the favorable denning conditions, no long-term effects on habitat suitability would be expected to 

occur. The effects of construction of ice and gravel roads and pads and pipelines would create the 

potential for temporary loss of use of suitable denning habitat through behavioral disturbance (described 

further in the next section below). The ITR/LOA process requires that surveys of potential denning habitat 

be conducted within a 1-mile buffer zone surrounding the proposed locations of roads and pads. The use 

of FLIR sensors has proven to be an effective means of locating dens in such surveys, as has the use of 

specially trained dogs (Amstrup et al. 2004b; York et al. 2004; Perham 2005; Shideler 2015). Even so, those 

survey methods do not provide perfect detection and occupied maternal dens are sometimes missed in 

preconstruction surveys.
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Future water withdrawal from lakes for the construction of ice roads and pads would not be likely to 

cause adverse effects on polar bear habitat, provided that no occupied maternal dens occur within 1 mile 

of the withdrawal sites or ice roads used for access. Similarly, the presence of snow dumps and drifts in 

the vicinity of oil and gas facilities probably would have negligible effects on polar bear habitat, inasmuch as 

they are unlikely to be located on or near bluff habitats. 

Most polar bears moving through areas near industrial facilities would likely be disturbed by activities on, 

or be hazed away from, drill-site pads. Disturbance from traffic on access roads would likely alter the use 

of habitats by bears nearby, although those effects would diminish for facilities located farther inland 

because they would be less likely to be used by bears than other areas near the coastline. Overall, the 

effects of reduced use of habitats near oil and gas facilities likely would be minimal, although they would be 

long-term in duration.

In summary, the potential effects of temporary habitat loss and alteration on polar bears are expected to 

be reduced if mitigation measures, similar to the ITRs in the Alaska Beaufort Sea currently in place west of 

the Coastal Plain, were implemented. After the placement of gravel pads and roads during the construction 

phase, the attractiveness of some potential maternal denning habitat in the vicinity of infrastructure likely 

would be diminished for some bears because of the presence of the facilities and associated human activity. 

SEALS

For ringed and bearded seals, potential alteration of benthic foraging habitat could result from modification 

of the seafloor profile caused by dredging or screeding operations at a barge landing site. The size of the 

affected area would be similar among the action alternatives, regardless of which possible landing site is 

used (one on Camden Bay near the mouth of Marsh Creek and the other farther east, between Griffin and 

Humphrey points; Clough et al. 1987). The exact amount of habitat to be altered would depend on the 

local bathymetry and the placement of the barge landing site.

A small number of ringed seals could over-winter and produce pups in the nearshore program area. One 

potential impact on ringed seals from the action alternatives could result from threats to lair integrity, such 

as lair collapse caused by tracked vehicles transiting sea ice during seismic activity. This impact could result 

in injury or mortality of pups and females. Noise from seismic activities could also disturb and displace 

individual seals. Overall, potential impacts of on-ice seismic activity could be lethal to a small number of 

seals, although the probability of this occurring is low. Most impacts would be temporary behavioral 

changes on the ringed seal population. 

WHALES

No whale habitat is expected to be lost or altered under any of the action alternative.

Disturbance and Displacement

All three action alternatives would result in a similar level of potential disturbance and displacement of 

marine mammals in the marine environment. Because vessel transit routes and the number of barge 

landing locations of hypothetical development scenarios do not differ among the action alternatives, 

neither would the potential effects of the activities associated with marine transport and STP development 

and operation (facility noise, dredging or screeding, and transportation) on marine mammals. Polar bears 

and seals would experience direct behavioral effects and indirect habitat loss from disturbance caused by 

human activities and noise associated with ice road and barge transportation (vehicle passage and noise), 

dredging or screeding for marine barge docks, human activities at camps, and oil spill response planning 

and drills. During the seasons of open-water barge transport, large vessel traffic transiting from Dutch 
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Harbor to the program area would have the potential to disturb or displace whales, seals, and possibly 

polar bears by the temporary disturbance of water and by creating strong low-frequency underwater 

sounds (Richardson et al. 1995). Terrestrial activities and facilities are not expected to have an effect on 

the behavior of whales because they do not generally approach within 1 NM of the coast.

POLAR BEAR

Noise and visual disturbance from human activity and operation of equipment, especially aircraft and 

vehicle traffic, have the potential to disturb polar bears nearby (Blix and Lentfer 1992; MacGillivray et al. 

2003; Perham 2005; Schliebe et al. 2006; USFWS 2006, 2008b, 2009; Andersen and Aars 2008). The 

greatest concern is disturbance of maternal females during the winter denning period, which could result 

in den abandonment and reduced survival of cubs (Amstrup 1993; Linnell et al. 2000; Lunn et al. 2004; 

Durner et al. 2006). Polar bear dens are known to occur onshore in relatively high numbers in the 

program area (Map 3-24 in Appendix A) and the incidence of terrestrial denning by the SBS population 

is increasing (Fischbach et al. 2007; Olson et al. 2017), so the potential for disturbance of dens during the 

drilling, construction, and operational phases of development projects is of concern. 

Various studies have evaluated the impacts of anthropogenic disturbance on polar bears. Amstrup (1993) 

reported that 10 of 12 denning polar bears tolerated exposure to a variety of disturbance stimuli near 

dens with no apparent change in productivity (survival of cubs). Two females denned successfully 

(produced young) on the south shore of a barrier island within 1.7 miles of an active oil processing facility 

and others denned successfully after a variety of human disturbances near their dens. Similarly, during 

winter 2000–2001, two females denned successfully within 1,312 feet and 2,625 feet of remediation 

activities being conducted on Flaxman Island (MacGillivray et al. 2003), located just northwest of the Arctic 

Refuge boundary. In contrast, Amstrup (1993) found that several females responded to disturbance early in 

the denning period by moving to other sites, suggesting that females may be more likely to abandon dens 

in response to disturbance early in the denning period than later. Hence, the initiation of intensive human 

activities during the period when females seek den sites (October–November) would give them the 

opportunity to choose sites in less-disturbed locations (Amstrup 1993). Abandonment later in the denning 

period exerts greater effects on productivity: survival was poor for cubs that left dens prematurely in 

response to the movement of sea ice (Amstrup and Gardner 1994) and females that remained in dens 

through the end of the denning period had much higher cub survival than did females that emerged from 

dens early (Rode et al. 2018). 

Experimental studies of noise and vibration in artificial (human-made) “dens” have been used to estimate 

the distances at which disturbance may occur. Blix and Lentfer (1992) reported that snow cover greatly 

diminished sounds and concluded that activities associated with oil and gas exploration and development, 

such as seismic surveys and helicopter overflights, would not be likely to disturb denning bears at distances 

greater than 328 feet from dens. In a more rigorous study, however, MacGillivray et al. (2003) compared 

noise levels inside and outside of artificial dens at sites on Flaxman Island during a variety of industrial 

remediation activities, including passage by different vehicles and overflights by helicopters at various 

distances. Snow cover provided an effective buffer, reducing low-frequency noise by as much as 25 dB and 

high-frequency noise by as much as 40 dB for activities conducted near the artificial dens. The noise levels 

produced by various stimuli were detectable above background levels at ranges from 0.3 miles to 1.24 

miles, however, depending on the stimulus. Low-frequency vibrations and noises were detected at the 

greatest distances. The most audible disturbance stimuli measured from inside the dens was an 

underground blast, detectable in artificial dens up to 0.8 miles from the source, and airborne helicopters 

directly overhead. Helicopters were detectable above background levels as far away as 0.6 miles, but the 
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authors noted that noises just above background are not likely to cause biologically significant responses 

(MacGillivray et al. 2003). The authors noted that high variability in the tolerance of different bears to 

noise and disturbance, including hazing with acoustic deterrents, was an important factor in evaluating 

human disturbance. 

Den surveys using FLIR sensors or trained dogs would be conducted annually before seismic exploration 

and construction of roads and pads commenced in the program area, as stipulated by the LOAs and polar 

bear interaction plans that would be required. If dens are detected within a 1-mile buffer zone around the 

proposed locations of roads and pads, then the facility locations would be moved outside of that radius to 

avoid dens, as required by ITRs, to reduce the effects on occupied dens to a negligible level. If dens are 

located after ice roads and pads are built, then traffic restrictions and emergency closures would be 

instituted. Such discoveries typically trigger emergency road restrictions and 24-hour monitoring until the 

bears depart the dens, as prescribed in typical polar bear interaction plans. 

Blasting at gravel mines and pile-driving of bridge abutments during future winter construction would be 

sources of noise in polar bear denning habitat. Pile-driving would occur at bridge crossings over rivers. Pile 

driving in or near water is known to produce strong underwater noise levels (e.g., Greene and Moore 

1995; Blackwell et al. 2004) and, along with gravel blasting, would be one of the noisiest activities resulting 

from construction. The level of received sound at any specific distance from pile-driving depends on the 

water (or ice) depth in which the piles are driven, the density or resistance of the substrate, bottom 

topography and composition (e.g., mud, sand, rock), the physical properties and dimensions of the pile 

being driven, and the type of pile-driver that is used (Richardson et al. 1995; Blackwell et al. 2004). Winter 

blasting and pile-driving are likely to disturb some polar bears. Possible impacts on polar bears exposed to 

noise potentially include disruption of normal activities, displacement from foraging and denning habitats, 

and displacement of maternal females and young cubs from dens. USFWS-approved mitigation measures 

for avoidance and minimization of disturbance of dens, as required under MMPA ITRs, would reduce the 

potential impacts of blasting and pile-driving on polar bears, however.

Displacement of nondenning bears from preferred coastal habitats would be another potential impact. In 

one study female bears with young cubs reacted to direct approaches by snowmachines nearly 1 mile away 

(mean distance 5,032 feet; Andersen and Aars 2008). Medium-sized single bears (subadults) in that study 

also reacted at fairly long distances (mean distance 3,806 feet) and adult males and females without cubs 

were the least reactive (mean distances 1,070 and 538 feet, respectively). Besides reacting at longer 

distances, maternal females and subadults showed stronger responses than did adults without cubs. 

Polar bears passing near infrastructure in the program area would be exposed to a wide variety of 

potentially disturbing stimuli resulting from exploration, drilling, pipeline and pad construction and other 

human activity on the pads, vehicles on pads and interconnecting access roads, barge traffic in the lagoon 

system and associated offloading operations at marine docks, and spill-response drills. A wide variety of 

behavioral responses by polar bears is likely to occur, ranging from avoidance by maternal females with 

young cubs in spring to approach by curious bears or those attracted by sights, sounds, and odors. The 

USFWS (2006, 2008b, 2009; 81 FR 52276) has concluded that the types of activities typical of oil and gas 

exploration, development, and production projects in northern Alaska were not likely to have populationlevel effects on polar bear populations at the levels analyzed in developed areas. This is because the 

behavioral responses of individual bears were short term and localized. 

Disturbance and localized displacement could occur during seasonal movements by polar bears in the 

program area. The net direction of movement by maternal females leaving terrestrial denning areas with 
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young cubs is northward, potentially requiring them to cross roads and pipelines, although the number of 

such encounters likely would be small. The greatest likelihood for bears to encounter program-related 

infrastructure and activities is along the coast during the open-water season (mainly July–October), as 

bears move eastward along the coast and gather near the Kaktovik whalebone pile in advance of the 

formation of seasonal ice. Early detection of bears by trained bear monitors and detection systems would 

allow industrial activities to be modified to minimize disturbance of bears moving through the vicinity. The 

completion of barging in summer would reduce the potential for those activities to disturb bears moving 

along the shoreline, although some encounters are likely to occur in July and early August. Barge traffic 

operating in open water may cause some short-term disturbance of bears swimming in the ocean, but the 

likelihood of such encounters is low. 

Polar bears moving along the coast through established oilfields (Kuparuk, Greater Prudhoe Bay, and Point 

Thomson) routinely encounter human-made obstructions and are able to cross or move past them 

without difficulty, resulting in short-term disturbance at most (USFWS 2008b, 2009; 81 FR 52276). Shortterm behavioral responses are not likely to have population-level effects and thus are considered less 

problematic than are den disturbance and abandonment (USFWS 2008b, 2009; 81 FR 52276). 

The potential effects of short-term behavioral disturbance are likely to be negligible on the SBS population, 

although the magnitude may increase in the future with increasing terrestrial presence of bears in late 

summer and autumn. Polar bears spending more time on land and fasting more as sea-ice cover diminishes 

are likely to experience an increase in negative effects on energy budgets as a result of reduced access to 

fat-rich prey (Molnár et al. 2010; Wilson et al. 2017; Pagano et al. 2018). 

Another source of potential disturbance of polar bears during all phases of exploration and potential

development would be noise and light generated by industrial facilities, such as CPFs. Noise from 

production facilities would be relatively constant, with wind direction affecting the perception of sounds by 

polar bears. Depending on the individual bear, however, such stimuli could also be attractants.

Behavioral disturbance on the productivity of polar bears in the program area is likely to be low. This 

assumes that all mitigative measures are implemented, as required under ITRs and specified in typical 

wildlife interaction plans for industrial activity in Arctic Alaska, and that preconstruction den surveys 

detect most maternal dens in the affected areas. 

The number of bears potentially affected is likely to increase during the operational life of program-related 

development as summer sea-ice cover continues to diminish in the future. This could result in more bears 

being present onshore during the open-water period, traveling the coastline more in summer and fall, and 

denning onshore. Such an increase is expected as a result of the current trends for increasing use of 

coastal habitats and terrestrial denning habitats (Fischbach et al. 2007; Schliebe et al. 2008; USFWS 2006, 

2008b, 2009; Olson et al. 2017; Wilson et al. 2017). It is likely that maternal denning would continue to 

increase in terrestrial habitats in the future, although the presence of operating facilities would probably 

discourage female bears from denning in suitable habitat nearby; instead, they would be more likely to seek 

suitable den sites in less-disturbed areas.

SEALS

Potential noise and disturbance from program-related facilities and activities are likely to affect ringed, 

spotted, and bearded seals annually while they are in the program area. A primary source of potential 

disturbance to seals would be anthropogenic noise. This could be generated by vessel traffic and coastal 

facilities, such as the STP during the open-water season. Noise also could be generated by activities in the 
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nearshore coastal or lagoon areas, such as seismic programs, during the ice-covered season; this could 

affect individual seals by exposing them to noise and lair disturbance. In-air noise would be relatively 

constant, with wind direction affecting the perception of sounds at haul-out locations and in lairs within a 

radius of 2.5–3.7 miles from facilities. Additional noise could be generated by dredging or screeding and 

vessel traffic during barging operations in summer, mobilization of modular units in winter, and oil-spill 

drills year-round.

Although marine mammals show overt reactions to noise from industrial activities, individuals or groups 

may become habituated if the noise does not result in physical injury, discomfort, or social stress (NRC 

2003). Based on habituation reported for ringed seals at the Northstar Island facility (Blackwell et al. 2004), 

it is likely that at least some ringed seals may habituate to the noise and continue to use haul-outs and lairs 

for pupping near a STP location, but that cannot be predicted with confidence. The effects of disturbance 

on seals are predicted to be less than 5 years, with no demographic effects expected.

Future vessel traffic is not expected to significantly disrupt normal pinniped behavioral patterns (breeding, 

feeding, sheltering, resting, and migrating). This is because most pinniped/vessel interactions documented 

during arctic oil and gas exploration operations show little to no observable behavioral reactions due to 

vessels (NMFS 2018). Pinnipeds typically show limited responses to vessel noise, such as increased 

alertness, diving, moving from the vessel’s path by up to several hundred feet, or by ignoring the vessel. If 

hauled out, seals and walruses typically enter the water when approached by vessels. Seals are quick and 

agile in the water, making them unlikely to be injured by large, slow-moving vessels. The vessel noise and 

presence would be temporary and limited to affecting a few individuals by eliciting small, behavioral 

responses. Impacts at the population level for all pinnipeds are not expected.

WHALES

Baleen whales, considered a low-frequency hearing group, have a hearing range of 7–35 (kilohertz (kHz) 

(NMFS 2016b). Toothed whales are a mid-frequency group with a hearing range of 150–160 kHz. The 

primary underwater noise associated with vessel operations is the continuous cavitation noise produced 

by the propellers on the oceanic tugboats, especially when pushing or towing a loaded barge (NMFS 2018). 

Oceanic tugboats have a source level of approximately 170 dB at 3.3 feet that is anticipated to decline to 

120 dB re 1μPa rms within 1.15 mile of the source (Richardson et al. 1995). Generally, vessels do not 

produce sound source levels capable of injuring whales (Richardson et al. 1995; NMFS 2016a).

Whales often show tolerance to vessel activity; however, they may react at long distances if they are 

confined by ice or shallow water or were previously harassed by vessel operators (Richardson et al. 1995). 

Whale reactions to vessels may include behavioral responses, such as altered headings or avoidance (Blane 

and Jaakson 1994; Erbe and Farmer 2000); fast swimming; changes in vocalizations (Lesage et al. 1999; 

Scheifele et al. 2005); and changes in dive, surfacing, and respiration patterns. Beluga whale reactions to 

vessels depend on whale activities and experience, habitat, boat type, and boat behavior (Richardson et al. 

1995). 

Future vessel traffic associated with the program area activities would produce temporary avoidance of 

vessels, as well as changes in vocalizations, diving, swimming, and respiration patterns. None of these 

potential effects would be chronic or sufficient to produce meaningful energetic losses to individual whales 

or to their populations. Because of the slow vessel speeds and the presence of PSOs onboard operating 

vessels, as specified under ROP 46, no vessel strikes are expected to occur from any of the action 

alternatives. With this mitigation, whales would be expected to have temporary behavioral responses. 
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Injury and Mortality

Small numbers of accidental injury or mortality of marine mammals may occur under all of the action 

alternatives. Polar bears could be susceptible to vehicle strikes and other marine mammals to 

vessel/equipment strikes during barging and in-water work. Additional injury or mortality of marine 

mammals may occur due to accidental spills or contamination. For polar bears, program-related actions 

are most likely to result in injury or mortality due to human-bear interactions. 

The BLM qualitatively evaluated the potential injury or mortality of marine mammals due to collisions. The 

assessment was based on documented species behavior, sensitivity to the activity, mobility, and distribution 

relative to the frequency and seasonality of vehicle and vessel traffic.

POLAR BEAR

When the polar bear was listed as a threatened species in 2008 (73 FR 28212), the USFWS noted that the 

factors contributing to the primary threat identified in the listing analysis—rapidly diminishing sea-ice 

habitat—cannot realistically be regulated under their management purview; therefore, in lieu of influencing 

the causes underlying climate change, such as GHG, the USFWS has focused on factors more amenable to 

regulation, such as habitat protection and the prevention and reduction of lethal take. The result of this 

approach is that even greater emphasis has been devoted to mitigation through interaction planning to 

avoid and minimize injury and mortality of polar bears (USFWS 2016). 

Under all action alternatives, future oil and gas activities would increase the level of human-polar bear 

interactions, creating the possibility for increased bear injuries or deaths. As sea-ice cover continues to 

diminish, the number of encounters between humans and nutritionally stressed bears is expected to 

increase (DeBruyn et al. 2010). Sightings of polar bears at industrial sites in the Beaufort Sea region of 

Alaska have increased in recent years, consistent with increasing use of coastal habitats as summer sea-ice 

cover has diminished (Schliebe et al. 2008; USFWS 2008b; 76 FR 47010; 81 FR 52276); however, the 

incidence of human-bear encounters and harassment by deterrence (hazing) remains low. From 2010 

through 2014, 14 percent of the polar bears observed in the North Slope oilfields (260 of 1,911 

individuals) were intentionally deterred (81 FR 522760); that percentage decreased over time from a high 

of 39 percent of bears observed in 2005. The USFWS attributes the decrease in deterrence events to 

increased polar bear safety and awareness training of industry personnel, as well as ongoing deterrence 

education, training, and monitoring programs (76 FR 47010; 81 FR 522760). 

Despite increased interactions in the existing oilfields in recent years, lethal take associated with oil and gas 

activities is rare. Three polar bears have been killed at oil and gas industrial sites in Alaska since the late 

1960s: one in winter 1969, another in 1990 at the Stinson exploration site in western Camden Bay, north 

of the program area (Perham 2005; USFWS 2006), and one bear in 2011 (killed accidentally during hazing) 

since the Chukchi Sea and Beaufort Sea ITRs went into effect in 1991 and 1993, respectively (USFWS 

2008b, 2009; 81 FR 52276). 

Several other mortalities have been associated with military and industrial activity. A polar bear was killed 

at the Oliktok Point Long-range Radar Site in 1993 (USFWS 2010) after attacking a worker who provoked 

it. In 1988, a polar bear died on Leavitt Island, 5 miles northwest of Oliktok Point, after ingesting a mixture 

that included ethylene glycol and Rhodamine B dye (Amstrup et al. 1989). In 2012, two polar bears that 

had been exposed to Rhodamine B (and possibly other chemicals) were found dead on Narwhal Island, 

northwest of Endicott; although the deaths were human caused, the source of the chemicals could not be 

identified (FR 81 52276). In contrast, 33 polar bears were killed at industrial sites in the Northwest 
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Territories from 1976 to 1986 (Stenhouse et al. 1988). Dyck (2006) reported that 618 polar bears 

(averaging 20 per year) were killed from 1970 to 2000 in the Northwest Territories and Nunavut in 

northern Canada, 25 (4 percent) of which occurred at industrial sites.

In addition to attraction to areas of human activity and direct interaction with humans, a second potential 

source of injury or mortality is premature den abandonment, which is a possible outcome of den 

disturbance and has been documented as an adverse effect on cub survival (Amstrup and Gardner 1994; 

USFWS 2008b, 2009; 76 FR 47010; 81 FR 52276). The precautions against den disturbance in the 

interaction plan, required under ITRs, and the denning surveys conducted before seismic exploration and 

construction of roads and pads would minimize the likelihood of this potential risk. 

A third potential source of injury or mortality is traffic on ice and gravel roads that intersect the 

movement paths taken by females with young moving from terrestrial denning habitat to hunting areas 

offshore in late winter (March–April). This poses a risk of vehicle strikes and disturbance-related 

distributional shifts. No vehicle strikes of polar bears along ice roads in the North Slope oilfields have been 

reported in agency documents evaluating impacts on polar bears, indicating the impact is negligible. 

A fourth potential source of injury or mortality is accidental spills, leaks, and other sources of 

contamination. Polar bears are susceptible to thermal stress after fouling their fur by direct contact with 

spilled petroleum products. This reduces body temperature and increases metabolic rate; oil is absorbed 

through skin contact, through the gastrointestinal tract, and by inhalation (Engelhardt 1983). Contact and 

ingestion can lead to severe blood and kidney problems. The direct and indirect effects of spills depend 

primarily on the seasonal timing and location of the spills and on the volume of material released into the 

environment. Terrestrial spills during winter would have substantially less impact on polar bears than 

would marine spills during the open-water period in summer and fall. 

The only substantial potential program-related activity occurring in the marine environment would be 

barging of modules in several years during the open-water period, which would pose a low risk of spilled 

fuel if a vessel carrying fuel were to run aground. The number of bears potentially affected by such an 

accident would be smaller than the numbers that would be affected by modeled, hypothetical, large marine 

spills (Amstrup et al. 2006b; BOEM 2018b; Wilson et al. 2018). This is because the spill volume and the 

area affected would be substantially smaller. To date, large oil spills in the marine environment from 

industry activities in the Beaufort Sea and coastal regions that would affect polar bears have not occurred, 

although the interest in, and the development of, offshore hydrocarbon reservoirs has increased the 

potential for such spills.

Spills associated with development projects on the mainland are of much less concern for polar bears than 

are marine spills. Although the risk of a large spill during the drilling, construction, and operational phases 

of the proposed program is low, several large terrestrial oil spills have occurred in the Prudhoe Bay area 

without any known impacts on polar bears. The volume of material released and the area affected would 

likely be small due to the volumes of material being used and the terrestrial base of activities. 

Small releases of contaminants also can have effects. As described above, three polar bears have died near 

industrial sites from chemical ingestion as a result of human activity (Amstrup et al. 1989; 81 FR 52275). 

Effective control of potentially toxic substances and careful attention to preventing spills of any size are the 

key to preventing such injuries. Overall, potential impacts on polar bears and their habitat in the program 

area from oil spills, leaks, and contaminant releases would be lessened through the safeguards specified in 

the required spill prevention and contingency plan, the relatively small amounts of material likely to be 
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released under most scenarios, and the responsible party’s ability to detect and clean up spills quickly on 

land, where most program-related activities would occur.

Any injury or mortality from oil and gas development-related human-bear conflicts would pose a problem 

because of the declining status of the SBS population. The attraction of polar bears to facilities and the

attendant problems from such attraction may increase through the operational life of the proposed 

program, as more bears use onshore areas during the open-water season due to declining sea ice, leading 

to increased use of coastal travel routes past oil and gas facilities. 

In summary, although the potential for injury or mortality could be high when developing new oil and gas 

projects in polar bear habitat, the risks are well understood. Also, effective mitigation is available and has 

been implemented in the established North Slope oilfields west of the program area. With mitigation in 

place, the net effects of program-related activities are likely to be negligible in terms of injury and mortality 

at the population level. Given the current and predicted continuing decline of the SBS stock of polar bears, 

emphasis would be placed on avoiding injury or mortality, and current mitigation measures appear to be 

effective at reducing such risks.

WHALES AND SEALS

Any vessels operating in or along transportation corridors to the program area would follow specified 

procedures for changing vessel speed and direction to avoid collisions with marine mammals. TLs on 

barging activity would avoid adverse effects on newborn ringed seals, particularly when nursing and molting 

(NMFS 2016a), because program-related vessel traffic would occur late in the open-water season when 

pups would be larger.

The number and speed of ships is related directly to the severity of collisions between vessels and whales 

(Jensen and Silber 2004). In contrast, seals are less likely than whales to be struck due to their smaller size 

and higher maneuverability. BOEM estimated that 67 vessels per year could transit the Beaufort Sea 

associated with oil and gas leasing and exploration (NMFS 2013). Collisions with whales are rare for slowmoving vessels traveling at less than 10 knots (Laist et al. 2001; Vanderlaan et al. 2008). Barge convoys 

would move slowly, but the vessels would be unable to change direction or speed quickly. Although it is 

possible that a marine mammal could be struck by a vessel engaged in the barging operation, such incidents 

are highly unlikely due to the slow vessel speed and low frequency of barge deliveries (assumed to be two 

landings per year).

The low incidence of propeller scars found on bowhead whales landed by Alaska Native whalers indicates 

that vessel strikes of bowhead whales are rare (Laist et al. 2001, George et al. 2017). There is no indication 

that vessel strikes would be a major source of mortality for whales during marine transport to the 

program area (NMFS 2013). Data recorded by PSOs aboard sound-source and monitoring vessels indicate 

that ringed and bearded seals in the Beaufort Sea avoid oncoming vessels (NMFS 2016a), and there is no 

indication that vessel strikes would become an important source of injury or mortality (NMFS 2013).

The absence of collisions involving industry vessels and marine mammals in the Bering, Chukchi, and 

Beaufort seas, despite decades of spatial and temporal overlap, suggests that collision probabilities are low 

along the transit route from Dutch Harbor to the program area (NMFS 2013). More specifically, it is 

unlikely that vessels would strike subarctic whales because: (1) Few blue and sperm whales could be 

encountered, as they are found in deeper waters than those in which the transit route would occur, and 

are rare; (2) approximately 30 North Pacific right whales are known to exist; (3) Few western North 

Pacific gray whales have been documented outside their feeding areas in waters around Sakhalin Island, 
3. Affected Environment and Environmental Consequences (Marine Mammals)

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Russia; and (4) Vessel mitigation measures, such as reducing speed, are typically required by NMFS and 

reduce the likelihood of vessel strikes. Thus, potential ship strikes of marine mammals would be highly 

unlikely and are not expected to occur.

The presence and movement of ships may cause some ringed and bearded seals to abandon preferred 

feeding and resting habitat in areas of high traffic. Interactions with whales and seals would be reduced 

somewhat by the seasonal timing of barge transport in mid to late summer, a time when ringed and 

bearded seals also tend to occur farther offshore and when most bowhead and beluga whales are foraging 

father east or northeast of the analysis area. Exposure to vessels during the open-water period may affect 

individual seals and whales, but evidence of habituation to activity and evasion of vessels indicates that 

activities associated with marine transport to the program area are not likely to affect the reproductive 

success or survival of seals and whales.

Another potential source of injury or mortality is accidental spills, leaks, and other sources of 

contamination. All of the exploration and development would occur on land, with oil being transported in 

terrestrial pipelines to TAPS. The potential effects of accidental releases of hazardous materials (including 

oil spills) that reach the distributary channels of rivers and streams and adjacent marine waters would be 

negligible due to the safeguards in place to avoid and minimize oil spills. In the unlikely event of a large oil 

spill reaching open water during summer or fall, small numbers of bearded, ringed, and spotted seals and 

beluga whales could be negatively affected. The probability, volume, and potential spread of different types 

of spills are discussed in Section 3.2.11. Assuming that no large oils spills reach the open water 

environment, potential impacts of terrestrial oil spills on marine mammals are expected to be negligible.

Small, accidental fuel spills could occur with refueling at sea. This potential impact would be common to all 

marine mammals. In previous analyses, the BOEM assumed a vessel transfer spill during offshore refueling 

to have an estimated volume range from <1 to 13 barrels (blue barrel [bbl]). The 13 bbl maximum spill 

volume represents a spill where spill prevention measures fail, fuel lines rupture, and no oil remains on the 

vessel. A spill of less than 1 bbl could persist for up to 30 hours in open water, while a 13 bbl spill could 

persist for up to 2 days (BOEM 2015). Exposure of marine mammals to this type of spill would be highly 

unlikely and is not expected to occur.

Attraction to Human Activity and Facilities

Other than polar bears, marine mammals are not likely to be attracted to program-related activities or 

facilities. Polar bears are curious and opportunistic hunters, frequently approaching and investigating 

locations where human activity occurs (Stirling 1988; Truett 1993). Proximity to humans poses risks of 

injury and mortality for both bears and humans and may necessitate nonlethal take through deterrence and 

hazing or, on rare occasions, lethal take to defend human life (Stenhouse et al. 1988; Truett 1993, Perham 

2005). 

Stirling (1988) reported that curious polar bears commonly approach offshore drilling rigs in the Canadian 

Beaufort Sea whenever sea ice moved into the area but did not remain nearby for long, unless seals were 

present in the leads created by the rigs. Similar behavior has been observed at Northstar Island, north of 

Prudhoe Bay. Sightings of polar bears at industrial sites in the Beaufort Sea region of Alaska have increased 

in recent years, consistent with increasing use of coastal habitats, as summer sea-ice cover has diminished 

(Schliebe et al. 2008; USFWS 2008b; 81 FR 52276), and this trend is likely to continue. 

Encounters between polar bears and humans in the program area are most likely to occur on and near the 

coastline, as bears move through in late summer and fall (August–October) and as maternal females search 
3. Affected Environment and Environmental Consequences (Marine Mammals)

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for den locations in autumn and early winter (October–November) and depart from dens with dependent 

cubs in late winter (March–April); however, the latter animals are the least likely to be attracted to 

industrial facilities, due to their greater sensitivity to disturbance.

The current ITR/LOA process has proven to be effective at addressing and mitigating the risks of polar 

bear encounters with humans. Besides denning surveys, the interaction plan required by the ITRs stipulates 

monitoring and reporting of bear sightings and encounters using trained observers, as well as training of 

personnel in nonlethal means of protection (deterrence and hazing). 

Although camps and other activity areas have the potential to attract polar bears, experience 

demonstrates that these risks can be mitigated effectively by following the interaction plan; for example, 

with Detection systems using bear monitors, motion/infrared sensors, and adequate lighting; Safety gates, 

fences, and cages for workers, as well as skirting of elevated buildings; Careful waste handling and snow 

management; Chain-of-command procedures to coordinate responses to sightings; and Employee 

education and training programs (Truett 1993; Perham 2005; USFWS 2006, 2008b, 2009). All programrelated activities must be conducted to minimize the attractiveness of work and facility sites to polar bears 

and to prevent their access to food, garbage, rotting waste, and other potentially edible or harmful

materials, as required by ROPs 1–3 and 5. Trained bear monitors would be on-site, and all polar bear 

sightings would be reported immediately to safety personnel. 

Alternative B 

The types of future program-related activities and facilities would be similar among the action alternatives, 

but the location and extent of infrastructure and associated activity would differ among alternatives, in 

accordance with lease stipulations and ROPs. Differences that would alter effects on marine mammals 

among alternatives primarily are those in the distribution and acreage of potential denning habitat for 

maternal polar bears, as well as the extent to which activities and facilities would be permitted in coastal 

habitats used as travel routes by polar bears. 

The potential impacts among action alternatives cannot be quantified accurately without knowing the 

future locations of program-related activities and facilities, so this evaluation assesses impacts by comparing 

the number of historical dens, amount of potential maternal denning habitat mapped, and likelihood of use 

by polar bears of the areas subject to various lease types and stipulations.

Because the entire program area is available to lease for oil and gas activity, Alternative B presents the 

greatest difference from Alternative A by enabling program activities and facilities in nearly all potential 

terrestrial maternal denning habitat for polar bears in the program area. Despite the lack of specific 

protection of denning habitat under this alternative, however, Lease Stipulation 1 would protect some 

potential maternal denning habitat by prohibiting permanent facilities within 0.5 to 1 mile of the 10 rivers 

and streams listed under that stipulation. The NSO area under Lease Stipulation 1 includes 48 percent of 

the known historical polar bear dens (Table 3-23) and 29 percent of the potential maternal denning 

habitat mapped in the program area (Table 3-24).

Except for those river buffers, all program activities and facilities would be allowed throughout the areas of 

greatest proportional occurrence of dens (high and medium HCP zones), relying on adherence to 

mitigation measures described in ITRs, and requiring surveys to detect occupied dens before beginning 

winter activities. Under Alternative B, Lease Stipulations 2, 3, 4, and 5 contain no specific requirements 
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Table 3-23

Number and Percentage of Documented Polar Bear Dens by Alternative, Hydrocarbon Potential, and Lease Type

Lease Type Alternative B Alternative C Alternative D

(Identical for D1 and D2)

Hydrocarbon Potential High Medium Low Total High Medium Low Total High Medium Low Total

Not offered for lease sale - - - - - - - - - 2 2 4

- - - - - - - - - 11% 100% 9%

Subject to NSO 17 4 1 22 18 9 2 29 23 15 - 38

68% 21% 50% 48% 72% 47% 100% 63% 92% 79% - 83%

Subject to CSU - - - - - - - - - 1 - 1

- - - - - - - - - 5% - 2%

Subject to TLs - 3 1 4 3 7 - 10 - - - -

- 16% 50% 9% 12% 35% - 21% - - - -

Subject to only standard 

terms and conditions

8 12 - 20 4 5 - 9 2 1 - 3

32% 63% - 43% 16% 25% - 19% 8% 5% - 7%

Total 25 19 2 46 25 19 2 46 25 19 2 46

Source: BLM GIS 2018

- = not applicable

Table 3-24

Estimated Acreage and Percentage of Potential Maternal Denning Habitat by Alternative, Hydrocarbon Potential, and Lease 

Type

Lease Type Alternative B Alternative C Alternative D 

(identical for D1 and D2)

Hydrocarbon Potential High Medium Low Total High Medium Low Total High Medium Low Total

Not offered for lease sale - - - - - - - - - 300 1,000 1,300

- - - - - - - - - 15% 77% 28%

Subject to NSO 400 600 400 1,400 600 1,100 1,100 2,800 800 1,400 300 2,500

31% 29% 29% 29% 43% 52% 79% 57% 62% 70% 23% 54%

Subject to CSU - - - - - - - - 100 200 - 300

- - - - - - - - 8% 10% - 7%

Subject to TLs - 600 800 1,400 300 600 300 1,200 - - - -

- 29% 57% 29% 21% 29% 21% 24% - - - -

Subject to only standard 

terms and conditions

900 900 200 2,000 500 400 - 900 400 100 - 500

69% 43% 14% 42% 36% 19% - 18% 31% 5% - 11%

Total 1,300 2,100 1,400 4,800 1,400 2,100 1,400 4,900 1,300 2,000 1,300 4,600

Source: BLM GIS 2018

- = not applicable
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relevant to polar bears or their habitat (other than complying with the ESA and MMPA), resulting in 

greater potential long-term disturbance effects than under Alternative A and the greatest among the action 

alternatives because of the larger area open to leasing under this alternative.

The coastline survey required under Lease Stipulation 9 for this alternative would provide some specific 

information for planning purposes but would not specifically restrict activities that could disturb polar 

bears using coastal habitats. This would leave the regulatory requirements of ITRs as the sole mitigation 

measures in effect in the coastal area. They would reduce disturbance of bears moving along and denning 

near the sea coast, including the barrier islands unit of designated critical habitat and its attendant 1-mile 

no-disturbance zone.

ROPs 1 and 2, and adherence to ITR requirements would reduce the potential for attraction to 

improperly handled garbage and other rotting waste, greatly diminishing the safety risks that could result 

from habituation and food-conditioning of polar bears. ROP 4 would reduce the safety risks for both 

humans and bears by ensuring that measures are in place to address the risks of, and solutions for, bearrelated problems and to follow accepted practices for deterring bears around facilities, when necessary. 

The highest number of documented historical polar bear dens and the greatest area of potential maternal

denning habitat occur in the high- and medium-potential hydrocarbon zones, where the least restrictive 

development activities would be most likely to occur. Because of this, the potential impacts of waste 

handling and bear-human interactions under this alternative would be the most different from Alternative 

A and would be greater than those under the other two action alternatives.

Under ROP 10, the pre-activity surveys required to locate dens, plus the 0.5-mile and 1-mile buffers for 

seismic and heavy equipment operation around occupied dens of grizzly and polar bears, respectively, 

would help to reduce the impacts of behavioral disturbance on denning bears (as well as birth lairs of 

ringed seals on landfast ice along the coast) throughout the entire program area. Even so, complete 

detection of occupied bear dens is unlikely to be achieved, so an unknown (though probably small) number 

of denning bears could be exposed to disturbance until discovered by such operations every winter during 

exploration, construction, and development drilling phases. This would reach the highest levels under this 

alternative, in comparison with Alternative A. As part of the ITR/LOA process, however, the USFWS 

implements protective mitigation measures around a maternal polar bear den once it is discovered, which 

can include applying a 1-mile no-disturbance buffer around the den site and 24-hour monitoring of the den 

site.

The requirement to obtain permits before installing fences to capture snow under ROP 15 (identical under 

all action alternatives) could alleviate potential conflicts with denning bears. Pregnant polar bears could be 

attracted early in the denning season to the drifts in the lee of snow fences, which could create suitable 

denning habitat if the drifts become deep enough.

Alternative C

Most of the historical dens that have been documented in the program area occur in the zones of high and 

medium HCP, which would be open to development subject to only standard terms and conditions or 

under NSO stipulations. The NSO area under Lease Stipulations 1 and 9 would include 63 percent of the 

known maternal dens and 57 percent of potential denning habitat (Table 3-23 and Table 3-24). The 

expanded NSO setback (2 miles rather than 1 mile) around the Canning, Hulahula, and Okpilak Rivers 

under Lease Stipulation 1 would provide additional protection of potential denning habitat along those 

drainages. The NSO buffer within 1 mile of the coastline, barrier islands, and lagoons under Lease 

Stipulation 9 would reduce potential disturbance of polar bears moving through those habitats during all 
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seasons and denning there in winter; thus, it would be consistent with the 1-mile no-disturbance zone that 

is required around the barrier islands unit of critical habitat designated for the species. Lease Stipulations 2, 

3, 4, and 5 contain no specific requirements relevant to polar bears or their habitat (other than complying 

with the ESA and MMPA), resulting in greater long-term disturbance effects on the species than under 

Alternative A and similar effects as under Alternative B in the areas covered by those lease stipulations. 

The area subject to TLs under Alternative C would include an additional 17 percent of known dens and 24 

percent of potential denning habitat (Table 3-23 and Table 3-24), but those TLs are intended primarily 

as mitigation for caribou post-calving habitat during summer and thus would not benefit maternal polar 

bears during winter; therefore, potential long-term disturbance impacts likely would be greater than those 

under Alternative A and similar to those under Alternative B. 

The requirements of ROPs 1, 2, and 4 under this alternative would be identical to those under Alternative 

B, but the potential impacts would be less under this alternative because the NSO area would be larger 

than under Alternative B. The requirement of ROP 10 would be identical to Alternative B, so the potential 

impacts would be similar.

Alternative D

Alternatives D1 and D2 would be identical with regard to potential impacts on polar bears, so they are 

discussed together here. By affording the highest degree of protective measures for polar bears, this 

alternative would be the most similar to Alternative A in terms of potential impacts than would the other 

two action alternatives. The areas not offered for lease and NSO areas—0.5- to 4-mile buffers around 17 

rivers and streams, the Canning River delta and lakes, and three springs—would encompass 92 percent of 

known historical dens and 82 percent of potential denning habitat, affording the highest level of protection 

for polar bear denning among the action alternatives. The 34 percent of the program area not available for 

lease contains 28 percent of the potential maternal denning habitat but only 9 percent of historical 

maternal dens (Table 3-23 and Table 3-24). In contrast, the various NSO areas under this alternative 

contain 54 percent of the potential denning habitat and 83 percent of the known dens (Table 3-23 and

Table 3-24). This reduces the potential for impacts from program-related habitat loss and disturbance to 

the lowest degree among the action alternatives. 

Under Lease Stipulation 5, the “coastal polar bear denning river habitat” zone (see Map 2-6 and Map 2-8

in Appendix A) subject to NSO and TLs totals 105,400 acres. This constitutes 6.7 percent of the 

program area and 8.8 percent of the terrestrial denning unit of designated critical habitat in the program 

area. Despite being such a small percentage of that unit of critical habitat, the stipulated area within 5 miles 

of the coast and 1 mile of the Sadlerochit, Niguanak, and Katakturuk Rivers and Marsh and Carter Creeks 

encompasses 37 percent of the historical maternal dens documented in the program area. 

In addition to the specific protection of maternal denning habitat in that zone under Lease Stipulation 5, 

Lease Stipulations 1 and 2 would also protect denning habitat by prohibiting permanent facilities in NSO 

buffers within 0.5 to 4 miles of the 17 rivers and streams and 0.5 mile of the other waterbodies listed 

under those two stipulations. Lease Stipulation 3 would protect additional denning habitat by excluding 

leasing and instituting 3- to 4-mile NSO buffers around Sadlerochit Spring, Fish Hole 1 on the Hulahula 

River, Tamayariak Spring, Okerokavik Spring, and along the east bank of the Canning River. 

The various stipulations restricting facilities and activities in coastal habitats would reduce potential 

behavioral disturbance of polar bears moving along the coastline throughout most of the year. Under 

Lease Stipulation 5, TLs would reduce disturbance of polar bears by prohibiting program-related activities 
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within 1 mile and up to 5 miles inland between October 30 and April 15. In addition, the TLs under Lease 

Stipulations 4 and 9 would reduce disturbance between May 15 and November 1, or whenever sea ice 

comes within 10 miles of shore. They would do this by restricting program-related activities within a 2-

mile coastal buffer, extending protections 1 mile farther inland than under Alternative C.

As with the other two action alternatives, ROPs 1 and 2 would reduce the potential for attraction to 

waste and would greatly diminish the safety risks that could result from habituation and food-conditioning 

of polar bears, and ROP 4 would further reduce the safety risks for both humans and bears. ROP 10 

would reduce the impacts of behavioral disturbance on denning bears (and birth lairs of ringed seals on 

landfast ice) to the greatest degree among the action alternatives, most similar to Alternative A. 

Cumulative Impacts

Most existing industrial development along the Beaufort Sea coast has occurred in terrestrial habitats, 

which typically receive much less use by polar bears throughout the year than do marine habitats offshore; 

however, over time, development began to expand into marine areas, starting with the construction of 

West Dock in the Prudhoe Bay field. It was followed by the Endicott Project, which was the first offshore 

production facility in the region, and the Northstar Project, located on artificial islands offshore from 

Prudhoe Bay. 

Offshore production facilities (Endicott, Northstar, Oooguruk, and Nikaitchuq islands) have recorded the 

highest incidences of polar bear sightings and nonlethal hazing incidents in the established oilfields in recent 

years, accounting for 47 percent of polar bear observations (182 of 390 sightings) from 2005 to 2008 (76 

FR 47010; 81 FR 52276). Analysis of the cumulative effects of oil and gas leasing, exploration, development, 

and production by the National Research Council (NRC 2003, pg. 105) showed that “industrial activity in 

the marine waters of the Beaufort Sea has been limited and sporadic and likely has not caused serious 

cumulative effects on ringed seals or polar bears.” Nevertheless, expansion of oil and gas development 

along the arctic coast on both land and sea may reach a level at which such effects become problematic for 

polar bears in the future (Amstrup 2003a; USFWS 2009). 

Existing oil and gas development, commercial transportation, subsistence harvest and changes in the 

activities of local communities, and management and research actions by federal and state agencies are the 

principal activities contributing to cumulative effects on polar bears and other marine mammals in Arctic 

Alaska. Tourism is growing in Kaktovik, with commercial enterprises offering viewing opportunities of 

polar bears and recreational travel in the Arctic Refuge. 

Marine mammals are exposed to potentially toxic chemical compounds in the water and the food web that 

have been transported to the Arctic from around the world through the atmosphere, water currents, and 

migrating animals (AMAP 2010). As a top predator, polar bears tend to have higher levels of potentially 

toxic compounds that bioaccumulate in the food chain, such as organochlorines and mercury (Braune et al. 

2005; AMAP 2010). At the time of listing under the ESA, however, contaminant levels in Alaska polar bears 

were considered relatively low compared to other stocks (USFWS 2017). Alaska stocks, including the SBS 

stock, continue to have some of the lowest concentrations of polychlorinated biphenyls, chlorinated 

pesticides, and flame retardants among all polar bear stocks (McKinney et al. 2011).

Onshore oil and gas production, such as that proposed in the program area, typically requires large sea lifts 

using barges to transport facility modules, equipment, and material from southern ports to docks on the 

Beaufort Sea coast. Onshore infrastructure also can affect marine mammals through the need for sea ice 

roads that cross ringed seal habitat in landfast ice, and ice and gravel infrastructure can affect polar bear 
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habitat and maternal polar bear denning, as described above. These impacts of onshore production would 

likely affect polar bears through disturbance in coastal barrier-island and denning habitats, especially during 

construction, but would be mitigated through the ITRs and LOAs issued by the USFWS. The combined 

effects of likely future actions, particularly those located in the arctic marine environment, may contribute 

to adverse effects on polar bear, seal, and whale populations in the future, primarily through expansion of 

coastal and offshore development and the increased risk of a major marine oil spill. 

Considering all past, present, and reasonably foreseeable future actions, human-bear interactions have the 

greatest potential to affect polar bears. Furthermore, the effects of human-bear interactions would interact 

both spatially and temporally with those of the proposed leasing program. Considering the effects of postlease oil and gas activities in conjunction with human-bear interactions, and other reasonably foreseeable

future actions, the effects post-lease oil and gas activities would have additive cumulative effects on polar 

bears, possibly resulting in additional impacts on the SBS stock of polar bears. The effects of climate change 

described under Affected Environment above, could influence the rate or degree of the potential cumulative 

impacts.

3.4 SOCIAL SYSTEMS

3.4.1 Landownership and Use

Affected Environment

The affected environment for landownership and use is similar to Section 4.1.2, Land Status, in the Arctic 

Refuge CCP (USFWS 2015a); however, because the Coastal Plain program area does not include the 

entire Arctic Refuge, a revised description of the program area is included here. Lands administered by the 

USFWS, including submerged lands, account for greater than 99.9 percent (1,562,600 acres) of the 

1,563,500-acre program area. The remaining 900 acres of lands are Alaska Native Allotments. Patented 

and allotment lands are mostly located along the Beaufort Sea between the Hulahula and Jago Rivers. 

There also are smaller, isolated allotments along the coast. Descriptions of Alaska Native Lands and 

Allotments are incorporated here by reference from the USFWS CCP (USFWS 2015a). 

There are no BLM-administered surface lands in the program area; however, the BLM manages all of the 

subsurface mineral estate there (see Sections 3.2.5 and 3.2.6). Although none currently exist, the BLM 

would manage federal oil and gas leases, permits, and ROWs associated with fluid mineral development. 

The BLM would verify subsurface mineral estate ownership at a site-specific level prior to a lease sale.

With the exception of Barter Island, there are no roads, power lines, pipelines, or other permanent 

facilities or structures in the program area. On Barter Island is a single runway airport and the city of 

Kaktovik, a community of approximately 250 people.

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

landownership and use from on-the-ground post-lease activities.
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Potential impacts on landownership and uses are the result of decisions that change landownership or 

from lease stipulations that allow or restrict certain land uses. Landownership decisions, such as 

conveyance or transfers, can increase or decrease the amount of federal land and the type of management 

available for those lands. Use restrictions, such as those intended to protect resources or to reduce 

conflicts with other uses, can preclude the placement of new infrastructure or require special conditions 

for development. In areas subject to NSO, new land uses would be precluded. Any new uses would be 

required to locate in areas outside of the NSO area. Depending on the use, developing the use outside of 

the NSO area may not be physically or commercially viable. In areas subject to CSU or TLs, additional 

requirements, such as long-term monitoring, special design features, and special siting requirements, could 

restrict a future project’s location or viability of projects. 

Alternative A

Under Alternative A, there would be no federal minerals offered for future oil and gas lease sales in the 

program area and therefore no direct or indirect impacts on uses. There would be no change in 

landownership. 

Impacts Common to All Action Alternatives

Under all action alternatives, areas would be made available for lease sales consistent with PL 115-97. 

Demand for petroleum resources would result in the subsequent development of oil and gas exploration 

and production well pads, CPFs, roads, pipelines, barge dock, a STP, and other ancillary uses to support oil 

and gas development. While the location of these uses would vary under the action alternatives, as 

discussed below, the size, type, and amount would be nearly the same. 

New oil and gas development in the program area would indirectly affect land uses in and surrounding the 

community of Kaktovik. As one of the North Slope’s larger communities and the main point of arrival and 

departure for air travel to the program area, new or expanded residential, commercial, industrial, and civic 

land uses would be expected, especially over the long term. Areas south of Kaktovik’s current 

development footprint more likely to experience the most notable growth (NSB 2015a). 

There would be no change in landownership under any of the action alternatives.

Alternative B

The nature and types of impacts on land uses under Alternative B would be the same as those described 

under Impacts Common to All Action Alternatives. Making the entire program area available for lease sale and 

applying NSO stipulations to only 23 percent of the lands available for leasing would allow land uses to be 

developed in most areas. Areas subject to NSO where uses would be precluded would largely be along 

river corridors. 

Alternative C

Under Alternative C, the nature and types of impacts on land uses would be as described under Impacts 

Common to All Action Alternatives. Making 932,500 acres subject to NSO would limit the locations where 

new uses could be developed to 631,000 acres (40 percent) of the program area. These areas would be 

subject to TL or CSU lease stipulations, which would influence the future design, location, and extent of 

seasonal use associated with the use. 

Alternative D

Under both subalternatives of Alternative D, the nature and types of impacts on land uses would be the 

same as those described under Impacts Common to All Action Alternatives and would be similar to Alternative 
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C. Making 526,300 acres unavailable for lease sales and an additional 708,600 acres subject to NSO would 

limit the locations where new uses could be developed to the remaining 328,600 acres (21 percent) of the 

program area. 

Cumulative Impacts

Cumulative impacts on landownership and uses would be the result of a change in the demand for lands to 

be transferred out of federal ownership to support a public use or demand for land uses associated with 

energy or mineral development. Past, present, and reasonably foreseeable future actions, described in 

Appendix F, that would cumulatively affect landownership and uses include future oil and gas exploration 

and production and associated demand for infrastructure, and community expansion, particularly near 

Kaktovik, with associated demand for land uses and potential land tenure actions. 

Under all action alternatives, new oil and gas exploration and development would increase the number and 

density of uses in the program area. Applications for uses would be processed on a case-by-case basis, 

subject to lease stipulations and other protective measures. NSO stipulations, particularly under 

Alternatives C and D could result in the concentration of new uses in smaller areas. As new oil and gas 

uses are developed in an area, the availability of those public lands for other oil and gas infrastructure 

would decline. Collocation or use of shared facilities would alleviate this potential impact. 

Expanding interest in the program area would influence uses in nearby Kaktovik. Combined with past, 

present, and future actions, which include plans to expand community infrastructure and transportation 

facilities in the city, new oil and gas development could increase demand for new residential, commercial, 

civic, and industrial lands uses in the city. Because Kaktovik’s urban footprint is confined by the Beaufort 

Sea to the north, by public lands to the east and west, and by private lands to the south, there may be 

future interest in conveying lands out of federal ownership to accommodate new community development.

3.4.2 Cultural Resources

Affected Environment

This section incorporates information from the following sources: ADNR, Office of History and 

Archaeology (ADNR OHA 2018) Alaska Heritage Resources Survey (AHRS);28 NSB’s Iñupiat History, 

Language, and Cultural (IHLC) Division’s repository of Traditional Land Use Inventory (TLUI) sites (IHLC 

2018); ADNR, Division of Mining, Land and Water (ADNR MLW 2018) Revised Statute (RS) 2477 trail 

database (e.g., historic public ROWs; the NOAA Office of Coast Survey (NOAA OCS 2016) wrecks and 

obstruction database; and previous literature and EIS documents near the program area, including the 

Point Thomson EIS (USACE 2012) and Arctic Refuge CCP (USFWS 2015a). The BLM also reviewed 

scoping comments for this EIS for information on cultural resources in the program area. 

The relevant regulations for evaluating the effects on cultural resources are NEPA and Section 106 of the 

NHPA and its implementing regulations in 36 CFR 800.29 Federal agencies are encouraged to coordinate 

compliance with Section 106 with any steps taken to meet the requirements of NEPA and should consider 

their Section 106 responsibilities as early as possible in the NEPA process (36 CFR 800.8a). Other relevant 

legislation or EOs that apply to the management of cultural resources include the Antiquities Act of 1906 

(16 USC 431 et seq.); the Archaeological Resources Protection Act of 1979 (16 USC 470 et seq.); the 

Abandoned Shipwreck Act of 1987 (PL 100-298); the American Indian Religious Freedom Act; Section 4(f) 

 

28AHRS data reviewed for this EIS in June of 2018

29Section 106 of the NHPA requires the BLM to evaluate effects on historic properties, which are a type of cultural 

resource. 
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of the DOT Act (49 USC 303); the Archaeological and Historic Preservation Act of 1974 (the MossBennett Act); EO 13007 (Indian Sacred Sites); and the Native American Graves Protection and 

Repatriation Act (25 USC 3001-3013).

Cultural and Historic Context

The Arctic Refuge Revised CCP (USFWS 2015a) and Point Thomson EIS (USACE 2012) describe the 

cultural themes and periods of the Arctic Refuge, including the program area. Table 3-25, below, provides 

a summary of the cultural context of the Arctic Refuge as presented in the CCP (USFWS 2015a) and 

based on information provided in USACE (2012). Section 3.4.4, Sociocultural Systems, also provides a 

cultural overview of the Iñupiat and Gwich'in people that is relevant to this section. 

Table 3-25

Cultural Themes and Periods of the Arctic Refuge Area

Theme Period

Paleoindian 13,700 to 9,800 years ago

American Paleo-Arctic 11,800 to 8,000 years ago

Northern Archaic 8,000 to 3,000 years ago

Arctic Small Tool Tradition 5,000 to 2,400 years ago

Athabascan 2,000 years ago, to present

Birnirk Culture 1,600 to 1,000 years ago

Thule 1,000 to 400 years ago

Iñupiat 400 years ago, to present

Euro-American exploration 1820s to 1880s

Early ethnographic research 1900s to 1920s

Trading posts and reindeer herding 1920s to 1940s

Military presence/DEW Line sites 1950s to 1980s

Land conservation 1950s to present 

Oil development 1970s to present

Cultural Resources in the Program Area

Previous Archaeological and Historic Resources Surveys

In general, previous survey efforts focused on identifying archaeological and historic resources in the 

program area have been concentrated primarily along the coastal region, with fewer investigations along 

the river systems and little research in the overland areas. A review of the previous surveys module of the 

AHRS database, using section-level30 spatial coverage for the program area 10 literature reviews, 12 

reconnaissance surveys, and one intensive survey. A similar review of the document repository module of 

the AHRS returned 30 records for reports associated with those sections. 

Past surveys have largely been concentrated in and around the village of Kaktovik, along the coast and 

barrier islands of the Beaufort Sea, and along several of the major rivers in the area. Of special note is one 

wide-area survey of the program area conducted by Edwin Hall (1982) over approximately 20 days, using 

aerial overflights and limited pedestrian investigation of the coastal area and select river systems. This 

survey represents the only attempt at systematic coverage of the program area guided by targeted surveys 

at high potential landforms and topographic settings. Overall, vast inland areas of the program area have 

received little to no systematic investigation for cultural resources; while the coastal region has been the 

 

30The finest resolution of the AHRS database for wide-area queries is the section level, which may result in nonprogram area lands being included in the search.
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subject of a greater number of survey efforts, dynamic coastal erosion processes are affecting those 

resources.

Previously Documented Sites

For the Arctic Refuge, the USFWS (2015a) identified several categories of site types that could be found. 

These types are as follows for the five categories most likely to be found in the program area, which 

correspond to the specific sites identified in the program area:

 Coastal settlements, consisting of semi-subterranean driftwood or whalebone houses, in some 

cases associated with cemeteries or additional structures; post-contact and pre-contact houses are 

present along the coast of the Beaufort Sea

 Inland settlements, consisting of semi-subterranean driftwood or whalebone houses, also in some 

cases associated with cemeteries or additional structures; this is the least known type of site on 

the Arctic Refuge

 Tent ring complexes, consisting of arrangements of stones used to secure skin tents to the 

ground, often with associated hearths in and outside the ring; these features are found along river 

corridors on elevated terraces and likely relate to seasonal caribou hunting by coastal people; in 

some cases, these complexes are near or next to caribou drive lines or fences

 Lithic scatters, consisting of surface and subsurface collections of artifacts and debris resulting 

from the procurement, preparation, and manufacture of stone tools; in many cases, lithic 

typological and technological comparisons are the only way of assigning an age to a site

 Historic structures, including sod houses and cabins, built by indigenous peoples, early explorers, 

and trappers that offer insights into the early contact period

As identified in the AHRS database, there are 89 AHRS sites recorded in the program area, including sites 

of both prehistoric and historic origin (Appendix L). Approximately one-third of the sites have 

prehistoric components, including such features as sod houses, lithic scatters, tent rings, and various 

artifact scatters. Historic sites comprise the remaining two-thirds of sites and include military sites 

associated with the DEW Line and several historic Iñupiaq structures, such as sod houses, cellars, tent 

frames, and other buildings. The NSB’s TLUI database documents place names, landmarks, traditional land 

use sites, travel routes, and important locations remembered by the Iñupiat. According to the TLUI 

database, there are 34 recorded TLUI sites in the program area (Appendix L). These sites primarily 

consist of house ruins (both collapsed sod and cabin structures), graves, and important hunting, fishing, 

camping, and lookout areas. Except for five TLUI sites inland, the remaining 29 sites are located along 

coastal areas of the program area.

Other repositories of cultural resources are the RS 2477 database, and the NOAA Wrecks and 

Obstruction database. The RS 2477 trail database identifies three RS trails (914, 1043, and 1649) in the 

program area. RS 914 is the Poker (Pokok) Lagoon Southeast Trail, a 5.5-mile winter trail near Pokok 

Lagoon; RS 1043 is the Bullen-Staines River Trail, a 22-mile tractor trail; and RS 1649 is the Tamayariak 

River-Simpson Cove Trail, a 20-mile tractor trail.31 The NOAA database identifies two shipwrecks in the 

program area, one just off the northeast shoreline of Barter Island and a second in Camden Bay next to 

the POW-DEW Line site.

 

31The RS 2477 trails have been identified and asserted by the State of Alaska, but the validity of all RS 2477 trails 

must be determined either via a determination of perfection prior to the Federal Land Policy and Management Act 

or through appropriate judicial proceedings
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Locations of Previously Documented Sites

Due to the confidential and sensitive nature of cultural resource sites, no map is provided in this EIS; 

however, there are two main locations where cultural resources have been documented in the program 

area: on barrier islands and protected coasts of the Beaufort Sea and inland on elevated dry ground 

landforms, such as pingos, river terraces, and bluffs. While these are the types of landforms on which 

inland sites have been found, one reason for this is because these were the types of landforms focused on 

by Hall (1982) when he surveyed in the interior. Sites of greatest antiquity are found inland, as these 

landforms appear to have long periods of relative stability. Documented coastal sites are mainly historic, as 

the dynamic coastal environment appears to cause rapid displacement of sediments and soils through 

erosion, underlying permafrost thawing, elevated sea levels, and the likely destroying ancient shoreline sites 

(CCRS and NLUR 2010). These areas correspond to locations having the highest potential for human 

activity and where previous surveys have focused. Other undocumented sites are likely present in 

unsurveyed portions of the program area.

Ethnographic Cultural Resources

Cultural aspects of the environment are not limited only to discrete locations where physical remains of 

past human activities are preserved, but they may also include culturally valued places, cultural use of the 

biophysical environment, such as religious and subsistence uses, and sociocultural attributes, such as social 

cohesion, social institutions, lifeways, religious practices, and other cultural institutions (National 

Preservation Institute 2018). These ethnographic resources are cultural or natural features of a region, 

where traditionally associated cultures have formed significant connections. They are closely linked with 

their own sense of purpose, existence as a community, development as ethnically distinctive peoples, and 

survival of their lifeways. 

Ethnographic resources are held as traditionally meaningful and may be sites, landscapes, structures, 

objects, or natural resources, such plants, animals, minerals, and bodies of water, that are assigned 

traditional legendary, religious, subsistence, or other significance in the cultural system of a group. The 

significance that cultures assigned to ethnographic resources may encompass both the tangible and the 

intangible aspects of these special places. These types of sites provide knowledge regarding places 

important to identity, spirituality, and, in the case of ethnographic landscapes, a broader more holistic way 

of viewing cultural resources in the natural resources that surround them. 

Many terms are used by different groups to describe these ethnographic resources. Although not an 

exhaustive list, commonly used terms to describe the various types of ethnographic resources include the 

following: 

 Traditional cultural properties (TCPs)

 Ethnographic landscapes 

 Native American sacred sites

 Intangible cultural resources (e.g., oral traditions, indigenous knowledge, traditional skills) 

Traditional knowledge provided through oral histories and scoping testimonies is one avenue of identifying 

ethnographic resources. Such knowledge can be derived from oral histories and public testimony and can 

provide traditional knowledge that is both general, such as testimony on long-standing use of the arctic 

environment, or very specific, such as testimony about use of a specific family subsistence camp.
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During the scoping process, commenters, particularly the Gwich'in people in Arctic Village and Venetie, 

expressed the importance of investigating TCPs in the program area. They commented that there should 

be an emphasis on consultation with local tribal governments and organizations, nongovernmental 

agencies, and other interested parties. Broadly speaking, it is evident that the program area is held as 

sacred among the Gwich'in people, particularly for those residing in Arctic Village and Venetie. They hold 

it sacred because it is where life begins and for its association with caribou calving and bird nesting grounds 

(see Section 3.4.4, Sociocultural Systems). 

Besides the NSB’s TLUI program, surveys and research to identify and document potential sacred sites, 

TCPs, ethnographic landscapes, or intangible resources have not been completed to date in the program 

area. Kaktovik commenters stressed the importance of residents being able to maintain, if not increase, 

their access to and management of traditional areas in the program area and broader Arctic Refuge. 

Further efforts to describe the process for consulting, identifying, and documenting these types of 

ethnographic cultural resources that the Iñupiat and Gwich'in people hold as culturally important would be 

addressed in accordance with the Section 106 process. 

Climate Change

As identified in the GMT2 Final SEIS (BLM 2018a), cultural resources on the North Slope are susceptible 

to climate change effects of erosion, mass wasting, and cryoturbation32, which results in increased thawing 

and lack of preservation of frozen artifacts and loss of spatial relationships between cultural levels. 

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

cultural resources from on-the-ground post-lease activities. The effects of climate change described under 

Affected Environment above, could influence the rate or degree of the potential direct and indirect impacts.

Alternative A

Alternative A would not result in potential direct or indirect impacts on cultural resources because no 

leasing activity that could affect cultural resources would occur in the program area. Existing activities that 

could affect cultural resources would include people using Arctic Refuge lands and waters that could lead 

to purposeful or inadvertent damage to cultural resources. Additionally, natural processes, such as erosion, 

would continue to affect cultural resource sites under this alternative. 

Impacts Common to All Action Alternatives

Potential impacts associated with the development of a lease, including the exploration, construction, and 

operation phases of any permitted development, could include physical destruction of or damage to all or 

part of a cultural resource, removal of the resource from its original location, change in the character of 

the resource’s use, or change of the physical features in the resource’s setting (e.g., vibration, noise, visual, 

 

32Refers to the mixing of materials from various horizons of the soil down to the bedrock due to freezing and 

thawing. Occurs to varying degrees in permafrost soils.
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or olfactory) that contribute to the importance of the resource, or change in access to traditional use sites 

by traditional users. 

In areas where avoidance does not occur, examples of ground-disturbing activities that could potentially 

cause direct impacts are excavation of material sites; construction and maintenance of gravel roads, pads, 

airstrips, bridges and culverts; construction of ice roads and pads; construction of VSMs for power lines 

and pipelines; and any other disturbance of the ground surface in the proximity of development project 

components. 

Other activities and events that could potentially cause direct impacts on cultural resources include seismic 

and other exploratory activities, damage caused by equipment during the construction, drilling, and 

operation phases of development projects, and unanticipated accidents, such as blowouts, spills, or fires, 

and subsequent cleanup activities. Certain future impacts, such as oil spills, can contaminate site artifacts 

and organic materials to make them undatable. Section 4.3.12.2 in BLM 2012 provides additional discussion 

of potential direct impacts on cultural resources associated with oil and gas exploration and development.

Potential indirect impacts on cultural resources could also occur at distances greater than the 

development project footprints. Indirect impacts on cultural resources could occur throughout the 

construction and operation phases of a development project and during closure and reclamation. Examples 

of indirect impacts on cultural resources could include increased access and potential removal, trampling, 

or dislocation of cultural resources and culturally sensitive areas by personnel and visitors; complete or 

partial destruction of a site from erosion, thawing permafrost, and thermokarsting; the loss of traditional 

meaning, identity, association, or importance of a resource; effects on beliefs and traditional religious 

practices; or neglect of a resource that causes its deterioration.

While potential impacts on specific cultural resource sites would differ by alternative (see discussion 

below), broader cultural impacts on belief systems/religious practices would be common across all 

alternatives. Particularly for the Gwich'in people, who hold the program area as sacred ground to their 

culture and as Iizhik Gwats’an Gwandaii Goodlit, “The Sacred Place Where Life Begins” (Gwich'in Steering 

Committee 2004), the presence of development in the program area would constitute a cultural impact on 

the Gwich'in people. This is because they believe that development in the program area would harm the 

caribou and other migratory resources (such as waterfowl) that migrate to the Coastal Plain to give birth. 

This sacred pattern of migration and birth maintains the value of, and gives essence to, the Coastal Plain as 

the place where life began. This sacred belief is based on the intergenerational traditional knowledge of the 

Gwich'in people that is built on millennia of residence in the region (see Irving 1958 and Kofinas et al. 2002 

for examples of this knowledge). Similar to the cultural value that Iñupiat place on bowhead whales in their 

culture, caribou are held in the highest regard by the Gwich'in people and are the backbone of their 

cultural identity (Slobodin 1981). Any potential impacts on the resource would constitute a cultural effect. 

These effects, including those on belief systems, are also discussed in Section 3.4.4.

Both the Iñupiat and the Gwich'in people have cultural and ethnographic ties to the program area, as 

evidenced by cultural sites, traditional and contemporary uses, oral histories, and current beliefs and 

values. When these are viewed as a whole, these ties to land and place are often documented and 

identified in the cultural resource regulatory framework as TCPs or cultural landscapes. 

These types of cultural resources have not been documented to date in the program area under the 

existing regulatory frameworks, although the wide array of individual TLUI and AHRS sites in the program 

area demonstrate the potential for these ethnographic resources, such as TCPs, cultural landscapes, and 
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sacred sites, to be documented. While the available data (see Affected Environment section above) have not 

documented these types of cultural resources for Iñupiat or the Gwich'in people in the program area, the 

absence of these cultural resources can be attributed to the lack of past research to document these types 

of resources rather than the fact that they do not exist. 

The Gwich'in people in Arctic Village have stated that documented and undocumented TCPs do exist for 

them that they believe could be affected by oil and gas leasing in the program area and that the Section 106 

consultation process needs to fully consider these cultural resources. Other scoping testimony identified 

the Coastal Plain of the Arctic Refuge as a cultural landscape that provides for indigenous communities and 

that the area should be explicitly analyzed as a traditional cultural landscape of the Gwich'in Nation.

In summary, given the information currently available and the undetermined location and nature of 

development in the program area, potential impacts on traditional belief systems/religious practices and 

other ethnographic cultural resources, such as TCPs and cultural landscapes, particularly for the Gwich'in 

people, would be adverse, regional, and long term. Consultation with the tribes during the NEPA and 

Section 106 processes will occur to explore options for minimization and mitigation measures related to 

ethnographic cultural resources. For cultural resource sites in the program area that could not be avoided 

or that would experience indirect effects, the impacts would be adverse, local, and long term.

No potential adverse effects on documented specific cultural resource sites would be expected in areas 

where adequate investigation, such as surveys, consultation, and interviews, has occurred prior to 

development and where appropriate avoidance, minimization, or mitigation measures are implemented. 

The Section 106 process for addressing effects on historic properties is occurring concurrently with the 

NEPA process and will include the development of a programmatic agreement to address the process for 

identifying historic properties and resolving potential adverse effects through avoidance, minimization, or 

mitigation. Lease stipulations already proposed include conducting cultural surveys prior to grounddisturbing activities, a plan for unanticipated discovery stoppage, and cultural awareness training and 

orientation.

Alternative B

Under Alternative B, the types of potential impacts on cultural resources would be the same as those 

described above (Impacts Common to All Action Alternatives). Alternative B would make available the largest 

number of acres for potential leasing and development; therefore, in terms of direct and indirect impacts 

on cultural resource sites (e.g., TLUI, AHRS, RS 247733 trails), Alternative B could affect the greatest 

number of documented sites (Table 3-26). Thirty-six AHRS and 25 TLUI sites are in areas that are open 

with standard terms and conditions or TLs and could experience ground-disturbing activities. RS 2477 

trails #1649 and #914 also occur in these areas. An additional 57 AHRS and 9 TLUI sites are in areas of 

NSO and would have less potential to be affected, due to the reduced levels of ground-disturbing activities 

in the NSO areas. RS 2477 trails #1649, #1043, and #914 and the two shipwrecks occur in the NSO area.

 

33RS 2477 is found in Section 8 of the Mining Law of 1866 and states, “The ROW for the construction of highways 

over public lands, not reserved for public uses, is hereby granted.” This statute granted states and territories 

ROWs over federal lands that had no existing reservations or private entries. In Alaska, this law effectively ended 

in 1969, but due to the time frame in which these ROWs were established (1866–1969), these highways, trails, and 

other ROWs are considered historical resources and are taken into consideration in this EIS (ADNR MLW 2013).
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Table 3-26

Cultural Resource Sites by Action Alternative

Alternative STC/TL CSU NSO Not Offered for 

Lease Sale

B 36 AHRS

25 TLUI

2 RS 2477

n/a 57 AHRS

9 TLUI

3 RS 2477

2 shipwrecks

n/a

C 6 AHRS

1 RS 2477

n/a 85 AHRS

34 TLUI

3 RS 2477

2 shipwrecks

n/a

D1 and D2 1 AHRS 0 74 AHRS

30 TLUI

3 RS 2477

2 shipwrecks

15 AHRS

4 TLUI

Source: BLM GIS 2018

Notes: Some larger sites may overlap multiple lease areas. This table does not include ethnographic resources, which are 

addressed under Impacts Common to All Action Alternatives.

STC = Subject only to standard terms and conditions

TL = Timing limitations

CSU = Controlled surface use

NSO = No surface occupancy

Because Alternative B has the smallest setbacks from areas of highest potential for containing 

undocumented cultural resources, such as rivers and coastline, this alternative would have the highest 

likelihood for affecting undocumented resources. Potential impacts on cultural resource sites under 

Alternative B would be adverse, local (up to 2,000 acres of disturbance and general vicinity), and long term 

for sites that could not be avoided or would experience indirect effects.

Alternative C

Alternative C would have the same number of acres available for potential leasing and development 

compared to Alternative B, but a larger number of acres would be subject to NSO stipulations, which have 

less potential to impact cultural resource sites; therefore, in terms of direct and indirect impacts on 

documented cultural resource sites (e.g., TLUI, AHRS, RS 2477 trails), Alternative C would have fewer 

sites affected in areas subject only to standard terms and conditions or TL stipulations than Alternative B. 

Six AHRS are in standard terms and conditions/TL areas that are open to leasing and could experience 

ground-disturbing activities (Table 3-26). RS 2477 trail #1649 occurs in these areas. An additional 85 

AHRS and 34 TLUI sites are in the NSO area and would have less potential to be affected due to the 

reduced levels of ground-disturbing activities. RS 2477 trails #914, #1043, and #1649 occur in the NSO 

area as do the two shipwrecks. 

Because Alternative C has a 1-mile pad and CPF exclusion area near the coast, it has a slightly lower 

likelihood than Alternative B for affecting undocumented cultural resources. Potential impacts on cultural 

resource sites under Alternative C would be of lower intensity than Alternative B and would be adverse, 

local (up to 2,000 acres of disturbance and general vicinity), and long term for sites that could not be 

avoided or would experience indirect effects.
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Alternative D

Alternative D would make available the fewest number of acres for potential leasing and development and 

therefore, in terms of potential direct and indirect impacts on documented cultural resource sites (e.g., 

TLUI, AHRS, and RS 2477 trails), Alternative D would affect the fewest number of sites. Only one AHRS 

site is in the areas subject to only standard terms and conditions or TLs that are open to leasing and could 

experience ground-disturbing activities (Table 3-26). An additional 74 AHRS and 30 TLUI sites are in the 

NSO area and would have less potential to be affected, due to the reduced levels of ground-disturbing 

activities. All three RS 2477 trails occur in the NSO area, as do the two shipwrecks. Lastly, 15 AHRS sites 

and 4 TLUI sites are in areas not offered for lease sale and would not experience impacts. 

Because Alternative D has the largest setbacks from areas of highest potential for containing 

undocumented cultural resources, such as rivers and coastline, this alternative would have the lowest 

likelihood for affecting undocumented resources. Potential impacts on cultural resource sites under 

Alternative D would be of lower intensity than under Alternative B and would be adverse, local (up to 

2,000 acres of disturbance and general vicinity), and long term for sites that could not be avoided or would 

experience indirect effects. 

Cumulative Impacts

Past, present, and reasonably foreseeable future activities, in combination with oil and gas development in 

the program area, would increase the potential for cultural resource impacts, both directly on specific 

cultural resource sites and other ethnographic resources such as TCPs and cultural landscapes. Past and 

present actions that have affected cultural resources are oil and gas development, onshore and offshore 

transportation and infrastructure projects, increased recreation and tourism, and community development. 

The proposed oil and gas leasing program, in addition to future activities, could lead to additional oil and 

gas development and other development and infrastructure projects, in addition to increasing access to 

otherwise remote areas inside the program area and increasing the risk of damage or unauthorized 

collection. 

Cumulative impacts would have the greatest effect on ethnographic resources, such as TCPs and cultural 

landscapes, which are less easy to avoid than specific sites, and would mitigate impacts because their 

significance is tied to historic and present cultural identity. These could be affected by the presence of 

development. This cultural identity relates to the cultural importance of the land and its surrounding 

natural resources, such as the Gwich'in and Iizhik Gwats’an Gwandaii Goodlit, “The Sacred Place Where Life 

Begins”. The effects of climate change described under Affected Environment above, could influence the rate 

or degree of the potential cumulative impacts.

Alternatives that allow the greatest amount of land to be developed are likely to have the greatest 

cumulative effect on cultural resources. This is because they could affect a greater number of documented 

and undocumented cultural resources; thus, Alternative B would have the largest contribution to 

cumulative effects on cultural resources, while Alternative D would have the smallest contribution to 

cumulative effects on cultural resources.

3.4.3 Subsistence Uses and Resources

Affected Environment

This section summarizes the relevant subsistence activities of communities that use the program area or 

the resources that migrate through the program area and are harvested elsewhere. For the purposes of 

this analysis, there are four primary subsistence study communities: Kaktovik, Nuiqsut, Arctic Village, and 
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Venetie. They are the closest to the program area and have subsistence uses in or near the program area 

or rely heavily on resources that use the program area. In addition, because of the importance of the 

program area to caribou—particularly the PCH and CAH—this section also includes relevant data on 

subsistence uses of caribou by 22 Alaskan communities, including the four subsistence study communities 

listed below, in GMU subunits in the PCH and CAH herd ranges, which have Federal Subsistence Board 

customary and traditional34 use determinations for caribou (Map 3-27, Coastal Plain EIS Subsistence Study 

Communities, in Appendix A). In this EIS, these communities are referred to as the caribou study 

communities. Many of these communities, such as Fort Yukon, Chalkyitsik, Wiseman, Beaver, Circle, Birch 

Creek, and Stevens Village, have reported geographic, historic/prehistoric, or cultural ties to the Arctic 

Refuge as a whole (USFWS 2015a). 

Additionally, Gwich'in people, Inuvialuit, and other user groups in Canada have cultural, historical, and 

subsistence ties to the Arctic Refuge or the PCH or both. According to the Agreement Between the 

Government of Canada and the Government of the United States of America on the Conservation of the 

Porcupine Caribou Herd, “when evaluating the environmental consequences of a proposed activity, the 

Parties will consider and analyze potential impacts, including cumulative impacts, to the Porcupine Caribou 

Herd, its habitat and affected users of Porcupine Caribou” (Section 3(g)). Canadian uses of the PCH are 

addressed under the section below, Subsistence Uses of the CAH and PCH.

Additional associated information relevant to subsistence is in Section 3.4.4, which addresses cultural 

history, social and political organization, mixed cash/subsistence economy, and belief systems; Section 

3.4.2, Cultural Resources, addresses prehistory/history, archaeological sites, and traditional land use sites.

Subsistence Definition and Relevant Legislation

Subsistence is a central aspect of rural life and culture and is the cornerstone of the traditional relationship 

of the indigenous people with their environment. Residents of the study communities rely on subsistence 

harvests of plant and animal resources both for nutrition and for their cultural, economic, and social wellbeing. Activities associated with subsistence—processing, sharing, redistribution networks, cooperative 

and individual hunting, fishing, and gathering, and ceremonial activities—strengthen community and family 

social ties, reinforce community and individual cultural identity, and provide a link between contemporary 

Natives and their ancestors. These activities are guided by traditional knowledge, based on a long-standing 

relationship with the environment. More than just food, subsistence includes economic, social, 

cultural/traditional, and nutritional elements. 

The program area is almost entirely on federal lands managed by the USFWS; Alaska Native allotments 

comprise about 900 surface acres. In Alaska, subsistence hunting and fishing are regulated under a dual 

management system by the State of Alaska and the federal government. Subsistence activities on all lands in 

Alaska, including private lands, are subject to state or federal subsistence regulations. Fish and wildlife 

harvesting on corporation-owned land being managed by the State. See USFWS (2015a) for a more indepth discussion of subsistence management in the Arctic Refuge. 

 

34Customary and traditional use, based on federal definitions (36 CFR 242.4), means a long-established, consistent 

pattern of use, incorporating beliefs and customs that have been transmitted from generation to generation. This 

use plays an important role in the economy of the community. Where the Federal Subsistence Board has made a 

customary and traditional use determination regarding subsistence use of a specific fish stock or wildlife population 

(36 CFR 242.24), only those Alaskans who are residents of rural areas or communities designated by the board are 

eligible for taking of that population or stock on public lands for subsistence uses. 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources)

Coastal Plain Oil and Gas Leasing Program 3-161

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Overview of Subsistence Uses

The following sections provide a brief overview of subsistence uses for the four study communities, in 

addition to Subsistence Uses of the PCH and CAH, below. Additional subsistence data tables are provided in 

Appendix M, and maps are provided in Appendix A. Other sources provide additional descriptions of 

subsistence or contain data that are relevant to subsistence but are not directly comparable to the 

information in this section, such as reported versus estimated harvests and Native households versus all 

households. These sources include the USFWS (2015a), which provides a detailed description of 

subsistence uses in the Arctic Refuge, and the NSB census reports and community plans (e.g., NSB 2015a, 

2015b), which includes subsistence data that focus on Native households and selected resources.

Kaktovik

Kaktovik residents are the primary subsistence users of the program area, which crossed much of the 

community’s traditional and contemporary area of subsistence use (Map 3-28, Kaktovik Subsistence Use 

Areas, in Appendix A). Kaktovik use areas from the two previous comprehensive all resources mapping 

studies show overlap with the program area; for the most recent period (1996 to 2006), the data show 

the greatest amount of overlapping use areas in the program area occurring along the coast, between 

Beaufort Lagoon and Brownlow Point, and inland around the Sadlerochit, Hulahula, and Jago Rivers. In 

addition, high levels of overlapping subsistence use areas occur offshore from the program area in the 

Beaufort Sea. All respondents (38 active harvesters) (SRB&A 2010) reported 1996 to 2006 subsistence 

uses in the program area. 

Kaktovik use areas overlap with the program area for the following resources: terrestrial mammals 

(including caribou, moose, grizzly bear, and Dall sheep), furbearers and small land mammals, fish, birds 

(including geese and eiders), vegetation, and marine mammals (including bowhead whale, beluga whale, 

seal, walrus, and polar bear) (Map 3-29, Kaktovik Caribou Subsistence Use Areas in Coastal Plain, 

through Map 3-39, Kaktovik Polar Bear Subsistence Use Areas in Coastal Plain, in Appendix A). The 

primary inland subsistence uses for Kaktovik in the program area are caribou, furbearer, and grizzly bear 

hunting, in addition to limited moose hunting, vegetation gathering, and fishing in select locations along 

rivers. The primary coastal subsistence uses that overlap the program area are fishing, harvesting 

vegetation, and hunting for caribou, geese, eider, and bearded and ringed seals in nearshore areas. 

Offshore areas are used primarily for hunting bowhead whales, with more limited walrus hunting. 

The timing of subsistence activities in Kaktovik is depicted in Table M-4 in Appendix M. Subsistence 

activity, in terms of the number of resources targeted, is highest during the late summer/fall, when 

residents hunt bowhead whales in addition to targeting caribou, moose, fish, waterfowl, and plants and 

berries. April is another busy time, when geese arrive in the area and are harvested along the coast and 

inland. The fewest resources are targeted from December through February, although some residents 

pursue inland resources, such as furbearers, moose, caribou, and freshwater fish during this time. 

Kaktovik residents access much of their subsistence use along the coast using boats, while inland travel is 

limited exclusively to four-wheel vehicles along coastal locations in the summer/fall and large overland 

areas by snowmachine in the winter (Table M-5 in Appendix M; SRB&A 2010). Inland travel during the 

snow-free months is limited due to restrictions on motorized access in the Arctic Refuge. Residents also 

walk or use vehicles to access subsistence use areas on Barter Island. The program area, which includes 

coastal, nearshore, and inland subsistence use areas, is accessed using boats and snowmachines, with some 

inland travel from the coast by four-wheel vehicles.
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As shown in Table 3-27, based on years with available data, Kaktovik residents harvest an annual average 

of 588 pounds of subsistence resources per capita. Marine mammals are the primary resource harvested in 

terms of edible weight, contributing over 60 percent toward the community’s subsistence diet. Large land 

mammals are the second-most harvested resource by edible weight, followed by fish other than salmon 

and migratory birds. During most years, the primary subsistence species harvested by Kaktovik residents 

(Table M-3 in Appendix M) is bowhead whale, caribou, Dolly Varden, Arctic cisco, beluga whale (during 

some years), bearded and ringed seal, Dall sheep, and moose.

Table 3-27

Selected Kaktovik Harvest and Participation Data, Average Across Available Study Years

Resource 

Category

Estimated 

Pounds Per 

Capita

Percent 

of Total 

Harvest

Percentage of Households

Using Attempting to 

Harvest Giving Receiving

All resources 588 100.0 99 92 83 98

Salmon 1 <1 16 5 6 12

Non-salmon fish 57 10.1 87 70 53 72

Large land mammals 176 24.7 97 68 60 93

Small land mammals 1 <1 45 41 21 22

Marine mammals 318 62.7 93 72 61 91

Marine invertebrates <1 <1 1 1 0 1

Migratory birds 12 1.9 80 63 45 65

Upland game birds 3 <1 80 60 42 47

Bird eggs <1 <1 9 6 5 6

Vegetation 1 <1 49 38 15 36

Sources: 1985, 1986 (ADFG 2018c); 1992 (Fuller and George 1999); 1992 (Pedersen 1995a); 1994-95 (Brower et al. 2000); 

2000-01, 2001-02 (Pedersen and Linn 2005); 2002-03 Bacon et al. 2009); 2007-2012 (Harcharek et al. 2018); 2010-11 (Kofinas 

et al.2016)

Note: See Tables M-1, M-2, and M-3 in Appendix M for data by study year.

Over 90 percent of Kaktovik households participate in one or more subsistence resource harvesting 

activities, with over two-thirds of households participating in marine mammal hunting, fishing, and large 

land mammal hunting. Sharing is a central aspect of Kaktovik subsistence. A recent BOEM-funded study on 

sharing networks documented Kaktovik households giving an average of 3.1 and receiving 4.5 core species 

(identified by Kofinas et al. [2016] as being harvested in the greatest quantity, having the most cultural 

importance, and being representative of a range of resources). The study found that during a single year, 

176,577 pounds of subsistence foods flowed between Kaktovik households. In addition to food, sharing 

was in the form of labor, money/equipment, and other contributions. Sharing networks extend across 

nearly all regions of Alaska and to other states (Kofinas et al. 2016). Sharing not only serves to distribute 

food throughout a community, but “social relations in the form of cooperation and sharing persist and may 

act as sources of resilience for community households” (Kofinas et al. 2016); thus, sharing is a crucial part 

of social structure, social ties, and resiliency in Alaska Native communities. 

An analysis of resource importance, based on material (percentage of total harvest) and cultural 

(percentage of households harvesting and percentage of households receiving), is provided in Table M-6 

in Appendix M (see USACE [2012] for a description of the method used). Based on this analysis, 

resources of major importance in Kaktovik are bearded seal, Bering cisco, bowhead whale, caribou, Dall 

sheep, Dolly Varden/Arctic char, ptarmigan, and wood.
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources)

Coastal Plain Oil and Gas Leasing Program 3-163

Draft Environmental Impact Statement

Nuiqsut

Nuiqsut is west of the program area, where there are limited subsistence uses; however, Nuiqsut 

residents harvest resources that migrate through the area (Map 3-40, Nuiqsut Subsistence Use Areas, in

Appendix A). For the most part, Nuiqsut subsistence users utilize lands west of the Prudhoe Bay area, 

although many of the lands in the area were traditionally used by Nuiqsut people. In addition, the 

community’s whaling grounds are based out of Cross Island and whaling sometimes extends offshore of 

the program area. As shown in Map 3-41, Nuiqsut Whales Subsistence Use Areas in Coastal Plain, Map 

3-42, Nuiqsut Seal Subsistence Use Areas in Coastal Plain, and Map 3-43, Nuiqsut Wolf and Wolverine 

Subsistence Use Areas in Coastal Plain, in Appendix A, Nuiqsut use areas overlap the program area for 

marine mammals (bowhead whale and ringed/bearded seal; three mapping studies) and furbearers (wolf 

and wolverine; one mapping study). 

For the most recent period for which information is available (1995 to 2006), bowhead whale and seal use 

areas overlap the program area in nearshore areas east of Flaxman Island. Cross Island whaling crews 

travel this far east during certain years, depending on ice conditions and resource availability. During 

certain years, whaling crews have reported disturbances in their hunting area from vessel traffic and 

seismic activity. A wolf and wolverine hunting area, likely reported by a single hunter, was documented 

extending overland from Nuiqsut’s core hunting area and crossing the Sadlerochit, Hulahula, and Jago 

Rivers. Use areas overlapping the program area were reported by four Nuiqsut respondents (12 percent; 

SRB&A 2010). Nuiqsut residents harvest caribou primarily from the Teshekpuk Herd and the CAH, which 

sometimes passes through the program area before heading west toward the Colville River delta. 

Data on the timing of Nuiqsut subsistence activities are depicted in Table M-9 in Appendix M. August 

and September are the peak of hunting and harvesting in Nuiqsut, when residents station whaling crews at 

Cross Island, hunt moose and caribou, and harvest fish. October/November is a crucial time for 

subsistence in the community, when residents set nets for Arctic cisco (qaaktak) as they run upriver. 

These qaaktak are the same that originate in the Mackenzie River delta and migrate west along the coast, 

passing by the program area, before arriving at their destination in the Colville River delta. 

Winter activities are limited primarily to furbearer and caribou hunting, with some fishing through the ice. 

Residents travel by snowmachine and boat during the spring to hunt waterfowl and then travel offshore 

and inland during the summer by boat to hunt seals and caribou, set nets for broad whitefish, fish for 

grayling and Dolly Varden, and harvest berries. Boats are the most commonly used method of 

transportation for Nuiqsut subsistence activities, although snowmachines are necessary for inland pursuits, 

such as wolf and wolverine hunting and geese hunting (Table M-10 in Appendix M). In recent years, allterrain vehicles and trucks have become more commonly used during the summer and fall, when residents 

hunt caribou to the west of the community (SRB&A 2017). 

As shown in Table 3-28, based on years with available data, Nuiqsut residents harvest an annual average 

of 679 pounds of subsistence resources per capita. Marine mammals, large land mammals, and fish other 

than salmon contribute nearly equal amounts toward the subsistence harvest, although bowhead whaling 

success often determines the relative contribution of other resources (Table 3-28, and Table M-7 in

Appendix M). During most years, the primary subsistence species harvested by Nuiqsut residents (Table 

M-8 in Appendix M) are bowhead whale, caribou, Arctic cisco, broad whitefish, bearded and ringed seal, 

white-fronted geese, and moose. 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources)

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Table 3-28

Selected Nuiqsut Harvest and Participation Data, Average Across Available Study Years

Resource 

Category

Estimated 

Pounds per 

Capita

Percent 

of Total 

Harvest

Percentage of Households

Using Attempting 

to Harvest Giving Receiving

All resources 679 100.0 100 95 93 98

Salmon 5 <1 65 43 31 35

Fish other than salmon 209 30.6 97 81 81 79

Large land mammals 224 32.6 96 77 77 78

Small land mammals <1 <1 45 41 17 12

Marine mammals 226 33.8 97 54 60 97

Migratory birds 13 2.3 85 78 58 52

Upland game birds 2 <1 54 48 36 15

Bird eggs <1 <1 24 16 8 11

Vegetation 1 <1 61 52 19 33

Sources: 1985 (ADFG 2018c); 1992 (Fuller and George 1999); 1993 (Pedersen 1995b); 1994-95 (Brower and Hepa 1998); 

1995-96, 2000-01 (Bacon et al. 2009); 2014 (Brown et al. 2016)

Note: See Tables M-7 and M-8 in Appendix M for data by study year.

One hundred percent of Nuiqsut households report using subsistence resources, and 95 percent 

participate in one or more subsistence resource harvesting activities, with over two-thirds of households 

participating in harvests of fish other than salmon, large land mammals, and migratory birds. Household 

participation in bowhead whale hunting is relatively limited, due to the substantial distance of the whaling 

site (Cross Island) from the community and the required absence from the community. Nuiqsut residents 

consider sharing to be central to their identity; the bowhead whale hunt, in particular, centers on sharing, 

as evidenced by the 97 percent of households who receive bowhead whale meat annually.

An analysis of resource importance, based on indices of harvest (percentage of total harvest), harvest 

effort (percentage of households attempting harvests), and sharing (percentage of households receiving), is 

provided in Table M-11 in Appendix M. Based on this analysis, resources of major importance in 

Nuiqsut are Arctic cisco, Arctic grayling, bearded seal, bowhead whale, broad whitefish, burbot, caribou, 

cloudberry, white-fronted geese, and drift wood.

Arctic Village

Arctic Village is south of the program area, on the south side of the Brooks Range, along the East Fork 

Chandalar River. As shown in Map 3-44, Arctic Village and Venetie Subsistence Use Areas, in Appendix 

A, Arctic Village subsistence use areas do not overlap the program area; however, Arctic Village is on the 

Arctic Refuge boundary, so most subsistence activities do extend into the refuge. Resource uses farthest 

north toward the program area are sheep and caribou hunting and furbearer harvesting. 

Arctic Village and other northern Gwich'in people consider caribou their most important food source and 

refer to themselves as the caribou people (see Section 3.4.4). Caribou from the PCH calve in the 

program area, and for this reason, it is considered sacred ground to the Gwich'in people (USFWS 2015a). 

Subsistence harvesting by Arctic Village residents generally occurs on their lands or in the Arctic Refuge 

south of the program area. Key harvesting locations are Old John Lake, the Chandalar, Sheenjek, Junjik, 

and Wind rivers, and Red Sheep Creek (USFWS 2015a).

Data on the timing of Arctic Village subsistence activities are depicted in Table M-14 in Appendix M. In 

terms of the number of resources targeted, the fall and winter are the most active times for subsistence 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources)

Coastal Plain Oil and Gas Leasing Program 3-165

Draft Environmental Impact Statement

harvesters in Arctic Village. From August through October, residents target a variety of large land 

mammals, including caribou, moose, and Dall sheep, in addition to fishing and harvesting wood for the 

upcoming winter. The fall is particularly important for caribou hunting, as residents wait for caribou from 

the PCH to migrate through their traditional hunting grounds after the PCH has spent the spring and 

summer on the North Slope, including in the program area (USFWS 2015a). Caribou hunting continues 

through the winter as caribou are available, and residents also set traps during this time. The spring and 

summer are primarily dedicated to the harvest of waterfowl and fish. 

Data that estimate harvest for the entire community are limited to less complex studies documenting 

harvests of migratory birds and fish. As shown in Table 3-29, based on 3 years of limited data, Arctic 

Village residents harvested an average of 51 pounds of non-salmon fish per capita, and 6 pounds of 

migratory birds per capita. Scoters were the most commonly harvested migratory bird, followed by scaup, 

long-tailed ducks, mallards, and white-fronted geese. Whitefish, particularly humpback whitefish and broad 

whitefish, contributed the greatest amount to the non-salmon fish harvest, with Arctic grayling and 

northern pike also contributing substantial amounts (Table M-13 in Appendix M). An average of 70 

percent of households use non-salmon fish (Table 3-29), and half of Arctic Village households report 

harvesting fish other than salmon. Forty-six percent reported harvesting migratory birds during the 2000 

study year and 87 percent used migratory birds (Table M-12 in Appendix M). 

Table 3-29

Selected Arctic Village Harvest and Participation Data, Average Across 

Available Study Years

Resource 

Category

Estimated 

Pounds Per 

Capita

Percent 

of Total 

Harvest

Percentage of Households

Using Attempting 

to Harvest Giving Receiving

Non-salmon fish 51 — 71 — 23 35

Migratory birds 6 — — — — —

Sources: 2000 (Andersen and Jennings 2001); 2001, 2002 (ADFG 2018c)

Note: See Tables M-12 and M-13 in Appendix M for data by study year.

The USFWS (2015a) states that, based on reported harvests alone and not community-wide estimates, 

moose and caribou comprised more than 90 percent of the harvest by weight during harvest years in the 

1990s and early 2000s. These data (e.g., Council of Athabascan Tribal Governments 2002, 2003, 2005) are 

not estimated for the entire community or have low response rates. Because of this, they are not 

comparable to the more comprehensive surveys, which report estimated harvests for the community as a 

whole. These data are not described here;35 however, the reported percentages demonstrate that moose 

and caribou are highly important to the subsistence harvest of Arctic Village.

Data to calculate resources of importance for Arctic Village are not available, as there have been no 

comprehensive household harvest surveys in that community; however, based on existing literature 

reviews and statements from community members during public scoping and elsewhere, the assumption is 

that caribou are a resource of primary subsistence, economic, cultural, and spiritual importance for the 

community of Arctic Village.

 

35ADFG, the primary repository for subsistence harvest data in Alaska, removed these data from their Community

Subsistence Information System due to data quality issues.
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources) 

3-166 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement 

Venetie 

Venetie is south of Arctic Village on the Chandalar River. As shown on Map 3-44 in Appendix A, 

Venetie subsistence use areas do not overlap the program area. As with Arctic Village and other Gwich'in 

people, Venetie residents consider caribou to be a primary food source and central to their cultural 

identity (see Section 3.4.4). Subsistence harvesting by Venetie residents generally occurs on tribal lands 

surrounding their community and surrounding the Chandalar (including the East and Middle Forks), Yukon, 

Christian, and Hadweenzic Rivers (Caulfield 1983; Van Lanen et al. 2012). Caribou are primarily available 

to Venetie and Arctic Village residents along the upper Chandalar River drainage and the foothills of the 

Brooks Range (Van Lanen et al. 2012). 

Data on the timing of Venetie subsistence activities are listed in Table M-18 in Appendix M. In terms of 

the number of resources targeted, the spring and fall are the most active times for subsistence harvesters 

in Venetie. Fishing and hunting of waterfowl, black and brown bears, and small land mammals (muskrats 

and ground squirrels) are common activities during April and May; these activities continue through the 

summer and into the fall. Berries are harvested also during summer and early fall. As with Arctic Village, 

caribou hunting begins in the fall (generally August), when caribou from the PCH begin their annual 

migration through northern Gwich'in people’s hunting grounds. Residents also hunt moose during the fall 

and continue to hunt both moose and caribou through the winter, along with trapping furbearers. 

Data on subsistence harvests for Venetie are provided in Tables M-15 through M-17 in Appendix M

and in Table 3-30, below. Venetie data are limited to one comprehensive study of all subsistence 

resources for the 2009 study year, in addition to several years of data for migratory birds and land 

mammals. As shown in Table 3-30, based on years with available data, Venetie residents harvest an annual 

average of 274 pounds of subsistence resources per capita. Large land mammals constitute approximately 

half of the subsistence harvest in terms of edible pounds. Also important are harvests of salmon, fish other 

than salmon, and migratory birds (Kofinas et al. 2016). 

Table 3-30

Selected Venetie Harvest and Participation Data, Average Across Available Study Years 

Resource Category

Estimated 

Pounds Per 

Capita

Percent of 

Total 

Harvest

Percentage of Households

Using Attempting 

to Harvest Giving Receiving

All Resources 274 100.0 99 86 — —

Salmon 76 27.8 76 37 — —

Non-Salmon Fish 25 9.0 81 67 — —

Large Land Mammals 95 49.6 94 63 — —

Small Land Mammals 12 4.2 56 44 — —

Marine Mammals 0 0.0 18 0 — —

Migratory Birds 27 7.4 79 57 — —

Upland Game Birds <1 <1 20 31 — —

Bird Eggs — — — — — —

Vegetation 5 1.8 67 46 — —

Sources: 2000 (Andersen and Jennings 2001); 2009 (Kofinas et al. 2016); 2008-09, 2009-10 (Van Lanen et al. 2012), 2010-11 

(Stevens and Maracle n.d.) 

Note: See Tables M-15, M-16, M-17 in Appendix M for data by study year.

The primary subsistence species for Venetie residents are moose, caribou, chum and chinook salmon, 

grayling, geese, and whitefish. Ninety-nine percent of Venetie households report using subsistence 

resources, and 86 percent participate in subsistence activities. Over half of the households participate in 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources) 

Coastal Plain Oil and Gas Leasing Program 3-167 

Draft Environmental Impact Statement 

harvests of large land mammals, fish other than salmon, and migratory birds. A recent BOEM-funded study 

documented Venetie sharing networks extending throughout the state, but with a focus on nearby interior 

communities, such as Arctic Village, Fort Yukon, Eagle, Chalkyitsik, Stevens Village, Beaver, and Birch 

Creek. Venetie residents also have sharing networks with multiple North Slope communities, including 

Utqiaġvik, Nuiqsut, and Anaktuvuk Pass (Kofinas et al. 2016). The study notes the importance of the close 

kinship ties between Venetie and Arctic Village as a source of resiliency, as caribou harvested in Arctic 

Village are often shared with Venetie, sometimes in exchange for resources, such as salmon, which are less 

available in Arctic Village (Kofinas et al. 2016). The importance of caribou in Venetie sharing networks is 

evidenced by the 22,445 pounds of caribou that flowed between households (nearly half of all subsistence 

food flows). 

An analysis of resource importance, based on harvest (percentage of total harvest), harvest effort 

(percentage of households attempting harvests), and sharing (percentage of households receiving), is 

provided in Table M-19 in Appendix M. Based on this analysis, resources of major importance in 

Venetie are Arctic grayling, caribou, chinook salmon, chum salmon, and moose. 

Subsistence Uses of the PCH and CAH 

Harvest and sharing patterns of 22 Alaskan communities and seven Canadian user groups are relevant if 

post-lease oil and gas activities changes caribou resource availability or abundance for those users. Map 

3-27 in Appendix A shows the location of the 22 caribou study communities and communities 

associated with the seven Canadian user groups. Table M-20 in Appendix M provides caribou use and 

harvest data for all of the 22 Alaskan caribou study communities, along with data averages for each study 

community across all available study years. The 22 Alaskan communities have documented customary and 

traditional uses for caribou in GMU subunits that are in the ranges of the CAH and PCH. Table M-21 in 

Appendix M provides caribou harvest data for the following seven Canadian user groups of the PCH: 

Inuvialuit (Aklavik, Inuvik, and Tuktoyaktuk), Northwest Territory (NWT) Gwich'in people (Aklavik, 

Inuvik, Fort McPherson [Tetlit Zheh], and Tsiigehtchic), Vuntut Gwich'in people (Old Crow), Tr'ondek 

Hwech'in (Dawson City), Nacho Nyak Dun (Mayo), and other residents living in the Yukon Territory and 

the NWT. 

With few exceptions, use of caribou among the 22 Alaskan study communities is high; over 50 percent of 

households in Bettles, Eagle, Evansville, Allakaket, Venetie, Coldfoot, Wiseman, Alatna, Utqiaġvik. 

Anaktuvuk Pass, Point Lay, Kaktovik, Atqasuk, Nuiqsut, and Wainwright use caribou. Less than 5 percent 

of households in Stevens Village, Beaver, and Chalkyitsik have reported using caribou during years when 

data are available. The contribution of caribou toward the total subsistence harvest is highest in the 

communities of Anaktuvuk Pass (84 percent) and Coldfoot (85.3 percent) and lowest in the communities 

of Fort Yukon (2.5 percent) and Evansville (4.9 percent). Four communities reported zero harvests of 

caribou during available study years: Birch Creek, Stevens Village, Beaver, and Chalkyitsik. Caribou sharing 

ranges widely, with 0 percent receiving caribou in Beaver and Chalkyitsik during reported study years; 

between 8 and 28 percent of households receiving caribou in Stevens Village, Wiseman, Birch Creek, and 

Fort Yukon; and at least 30 percent of households receiving caribou in the remaining study communities. 

According to recent data on PCH harvests by Canadian user groups (Table M-21 in Appendix M), the 

NWT Gwich'in people, the Vuntut Gwich'in people, and the Invialuit are the primary users of the PCH in 

terms of number of caribou harvested. These data primarily represent a minimum count of actual harvest 

(whereas the data for Alaska communities are estimated for the community as a whole). Furthermore, 

variability in herd distribution affects the harvest, and harvests in the 2010s have not been as high as they 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources) 

3-168 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement 

were in the 2000s due to migratory variability.36 The most recent data that compare PCH harvests 

between the US and Canada from 1992 to 1994 (the last time that harvest data were compiled for PCH 

user groups in Alaska and Canada) indicate that Canadian users accounted for 85 percent of the harvest, 

and Alaska users were 15 percent of the harvest (Figure 3-7, Average Portion of Harvest of Porcupine 

Caribou Herd Between the US and Canada (1992-1994), in Appendix A). The NWT Gwich'in people 

accounted for 45 percent of all PCH harvests, followed by Inuvialuit (20 percent), Yukon Territory First 

Nations (13 percent), Alaska Native (12 percent), and the remaining 10 percent split among Yukon 

Territory and Alaska residents/non-residents (Figure 3-7 in Appendix A); thus, most of the PCH 

harvest occurs in Canada. 

Climate Change 

The changing climate within the program area could affect the availability of subsistence resources and user 

access to harvesting areas. Changes in the predictability of weather conditions, such as the timing of 

freeze-up and breakup, snowfall, storms and winds, and ice conditions, can prevent individuals from 

traveling to subsistence use areas. This would be the case when resources are present in those areas or 

when there are greater risks to safety when travel conditions are not ideal. Additionally, changes in 

resource abundance resulting from climate change could contribute to changes in resource availability 

caused by development in and around the program area, thus further reducing their availability to 

subsistence users. 

Direct and Indirect Impacts 

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

subsistence uses and resources from on-the-ground post-lease activities. 

Included in the discussion below are potential impacts on user access (resulting from legal or physical 

barriers), resource availability (resulting from resource migration, distribution, or health), and resource 

abundance (resulting from overall population changes), which, following BLM Alaska guidance (Instruction 

Memorandum No. AK-2011-008), are the three impact categories that must be addressed to inform the 

ANILCA Section 810 preliminary evaluation (see Appendix E). Common types of direct and indirect 

effects associated with oil and gas development in the program area include changes in subsistence use 

areas, harvest success, harvest amounts, participation, costs and time, competition, culture, and access 

(both physical and legal barriers and user avoidance). The hypothetical development scenario is used to 

inform the analysis of impacts for each alternative, but future analyses would occur with site-specific 

proposals. The effects of climate change described under Affected Environment above, could influence the 

rate or degree of the potential direct and indirect impacts. 

 

36Suitor, Mike. Personal communication. Email from Mike Suitor, Regional Biologist, Environment Yukon to Paul 

Lawrence, SRB&A on September 27, 2018 regarding Porcupine Caribou Herd harvests in Canada. 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources) 

Coastal Plain Oil and Gas Leasing Program 3-169 

Draft Environmental Impact Statement 

Alternative A 

Under Alternative A, no oil and gas leasing would take place in the program area, so subsistence uses 

among the Iñupiaq and Gwich'in peoples would be unaffected by oil and gas development in the Coastal 

Plain. Existing impacts on subsistence would continue, including oil and gas development to the west of the 

program area, increased vessel traffic in the Beaufort Sea, infrastructure and transportation projects, 

environmental and biological changes affecting subsistence resources, changes in land status, and hunting 

and fishing regulations. 

Impacts Common to All Action Alternatives 

This section discusses potential impacts on the subsistence uses and resources from post-lease activities 

that are common to all alternatives. The primary factors which may result in impacts on subsistence 

resources and uses include: 1) noise, traffic, and human activity, 2) infrastructure (including physical 

barriers), 3) contamination, 4) legal or regulatory barriers, and 5) increased employment or 

income/revenue. These factors could affect resource availability, resource abundance, and user access for 

residents of the study communities. Short-term, or lasting less than 5 years, does not necessarily reflect 

the level of impact on subsistence uses; an impact lasting 4 years, for example, could have a large effect on 

subsistence uses. 

In all cases, future development would affect subsistence uses of resources of major importance for the 

subsistence study communities (see Tables M-6, M-11, and M-19 in Appendix M). As described in 

Affected Environment above, Kaktovik is the primary user of the program area and would therefore be most 

likely to experience direct impacts associated with development. Nuiqsut could experience potential direct 

and indirect impacts on harvesting marine mammals, such as bowhead whale, and indirect impacts 

associated with the harvests of caribou, waterfowl, and fish. Arctic Village, Venetie, and other communities 

that use the PCH and CAH herds, have the potential to experience indirect impacts associated with 

caribou and, to a lesser extent, waterfowl. 

In the case of the 22 Alaskan caribou study communities and seven Canadian user groups (Table M-20

and M-21 in Appendix M), those with a greater reliance on caribou would be more likely to experience 

potential indirect impacts related to caribou abundance or availability. Alaskan communities with the 

greatest reliance, that is those where caribou accounts for greater than 10 percent of the annual 

subsistence harvest, on average, and over 50 percent of households use the resource, are Alatna, 

Anaktuvuk Pass, Utqiaġvik, Bettles, Coldfoot, Eagle, Kaktovik, Nuiqsut, Point Lay, Venetie, Wainwright, and 

Wiseman. In Allakaket, Atqasuk, and Evansville, caribou accounts for less than 10 percent (or data are not 

available), but over 50 percent of households use caribou (Table M-20 in Appendix M). In addition, as 

noted under Subsistence Uses of the CAH and PCH, above, approximately 85 percent of the PCH harvest 

occurs in Canada; the NWT Gwich'in people, Vuntut Gwich'in people, and Inuvialuit are the primary 

Canadian users in terms of number harvested (Figure 3-7 in Appendix A). 

Potential impacts, particularly those relating to changes in calving distribution and calf survival, are 

expected to be more intense for the PCH because of their lack of previous exposure to oil field 

development (see Section 3.3.4). Among Alaskan communities, Kaktovik, Venetie, and Eagle are in GMU 

subunits overlapping the PCH herd and have a high reliance on caribou; however, a portion of Eagle 

harvests likely come from the Fortymile Caribou Herd; therefore, caribou study communities most likely 

to experience impacts from the leasing program include the communities of Kaktovik and Venetie (ADFG 

2018b). In addition, Arctic Village, although lacking harvest data, would also be most likely to experience 

impacts due to their proximity and reported reliance on the PCH. Compared with these three Alaskan 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources) 

3-170 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement 

communities, uses of PCH caribou (in terms of number harvested) by the NWT Gwich'in people, Vuntut 

Gwich'in people, and Inuvialuit user groups are comparable or higher, and communities associated with 

these user groups—Old Crow, Aklavik, and Fort McPherson—are in the PCH range (Map 3-27 in 

Appendix A); thus, these Canadian communities would be among the most likely to experience potential 

indirect impacts due to their proximity to and reliance on the PCH. 

Noise, Traffic, and Human Activity 

Noise, traffic, and human activity associated with post-leasing oil and gas activities would result from 

construction, gravel mining, air, vessel, and ground traffic, seismic activity, drilling, and human presence. 

Noise, traffic (both ground and air), and human activity can cause both direct and indirect impacts on 

subsistence users. Impacts related to noise and traffic have been a primary concern reported by 

subsistence harvesters on the North Slope and elsewhere. Noise and traffic associated with the leasing 

program could potentially affect the availability of resources, such as caribou, marine mammals, furbearers, 

and small land mammals, fish, and migratory birds. While most impacts related to noise and traffic would 

be local, occurring in areas where Kaktovik subsistence use areas overlap with action areas, certain 

impacts, particularly those related to caribou migration, could extend outside the program area and would 

be regional. 

According to traditional knowledge of North Slope Iñupiat, furbearers, caribou, and marine mammals are 

particularly sensitive to noise and human activity (SRB&A 2017, 2009a). Potential impacts on caribou 

availability include displacement of caribou from areas of heavy oil and gas activity, diversion of caribou 

from their usual migratory routes, and skittish behavior, which results in reduced harvest opportunities 

(SRB&A 2017). 

Air traffic—particularly helicopter traffic—has been the most commonly reported impact on caribou 

hunting by Nuiqsut harvesters since the Nuiqsut Caribou Subsistence Monitoring Project began in 2009. 

Residents note that air traffic can cause skittish behavior in caribou, either causing them to stay inland from 

riversides or diverting them from their usual migration and crossing routes (see Section 3.3.4); such 

potential impacts could occur for Kaktovik harvesters as they travel along the coast by boat or inland by 

snowmachine looking for caribou. Ground traffic has also been observed diverting or delaying caribou 

movement across roads, and biological research have shown caribou, especially cows with calves, avoiding 

roads and other areas of human activity (see Section 3.3.4). 

These responses may be more likely for PCH caribou, as they have had less exposure to development 

than the CAH. If development causes large-scale displacement from PCH calving grounds, then the herd 

could experience a decline in calf survival and stagnant herd growth. In addition to large land mammals, 

furbearers, such as wolf and wolverine, may avoid areas of heavy traffic, drilling noise, seismic testing, and 

other activity. ROPs 36, 37, and 39, associated with subsistence consultation for permitted activities, 

would require consultation with potentially affected communities regarding the timing, siting, and methods 

of development, including seismic activities. ROP 34 places restrictions on the timing, location, and altitude 

of aircraft, in addition to requiring consultation with subsistence users, which would help reduce air trafficrelated impacts. 

Impacts on marine mammals from noise and traffic have also been reported by whaling crews and marine 

mammal hunters in Kaktovik and Nuiqsut (SRB&A 2009a); biological science also shows that marine 

mammals are sensitive to such disturbance. As noted in the Affected Environment discussion, Kaktovik 

whaling crews hunt offshore from the program area, and Nuiqsut whaling crews hunt to the west of the 

program area from Cross Island, sometimes hunting in areas offshore from the program area. 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources) 

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Whaling crews have reported skittish behavior in bowhead whales and other marine mammals during 

times of heavy air and vessel traffic and seismic exploration. Such activity can divert bowhead whales 

farther from shore or cause unpredictable behaviors, resulting in greater risks to hunter safety (SRB&A 

2009a; Galginaitis 2014). If CAAs between industry and the Alaska Eskimo Whaling Commission continue 

in relation to the proposed oil and gas leasing program, then impacts on whaling from the leasing program 

are unlikely; however, not all vessel traffic, such as that from barging not associated with oil and gas 

development, is subject to CAAs, so impacts from shipping and other activity could occur even with a 

CAA in place. CAAs are generally considered an effective measure by whaling crews, industry, and 

agencies (SRB&A 2013). ROP 46 provides a number of restrictions to marine vessel traffic and associated 

activities when in the vicinity of whales, walruses, polar bears, and seals in addition to restrictions near 

important habitat areas. It also would help reduce potential conflicts with subsistence users, resources, and 

offshore activities. Because seismic exploration would be limited to the winter, impacts on marine mammal 

harvesting from seismic testing would be unlikely. 

Noise and traffic associated with future oil and gas development would also potentially disturb subsistence 

resources, such as birds and fish, and could cause temporary reductions in harvesting success for Kaktovik 

harvesters; however, most displacement would be temporary and would not change the overall population 

levels (Section 3.3.2 and Section 3.3.3). Potential impacts of noise on fish would be relatively limited, as 

most impact sources, such as seismic activity and pile driving, would occur during the winter. Disturbances 

to birds and fish have been reported by Nuiqsut harvesters as a result of the Alpine Satellite Development 

Plan and other developments; however, such disturbances have not resulted in overall reductions in 

harvests of these resources over time (SRB&A 2009a) (see Section M.2 in Appendix M). ROPs 14 and 

16 would address some disturbances to fish habitat from seismic activity and exploratory drilling. 

The above impacts on resource availability may be considered localized from a biological standpoint; 

however, small localized changes can have larger impacts on subsistence harvesters when resources are 

not present in traditional hunting areas at the expected times and in adequate abundance. Residents may 

experience reduced harvest success, increased costs and time, and increased safety risks if resources are 

less available. 

While potential impacts on resource availability related to noise and traffic are most likely to be local in 

extent, such as for Kaktovik or Nuiqsut residents who use the program area, more widespread changes in 

migration or abundance resulting from noise and traffic and infrastructure (see discussion below) could 

cause regional impacts extending outside the program area to other communities, such as the Gwich'in 

peoples communities of Arctic Village and Venetie and the Gwich'in and Inuvialuit user groups in Canada. 

Residents of these communities harvest from the PCH and CAH (see Table M-20 in Appendix M). In 

addition, reduced harvests by Kaktovik residents could disrupt existing sharing networks to other 

communities and regions if residents are unable to share as widely or frequently as they are accustomed 

to. 

In addition to affecting resource availability, future noise, traffic, and human activity may also affect user 

access by deterring subsistence users from their usual harvesting areas. Avoidance of subsistence use areas 

due to development has been documented in Nuiqsut (SRB&A 2017) and would likely occur for some 

Kaktovik harvesters if development occurs in their harvesting area. Residents may experience discomfort 

hunting in the presence of outsiders; may avoid hunting near areas of high air or ground traffic because of a 

perceived or actual reduction in the availability of subsistence resources; may avoid hunting near human 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources) 

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activity due to safety concerns; or may consider noise pollution and increased human activity to degrade 

the subsistence experience. 

Infrastructure 

Infrastructure associated with the leasing program could include future gravel and ice roads, pipelines, 

gravel pads, bridges, gravel mines, and runways. While most potential impacts related to infrastructure 

would be site-specific or local, occurring in and around action areas, certain impacts—particularly those 

related to caribou migration and abundance—could extend outside the program area and would be 

regional. 

Infrastructure could cause loss of subsistence use areas due to direct overlap (Map 3-45, Kaktovik 

Subsistence Use Areas and Areas of Hydrocarbon Potential, in Appendix A). Much of the coastline in the 

area of high HCP shows high overlapping use by the community of Kaktovik for subsistence purposes, 

particularly for caribou, fish, and waterfowl (Map 3-29, Map 3-33, Kaktovik Fish Subsistence Use Areas in 

Coastal Plain, and Map 3-34, Kaktovik Bird Subsistence Use Areas in Coastal Plain, in Appendix A). 

While actual infrastructure would be limited to a smaller proportion of the overall development area, 

areas excluded from subsistence use would likely be greater than the actual footprint, either due to 

avoidance or security and firearm restrictions. Up to 50 percent of harvesters may avoid development 

activities or infrastructure at one time or another over the period of development (SRB&A 2017). If future 

development extends into areas of medium and low potential for oil and gas development, as is expected, 

associated infrastructure could extend throughout areas of high overlapping use for the community of 

Kaktovik and could present a barrier (either perceived or actual) between the community and more highly 

used inland hunting areas for caribou, wolf/wolverine, moose, Dall sheep, and fish (Map 3-29 through 

Map 3-33 in Appendix A). 

Infrastructure would pose physical obstructions to subsistence users if roads and pipelines are not 

designed to account for overland hunter travel, or if bridges and causeways obstruct travel along rivers or 

coastlines. Some residents in Nuiqsut have reported difficulty safely crossing certain gravel roads with 

snowmachines or four-wheel vehicles due to the steep side slopes (SRB&A 2017). 

Kaktovik hunters frequently travel by boat to the west and east of the community, searching for caribou as 

they congregate along the coast during the insect relief season. Pipelines in coastal areas could cause 

physical obstructions for these individuals; residents may be unable to shoot inland or may have to expend 

extra effort accessing suitable use areas if pipelines are situated too close to the coast. As noted in USACE 

2012, such impacts would be particularly likely if pipelines are within 1 or 2 miles of the coast. Increased 

use of roads or changes in travel routes due to the presence of infrastructure could increase the likelihood 

of injuries and accidents for Kaktovik harvesters (see Section 3.4.11, Public Health). ROPs 18, 20, 21 and 

23 would minimize potential direct obstructions to subsistence uses from infrastructure; however, impacts 

on access may still occur due to some harvesters avoiding industry. 

If Kaktovik residents have easy access to roads associated with the oil and gas leasing program, it is likely 

that some would use the roads to access subsistence harvesting areas, when overland snowmachine travel 

is difficult and for residents who do not have access to overland modes of travel, such as snowmachines 

and four-wheel vehicles. Use of these roads would be less likely or frequent if the roads are not connected 

to the community of Kaktovik or are connected only seasonally via ice roads. 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources) 

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Draft Environmental Impact Statement 

The use of future program roads for subsistence activities can introduce effects on subsistence users; 

examples are facilitating access to areas at times when access is difficult, providing access for community 

residents who do not own snowmachines, four-wheelers, or boats, and allowing residents to access 

resources when they are unavailable closer to the community. Impacts include increased competition 

between community residents along newly introduced hunting corridors and the deflection of caribou 

from areas closer to the community because of traffic and hunting along the road (SRB&A 2017). If roads, 

such as the Dalton Highway, connect to the road system and facilitate access by non-local hunters, then 

residents could experience increased competition from outsiders hunting in traditional subsistence use 

areas. ROP 38 would prohibit hunting and trapping by lessees, operators, and contractors when persons 

are on work status; however, this would not apply once workers’ shifts end and they return to a public 

airport or community, such as Kaktovik or Deadhorse. 

Similar to noise, traffic, and human activity, infrastructure could also affect the availability of certain 

resources through changes in resource abundance, migration/distribution, and behavior. Infrastructure 

would be most likely to affect migratory terrestrial resources, particularly caribou, but could also affect 

furbearers, waterfowl, and fish. Infrastructure could divert or impede caribou movement, displace 

waterfowl from nesting and other habitat, and displace fish from nearshore or riverine habitats, at least 

temporarily. 

Studies on the North Slope show that caribou distribution, especially cows with calves, changes around 

transportation corridors, and that a percentage of caribou (approximately 30 percent) are influenced in 

their movement by the presence of roads (NRC 2003; Wilson et al. 2016). Future development in the 

areas of high, medium, and low oil and gas potential could present obstacles to caribou migrating from 

inland areas to the coast, where many Kaktovik residents hunt them. While infrastructure is not expected 

to divert caribou migration altogether, linear features occurring perpendicular to migratory routes could 

slow caribou movement through the area, resulting in changes in the herd/group sizes and timing of their 

availability along the coast (NRC 2003; Wilson et al. 2016) (see Section 3.3.4). Road avoidance is 

particularly likely during times of high human activity, including ground vehicle use. 

Future oil and gas infrastructure in the program area is expected to result in long-term loss and alteration 

of bird habitat; however, these changes are not expected to cause overall changes in bird populations 

(Section 3.3.3). Infrastructure could affect fish habitat by causing habitat loss, increased turbidity from 

dust and gravel spray, reduced fish passage, and reduced water quantity (Section 3.3.2). 

According to Section 3.3.4, future oil and gas infrastructure in the program area, particularly in the PCH 

calving grounds, could cause a shift in calving distribution during some years, which would likely reduce calf 

survival and halt herd growth. To the extent that calving grounds are disturbed by oil and gas 

development, PCH calf survival and herd numbers could be reduced. An overall reduction in the PCH 

could also affect harvest success among Iñupiaq, the Gwich'in people, and Inuvialuit caribou hunters. 

According to the Gwich'in people’s knowledge, any development in the program area would have

devastating effects on the population of the PCH and other resources, such as migratory birds, that have 

key habitat in the coastal plain. In addition, there are those among the Iñupiat who report similar 

knowledge regarding the effects of ACP development (BLM 2018c, 2018d, 2018e, 2018f). These 

concerns are based on Alaska Native observations of the sensitivity of resources to development and 

change, in addition to traditional knowledge that has been passed on through generations. 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources) 

3-174 Coastal Plain Oil and Gas Leasing Program 

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Contamination 

Real or perceived contamination, including contamination from oil spills and air pollution, could affect 

resource availability and user access. If an oil spill causes reduced abundance or reduced health of certain 

resources, then they could become less available to the subsistence users. 

Potential impacts on resources from oil spills would occur for marine and riverine resources such as fish, 

seals, and bowhead whales, in addition to bird and terrestrial resources that frequent riverine and marine 

areas. Small spills in the program area or air contamination (either real or perceived) could also cause 

subsistence users to avoid harvesting certain resources, particularly near development areas. This could 

have potential indirect effects on human health through reduced consumption of nutritional foods 

(Section 3.4.11). 

Potential impacts from contamination are most likely to occur for Kaktovik residents and would be local; 

however, in the event of a large-scale oil spill or other contamination event, subsistence users who harvest 

resources that use or pass through the development area—such as those from Nuiqsut, Arctic Village, and 

Venetie—may also experience reduced resource availability. This would be due to physical contamination 

or avoidance of resources from the perception that resources are contaminated; thus, impacts related to 

contamination would be of local to regional context. Monitoring air quality and contaminants in 

subsistence foods (ROPs 6 and 7) and comprehensive waste management plans (ROP 2) would help 

address subsistence user concerns related to contaminants and would help to identify potential human 

health issues. 

Legal or Regulatory Barriers 

Legal or regulatory barriers—including restrictions on access and firearm discharge near oil and gas 

facilities—would reduce user access and resource availability in traditional use areas. Hunters would likely 

be subject to certain restrictions regarding discharging firearms near pipelines, roads, and other facilities. 

Depending on the parameters of such restrictions, such as the distance at which a firearm can be 

discharged, subsistence users may potentially have difficulty hunting in certain areas, particularly where 

pipelines or roads parallel the coast. 

Miscommunication surrounding rules and restrictions around future oil and gas facilities, as has been 

documented in the case of Nuiqsut (SRB&A 2017), may dissuade residents from accessing development 

areas. Impacts related to legal or regulatory barriers are most likely to occur for Kaktovik and would be of 

local extent; however, whaling crews from Nuiqsut could experience impacts when hunting offshore of the 

program area. Lease Stipulation 11 would require consultation with the community of Kaktovik to develop 

a subsistence access plan. 

Employment and Revenue 

Increased employment and revenue related to future oil and gas development could have potential positive 

and negative impacts on subsistence uses in affected communities. Increased income from employment and 

corporation dividends would likely be put to use in supporting subsistence activities through the purchase 

of faster and more efficient equipment and technologies and through supporting super-harvester 

households37 in the community. Data on Kaktovik and Venetie show that community engagement in 

subsistence activities has remained strong, alongside significant social and economic changes over the past 

several decades, such as higher household incomes (Kofinas et al. 2016). 

 

37Households with an abundance of able-bodied labor who are able to become the centers of subsistence 

production and distribution for a community. 
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Despite the relative persistence of subsistence harvesting, data also show a relatively high percentage of 

households that report low food security (40 percent in Kaktovik and 34 percent in Venetie), which 

showed no correlation with household income or harvest levels. In terms of harvest and income levels, 

there is a great diversity among village households, from high income/high harvest to low income/low 

harvest. These households show different levels of social connections, such as sharing ties, depending on 

harvest and income levels; thus, certain households may be less able to adapt to changing conditions and 

may be more vulnerable than others (Kofinas et al. 2016). Social connections are an important mitigation 

in the absence of household assets, such as income and harvest equipment, through sharing and 

cooperation; disruption of social connections could thus increase vulnerability in communities. 

A potential increase in employment could cause a shift in subsistence roles in the community, as employed 

individuals may have less time to engage in subsistence activities (see Section 3.4.4). These potential 

impacts would be most likely to occur for Kaktovik (see Section 3.4.10, Economy), which is most likely 

among North Slope villages to see an increase in employment and income from the proposed oil and gas 

leasing program; however, increased income resulting from ASRC and village corporation dividends could 

extend throughout the North Slope and would therefore be of regional context. 

General Development and Culture 

Overall, future development in the program area could have lasting effects on cultural practices, values, 

and beliefs through its impacts on subsistence. The potential impacts of development could result in 

reduced harvests, changes in uses of traditional lands, and decreased community participation in 

subsistence harvesting, processing, sharing, and associated rituals and feasts. Because of this, communities 

could experience a loss of cultural and individual identity associated with subsistence, a loss of traditional 

knowledge about the land, damaged social and kinship ties, and effects on spirituality associated with 

degradation of the Alaska coastal plain. These are key concerns that were reported by the Iñupiaq and 

Gwich'in people during public scoping meetings associated with the oil and gas leasing program (BLM 

2018c, 2018d, 2018e, 2018f). 

The various impacts on subsistence from development can weaken social cohesion over time through 

reduced participation in subsistence activities, including hunting, processing, and sharing. See Section 

3.4.4 for a discussion of potential effects related to social cohesion. ROP 40 would require cultural 

training for oil and gas personnel on environmental, social, traditional, and cultural concerns. Proper 

education may reduce the potential for conflicts between subsistence users and visiting workers. 

Alternative B 

Under Alternative B, the types of potential impacts on subsistence uses and resources would be the same 

as those described under Impacts Common to All Action Alternatives, above. The duration of all types of 

impacts would be long term, although certain specific impacts, such as those from seismic activity and 

construction noise, would occur only during the exploration and construction phases of individual 

development plans. 

Potential direct impacts on resource availability, resource abundance, and user access from noise, traffic, 

and human activity, infrastructure, contamination, and legal or regulatory barriers would occur primarily 

for Kaktovik residents who use the program area. Potential indirect impacts on resource availability and 

resource abundance resulting from noise, traffic, and human activity, infrastructure, and contamination 

could extend outside the program area to other communities, such as Nuiqsut, Arctic Village, Venetie, and 

other Alaskan and Canadian communities that harvest from the PCH and CAH (Table M-20 in 
3. Affected Environment and Environmental Consequences (Subsistence Uses and Resources) 

3-176 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement 

Appendix M). Changes in user access related to an increase in employment rates or income, including 

decreased time to engage in subsistence activities and increased income with which to support subsistence 

activities, are most likely for the community of Kaktovik; however, these changes could extend to other 

communities on the North Slope. 

Because of its proximity to the program area and the high potential for development in areas of high 

overlapping use, the community of Kaktovik would experience the greatest intensity of potential effects 

associated with the proposed oil and gas leasing program. Impacts on subsistence resources and uses may 

also occur for other communities if oil and gas development in the program area results in changes to 

resource abundance or availability, particularly caribou, which is a resource of major importance to the 

communities of Kaktovik, Nuiqsut, Arctic Village, and Venetie (see Tables M-6, M-11, and M-19 in 

Appendix M). Under Alternative B, 721,200 acres of calving habitat would be available for leasing, which 

would result in the greatest potential impact on calf survival and overall herd numbers. In addition, 

Alternative B would include 0.5- to 1-mile setbacks, with no permanent oil and gas infrastructure, including 

roads and pipelines, allowed, for 10 major rivers. Many of these rivers, such as the Hulahula, Okpilak, and 

Jago, are key drainages used for subsistence activities. Alternative B may include roadless developments for 

some of the CPFs and construction of associated airstrips, which would likely result in higher levels of air 

traffic, compared with roaded developments. Some timing and other restrictions on oil and gas activity 

(see Lease Stipulation 7 and ROP 23 and 34) would be in place for calving and post-calving habitats of the 

PCH, which could reduce impacts on resource abundance and availability. Coastal waters, lagoons, and 

barrier islands would be subject to NSO, which would minimize potential impacts on coastal hunters. 

Alternative C 

The types of potential impacts under Alternative C would be the same as those described under 

Alternative B but of lower intensity. Under Alternative C, fewer acres overlapping PCH calving grounds 

would be available for lease, most (606,200) acres of PCH primary calving habitat would be subject to 

NSO, 985,500 acres of post-calving habitat would be subject to TLs restricting road traffic, and pads and 

CPFs would not be allowed within 1 mile of the coast, although essential pipelines and roads may still 

occur. Alternative C would include greater setbacks (2 miles) along the Canning, Hulahula, and Okpilak 

Rivers. In addition, Alternative C would impose greater TLs on human activity in the PCH post-calving 

habitat area than Alternative B. Demographics impacts on the PCH would be less likely than Alternative B; 

therefore, the intensity of potential subsistence impacts under Alternative C would be less than under 

Alternative B. 

Alternative D 

The types of potential impacts under Alternative D would be the same as those described under 

Alternative B; however, the intensity of subsistence impacts would be substantially less under Alternative 

D. Less than half of the calving ground acres offered for sale under Alternative B would be offered for sale 

under Alternative D, and more lands would be subject to NSO lease stipulations or not made available for 

lease. As a result, Alternative D would be the least likely to affect calf survival and overall herd numbers of 

all action alternatives. 

Alternative D also includes greater setbacks from key subsistence drainages, compared with Alternative B, 

including 4 miles for the Hulahula River and 3 miles for the Okpilak River, which would greatly reduce 

impacts on subsistence in those areas, particularly during the winter. Under Alternative D, no pads or 

CPFs would be allowed within 2 miles of the coast, reducing potential impacts on coastal subsistence 

hunters and fishers. Any development in coastal areas would be subject to NSO and various TLs and 
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consultation requirements (Lease Stipulation 4). In addition, reclamation of infrastructure would be on 

ongoing process for each development area, thus lessening the duration of impacts for individual 

developments related to infrastructure. 

Alternative D would require greater design features meant to address impacts on subsistence resources 

and users and greater consultation with tribal governments on design features, timing, development 

methods, and access. Alternative D2 would be somewhat less likely to affect subsistence uses and 

resources, when compared with Alternative D1, because of increased TLs in caribou summer habitat 

under Alternative D2 (Lease Stipulation 6). 

Cumulative Impacts 

Past and present actions that have affected subsistence uses and resources include oil and gas 

development, transportation and infrastructure projects, scientific research, recreation and tourism, 

government hunting and harvesting regulations, and improved technologies and modernization. Oil and gas 

development in the program area, in combination with past, present, and reasonably foreseeable activities, 

would lead to additional impacts on subsistence resources and uses, including impacts on user access, 

resource availability, and resource abundance. This would ultimately lead to reduced harvesting 

opportunities and reduced participation in subsistence activities. 

Increased infrastructure and activity in and around the program area and in offshore areas could contribute 

to a feeling of being boxed in by development, particularly for Kaktovik. Concerns to this effect have been 

reported as early as the 1980s, when some Kaktovik hunters indicated they no longer approach or cross 

the Canning River because of oil and gas activity to the west of it (Impact Assessment Inc. 1990a). The 

overall area available for subsistence use would likely shrink over time due to the increasing presence of 

infrastructure and human activity in traditional use areas. While Kaktovik hunters would adapt, to varying 

extents, to the changes occurring around them and may continue to harvest resources at adequate levels, 

their connection to certain traditional areas may decrease over time. 

Increased development around Nuiqsut, including development in the program area, could also contribute 

to existing concerns about being surrounded by development and losing connections to traditional 

harvesting areas (SRB&A 2017, 2009a). The shifting of subsistence use areas away from oil and gas 

development would likely continue and result in long-term changes in subsistence use patterns. In addition, 

the increased existence of road corridors in traditional use areas could shift how residents access 

subsistence harvesting areas, such as via roads, but could also affect resource availability, particularly for 

those who choose not to use roads. Such changes have been documented elsewhere in Alaska (SRB&A 

2007, 2009b). 

Future development of the program area would lead to further expansion of the developed area on the 

North Slope, increasing the area accessible by outsiders, including non-local hunters, who could increase 

competition for locals, and resulting in higher levels of oil and gas activity; examples are vessel, ground, and 

air traffic, seismic activity, gravel mining and blasting, and drilling. Other similar activities, including shipping 

activity not subject to CAAs and research-related air traffic, would also continue and be additive to oil and 

gas related disturbances. Harvesters may adapt to such changes by increasing the amount of effort and 

time spent on the land, investing in more efficient means of travel, and shifting to new subsistence areas in 

an effort to increase harvest success rates. Increased income, primarily expected to occur for Iñupiaq 

residents, could help offset some of these impacts by providing cash with which to purchase fuel, 

equipment, and supplies for subsistence pursuits. 
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Nuiqsut residents have shown adaptability to the changes around them and continue to harvest 

subsistence resources at rates similar to before; however, despite continued harvests, residents stress that 

the frequent disturbances to subsistence activities, loss of connection to traditional use areas resulting 

from oil and gas infrastructure, and increased time and effort spent by harvesters continue to affect their 

overall subsistence way of life (SRB&A 2017). If changes in resource availability occur on a larger scale, 

such as changes in migration or overall abundance of the PCH, then communities farther away, particularly 

those not experiencing increased economic activity and revenues from the increased development, such as 

Arctic Village, Venetie, and Canadian user groups, could experience greater net impacts on subsistence. As 

noted in Kofinas et al. (2016) a total loss of caribou harvests would represent a 31 percent decline in 

subsistence foods for Venetie and a 32 percent decline for Kaktovik. Such a scenario would cause a severe 

disruption in social ties and cohesion for the study communities. 

Cumulative impacts on subsistence could alter subsistence use areas, user access, and resource availability 

for Iñupiaq, Gwich'in people, and Inuvialuit subsistence users. Over time, changes in how residents access 

and use the land and reduced opportunities for participation in subsistence harvesting, processing, 

distribution, and celebrations resulting from decreased harvests, could have potential negative effects on 

culture by weakening social ties and knowledge of cultural traditions. 

Thus far, communities on the North Slope have adapted to the changes occurring around them and 

maintained a strong subsistence identity. The continued maintenance of subsistence traditions would 

depend on the continued availability of subsistence resources and the continued ability of subsistence users 

to access resources, particularly if there are changes in resource abundance, distribution, or migration. 

Alternatives that allow the greatest amount of land to be developed and which have fewer timing and 

other restrictions would provide the greatest potential contribution to cumulative effects on subsistence 

uses and resources. This is because they would have a greater effect on resource availability, resource 

abundance, and user access; thus, Alternative B would have the largest potential contribution to cumulative 

effects on subsistence uses and resources, while Alternative D2 would have the smallest potential 

contribution to cumulative effects on subsistence uses and resources. 

The effects of climate change described under Affected Environment above, could influence the rate or 

degree of the potential cumulative impacts. 

3.4.4 Sociocultural Systems 

Affected Environment 

This section describes the affected environment for sociocultural systems potentially affected by the leasing 

program. In particular, the program could affect sociocultural systems among the Iñupiaq and Gwich'in 

peoples who use the program area, who have cultural ties to the program area, who use resources that 

cross through the program area, or who could experience social or economic changes associated with the 

leasing program. 

This section provides a brief overview of sociocultural systems among the Iñupiat and Gwich'in peoples, 

including history, social/political organization, the mixed cash/subsistence economy, and belief systems. 

There is an emphasis on the communities closest to the program area: Kaktovik, Nuiqsut, Arctic Village, 

and Venetie. Additional associated information relevant to sociocultural systems is given in Sections 

3.4.2, 3.4.3, 3.4.10, Economy, and 3.4.11. 
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History 

Iñupiaq 

Prehistory and history associated with the program area is described in USFWS (2015a). Kaktovik and 

Nuiqsut are the two Iñupiaq communities closest to the program area. The Iñupiat are an Alaska Native 

people whose territory ranges throughout Northwest and Northern Alaska. Archaeological research 

indicates that humans have occupied northern Alaska for roughly 14,000 years (Kunz and Reanier 1996). 

The earliest people entering the North American Arctic were the bearers of the Paleoindian and 

Paleoarctic traditions. Over thousands of years different cultures came to occupy Arctic Alaska and 

various parts of the program area, subsisting on resources available to them and developing various tools 

for survival. The Thule people, whose culture emerged about 1,000 years ago, are the direct ancestors of 

the Iñupiat living on the North Slope today and are the forebearers of modern whaling technologies and 

culture. 

At the time of Euro-American contact, the North Slope was inhabited by two indigenous Iñupiaq 

populations, the Tagiugmiut and the Nunamiut. The Tagiugmiut (“people of the sea”) inhabited coastal 

areas of the ACP and the Nunamiut (“people of the land”) inhabited the Brooks Range and Arctic Foothills 

areas (Burch 1976). While these labels are useful in providing a general idea of the Iñupiaq inhabitants of 

the North Slope at the time of contact, the distinction between the Nunamiut and Tagiugmiut is not a 

definitive one, and more often Iñupiaq groups and territories were defined based on kinship ties and place 

in which they lived (Spencer 1984). 

Residents of Kaktovik and Nuiqsut primarily descend from the Tagiugmiut (Burch 1976). The Tagiugmiut 

settlement pattern was characterized by permanent villages along the coast with outlying minor permanent 

and temporary settlements (Spencer 1959). One reason for the Tagiugmiut villages’ permanence was due 

to the marine mammal resource base—particularly bowhead whales—on which community members 

subsisted. On the North Slope, there is evidence for coastal Iñupiaq settlements from Point Hope (Tikigaq) 

in the west to as far as Demarcation Point near Canada in the east. The Nuiqsut and Kaktovik areas were 

known as places where Iñupiat and Athabascan people gathered to trade and fish, maintaining connections 

between the inland areas and the coast for millennia (Maguire 1988; Brown 1979; Impact Assessment Inc. 

1990b). 

Initial contact between the Iñupiat of the North Slope and non-Iñupiaq people occurred in the early 

nineteenth century with the arrival of Euro-American explorers. The first major outside influence on 

Iñupiaq settlement patterns on the North Slope came with the introduction of commercial whaling in the 

second half of the nineteenth century. Not only were coastal Iñupiaq settlements and demographics 

affected, but commercial whaling also affected the inland inhabitants as well. Employment in the whaling 

industry as well as access to trade goods served to concentrate people along the coast, reducing interior 

populations. 

Following a decline in populations of caribou and marine mammals, caused in part by demand for these 

resources to support whalers during the commercial bowhead whaling period (SRB&A and ISER 1993), 

many Iñupiat had moved to Utqiaġvik (formerly Barrow) or Herschel Island (in Canada) where food and 

medical care were available. By the early to mid-1900s, many residents who had lived along the Arctic 

Coast had relocated to Utqiaġvik. 

Local mission schools and trading posts, established during the late 1800s and early 1900s, also had a 

profound effect on Iñupiaq settlement patterns through centralization of Iñupiat into permanent 
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communities. Compulsory education in local coastal settlements forced many of the interior people to 

abandon their more semi-nomadic lifestyle and relocate to coast communities. Trading posts also affected 

settlement patterns during the early 1900s. 

Kaktovik, which had been an important trading center for centuries, was permanently settled by EuroAmericans following the establishment of a trading post by Tom Gordon in 1923 (Wentworth 1979). The 

trading post was closed in 1942; however, Iñupiat were drawn back to Kaktovik for jobs when 

preparations for the DEW Line site at Barter Island began in the mid-1940s. 

In 1951, a Bureau of Indian Affairs school was built in the thrice-moved village, which—along with the draw 

for wage labor—led to permanent settlement and the establishment of the modern community of 

Kaktovik (Impact Assessment Inc. 1990a; Mikow 2010). In 1968, the largest oil discovery in North America 

was made by Arco at Prudhoe Bay, resulting in a rush to develop the physical and legal infrastructure of 

Alaska so that production could begin (Coates 1991). Oil development and production at Prudhoe Bay 

became the nucleus for expanding networks of oil and gas production wells at neighboring fields (Impact 

Assessment Inc. 1990b, a). In 1973, after the 1971 passage of the ANCSA, 27 families from Utqiaġvik 

permanently resettled in Nuiqsut to live in a more traditional manner (Brown 1979). Many of those who 

moved there had family connections to the area (Impact Assessment Inc. 1990b). The families selected the 

present location of Nuiqsut for its centrality to subsistence resources and ease of access to harvest 

locations inland, along the river and delta, and in the ocean (Brown 1979). 

Gwich'in People 

Prehistory and history associated with the program area is described in USFWS (2015a). The Gwich’in 

people are an Athabascan cultural group who traditionally occupied a massive territory that incorporated 

long sections of the Yukon, Porcupine, Peel, Chandalar, Itkillik, and Sagavanirktok Rivers and into presentday Canada to the Mackenzie Flats and River Delta (Burch 1998; Raboff 2001, 1999; Slobodin 1981). 

Archaeological data suggest a Paleoarctic human occupation in the Yukon River region, which includes the 

contemporary Gwich'in communities of Arctic Village and Venetie, beginning at least 12,000 years ago 

(Griffin and Chesmore 1988). Ancestral to the Gwich'in Athabascans, the Kavik culture occupied areas of 

the North Slope and Brooks Range as early as 600 years ago and as late as the early to mid-nineteenth 

century. 

In the north, interactions between the Gwich'in people or Koyukon and the Kukpigmiut Iñupiat of the 

Colville River were marked by territorial tensions and hostility, culminating in a series of violent incidents 

that forced the Athabascans south of the mountains (Raboff 2001). Continuing battles with the Iñupiat and 

other Athabascans in the 1840s pushed the Gwich'in people from the Koyukuk River east to Chandalar 

Lake and beyond. The Gwich'in people were among the most nomadic of the Athabascan groups in their 

settlement patterns and continued to travel north to trade with the Iñupiat at Barter Island into the 1920s 

(Jacobson and Wentworth 1982). Similar to the Nunamiut farther north, the Gwich'in people relied heavily 

on the harvest of large land mammals—particularly caribou, but also moose and Dall sheep—for their 

livelihood. 

Some of the first contact with the Gwich'in people by Europeans likely took place with the Hudson’s Bay 

Company trading post at Fort Yukon in 1847, some of the latest in terms of first contact in Alaska. It 

continued with little contact through the end of the nineteenth century (Hadleigh-West 1963). Still, the 

indirect contact that occurred with other groups trading with the Gwich'in people in the 1850s resulted in 

an epidemic that devastated their population, especially in the western extent of their territory near the 

Kanuti River. By 1870, most Gwich'in groups had moved into the Yukon Flats or east of Chandalar River. 
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This constitutes the known modern territorial range of the Gwich'in people today (Burch and Mishler 

1995). 

Continuous Euro-American presence in Gwich'in people territory came later than for some other 

indigenous groups in Alaska. As such, the traditional subsistence lifestyle, including a continued reliance on 

hunting and fishing as a primary source of food and as a primary basis for Gwich'in people’s belief systems, 

was substantially maintained until World War II (Caulfield 1983). 

A severe decline in caribou populations in the Yukon Flats area in the late 1930s and 1940s may have 

precipitated the need for the Gwich'in people to adapt to a more cash-based economy (Caulfield 1983). 

The US established several Native reservations in Alaska following the inclusion of Alaska in the Indian 

Reorganization Act of 1936. The Venetie Indian Reservation included the Gwich'in people of Arctic Village, 

Venetie, Christian Village, and Robert’s Fish Camp. It was during this period that the Gwich'in people made 

a final transition to permanent settlements (Inoue 2004). The early 1960s saw the creation of the Arctic 

Refuge, which included lands traditionally used by the Gwich'in people. 

Social and Political Organization 

Iñupiaq 

Iñupiaq social organization traditionally revolved around the family and extended kin, in addition to trading 

partnerships and friendships (Hall 1984). The social and political organization of Iñupiaq societies revolved 

around the family; however, one role in particular—the umialik—exerted the most political influence. In 

coastal communities, an umialik would be responsible for organizing hunts for marine mammals, such as 

whales, and also managed a crew that he enlisted during these hunts (Chance 1990; Burch 1980). 

Following Euro-American contact in the second half of the nineteenth century, the social and political 

organization of the Iñupiat changed. These changes were a result of various factors, including compulsory 

education. This led to the following (Chance 1990): 

 Centralization of people into permanent villages 

 Introduction of modern technologies, which altered residents’ methods for harvesting and 

processing subsistence foods 

 Introduction of a cash economy 

 Introduction of Christianity 

 Incorporation of the Iñupiat into new systems of laws and governing systems 

Alaska Natives began forming village councils, which were reorganized under the IRA. The ANCSA was 

passed in 1971 and resulted in the formation of regional and village corporations; the NSB formed in 1972. 

Despite the changes in social and political organization over time, the core of Iñupiaq social organization is 

similar on the North Slope today, in that it encompasses not only households and families, but also wider 

networks of kinship and friends and individual family groups that depend on the extended family for 

support. The sharing and exchange of subsistence resources strengthen these kinship ties. The Iñupiat 

continue to uphold certain traditional social roles, such as those of the whaling captains, whaling crew 

members, and whaling captains’ wives. Similar to the traditional role of the umialiks, today’s whaling 

captains play a key role in Iñupiaq society and political life. Six North Slope communities, including 

Kaktovik and Nuiqsut, are members of the Alaska Eskimo Whaling Commission and have local whaling 

captains’ associations.
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The program area is in the NSB, which has permit authority relevant to the leasing program. Other federal 

and state agencies, including the USFWS, which is the land manager for all nonnative land in the program 

area, also have permit authority related to the program (see Appendix D). Many residents of the eight 

permanent North Slope communities are members of the regional federally recognized Iñupiat Community 

of the Arctic Slope and are shareholders in the ASRC. 

The NSB and ASRC not only provide employment but also revenue and economic opportunities 

throughout the region. The NSB has taxing authority on all lands throughout the North Slope, while the 

ASRC and other village corporations generate revenue through leasing their lands and providing oilfield 

services. As oil and gas development has moved closer to Nuiqsut, the community’s Kuukpik Corporation 

has generated revenue, provided employment opportunities, and become a key player in advocating for 

environmentally and socially responsible development on the North Slope; thus, North Slope communities 

have shared in the financial gains associated with petroleum development since the 1970s. 

Community institutions in Kaktovik include the City of Kaktovik, the Native Village of Kaktovik (a federally 

recognized tribe), and the KIC. In addition, several subsistence-related organizations are in Nuiqsut, 

including the Kuukpik Subsistence Oversight Panel, Inc., which was established in 1996 in response to 

development of the Alpine oilfield. 

Gwich'in People 

The Gwich'in people are one of several Athabascan cultural groups in Alaska and Canada. Traditional social 

and political organization of the Gwich'in involved people who lived in small autonomous bands composed 

of closely related kinsmen. Kinship affiliations were extensive, reaching beyond the immediate group or 

band and providing people with a network of relationships from which to seek assistance in time of need. 

The Gwich'in people had a kinship system based on matrilineal38 clans organized into moieties39

(McKennan 1959; Guédon 1974; Haynes and Simeone 2007). Political organization was decentralized and 

informal, with most decisions affecting the group reached by consensus. In some cases, a leader attained a 

particular status that enabled him to attract a following (De Laguna and McClellan 1981; Clark 1981). 

Today, Gwich'in people continue to recognize certain highly respected individuals with the title of chief. 

Beginning in the mid- to late 1800s, the fur trade, mineral development, church, and government all 

worked to undermine traditional kinship patterns by emphasizing the individual over the group. Europeans 

and Americans also brought new social values, laws, and economic models that undermined and even 

banned the traditional practices that supported the existing social structure and hierarchy. The Episcopal 

Church, for example, attempted to stop the ceremonial potlatch,40 because missionaries believed it was 

wasteful (Dinero 2016, 2005; Simeone 1992). In doing so, the church failed to understand the importance 

of Gwich'in people’s reciprocity by sharing wealth and maintaining physical and social well-being. The 

church’s attempted ban threatened Gwich'in people’s social and political organization and their survival.

Despite the impacts of the Episcopal Church on social and political organization, the Gwich'in people in 

many ways embraced the religion and viewed it as a positive force in their lives, while maintaining a 

connection to traditional belief systems that emphasized a spiritual connection between the human and 

animal worlds (Dinero 2016). 

 

38Ancestral lineage traced through female relatives 

39Social organization divided into two parts 

40A ceremonial feast, where participants part with or destroy possessions, in a display of wealth or prestige. 
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Despite the various changes to social and political organization over time, much of the traditional Gwich'in 

people’s social and political structure remains intact. Subsistence remains central to their identity. The 

people of Arctic Village and Venetie are primarily descendants of the Neets'aii band of the Gwich'in and, 

along with other Gwich'in, identify as the “caribou people” in reference to their main source of food and 

cultural and spiritual identity (Kofinas 1998). They view their primary cultural tradition as living with the 

caribou, with an emphasis on the reciprocal nature of their relationship with this important resource. 

Many traditional roles and practices related to hunting, fishing, and gathering remain in place today, and 

residents still observe traditional rituals and feasts, including the potlatch. Similar to the Iñupiat, sharing is 

central to maintaining social and kinship ties among the Gwich'in people. Modern Gwich'in leadership also 

mirrors traditional leadership models, with village councils providing both moral and legal guidance to tribal 

members (Dinero 2005). 

After passage of ANCSA, residents of the formerly established Venetie Indian Reservation, including those 

from Arctic Village and Venetie, elected a provision in ANCSA that allowed villages to forgo payments in 

exchange for free and simple title to former reservation land, in the case of Venetie and Arctic Village, 

approximately 1.8 million acres (Venetie Village Council 2013; Inoue 2004). An additional 3.4 million acres 

north and west of the original reservation were later added, based on earlier petitions. Venetie and Arctic 

Village thus established the Venetie Indian Reserve, which is managed jointly under the Native Village of 

Venetie Tribal Government. Unlike many Alaska Native communities, Arctic Village and Venetie are not 

enrolled in a regional Native corporation and do not have ANSCA village corporations. As such, those 

communities do not receive any increased economic activity associated with resource development or 

shares therein by ANCSA corporations. 

Since interest in developing the Arctic Refuge began in the 1980s, the Gwich'in people—particularly the 

Gwich'in of Arctic Village and Venetie—have taken various legal and political actions to prevent such 

development. Based primarily on concerns about impacts on caribou who calve in the Coastal Plain and 

subsequent impacts on Gwich'in cultural survival, their opposition has led to many residents advocating for 

caribou and the Gwich'in way of life. Many of their people wish to protect their traditional lifestyle 

centered on the PCH. 

In 1988, the first of many Gwich'in gatherings was held in Arctic Village to discuss the potential for 

development in the Arctic Refuge. Out of this meeting the Gwich'in Steering Committee was established, 

whose stated goal was to “establish Gwich'in cultural survival as a major issue in the debate over oil 

development in the Arctic Refuge” (Inoue 2004). Meeting attendees included over 500 Gwich'in people 

from both Alaska and Canada. 

Community institutions in Arctic Village include the Arctic Village Council; community institutions in 

Venetie include the Venetie Village Council. Both Arctic Village and Venetie are members of the Native 

Village of Venetie Tribal Government, the Council of Athabascan Tribal Governments, and the Tanana 

Chiefs Conference (ADCCED 2018c). Both communities are, among other Gwich'in communities, 

members of the Gwich'in Steering Committee. 

Mixed Cash/Subsistence Economy 

Iñupiaq 

The Iñupiat traditionally participated in an economy that relied on subsistence resources and used trade to 

acquire goods not readily available in their immediate area. The concept of wealth was based on the 

number or amount of accumulated foods and goods; those with the most material possessions were the 
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wealthiest. Among the Tagiugmiut Iñupiat, the umialik was often held by the wealthiest person, who 

needed to have a surplus of food and property to outfit a whaling crew. 

Both the Tagiugmiut and Nunamiut Iñupiat participated in extended trade networks that included both 

formalized and less formal modes of trading (Spencer 1959). Their trade was not limited to other Iñupiat, 

and they also traded with Athabascan peoples farther south, often through established trade fairs, such as 

those at Nigliq and on Barter Island. 

The economy of the North Slope underwent major changes beginning in the mid-nineteenth century. This 

is when commercial whaling introduced a new type of economy to the Iñupiat, followed by other 

economic developments, such as reindeer herding and fur trapping. The development of petroleum 

reserves began in the 1940s and is still the driving force of the economy on the North Slope. 

Today, the Iñupiat of the North Slope continue to rely on subsistence resources, while participating in the 

cash economy. Like other communities on the North Slope, Kaktovik and Nuiqsut have a mixed, 

subsistence-market economy (Walker and Wolfe 1987), where families invest money into small-scale, 

efficient technologies to harvest wild foods. Native corporation dividends rely heavily on oil and gas 

development, and many residents use their dividends as investments into their subsistence way of life. 

These investments can include gill nets, motorized skiffs, and snowmachines used to conduct subsistence 

activities. They are not oriented toward sales or profits but are focused on meeting the self-limiting needs 

of families and small communities. 

The trade networks that characterized the traditional subsistence economy of the Tagiugmiut and 

Nunamiut continue today, exchanging subsistence marine mammal products for terrestrial resource 

products. In fact, sharing subsistence foods with other communities and regions is a major component of 

the mixed economy, and it has been facilitated by advancements in rural transportation and technology. 

Gwich'in People 

Before Euro-American contact, the Gwich'in people were seminomadic hunters and gatherers who moved 

seasonally throughout the year in reasonably well-defined territories to harvest fish, wildlife, and a variety 

of plants. The pre-contact Gwich'in economy revolved around subsistence resources, and they traded to 

acquire goods not readily available in their immediate area. The subsistence economy was focused 

primarily on harvesting not only caribou but also fish, such as whitefish, and other resources. 

First contact between Europeans and the Neets’aii Gwich'in occurred somewhere between 1847, upon 

establishment of Hudson’s Bay Company at Fort Yukon, and the 1860s, with missionary efforts in the 

region (Dinero 2016). Up until the discovery of gold in the Gwich'in territories in the 1890s (1893 at Birch 

Creek), the subsistence economy was largely intact, and Native people remained independent and essential 

to the Euro-American fur trading economy (Mishler and Simeone 2004). The Gwich'in people increasingly 

participated in the cash economy, while maintaining a strong subsistence lifestyle. This increasing reliance 

on a mixed cash/subsistence economy, in combination with the establishment of schools and requirement 

that all children attend them, prompted a shift to a more stable village life, which opened the door for 

further changes to the traditional economy (Dinero 2016; Stern 2018). 

Beginning with the gold rush and especially by the start of World War II, the Gwich'in people were 

presented with alternative ways of living, which were not oriented toward a life wholly dependent on the 

land. A living based on hunting, fishing, and trapping became only one of several choices; subsistence 
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became a component of a “mixed, subsistence-market economy” (Walker and Wolfe 1987), rather than 

supplying the entire economy as it once did. 

The Gwich'in people of Arctic Village and Venetie have a deep relationship with the land they occupy and 

the resources they use. In contrast to the Iñupiaq villages farther north, there is little economic 

development in the Gwich'in area and few opportunities for local employment (Kofinas et al. 2016). In 

most cases, seasonal employment rather than full-time or permanent employment directly supports the 

subsistence activities of individuals. They, in turn, share the harvest with residents, as well as those who 

live in villages and regional centers, including Fairbanks and Anchorage (Caulfield 1983). The relative lack of 

cash to support subsistence activities would make these communities more vulnerable to changes in the 

availability of resources, such as caribou. This is because residents have less capacity to travel great 

distances in search of subsistence resources or to purchase alternative foods that are less desirable. 

Belief Systems 

Iñupiaq 

Traditional Iñupiaq belief systems consisted of two religious elements: hunting ritual and shamanism. These 

elements were similar to belief systems held by other Eskimo populations (Spencer 1984). Iñupiaq beliefs 

originally revolved around a system oriented to the environment and its animals. 

Following proper hunting rituals was necessary to ensure a successful harvest. These rituals included 

actions taken before the hunt to avoid offending the animals and rituals taken after an animal was taken. 

Examples of this are offering freshwater to sea mammals, giving gifts to trapped land animals, and cutting 

the throat or opening the brain pan to free the soul (Spencer 1984). The more important the resource 

was to the community, the more elaborate and extensive the rituals and ceremonies associated with it. 

One of the most important ceremonies on the coast was the whale feast (Nalukataq); its inland 

counterpart was the caribou festival (Spencer 1959). The messenger feast (Kivgiq), which has seen a revival 

on the North Slope in recent years, was an opportunity for Iñupiat from across the region to come 

together for trading and sharing. 

Shamanism was a second key component to Iñupiaq belief systems. Shamans played specific roles relating 

to illness, predicting weather, finding lost items, foretelling the future, and speaking to the dead (Spencer 

1984; Hall 1984). Despite the existence of shamans in traditional Iñupiaq society, the traditional belief 

system was largely fatalistic (Chance 1990); in other words, Iñupiat believed that powers beyond their 

control governed their environment. Their rituals and shamans, while having some influence, might prove 

ineffective despite their efforts. 

Belief systems among the Iñupiat of the North Slope were largely unchanged before 1890, even though the 

region had experienced several changes from the whaling industry and various exploratory expeditions. 

After 1890, a number of Christian missions were established in the region, and rapid changes to Iñupiaq 

belief systems began. 

The introduction of Christianity also introduced a rippling effect of changes that altered some Iñupiaq 

cultural values and traditions, particularly those surrounding housing, morality, subsistence, and social 

organization; however, despite these changes, the Iñupiat of the North Slope today retain a strong cultural 

identity associated with traditional subsistence hunting and harvesting patterns, and many traditional belief 

systems are strongly held and celebrated. Contemporary Iñupiaq values strongly mirror traditional ones, 

and include cooperation, hunting traditions, family and kinship, respect for nature, sharing, and spirituality 

(NSB 2018a). 
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Coastal North Slope communities, such as Kaktovik and Nuiqsut, maintain a strong maritime culture that 

centers on the bowhead whale hunt and emphasizes cooperation, participation in hunting traditions, and 

sharing. Whaling captains continue to have central roles as leaders in their communities and across the 

region. To the Iñupiat, protecting the land and water is essential to maintaining a culture that relies on the 

harvest of wild resources. This includes maintaining lands that are untouched by industry and where 

residents can conduct subsistence activities in relative solitude. 

For the program area and greater territory of the Kaktovikmiut (“people of Kaktovik”), this belief in the 

duty of the Iñupiat to protect their homeland and to serve as stewards of the land and sea is described in 

the City of Kaktovik’s document “In This Place” and is succinctly expressed in the opening general 

statement as follows: “We the Kaktovikmiut, the people of Kaktovik, are principally Iñupiat Eskimo, Native 

people of the Arctic Slope, the country that drains northward from the Brooks Range to the Arctic 

Ocean. We use and occupy this country, its associated waters, and the sea; and have claimed it since time 

immemorial by virtue both of aboriginal rights and our continued and undisplaced use and occupance [sic]” 

(City of Kaktovik and Karl E. Francis & Associates 1991, page 1) 

Gwich'in People 

The Gwich'in people have a spiritual relationship with their environment that is integral to their cultural 

system. Before the gradual incorporation of Christian beliefs and Western values into their existing 

traditional belief system beginning in the mid-nineteenth century, the Gwich'in people followed a loosely 

organized, animistic religion. It centered on a reciprocal relationship between humans and the rest of the 

natural world (Slobodin 1981; VanStone 1974). 

Gwich'in people’s belief systems had a holistic view of nature, in that no distinction existed between 

humans and animals, and everything in nature was considered sentient or to have a spiritual essence. Plants 

and animals were not objects governed by instinct but social beings with a spiritual potency controlled by 

powerful spirits or guardians. According to testimony by Johnny Frank of Arctic Village, traditional spiritual 

beliefs held that humans and animals were once the same, and they all shared the same language. Caribou 

held a particularly special relevance to Gwich'in spirituality and were believed to share a physical and 

spiritual connection with humans (Dinero 2016). According to Gwich'in elders, before humans and animals 

separated, they reached an agreement in which they acknowledged each other’s hardships and came to 

agreement regarding human-animal relations. As part of the agreement, humans were given some of the 

wisdom of the caribou, while the caribou were given the ability to run fast. Caribou were still allowed to 

retain some of the wisdom that was imparted to humans and, hence, humans and caribou share a special 

bond (Kofinas 1998). In fact, the Gwich'in people believe that a piece of caribou heart is in every human, 

and vice versa (Gwich'in Steering Committee 2004). The key cosmological figures among the Gwich'in 

people were Raven, the cultural hero Attachookaii, and the trickster Vasaagijik (Slobodin 1981). 

Christian missionaries of various denominations had considerable effect on the traditional Gwich'in 

people’s belief system and used an intense five-fold strategy of building, speaking, teaching, healing, and 

traveling to undercut traditional ways of life and to provide what were perceived as appropriate Christian 

alternatives (Fienup-Riordan 1992). Early in the twentieth century the Episcopal Church attempted to 

abolish the potlatch, but was rebuffed, and today the potlatch is stronger than ever and remains a 

significant part of Native identity. Others fused Christianity and traditional beliefs into a single belief system 

as some of the Dena'ina had done with the Russian Orthodoxy and the Iñupiat had done with the 

Anglicans and Presbyterians. Lastly, some individual Athabascans saw the presence of missionaries as a 
3. Affected Environment and Environmental Consequences (Sociocultural Systems) 

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good thing, saving individuals from alcoholism, while others saw a bias against Native people and their 

traditional ways (Reckord 1979). 

The proper relationship between humans and animals is a central tenet of the traditional belief system. 

Animals were not only a source of food but powerful spiritual beings that must be treated with respect. 

Animals and humans shared an essence of personhood; both were sentient and volitional. They acted on 

their own values and choices and shared a fundamental organization in that each had a soul, a language, a 

family, and similar emotional characteristics, including anger and a desire for vengeance. 

Animals and humans existed in a reciprocal relationship in which humans needed to kill animals to survive 

and animals desired to give themselves as food, but only on the condition that humans treated them with 

respect. The importance of reciprocity extends to humans as well—failure to share resources with others 

is not only frowned on socially but is considered a violation of a kind of social contract with game animals, 

threatening the success of future harvests (Caulfield 1983). 

The importance of reciprocity in human and animal relationships is evident in contemporary Gwich'in 

culture through their continued identification as the caribou people, their continued observance of certain 

customary laws, the continued practice of traditional rituals, such as the potlatch, and the strong belief in 

the sacredness of places like the Coastal Plain, due to its integral connection to caribou calving and 

migratory bird nesting grounds. 

Direct and Indirect Impacts 

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

sociocultural systems from on-the-ground post-lease activities. As described in the previous section, 

Iñupiaq and Gwich'in sociocultural systems are based on social and kinship ties, subsistence harvesting, and 

a deep connection to the land and its resources. Oil and gas development in the program area would likely 

affect sociocultural systems by introducing changes to traditional subsistence lands and resources, the 

social, health, and cultural environment, and local and regional economies. 

Alternative A 

Under Alternative A, no oil and gas leasing program would take place in the program area. Sociocultural 

systems among the Iñupiat and Gwich'in would remain unaffected by additional oil and gas development 

and the associated economic, biological, and social changes. Iñupiaq and Gwich'in sociocultural systems 

would likely continue to evolve as a result of existing forces of change, such as increased modernization 

and technology, development and associated activities (such as oil and gas development and research) 

outside the Coastal Plain, infrastructure and transportation projects, changes to land status, environmental 

changes, and increased outsiders in traditional use areas. 

Impacts Common to All Action Alternatives 

This section discusses potential impacts on sociocultural systems from post-lease activities that are 

common to all alternatives. The primary factors that may result in impacts on sociocultural systems 
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include: 1) changes in income and employment levels, 2) changes in available technologies, 3) disruptions to 

subsistence activities and uses, 4) influx of non-resident temporary workers associated with post-lease oil 

and gas activities, and 5) influx of outsiders coming into the subsistence study communities. 

Changes in Income and Employment Levels 

Increased income and employment levels—most likely to occur among the Iñupiat of the North Slope—

could affect sociocultural systems by changing the socioeconomic status of certain community members, 

reducing the time spent by certain individuals on harvesting subsistence resources and thus affecting social 

ties in the community, and increasing the amount of cash available to engage in subsistence activities and 

support subsistence-related equipment and infrastructure. An influx of cash into a small, rural community 

can have both positive and negative impacts on sociocultural systems. Traditional Iñupiaq and Gwich'in 

societies are based on social and kinship ties, which are established and strengthened through the 

procurement, processing, consumption, and sharing of subsistence resources (see Affected Environment 

above). 

Certain households or individuals play a particularly important role in the harvesting of subsistence 

resources and distribution of those resources to households and individuals who are unable to hunt or 

harvest for themselves. These super-harvester households have been identified through previous ADFG 

research, which found that 30 percent of households generally harvest 70 percent of the total community 

harvest (Wolfe 2004). An increase in employment opportunities may result in some of these households 

shifting from their role as super-harvesters to high-earning households, as they lack the time to engage in 

subsistence activities as frequently as they once did. This could result in weakening or shifting of certain 

social ties in the community. 

While this could cause short-term social stresses in a community, Kofinas et al. 2016 notes that the role of 

super-harvester households often changes over time and that communities are in fact quite resilient to 

these changes. In addition, the roles of super-harvester households and high-earning households are not 

mutually exclusive; in fact, Kofinas et al. (2016) found that super-harvester households also tend to have 

high income. 

In Kaktovik, 14.3 percent of all households were high-harvest high-income households; of all highharvesting households, 43 percent were high-income, compared with 24 percent of medium-harvest 

households and 30 percent of low-harvest households (Kofinas et al. 2016); thus, an increase in income 

and employment may increase opportunities for subsistence harvesting. That said, a sudden and substantial 

increase in employment and income may cause a more dramatic shift in the role of super-harvester 

households in the community, and it may take longer for the community to adjust to the changes. 

During the initial period of post-lease development, there may be a lack of super-harvester households as 

new roles are established. As a result, distribution of subsistence foods throughout the community could 

temporarily decline. If communities experience a dramatic change in the availability of such subsistence 

resources as caribou, there would likely be a tipping point where residents would no longer be able to 

adjust to such changes. The potential sociocultural impacts of such an occurrence would likely be negative 

and long term (Chapin et al. 2009). 

In addition to super-harvester households, high earning households also play an important role in the 

subsistence economy. This is because they often provide financial support to subsistence harvesters in the 

community as well as in their own households. As noted above, super-harvester households also tend to 

be high-earning households. An increase in employment and income resulting from the proposed oil and 
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gas leasing program could therefore have potential positive effects on social ties once community roles are 

established; however, increased income opportunities in a community can also cause greater potential 

income disparities between households, especially if certain households are not shareholders in the village 

or regional corporations. Such disparities can affect social relations and leadership roles in a community. In 

general, an increase in employment opportunities could strengthen residents’ resolve to remain in their 

home communities rather than moving in search of employment. Subsistence activities have been shown to 

persist despite increased income and wage employment, which demonstrates that the importance of 

subsistence is not limited to its nutritional benefits alone (Kruse 1991). 

Changes in income and employment associated with post-lease activities would have the most potential 

direct impact on the Iñupiaq community of Kaktovik and may also extend to other Iñupiaq communities, 

although direct participation in oil and gas activities by North Slope residents would be relatively limited 

(Section 3.4.10). Kaktovik is closest to the program area, and therefore, when compared with other 

North Slope communities, Kaktovik residents are most likely to obtain employment associated with 

development and support activities in the program area. Levels of local employment would depend largely 

on the implementation of adequate local hiring policies and opportunities for NSB-based businesses and 

corporations. In addition, residents of Kaktovik would likely see greater economic revenues associated 

with the oil and gas leasing program as shareholders of KIC. The City of Kaktovik may also receive bed tax 

revenues associated with increased visitors to the community; an increase in tax revenue could support 

sociocultural systems by contributing to community improvements (Section 3.4.10). 

On a regional scale, Iñupiat communities across the North Slope may see increased economic activity 

resulting from post-lease activities as shareholders of the ARSC and through NSB revenues, and they may 

also be exposed to a greater number of employment opportunities. By contrast, Gwich'in residents would 

likely see only modest economic activity and revenues associated with profit sharing from ASRC to their 

regional corporation (Doyon, Inc.). The Gwich'in communities closest to the program area—Arctic Village 

and Venetie—do not belong to Doyon and do not have village corporations holding land in the program 

area; therefore, they would see limited economic activity and revenues associated with the proposed oil 

and gas leasing program (See Section 3.4.10). The comparative lack of economic activity for the Gwich'in 

people, especially the communities of Arctic Village and Venetie, could make those communities more 

vulnerable to social impacts, particularly those associated with disruption of subsistence activities. Without 

the increased economic activity associated with development, communities are more vulnerable to its 

impacts and less able to adapt to environmental and social changes resulting from the development. 

Changes in Available Technologies 

Increased income and employment resulting from future oil and gas exploration, development, and 

production could also increase access to technologies, such as subsistence equipment and fuel. Access to 

such technologies could aid subsistence users in accessing subsistence harvesting areas, particularly if 

development results in subsistence users having to travel farther or spend longer to find and harvest 

subsistence resources. Communities close to oil and gas development areas may also eventually have 

greater access to high-speed Internet and strong cell phone reception. In recent years, greater use of and 

access to cell phones and social media has shifted how residents in and between communities 

communicate with one another. In some ways, it has expanded social ties by facilitating connections across 

regions of Alaska and encouraged the establishment of trading relationships. Greater access to 

transportation and shipping options can also have a positive impact on sharing networks and the ability to 

bring goods directly into the community. Such changes would be most likely to occur for Kaktovik because 

of its proximity to the program area. 
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Disruptions to Subsistence Activities and Uses 

Disruptions to subsistence activities associated with future oil and gas activities could potentially indirectly 

affect social cohesion. As noted above, increased income and employment levels could change social ties 

and organization by causing certain individuals and households to shift to new, nonsubsistence roles. In 

addition to the extent that development in the program area disrupts subsistence or reduces the 

availability of certain resources to subsistence harvesters, residents may either experience reduced 

harvests of subsistence foods, or they may spend greater time, effort, and expense in pursuit of subsistence 

resources (see Section 3.4.3). 

Potential impacts on subsistence resource availability would likely occur throughout the life of post-leasing 

activities within the Coastal plain. Nuiqsut residents have reported impacts on resource availability 

associated with nearby developments but continue to harvest resources at levels similar to before; 

however, continued harvests do not imply an absence of impacts. Residents report adapting to changes in 

resource availability by shifting to new hunting areas, spending more effort and time on the land, or 

changing hunting methods, such as hunting caribou along newly introduced road corridors. 

An inability to harvest adequate subsistence resources can have negative social consequences for a 

community. Decreased harvests of subsistence resources—particularly key resources, such as bowhead 

whales (for the Iñupiat) and caribou (for the Iñupiat and Gwich'in people)—results in decreased 

opportunities for participation in such activities as processing, consuming, and sharing subsistence foods 

and participating in culturally important feasts and festivals. These are all important in maintaining and 

strengthening social and cultural ties in the community. 

The inability of subsistence harvesters to provide for their community can also have negative social and 

health/nutritional consequences (Section 3.4.11). Residents have reported that during times of reduced 

harvest success, they have witnessed increased social problems, such as drug and alcohol use, particularly 

among younger subsistence hunters (SRB&A 2009a). Increased access to program-related roads, 

introduction of new infrastructure in traditional use areas, and associated changes in subsistence travel 

routes and harvesting patterns could increase the risk of injuries and accidents during subsistence activities, 

causing negative social effects (Section 3.4.11). 

Finally, decreased use of certain traditional areas, due to changes in resource availability, user access, or 

the degradation of one’s experience on the land resulting from noise and human activity, can result in 

fewer opportunities for residents to pass on traditional knowledge about those places, weakening the 

cultural associations residents have with the land. 

Potential impacts on subsistence would occur to varying extents for different communities. Direct impacts 

from future oil and gas exploration, development, and production on subsistence activities would likely be 

greatest for Kaktovik; however, potential indirect impacts on the availability of resources, such as caribou, 

could occur for Nuiqsut, Arctic Village, Venetie, and other communities that rely on the PCH and CAH 

(see Section 3.4.3). 

Influx of Non-Resident Temporary Workers and Outsiders 

Another potential source of potential impacts on sociocultural systems is an influx of non-resident 

temporary workers associated with future oil and gas activities into local communities and traditional use 

areas and a general influx of outsiders into local communities associated with increased development in the 

region. While interactions with non-locals has become increasingly common in rural Alaskan communities, 

most Iñupiaq and Gwich'in communities continue to be relatively remote and primarily Alaska Native. 
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Interactions with non-locals can sometimes cause discomfort for residents when non-locals do not respect 

or understand local traditional values and customs. Residents have expressed discomfort conducting 

subsistence activities when non-locals are around for fear that their traditions are misinterpreted, 

misunderstood, or exploited for political purposes. Such concerns have become particularly prevalent in 

today’s climate of social media posts, viral videos, and negative online backlash (Oliver 2017). 

Witnessing non-locals mistreating or disrespecting the land and its resources can also have negative 

cultural and spiritual impacts on locals, especially if the area holds particular importance to a community. In 

the case of the Coastal Plain, the area is in Kaktovik’s core subsistence harvesting area and is considered 

sacred ground to many Gwich'in people because of its importance to the health and survival of the PCH. 

The presence of temporary workers who are associated with future post-lease development in traditional 

hunting areas could result in negative interactions between subsistence users and workers due to a lack of 

cultural understanding and respect on the part of the workers, or miscommunication of policies and 

procedures surrounding use of the land by local residents for hunting purposes. If future oil and gas 

activities facilitate or promote access of outsiders into Kaktovik for reasons associated with development 

or otherwise, potential impacts could include increased social problems (e.g., outsiders bringing in drugs 

and alcohol), lack of infrastructure to accommodate the increase in visitors (e.g., lodging and 

transportation), and conflicts resulting from lack of knowledge or respect of traditional values. 

An increase in population associated with post-lease activities is not expected for Kaktovik; workers are 

expected to stay in work camps and return to other areas of Alaska or outside Alaska (Section 3.4.10); 

however, while an increase in permanent residency is not likely, it is possible that Kaktovik would 

experience an increase in visitors associated with oil and gas industry, as has happened in Nuiqsut. 

Alternative B 

Under Alternative B, the types of potential impacts on sociocultural systems associated with future 

exploration, development, and production activities would be the same as those described under Impacts 

Common to All Action Alternatives, above. The duration of impacts would be long term for all types of 

impacts, although certain types of impacts, such as interactions with temporary workers, may be more 

frequent or intense during the exploration and construction phases of development. Potential impacts 

related to an increase in visitors to and an influx of nonresident temporary workers associated with future 

development would occur in the general vicinity of the action area or in the community of Kaktovik. 

Increases in income and employment levels may extend beyond the program area to other communities 

on the North Slope and possibly outside the North Slope. Changes related to disruption of subsistence 

activities and uses could extend outside the North Slope region to other communities that rely on the 

PCH and CAH herds. 

Because of its proximity to the program area, the community of Kaktovik would experience the greatest 

intensity of effects associated with future oil and gas activities in the Coastal Plain. Potential impacts on 

sociocultural systems may also occur for other communities if future oil and gas exploration, development, 

and production in the program area results in changes to resource abundance or availability, particularly 

caribou, which is a resource of major importance to the closest communities of Kaktovik, Nuiqsut, Arctic 

Village, and Venetie. Because of the particular spiritual and cultural importance of the coastal plain and 

PCH calving grounds to the people of Arctic Village and Venetie, any disruption to that herd or perceived 

contamination or degradation of calving grounds in the program area would have sociocultural impacts on 

the Gwich'in people, in terms of their belief systems, cultural identity, and the impact of development in 

the sacred calving grounds of the PCH. 
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Alternative C 

The types of potential impacts under Alternative C would be the same as those described under 

Alternative B. Because fewer acres of calving grounds would be available for leasing, the intensity of 

potential sociocultural impacts related to caribou under Alternative C would be less than Alternative B. 

Alternative D 

The types of potential impacts under Alternative D would be the same as those described under 

Alternative B. Because fewer acres of caribou calving grounds would be available for leasing, and because 

more lands would be subject to development restrictions, the intensity of potential sociocultural impacts 

under Alternative D would be less than under Alternative B. In particular, Alternative D2 would be 

somewhat less likely to affect sociocultural systems, when compared with Alternative D1. This is because 

of the greater restrictions under Alternative D2 on development in caribou summer habitat. 

Cumulative Impacts 

Past, present, and reasonably foreseeable future activities, in combination with oil and gas development in 

the program area, would increase the potential for sociocultural impacts, including changes in income and 

employment levels, changes in available technologies, disruptions to subsistence activities and uses, and 

increased interactions with outsiders. Past and present actions that have affected sociocultural systems 

among the Iñupiat and Gwich'in people include oil and gas development, onshore and offshore 

transportation and infrastructure projects, scientific research, increased recreation and tourism, 

demographic changes, changes in land status, and modernization. The proposed oil and gas leasing 

program, in addition to future activities, could lead to additional oil and gas development and other 

development and infrastructure projects. This could contribute to changes in sociocultural systems by 

affecting access to and abundance of subsistence resources, as well as the safety of subsistence harvesters. 

Tensions between communities relating to differences in opportunities for increased economic activity, 

such as increased employment, and potential negative sociocultural impact, such as disruptions to 

subsistence levels, could strain social ties and reduce social cohesion. Income disparities or political 

differences in and between communities could also contribute to social tensions between residents and 

community institutions. Such changes could exacerbate political differences between Iñupiat and Gwich'in 

communities, potentially weakening social ties. If employment opportunities were to increase to the extent 

that fewer community residents have the time to engage in subsistence activities, then overall community 

harvests and participation could decrease, weakening the community’s identity and association with the 

subsistence lifestyle (see Section 3.4.3) and causing reduced social cohesion and increased social 

problems. 

Alternatively, increased income through employment or dividends could encourage residents to remain in 

their home communities and provide financial support for subsistence activities in communities, thus 

strengthening the mixed subsistence cash economy. 

Increased interactions with outsiders in traditional use areas and communities has the potential to affect 

traditional values and belief systems over time and may also result in increased social problems, if such 

interactions lead to greater access to drugs and alcohol. 

Cumulatively, strong local economies could have positive social impacts as long as communities are able to 

adapt to such changes, while maintaining cultural traditions and values, such as subsistence, humility, 

respect for elders, family and kinship, and avoidance of conflict. Communities that are most likely to 
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Draft Environmental Impact Statement 

experience potential sociocultural impacts would be those that experience impacts on subsistence, while 

not experiencing increases in income or employment levels, such as Arctic Village and Venetie. 

Alternatives that allow the most land to be developed in the program area and that have fewer timing and 

other restrictions are likely to have the greatest potential contribution to cumulative effects on 

sociocultural systems. This is because future post-lease activities would have a greater effect on 

subsistence uses and resources and the greatest likelihood of interactions with outsiders, while increasing 

regional or local economic activity; thus, Alternative B would have the largest contribution to cumulative 

effects on sociocultural systems, while Alternative D2 would have the smallest contribution to cumulative 

effects on sociocultural systems. 

3.4.5 Environmental Justice 

Affected Environment 

Environmental justice is defined in EO 12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations. It requires that proposed projects be evaluated for 

“disproportionately high and adverse human health or environmental effects of its programs, policies, and 

activities on minority populations and low-income populations.”

In 2016, the DOI released the updated Environmental Justice Strategic Plan that establishes goals, 

objectives, and detailed guidance for federal agencies to ensure that no racial, ethnic, cultural, or 

socioeconomic group disproportionately bears the negative environmental consequences of governmental 

programs, policies, or activities (DOI 2016). 

Guidelines for evaluating the potential environmental justice effects of projects require specific 

identification of minority populations, when either the minority population of the affected area exceeds 50 

percent, or the minority population percentage of the affected area is meaningfully greater than the 

minority population percentage in the general population or other appropriate unit of geographic analysis. 

These guidelines also stipulate that low-income populations in an affected area should be identified using 

annual statistical poverty thresholds (CEQ 1997). The State of Alaska socioeconomic characteristics were 

selected as the reasonable general reference population for both minority populations and low-income 

populations. 

Guidelines on environmental justice also suggest that where an agency action may affect fish, vegetation, or 

wildlife, it may also affect subsistence patterns of consumption and indicate the potential for 

disproportionately high and adverse human health or environmental effects on low-income populations, 

minority populations, and Indian/Alaska Native Tribes. 

It is relevant to identify differential patterns of consumption of natural resources among minority 

populations and low-income populations, where the term means differences in rates or patterns of fish, 

water, vegetation, or wildlife consumption among minority populations, low-income populations, or 

Indian/Alaska Native Tribes, compared with the general population (CEQ 1997). Subsistence patterns in 

the affected environment are covered in detail in Section 3.4.3; if subsequent analysis of the action 

alternatives finds high and adverse impacts on subsistence, these would be of environmental justice 

concern as well. 

Kaktovik is the closest community to be potentially affected by the leasing program. Based on their 

identified use of subsistence resources (see Section 3.4.3), the communities of Nuiqsut, Arctic Village, 

and Venetie are also relevant to the environmental justice analysis. 
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According to 2010 Census data, American Indian/Alaska Native residents of Kaktovik, Nuiqsut, Arctic 

Village, and Venetie—specifically Iñupiat in Kaktovik and Nuiqsut and Gwich'in in Arctic Village and 

Venetie—account for between 87.1 and 91.6 percent of the total population of each community. The total 

minority41 populations of these communities range from 90.0 to 98.2 percent of the total community 

population. The statewide population is 14.4 percent American Indian/Alaska Native and 35.9 percent 

minority overall. 

The minority composition of Kaktovik, Nuiqsut, Arctic Village, and Venetie, compared with Alaska, is 

shown in Table N-2 in Appendix N. Based on 2010 census data, the minority population in all four 

communities is well above the 50 percent threshold and meaningfully greater than the general reference 

population, as specified in the CEQ guidelines (US Census Bureau 2010). Based on minority population 

criteria, these communities should be considered for potential environmental justice issues when 

evaluating the effects of the action. 

Additionally, as shown in Table N-1 in Appendix N, while the proportion of low-income residents in 

Kaktovik and Nuiqsut is well below that seen in the general population of Alaska, the low-income 

population components of Arctic Village and Venetie are meaningfully greater, at about 4.6 and 5.3 times 

higher, respectively, with roughly half the residents in both communities living below the poverty level (US 

Census Bureau 2016). Finally, each of these four communities is predominantly Alaska Native, with 

associated tribal entities. As a result, each community meets more than one criterion for potential impacts 

of the action to be of environmental justice concern. 

As noted in Section 3.4.10, residents of the NSB would experience a range of direct or indirect 

economic impacts from the action, such as increased economic activity and revenues. As shown in Tables 

N-1 and N-2 (Appendix N), while the low-income proportion of the NSB’s overall population is roughly 

equivalent to that of Alaska, the minority proportion of the NSB’s population is meaningfully greater than 

that of the state. The result is that there is the potential for impacts from future projects to 

disproportionately accrue to a population that is otherwise of environmental justice concern. 

The CEQ guidance on environmental justice under NEPA (CEQ 1997) directs federal agencies to apply 

CEQ guidance with flexibility. It says to consider them as a point of departure, rather than conclusive 

direction in applying the terms of the EO 12898. Following this guidance, analyses of potential impacts 

should be highly sensitive to the history or circumstances of a given community or population. 

As noted in the Sociocultural Systems and Economy affected environment discussions (Section 3.4.4 and 

3.4.10, respectively), the different histories and circumstances of the relevant Iñupiat and Gwich'in people, 

such as outcomes under the ANCSA and the formation of the NSB, are likely to not only result in a 

differential distribution of potential impacts from the action but also to affect the vulnerability and 

resilience relative to potential adverse impacts. 

As noted in Section 3.4.4, social and cultural values related to subsistence resources and activities 

represent another key area for the exploration of environmental justice. For example, primary concerns of 

the Gwich'in people expressed during public scoping were the sacredness of the caribou calving and bird 

nesting grounds in the program area. This is in addition to more direct potential impacts on the reliability 

of the PCH and waterfowl annual migrations through Gwich'in territory. In other words, potential 

 

41For the purposes of environmental justice analysis, a minority population includes all persons other than those 

who self-identify in the census as both White and non-Hispanic or Latino. 
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Draft Environmental Impact Statement 

environmental justice impacts related to potential adverse impacts on subsistence resources extend well 

beyond the immediate program area, and they encompass the social and cultural value of subsistence 

resources (and their uses), as described in ANILCA, as well as the value of direct reliance on these 

resources for physical sustenance. 

Climate Change 

As noted in BLM (2018a) climate change can be understood as an environmental justice issue. The Iñupiaq 

of the North Slope are disproportionately affected by it, both by the fact that climate change effects are 

more pronounced in the western Arctic and by the fact that Iñupiaq subsistence activities are particularly 

dependent on ice, wind, and permafrost conditions. 

Climate change is changing the environment of the North Slope and affecting subsistence users’ ability to 

access subsistence resources at appropriate times (Brinkman et al. 2016). The reduction of sea ice has 

exacerbated coastal erosion, the weather has become less predictable, the shore ice in spring is less stable 

for whaling, fall travel for caribou is hampered by a late and unreliable freeze up, spring hunting for geese is 

hampered by an early breakup, and ice cellars provide less reliable food storage. All of these issues create 

significant concerns for many Iñupiat because they are factors that cannot be controlled and that are 

threatening their way of life. Similar concerns also apply to those who are not on the North Slope but 

nevertheless depend on its subsistence resources, such as the Gwich'in communities of Arctic Village and 

Venetie. 

Direct and Indirect Impacts 

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

environmental justice from on-the-ground post-lease activities. 

This analysis of impacts related to environmental justice considers if implementation of the proposed 

alternatives would result in disproportionately high and adverse environmental or human health effects on 

the communities of Kaktovik, Nuiqsut, Arctic Village, or Venetie. These communities meet the 

demographic characteristics to be qualified as minority populations (and the latter two as low-income 

populations) and require evaluation for disproportionate impacts under environmental justice. 

EO 12898 directs federal agencies, to the greatest extent practicable and permitted by law, to achieve 

environmental justice by identifying and addressing disproportionately high and adverse human health or 

environmental effects of proposed federal actions on minority and low-income populations. The NEPA 

analysis of environmental justice is also informed by CEQ guidance, as follows: 

Under NEPA, the identification of a disproportionately high and adverse human health or 

environmental effect on a low-income population, minority population, or Indian [or 

Alaska Native] tribe does not preclude a proposed agency action from going forward, nor 

does it necessarily compel a conclusion that a proposed action is environmentally 

unsatisfactory. Rather, the identification of such an effect should heighten agency attention 
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Draft Environmental Impact Statement 

to alternatives (including alternative sites), mitigation strategies, monitoring needs, and 

preferences expressed by the affected community or population (CEQ 1997). 

Federal agencies also are required to give affected communities opportunities to provide input into the 

environmental review process, including the identification of mitigation measures. The BLM has assured 

meaningful community representation in the process by holding public meetings in the communities of 

Kaktovik, Arctic Village, and Venetie, among others; coordinating directly with federally recognized tribal 

governments in compliance with EO 13175 and BLM’s Tribal Consultation policy, which has resulted in 

government-to-government meetings with relevant entities in Kaktovik, Arctic Village, and Venetie, among 

others, and ANCSA corporation consultation meetings with the KIC and the ASRC, among others; and 

having several tribal governments sign on for participation as cooperating agencies, including the Native 

Village of Kaktovik, Arctic Village Council, Venetie Village Council, and the Native Village of Venetie Tribal 

Government. 

Following CEQ (1997) guidance on evaluating environmental justice under NEPA, the analysis should 

recognize if the question of whether agency action raises environmental justice issues is highly sensitive to 

the history or circumstances of a particular community or population. The historical context in which 

environmental justice issues are considered is presented in the sociocultural systems analysis (Section 

3.4.4). The BLM recognizes the interrelated cultural, social, occupational, historical, or economic factors 

that are likely to amplify the natural and physical environmental effects of post-lease oil and gas activities. 

CEQ guidance also directs the BLM to consider any multiple or cumulative effects on human health and 

the environment, even if certain effects are not in the control or subject to the discretion of the agency 

(CEQ 1997); therefore, the BLM determined whether the potential environmental effects of post-lease oil 

and gas activities would be disproportionately high and adverse. It based this on whether there is or would 

be an impact on the natural environment that significantly and adversely affects Alaska Native residents of 

Kaktovik, Nuiqsut, Arctic Village, or Venetie. Such effects may include subsistence, sociocultural, economic, 

or public health and safety impacts on residents when those impacts are interrelated to impacts on the 

natural and physical environment. 

Potential impacts for these resources are discussed in Sections 3.4.3, 3.4.4, 3.4.10, and 3.4.11, and are 

not recapitulated in this section beyond brief summaries. This environmental justice analysis also considers 

that some Inupiaq entities and Iñupiat individuals, as shareholders in ANCSA corporations, would see 

increased economic activity and revenues from post-lease oil and gas activities. 

Alternative A 

No potential environmental justice impacts are evident in the analysis of Alternative A. Specifically, 

subsistence uses, sociocultural systems, and public health and safety among the Iñupiaq and Gwich'in 

peoples would be unaffected by oil and gas development in the program area. Iñupiaq and Gwich'in 

sociocultural systems would likely continue to evolve due to existing forces of change. The economic 

conditions and the local, regional, and state level are expected to continue along current trends. 

Impacts Common to All Action Alternatives 

For all action alternatives, potential environmental justice impacts would derive from disproportionately 

high and adverse human health or environmental effects identified in other resource area analyses that 

would accrue to minority populations, low-income populations, or Alaska Native tribal entities. Impacts 

identified as subsistence, sociocultural, and public health and safety are largely, if not exclusively, also of 

importance to environmental justice. 
3. Affected Environment and Environmental Consequences (Environmental Justice) 

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Draft Environmental Impact Statement 

In the case of subsistence and sociocultural analyses, identified potential adverse effects are concentrated 

in communities with largely Alaska Native populations, namely Kaktovik, Nuiqsut, Arctic Village, and 

Venetie. All of these have affiliated tribal entities and, in the case of the North Slope communities, affiliated 

Alaska Native regional and local corporations, with substantial resident shareholder populations. 

In the case of potential public health and safety impacts, nearly all of the identified potential adverse effects 

are concentrated in Kaktovik as the community closest to likely future development. In the case of 

economic impacts, with the exception of subsistence-related impacts that, in turn, have an economic 

dimension, few potential adverse impacts are identified, but potential localized economic impacts are noted 

as most likely to accrue to residents of Kaktovik and other NSB communities, both in terms of 

governmental revenues and in terms of returns to resident Alaska Native corporation shareholders. 

Subsistence Uses and Resources 

The primary factors that may result in potential impacts on subsistence resources and uses are noise, 

traffic, and human activity; infrastructure, including physical barriers; contamination; legal or regulatory 

barriers; and increased employment or income/revenue. These factors would affect resource availability, 

resource abundance, and user access for residents of the study communities, which in turn would result in 

adverse economic impacts for those whose cost of living would rise as a result of needing to purchase 

alternative foodstuffs. 

In all cases, development could potentially affect subsistence uses of resources of major importance for the 

subsistence study communities. Kaktovik residents are the primary users of the program area and would 

therefore be most likely to experience potential direct impacts associated with development. Nuiqsut 

residents could experience potential direct and indirect impacts associated with harvests of marine 

mammals, such as the harvests of bowhead whale by Nuiqsut whalers near Cross Island, and indirect 

impacts associated with harvests of caribou, waterfowl, and fish. Arctic Village, Venetie, and other 

communities whose residents subsist in part on the PCH and CAH, could experience indirect impacts 

associated with caribou and, to a lesser extent, waterfowl. Impacts related to an increase in employment 

rates or income are most likely for the community of Kaktovik but would extend to other communities on 

the North Slope. Overall, future development in the program area would have potential lasting adverse 

effects on cultural practices, values, and beliefs through its impacts on subsistence. 

Sociocultural Systems 

The primary factors that may result in potential impacts on sociocultural systems include: 1) changes in 

income and employment levels, 2) changes in available technologies, 3) disruptions to subsistence activities 

and uses, 4) influx of non-resident temporary workers associated with the oil and gas leasing program, and 

5) influx of outsiders coming into the study communities. An influx of cash into a small, rural community 

can have both positive and negative impacts on sociocultural systems. 

Economy 

As noted in Section 3.4.10, historically, very few North Slope residents participate in direct oil and gas 

activities in the North Slope; however, North Slope residents who live near existing oil developments have 

participated in oil and gas jobs, such as ice road monitors, camp security and facilities operators, and 

subsistence representatives. 

As further noted in Section 3.4.10, in 2016, while 55 oil and gas jobs were held by NSB residents, or less 

that 0.5 percent of the total oil and gas jobs based on the North Slope, it is also possible that, with more 

education and training, the future composition of the oil and gas workforce would be different. Training 
3. Affected Environment and Environmental Consequences (Environmental Justice) 

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Draft Environmental Impact Statement 

programs geared toward developing special skills required in oilfield services are expected to create more 

employment opportunities for residents of Kaktovik in particular, given their proximity to the region 

where oil and gas activities are likely to occur. Petroleum development in the region is expected to 

generate revenues to the NSB government, the State, and the federal government from royalties, income 

taxes, production taxes, and property taxes, as shown in Table 3-37. 

The City of Kaktovik would likely receive increased bed tax revenues with higher hotel occupancy, 

especially during initial development years (mobilization) and stakeholder engagement and industry 

community outreach; however, the change in the level of hotel occupancy is difficult to quantify at this 

point, because the timing and amount of local consultations and mobilization is uncertain and may vary. No 

changes to population growth rate or increase in population are expected in Kaktovik, because industry 

workers are expected to commute on a rotational basis, rather than relocating to Kaktovik or other 

North Slope communities. 

Given that future oilfield workers would be housed in work camps at the CPFs and drill pads, no increase 

in demand for local services and other public infrastructure is anticipated in Kaktovik. As noted in Section 

3.4.10, however, local businesses in Kaktovik, including the KIC and its subsidiaries, could increase their 

economic activity from participation in oil and gas activities occurring during the exploration, development, 

and production of petroleum resources in the Coastal Plain; however, the level of increased economic 

activity cannot be quantified with existing data. 

Public Health 

All action alternatives are likely to be below applicable air quality standards for all phases of a future 

development project. Water would be contaminated in the event of an accidental discharge; however, the 

likelihood of any such discharge occurring with the resultant human exposure is low, given the lease 

stipulations and ROPs around waste prevention, handling, disposal, spills, and public safety. If exposure 

were to occur, it would be likely short term and intermittent and unlikely to lead to significant health 

effects. 

There is a low likelihood of contamination of subsistence food sources, with the possible exception of 

contamination through an oil spill or through contaminants mobilized through erosion or permafrost 

degradation. The history of oil and gas operations on the North Slope suggests a number of other 

potential oil and gas-related sources of contamination of subsistence foods (NRC 2003); however, the 

perception of contamination may result in stress and anxiety about the safety of subsistence foods and 

avoidance of subsistence food sources, with potential changes in nutrition-related diseases as a result. 

These health impacts (perceived or real) arise regardless of whether there is any contamination at levels of 

toxicological significance; the impacts are linked to the perception of contamination, not to measured 

levels. 

Noise level increases from construction or operation of oil and gas facilities would result in potential 

effects, ranging from minor irritation and annoyance to more severe health outcomes. Given the likely 

location of development away from Kaktovik, individuals at cabins or camps near developments would be 

most affected. Until site-specific development activities are proposed, the extent of this effect is not 

possible to determine. 

Increased income for Kaktovik residents and families could improve health through increases in the 

standard of living, reductions in stress, and opportunities for personal growth and social relationships; 

however, with other oil and gas development in the NSB, income and employment have been found to be 
3. Affected Environment and Environmental Consequences (Environmental Justice) 

Coastal Plain Oil and Gas Leasing Program 3-199 

Draft Environmental Impact Statement 

associated with an increased prevalence of social pathologies, including substance abuse, assault, domestic 

violence, and unintentional and intentional injuries. 

Future oil and gas development in the program area could increase the risk of injuries and accidents during 

subsistence activities. Increasing use of roadways increases the risk of motor vehicle accidents and injuries; 

however, the likelihood of accidents on ice roads or in-field roads is low, given the lease stipulations and 

ROPs that address vehicle and roadway use. 

Alternative B 

Subsistence Uses and Resources 

Alternative B would result in the greatest potential impact on caribou calf survival and overall herd 

numbers, due to the amount of lands available for oil and gas leasing. Alternative B would include 0.5- to 1-

mile setbacks (with no permanent oil and gas infrastructure, including roads and pipelines, allowed) for 

eight major rivers, many of which, such as the Hulahula, Okpilak, and Jago Rivers, are key drainages used 

for subsistence activities. Some TLs on human activity would be in place for calving and post-calving 

habitats of the PCH, which would reduce impacts on resource abundance and availability. 

Sociocultural Systems 

Because of its proximity to the program area, the community of Kaktovik would experience the greatest 

intensity of potential effects associated with the proposed oil and gas leasing program. Potential impacts on 

sociocultural systems may also occur for other communities if oil and gas development in the program 

area results in changes to resource abundance or availability, particularly of caribou, which is a resource of 

major importance to the closest communities of Kaktovik, Nuiqsut, Arctic Village, and Venetie. 

Because of the particular spiritual and cultural importance of the coastal plain and PCH calving grounds to 

the people of Arctic Village and Venetie, any disruption to that herd or contamination or degradation of 

calving grounds in the program area would have potential sociocultural impacts on the Gwich'in people, in 

terms of their belief systems and cultural identity. 

Economy 

Potential economic effects would be similar to those discussed above in Impacts Common to All Action 

Alternatives. There would be unquantifiable differences in economic effects due to the ROPs associated 

with the various lease stipulations under Alternative B. Some of these actions would likely also result in 

delays in exploration, development, and production; therefore, this would also delay potential employment 

and income effects, as well as revenues that would otherwise accrue to the local, State, and federal 

governments. 

Public Health 

Potential threats to subsistence activities and harvest patterns are a primary source of ongoing stress in 

North Slope communities. Avoidance of productive subsistence areas may reduce harvests and exacerbate 

dietary and nutritional outcomes, independent of any potential direct impact on the animals themselves. 

Reductions in the success of subsistence harvests for Kaktovik residents could cause a shift from 

subsistence resources to store-bought foods, worsening nutritional outcomes and food insecurity. 

Alternative C 

Subsistence Uses and Resources 

Under Alternative C, Lease Stipulations 6 and 7 would provide additional protections for caribou, and pads 

and CPFs would not be allowed within 1 mile inland of the coast under Lease Stipulation 9, although 
3. Affected Environment and Environmental Consequences (Environmental Justice) 

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Draft Environmental Impact Statement 

essential pipelines and roads may still occur. In addition, Lease Stipulation 8 would impose greater TLs on 

human activity in the PCH post-calving habitat area than Alternative B. Potential demographic impacts on 

the PCH would be less likely than under Alternative B, so the intensity of subsistence impacts under 

Alternative C would be less than Alternative B. 

Sociocultural Systems 

Of the lease stipulations noted above, the intensity of potential sociocultural impacts related to caribou 

under Alternative C would be less than Alternative B. 

Economics 

The potential economic effects under Alternative C would be similar in magnitude to the economic effects 

discussed above in Impacts Common to All Action Alternatives. Similar to Alternative B, there would be 

differences in economic effects resulting from areas available to lease in the program area, but these 

economic effects would be difficult to quantify at this leasing phase. 

Public Health 

Through additional protection for caribou, Alternative C would likely decrease the potential for impacts 

on Kaktovik residents’ subsistence harvest and the likelihood and severity of health impacts from reduced 

subsistence harvests, increased reliance on store-bought food, and food insecurity. 

Alternative D 

Subsistence Uses and Resources 

Under Alternative D, lease sales on calving grounds would be most limited of all action alternatives, and 

more lands would be subject to future development and TL; therefore, Alternative D would be the least 

likely to affect calf survival and overall herd numbers of all action alternatives. Alternative D also includes 

larger setbacks from key subsistence drainages than other action alternatives, including 4 miles of the 

Hulahula and 3 miles of the Okpilak Rivers, which would greatly reduce potential impacts on subsistence in 

those areas, particularly during the winter. 

Under Alternative D, no pads or CPFs would be allowed within 2 miles of the coast, reducing potential 

impacts on coastal subsistence hunters and anglers. In addition, reclamation of infrastructure would be on 

ongoing process for each development area, thus lessening the duration of impacts for individual 

developments related to infrastructure. Alternative D would include additional design features meant to 

address impacts on subsistence resources and users, and more consultation with tribal governments on 

design features, timing, development methods, and access. 

Sociocultural Systems 

Because of increased caribou calving grounds avoidance and because more lands would be subject to 

development restrictions, the intensity of potential sociocultural impacts under Alternative D would be 

less than under Alternative B. 

Economy 

Given the higher level of restrictions under Alternative D, the difference in the level of economic effects 

under this alternative would be higher, compared with the differences in economic effects under 

Alternatives B and C. These increased restrictions would likely reduce the amount of oil produced and 

defer or reduce revenues and taxes. 
3. Affected Environment and Environmental Consequences (Environmental Justice) 

Coastal Plain Oil and Gas Leasing Program 3-201 

Draft Environmental Impact Statement 

Public Health 

Similar to Alternative C, through additional protection for caribou, Alternative D would decrease the 

potential for impacts on Kaktovik residents’ subsistence harvest and therefore the likelihood and severity 

of health impacts from reduced subsistence harvests, increased reliance on store-bought food, and food 

insecurity. 

Cumulative Impacts 

While there has been no previous oil and gas development in the Coastal Plain and very little oil and gas 

exploration in the same area, the North Slope as a region sustained contact with outside entities and 

institutions. This includes the decades of oil exploration and development conducted by the federal 

government and industry. This has directly affected habitat use and behavior of subsistence species and 

resulted in additive impacts on subsistence resources, harvest patterns, and users (BLM 2018a). These 

effects have altered livelihoods and ways of life and account for some of the social disruptions seen in 

villages today. 

Oil and gas development has also provided the underpinning of a regional economy that has enabled the 

NSB a greater degree of local control and self-determination in addressing socioeconomic and 

sociocultural issues, although dependence on an undiversified economy based on the extraction of natural 

resources has created other challenges. The leasing program would likely contribute to potential 

cumulative impacts in a variety of ways across the subsistence, sociocultural, economic, and public health 

spectrum. 

Subsistence Uses and Resources 

Cumulative impacts on subsistence would alter subsistence use areas, user access, and resource availability 

for Iñupiaq and Gwich'in subsistence users. Over time, changes in how residents access and use the land 

and reduced opportunities for participation in subsistence harvesting, processing, distribution, and 

celebrations from decreased harvests would have negative effects on culture by weakening social ties and 

knowledge of cultural traditions. 

Sociocultural Systems 

Increased interactions with outsiders in traditional use areas and communities has the potential to affect 

traditional values and belief systems over time and may also result in increased social problems, if such 

interactions lead to greater access to drugs and alcohol. Cumulatively, strong local economies would have 

positive social impacts, as long as the communities are able to adapt to such changes, while maintaining 

cultural traditions and values. Communities that are most likely to experience negative sociocultural 

impacts would be those that experience impacts on subsistence, while not having increased income or 

employment opportunities, such as Arctic Village and Venetie; therefore, the action alternatives would 

constitute a disproportionate, adverse impact on the environmental justice communities of Arctic Village 

and Venetie. These effects would be highest under Alternative B, less under Alternative C, and the least 

under Alternative D. 

Economy 

The oil and gas leasing program and subsequent exploration, development, and production in the program 

area would increase oil and natural gas production on the North Slope and increase TAPS throughput. 

Economic activity would increase at the local, regional, and state level due to direct industry spending on 

labor, materials, and services. Government revenues would increase from shared royalties, tax payments 

such as property taxes, corporate income taxes, severance taxes, and other local taxes, although the 
3. Affected Environment and Environmental Consequences (Environmental Justice) 

3-202 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement 

cumulative impact cannot be quantified with existing data (see Table 3-37 for incremental contribution of 

post-lease oil and gas activities). Job opportunities would increase for Alaskans, including residents of 

communities in the NSB. Labor income would increase in regions where industry spending would occur 

and where the oil and gas workforce resides, although the cumulative impact cannot be quantified with 

existing data (see Table 3-35 and Table 3-36 and accompanying discussions for the incremental 

contribution of post-lease oil and gas activities).

Public Health 

As noted in Section 3.4.11, for most past, present, and reasonably foreseeable future projects, the village 

of Kaktovik and its residents have been buffered by surrounding undeveloped lands. Air and water quality 

in and around the village remains good, and the influx of oil and gas revenue for the NSB has improved 

infrastructure in the village. 

High rates of accidents and injury are primarily due to subsistence activities, and food security for Kaktovik 

households remains a concern (see Food, Nutrition, and Subsistence Activity in Section 3.4.11). Future 

development offshore in the Beaufort Sea would likely increase the risk of accident and injury by changing 

the subsistence harvest patterns and requiring more time on the water to harvest animals. The onshore 

leasing alternatives would have similar contributions to the cumulative effects on public health for Kaktovik 

residents with the pathways described above. 

Current levels of contamination of traditional food and water supplies in the region are low and, in the 

absence of major spills or accidents, are unlikely to significantly change under any alternative. Oil and gas 

development, particularly in areas of traditional use and subsistence harvest, would disrupt subsistence 

harvest patterns. Conflicts between uses of the land would lead to an increased risk of injury in hunters. 

All action alternatives would increase the potential likelihood of injury due to industrial use of land 

previously used only for subsistence activity. Continuing economic development and increasing revenues 

to the local governments under all action alternatives would support maintenance of Kaktovik 

infrastructure and systems. The potential direct and indirect employment resulting from oil and gas 

exploration and development, combined with the government and Native corporation revenues, are all 

major contributors to the positive health changes in the NSB over the last few decades. The future oil and 

gas activities under all action alternatives would contribute to these ongoing changes, with greater levels of 

employment generally being more likely to be associated with good health. 

3.4.6 Recreation 

Affected Environment 

Recreation opportunities and settings in the program area are largely as described in the Arctic Refuge 

CCP (USFWS 2015a), which is incorporated here by reference; a summary is provided below. 

The primary recreation opportunities in the program area are wildlife viewing, camping, backpacking, 

hiking, photographing, hunting, fishing, and boating (Christensen and Christensen 2009). These activities 

include hunting and fishing for non-federally qualified subsistence users, permitted commercial activities, 

such as guided float trips and hunting, and individual visitors engaged in dispersed recreation, such as 

backpacking and photographing. Polar bear viewing and ski touring are also popular (USFWS 2018). 

The recreation setting of the program area is remote; in many cases, visitors do not encounter other 

people during their visit. Many people visit the program area in the summer, when near constant daylight 

provides unique multiday recreation opportunities. Increasingly, visitors are coming to the program area 
3. Affected Environment and Environmental Consequences (Recreation) 

Coastal Plain Oil and Gas Leasing Program 3-203 

Draft Environmental Impact Statement 

later in the fall, experiencing rapid decreases in average daily daylight and increased opportunity to view 

the Northern Lights. Weather, surface water and land surface conditions, and near continual darkness limit 

or prevent access to many parts of the program area during the winter and spring. 

There is limited overland motorized access to or in the program area. Motorized recreation opportunities 

and use of motor vehicles to access other forms of recreation consist mainly of snowmachines, which are 

legal during periods of adequate snow cover. Most snowmachine use is associated with subsistence 

activities. The only roads are near the community of Kaktovik. Access to inland areas is either by boat, 

such as along the Kongakut, Canning, or Hulahula Rivers, by aircraft, or by foot. 

Most visitors to the inland portions of the program area arrive by chartered aircraft. Air operators 

providing transportation services to visitors are regulated through a special use permit system, which 

identifies the specifications for their operations. There is a relative absence of water bodies sizable enough 

to support float landings, so the vast majority of landings are made on land where surface conditions 

permit it. Visitors enter the program area directly via chartered aircraft, from the north via Kaktovik or, to 

a lesser extent, from the south via the Dalton Highway through the Arctic Refuge Wilderness Area. 

In 2017, four commercial air service operators provided air taxi service for 1,400 visitors; another seven 

operators chartered polar bear viewing excursions for 1,600 visitors. Air taxi service supported recreation 

for 850 river floaters, 300 backpackers, 40 base campers, and 100 hunters (BLM 2018g). 

Visitor use in the program area has increased in recent years with the emergence of polar bear viewing on 

waters immediately surrounding Kaktovik. Before the season for polar bear viewing, more than 90 percent 

of visitors access the program area via airplane, with more than 80 percent of all visitors arriving via 

chartered planes (Christensen and Christensen 2009). Other visitors accessed recreation opportunities in 

the program area via boat or on foot. 

During the summer and fall, the Kongakut, Canning, and Hulahula Rivers support most water-based access 

to the interior areas. Visitors typically travel by plane to the rivers’ headwaters in the southern portion of 

the program area and float northward toward the Arctic Ocean. Most recreation is in these river 

corridors. 

In 2017, guided polar bear viewing accounted for approximately 54 percent of all reported guided 

recreation activities in the program area. Polar bears are viewed on waters next to Kaktovik. 

Of the remaining 46 percent of visitors to the program area, use was more dispersed, and river floaters 

accounted for 60 percent of visitors, while backpackers, base campers, and hunters made up 40 percent of 

the activity types. Visitors for each of these four recreation types depend predominantly on use of river 

corridors during all or a portion of their visits (BLM 2018g). 

As described in the Arctic Refuge CCP (USFWS 2015a), the Kongakut River is popular among visitors 

during late spring and early summer to observe the caribou migration and in August to hunt. Caribou are 

the primary game species hunted in the program area, which is entirely in GMU 26C. There is also 

subsistence hunting of caribou and marine mammals that takes place in the program area (see Section 

3.4.3). In 2017, approximately 4 percent of all reported guided recreation in the program area was 

hunting. Of the visitors to the program area whose use was focused on river corridors and not polar bear 

viewing, approximately 8 percent were hunters (BLM 2018g). 
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3-204 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement 

Polar bear viewing is an increasingly popular activity in the program area. In 2013, it represented 

approximately one quarter of all recreation visits; in 2016 and 2017, it accounted for more than half (BLM 

2018g). There are viewing opportunities near Kaktovik, including through guided viewing tours. Expanded 

infrastructure at Kaktovik supports international visitors seeking the unique opportunity of viewing polar 

bears outside of captivity. 

Climate Change 

The unique character of landscapes in the program area would continue to change in response to climate 

change. Increasing temperatures would directly affect recreation by reducing opportunities to participate in 

over-snow activities, such as ski touring. Warmer temperatures associated with climate change would 

increase the potential for direct and indirect impacts on recreation from the earlier thawing of permafrost 

and variable stream flows, which are altering or diminishing the quality of recreation and the ability of 

visitors to access them. 

Direct and Indirect Impacts 

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

recreation from on-the-ground post-lease activities. 

Potential impacts on recreation would result from management that enhances or diminishes the quality of 

the recreation setting, limits access or physically displaces visitors or subsistence users because of new 

surface disturbance or development, increases or decreases conflicts between recreation uses, such as in 

high use areas, increases or decreases the ability of commercial operators to carry out specially permitted 

activities, or enhances or diminishes subsistence opportunities. The effects of climate change described 

under Affected Environment above, could influence the rate or degree of the potential direct and indirect 

impacts. 

Alternative A 

Under Alternative A, no oil and gas leasing program would take place in the program area; there would be 

no potential direct or indirect impacts on recreation from post-lease oil and gas activities in the program 

area. 

Impacts Common to All Action Alternatives 

The magnitude, spatial extent, and duration of potential impacts on recreation would vary, based on 

season, type of recreation, and location in the program area. In general, the potential for impacts on 

recreation would be greatest during the summer and fall, when weather and daylight conditions allow for 

the greatest number and type of recreation uses. Similarly, the potential for impacts would be greatest 

along river corridors, the Beaufort Sea coastline, and other areas where the number of recreation users is 

highest. Because visitors to the program area generally expect a physical setting consisting of little to no 

human disturbance and a social setting with little to no interaction with other visitors or human activity, 
3. Affected Environment and Environmental Consequences (Recreation) 

Coastal Plain Oil and Gas Leasing Program 3-205 

Draft Environmental Impact Statement 

small changes to the physical and social setting can have disproportionately large impacts on user 

experiences. 

Protective measures intended to limit ground disturbance and associated impacts on resources would 

improve recreation by limiting or prohibiting surface-disturbing activities that could diminish the quality of 

recreation experiences, conflict with recreation opportunities, or displace visitors and subsistence users. 

The magnitude of potential impacts on recreation would be directly related to the type and extent of 

proposed lease stipulations or ROPs under each alternative. In general, maintaining or improving resource 

conditions increases the quality of recreation (Dorwart et al. 2009). 

The program area offers recreationists primitive recreation experiences, such as expedition-length float 

hunts and polar bear viewing, that are unique on a global scale and that depend largely on the physical 

setting. Visual quality contributes to the physical setting and directly influences recreationists’ satisfaction 

with recreation in the program area. Undisturbed landscapes contribute to higher-quality recreation 

opportunities. Protective measures attached to leases, such as NSOs, which prevent surface disturbance 

and the placement of aboveground infrastructure, would eliminate the potential for changes to visual 

quality and associated physical setting. Where aboveground development is allowed, lease stipulations that 

minimize the visual contrast of new development, such as by requiring design elements that complement 

the predominant natural features of the characteristic landscape, would reduce the intensity of visual 

impacts and associated change to the recreation setting. 

Night sky conditions are a component of visual quality that also contribute to the recreation setting and 

user experiences. The addition of artificial lighting at facilities in the future and from vehicles would 

diminish the quality of night sky conditions, especially in the winter and spring, when daylight hours are 

shortest. Diminished night sky conditions during the winter and spring would affect fewer visitors, 

compared with daytime visual impacts. This is because there are fewer visitors to the program area during 

that time of year; however, any new artificial light would result in a potential impact on those visitor 

experiences because there are very few artificial light sources in the program area. 

Similarly, future artificial lighting during the limited nighttime hours in the summer and fall would result in a 

short but intense impact, which could diminish the overall quality of visitor experiences. There would also 

be potential indirect impact on the experience where artificial light reduces visitors’ ability to observe the 

Northern Lights. Protective measures that prevent the placement of aboveground infrastructure or that 

specify the use of downcast lighting or other light trespass mitigation measures would minimize impacts on 

the quality of nighttime recreation. 

The magnitude of potential impacts on the recreation setting from visual quality, including night skies, 

would decrease, relative to users’ increasing distance from the source of any visual impact or artificial light; 

however, the relatively flat topographic characteristics of the program area would result in new mineral 

development infrastructure being visible from far distances. Also, because there is no development 

currently, any new development that would be visible to recreation users would modify the recreation 

setting and visitor experiences. Even with protective measures to minimize potential visual impacts, surface 

disturbance and infrastructure development would modify the existing character of the landscape, diminish 

visual quality, and directly affect the quality of the recreation setting and associated experiences. The 

intensity and duration of the impact would depend on the type and location of the development, relative 

to recreation opportunities. 
3. Affected Environment and Environmental Consequences (Recreation) 

3-206 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement 

Noise from mineral development following a lease sale would modify the recreation setting and could 

potentially diminish visitor experiences. The magnitude of impacts depends on the distance between the 

observer and the noise source, the duration and frequency of the noise, the time at which the noise 

occurs, the presence of topographical features or vegetation that decreases noise, and the lease 

stipulations or mitigation strategies that reduce noise levels. The use of compression technology would 

increase the noise levels associated with mineral production. More frequent aircraft and ground-based 

vehicle trips could also increase the occurrence of noise impacts from those sources. Potential noise 

impacts on recreation would diminish farther from the source, because noise diminishes with distance. 

Lease sales resulting in future mineral exploration and production and associated pipelines, private roads, 

mineral material sites, and other infrastructure can physically displace recreation opportunities and prevent 

access to areas for recreation. The magnitude and type of potential impacts would depend on the location 

of the development and recreation activity affected. The potential for impacts would be greatest during the 

summer and fall when visitation is highest and near river corridors and other areas where visitors 

concentrate; however, permanent infrastructure would displace all types of visitors year-round and over 

the long term. 

Overland heavy equipment vehicle use for future seismic work could displace winter users when the 

equipment is in use. Vehicle operation would also produce noise and artificial light, which could detract 

from the primitive recreation experience. Over snow heavy vehicles used for seismic work can leave grid 

lines on the landscape visible by aircraft passengers following snow melt. This is the result of compacted 

snow melting slower than surrounding areas, creating darker vegetation patterns matching the gridlines 

used for the seismic work. In the summer and fall, for visitors arriving by air, or where the grid lines are 

visible from elevated areas, this modification would influence visitor perceptions of the program area’s 

setting. Once they are on the ground or in equal elevation to the grid lines, there would be potential 

impacts on visitor experiences. 

Recreationists in the program area rely heavily on commercial operators for access to desired recreation 

opportunities and experiences. Changes in resource conditions, including physical resources, such as visual 

quality, and biological conditions, such as wildlife, would directly influence the quality of recreation 

experiences obtained through commercial operators. For example, mineral development in leased areas 

that relocates or decreases polar bear or caribou populations would diminish the ability of operators to 

provide clients with desired recreation experiences. This could lessen the viability of certain operations, 

resulting in fewer permitted operators, which would indirectly affect recreation by potentially reducing 

access to the program area via specially permitted means. 

Alternative B 

Under Alternative B, 1,563,500 acres are available for lease sales, 77 percent of which (1,204,000 acres) 

would be available for surface use. This would result in potential direct and indirect impacts on recreation 

throughout nearly the entire program area. The types of impacts described under Impacts Common to All 

Action Alternatives would result from lease sales that would be followed by the construction and operation 

of drill pads, CPFs, gravel roads, pipelines, STP, and gravel pits to support mineral development. 

Over time as exploration, well pad development, road construction, and extraction occur, there would be 

a steady decline in the recreation setting from changes to the visual quality and night sky, compared with 

Alternative A. Noise from construction, production, aircraft, and vehicles would also diminish the quality 

of the recreation setting (see Section 3.2.3, Acoustic Environment). With the intensification of 

development through the construction and production phases, there would be a steady increase in surface 
3. Affected Environment and Environmental Consequences (Recreation) 

Coastal Plain Oil and Gas Leasing Program 3-207 

Draft Environmental Impact Statement 

disturbance, which would increase the potential for visitor displacement and restrictions on access for 

visitors and subsistence users. New roads would create up to 208 miles of dispersed, linear barriers. Yearround vehicle traffic on the roads would contribute to noise, visual, and light-related impacts on the 

primitive recreation uses that occur in the program area. 

One-mile setbacks from the Canning, Hulahula, and Jago Rivers, and narrow setbacks for other rivers that 

serve as primary recreation use areas, would potentially directly impact the recreation setting and visitor 

experiences as described above. The narrow setback would provide little opportunity for vegetation or 

topography to provide consistent screening of new facilities or vehicle traffic from view of users in the 

river corridors. The intensity of the impact would depend on structure height, topography, and vegetation 

that influence a user’s line of sight from the river corridor. Drill pads, roads, and pipelines near these river 

corridors would also physically displace visitors from areas outside the setbacks. Concentrating recreation 

uses in narrow river corridors would increase the density of activity in those corridors, compared with 

Alternative A, which would increase the number of interactions among visitors. This would directly affect 

the social setting and could increase the potential for conflicts among different types of recreation users. 

There would be no specific protection measures to minimize disturbance in polar bear denning critical 

habitat, which could result in potential species displacement or decline. Over time, fewer species would 

result in fewer viewing opportunities, which would lessen the viability of commercial operators providing 

guided polar bear viewing experiences. This could reduce the number of specially permitted operators and 

indirectly limit future opportunities for visitors to experience polar bears outside of captivity. 

Minimal protection measures for development in caribou summer, calving, and post-calving habitat areas 

could lead to displacement and possible decline in caribou populations, which would decrease hunting and 

viewing opportunities. Potential impacts on caribou populations would also indirectly affect the viability of 

commercial recreation uses that provide guided hunting and viewing opportunities. Fewer operators 

would result in an overall decline in opportunities to access the program area for recreation. 

The long-term, permanent degradation of the program area’s primitive recreation setting could result from 

not requiring final abandonment to meet minimal standards for WSR designation, not restoring general 

wilderness characteristics of the area, and allowing exceptions to abandonment conditions. 

Alternative C 

Compared with Alternative A, new oil and gas development following lease sales on up to 1,563,500 acres 

would potentially diminish the quality of the recreation setting and visitor experiences, displace visitors and 

subsistence users, and increase conflicts between users. Following the lease sales, the types of impacts 

described under Impacts Common to All Action Alternatives would result from the construction and operation 

of an anticipated 18 drill pads and construction of CPFs, gravel roads, pipelines, STP, and gravel pits to 

support mineral development. The intensity of impacts would be similar to those described under 

Alternative B; however, additional lease stipulations and a larger NSO area under Alternative C would 

result in potential impacts being experienced over a smaller area than under Alternative B. 

Four-mile NSO setbacks from rivers, such as the Canning and Hulahula Rivers, would maintain recreation 

opportunities and avoid the displacement of visitors in those popular recreation corridors. The potential 

for user conflicts in river corridors would be the same as Alternative A. This is because the wide corridor 

setbacks would support visitor dispersion in the corridor without being constrained by development. 
3. Affected Environment and Environmental Consequences (Recreation) 

3-208 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement 

Where unobstructed by topography or vegetation, infrastructure and vehicle traffic would be visible from 

the rivers. This would alter the recreation setting and could contribute to diminished user experiences. 

Where vegetation and topography provide screening, impacts would be nearly the same as under 

Alternative A. The exception would be at nighttime, when artificial lighting skyward of any new facilities 

would be visible, which would affect recreation, as described under Impacts Common to All Action 

Alternatives, above. A narrower 1-mile setback along the Jago River would result in the same impacts as 

Alternative B. Outside the river corridor setbacks, the potential for displacing visitors and limiting access 

would be the same as Alternative B and as described under Impacts Common to All Action Alternatives, above. 

Protection measures limiting activity in polar bear denning habitat and caribou summer, calving, and postcalving habitat would minimize the potential for species dispersion, or decline, which would indirectly 

maintain the quality of hunting and wildlife viewing experiences. This would also minimize impacts on the 

viability of specially permitted commercial operators. 

In the long term, requiring final abandonment to meet minimal standards for WSR designation and intent 

to restore general wilderness characteristics of the area would allow the program area to return to a 

primitive recreation setting. The removal of facilities and restoration of disturbed areas would eliminate 

displacement and access impacts associated with those features. 

Alternative D 

Potential impacts on recreation under both subalternatives of Alternative D would be similar to those 

described under Alternative C. The exception would be that making 1,037,200 acres available for leasing, 

of which 708,600 acres (45 percent) would be NSO, would largely concentrate the Impacts Common to All 

Action Alternatives described above into a smaller portion of the program area. Compared with Alternative 

A, the greatest potential for impacts would be in the 328,600 acres (21 percent of the program area) 

available for leasing with surface use; however, some impacts associated with an anticipated 21 well pads 

and associated infrastructure would occur inside of the NSO areas. These would include changes to the 

recreation setting from artificial lighting and alteration of the recreation setting and visitor experiences 

from the visual presence of infrastructure and vehicles. 

Cumulative Impacts 

Potential cumulative impacts on recreation would be the result of actions or circumstances, both in or 

outside the ability of BLM to manage, that would enhance or diminish the quality of the recreation setting, 

limit access or displace visitors or subsistence users, increase or decrease conflicts between recreationists, 

increase or decrease the ability of commercial operators to carry out specially permitted activities, or 

enhance or diminish subsistence opportunities. Past, present, and reasonably foreseeable future actions 

described in Appendix F that would cumulatively impact recreation include increasing recreation use in 

the program area, and energy and infrastructure development. 

Under all alternatives, there would be an increased demand for recreation use in the program area. This 

would be the case particularly on lands that are easily accessed from nearby communities or waterways. 

With this increased demand, the social recreational setting would continue changing, resulting in the 

potential for more frequent and intense user interactions. Under all action alternatives, with increasing 

demand, the displacement of visitors near leasing areas would increase recreation use in other locations in 

the program area. This would increase the potential for user conflicts in those areas. Over time, more 

rules and regulations to control access and use may be needed. These potential changes would 
3. Affected Environment and Environmental Consequences (Recreation) 

Coastal Plain Oil and Gas Leasing Program 3-209 

Draft Environmental Impact Statement 

cumulatively impact the quantity and quality of recreation opportunities that can be offered and the 

recreation experience and opportunities that can be provided. 

Under all action alternatives, oil and gas development, would increase the presence of well pads, pipelines, 

roads, and other infrastructure, which would potentially displace recreation in the program area. 

Combined with increased visitation and other reasonably foreseeable future actions, new infrastructure 

development would diminish the quality of the recreation setting and associated recreation experience. 

These potential impacts would last until the infrastructure is removed and the areas reclaimed. The 

intensity of impacts on visitor experiences and recreation setting would be greatest in areas where 

infrastructure is visible, and operations are audible. Visitors displaced from certain areas because of oil and 

gas activity could choose alternate locations in the program area to recreate, which could lead to more 

frequent conflicts among recreationists in those areas. The effects of climate change described under 

Affected Environment above, could influence the rate or degree of the potential cumulative impacts. 

3.4.7 Special Designations 

Affected Environment 

Arctic National Wildlife Refuge Purposes 

The Arctic National Wildlife Range was established in 1960 by Public Land Order 2214 “For the purpose 

of preserving unique wildlife, wilderness and recreational values....” In 1980, ANILCA redesignated the 

range as part of the larger Arctic Refuge. It also designated much of the original range as wilderness under 

the 1964 Wilderness Act and provided four purposes that guide management of the entire refuge. Section 

20001 of PL 115-97 Act amended Section 303(2)(B) of ANILCA to add a fifth purpose related to the oil 

and gas program on the Coastal Plain. Table 3-31 identifies the section of this EIS where impacts of oil 

and gas leasing on Arctic Refuge purposes can be found. 

Table 3-31

Arctic National Wildlife Refuge Purposes 

Purpose EIS Section Describing Impacts 

on Arctic Refuge Purpose

(i) to conserve fish and wildlife populations and 

habitats in their natural diversity

3.2.2 Air Quality

3.2.8 Soil Resources

3.2.10 Water Resources

3.3.1 Vegetation and Wetlands

3.3.2 Fish and Aquatic Species

3.3.3 Birds

3.3.4 Terrestrial Mammals

3.3.5 Marine Mammals

(ii) to fulfill the international fish and wildlife 

treaty obligations of the US

3.3.4 Terrestrial Mammals

(iii) to provide the opportunity for continued 

subsistence uses by local residents

3.4.3 Subsistence Uses and Resources

(iv) to ensure water quality and necessary water 

quantity in the refuge

3.2.10 Water Resources

(v) to provide for an oil and gas program on the 

Coastal Plain

3.2.5 Geology and Minerals

3.2.6 Petroleum Resources

3.4.10 Economy
3. Affected Environment and Environmental Consequences (Special Designations)

3-210 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Marine Protected Areas

The USFWS (2015a, Section 4.1.3.3, Marine Protected Area) described marine protected areas (MPAs). 

The discussion below tiers to and incorporates by reference relevant information, while placing emphasis 

on the program area.

MPAs come in a variety of forms and are established to protect ecosystems, preserve cultural resources, 

such as shipwrecks and archaeological sites, or sustain fisheries production. MPAs are defined as “...any 

area of the marine environment that has been reserved by Federal, State, territorial, tribal, or local laws or 

regulations to provide lasting protection for part or all of the natural and cultural resources therein” (EO 

13158, May 26, 2000).

The DOI nominated the Arctic Refuge in 2005 and it was accepted for inclusion in the national system of 

MPAs. There are no special conditions for managing the Arctic Refuge MPA, but designation provides its 

managers with an opportunity to prioritize using existing management authorities and to better understand 

the ecological quality and function of its coastal areas.

All marine waters in the Arctic Refuge boundaries and marine waters and lagoons off the northern coast 

of the program area (1,631,500 acres; BLM GIS 2018) are listed as part of the National MPA System.42

Shifting shorelines and marine-freshwater boundaries at river mouths create some variability in the acreage 

estimate for the refuge’s contribution to the National MPA System, on the order of plus or minus several 

hundred acres (USFWS 2015a).

Wild and Scenic Rivers

The USFWS conducted a WSR review as part of their Revised CCP (USFWS 2015b, Appendix I Wild and 

Scenic River Review). The discussion below tiers to and incorporates by reference relevant information, 

while placing emphasis on rivers in the program area. 

WSRs are rivers or segments of rivers designated by Congress under the authority of the Wild and Scenic 

Rivers Act of 1968 (PL 90-542, as amended; 16 USC 1271–1287). The purposes of the law are preserving 

the river or river section in its free-flowing condition, preserving water quality, and protecting its 

outstandingly remarkable values (ORVs). They are identified on a segment-specific basis and may include 

scenic, recreational, geologic, fish and wildlife, historic, cultural, or other similar values.

The Wild and Scenic Rivers Act mandates protections for rivers that are designated rivers of the National 

Wild and Scenic River System. Federal managers of rivers that were recommended pursuant to a 

congressionally authorized WSR study are obligated to use existing management authorities to protect the 

characteristics of rivers for the conditions under which they were found eligible and suitable (USFWS 

2015b). A river’s preliminary classification (either wild, scenic, or recreational, based on level of 

development), free-flowing condition, water quality, and ORVs must be maintained. The WSR study for 

Arctic Refuge (USFWS 2015b) was an agency-directed study, not a congressionally authorized study; 

however, where practicable and where it does not conflict with the purposes of PL 115-97, stipulations 

would be applied to protect WSR characteristics on rivers determined to be suitable and recommended 

to Congress to be included in the system. 

The Marsh Fork-Canning and Hulahula Rivers were found to be eligible and suitable for inclusion in the 

National Wild and Scenic River System (USFWS 2015b). The recommendation for this was carried 

 

42See the viewer of the NOAA National MPAs here: https://marineprotectedareas.noaa.gov/dataanalysis/

mpainventory/mpaviewer/.
3. Affected Environment and Environmental Consequences (Special Designations)

Coastal Plain Oil and Gas Leasing Program 3-211

Draft Environmental Impact Statement

forward to Congress in 2015. In the program area, the entire segment of the Hulahula River was found to 

be eligible and suitable, and the Canning, Jago, and Okpilak Rivers were found to be eligible in the Wild and 

Scenic River Review (USFWS 2015b; see Map 3-46, Special Designations in Appendix A). The Marsh 

Fork-Canning River is not in the program area.

The sizes and the ORVs and preliminary classification of each eligible and suitable river in the program area 

are presented in Table 3-32, below.

Table 3-32

Eligible and Suitable Rivers within the Program Area

River Preliminary 

Determination

Miles USFWSAdministered Land Preliminary 

Classification

Outstandingly 

Remarkable Values

Canning Eligible 41 Wild Cultural, wildlife, fish, 

recreational

Hulahula Eligible and Suitable 26 Wild Recreational and cultural

Jago Eligible 36 Wild Wildlife

Okpilak Eligible 33 Wild Scenic and geologic

Sources: USFWS GIS 2015

Wilderness Characteristics, Qualities, and Values

The USFWS (2015c, Appendix H, Wilderness Review) described the wilderness characteristics in the 

Arctic Refuge. This section tiers to and incorporates by reference relevant information, while placing 

emphasis on the program area location. There have been no new data on the wilderness values associated 

with the program area since the completion of the Arctic Refuge CCP (USFWS 2015c). 

The 1964 Wilderness Act established a national system of lands to preserve a representative sample of 

ecosystems in a natural and wild condition for the benefit of future generations. Public Land Order 2214 

(1960) established the original Arctic Range and identified three purposes of preservation: wilderness 

values, wildlife, and recreational values. ANILCA Section 101(b) outlines the intent “to preserve in their 

natural state extensive unaltered arctic tundra...ecosystems; and to preserve wilderness resource values 

and related recreational opportunities including but not limited to hiking, canoeing, fishing, and sport 

hunting, in large arctic and subarctic wildlands and on free-flowing rivers....” Further, ANILCA 

304(g)(2)(B) requires the Secretary of the Interior to identify and describe “the special values of the refuge, 

as well as...wilderness value of the refuge” when developing plans. In the Arctic Refuge CCP (USFWS 

2015a) the USFWS recommended the lands in the program area for wilderness designation; however, 

Congress did not act on these wilderness recommendations, and subsequently, the minimal management 

standard for the Coastal Plain must now be adjusted to account for the oil and gas leasing program 

required by the PL 115-97. 

The Wilderness Act describes four primary qualities of wilderness: 

 Generally appears to have been affected primarily by the forces of nature, with the imprint of 

man’s work substantially unnoticeable

 Has outstanding opportunities for solitude or a primitive and unconfined type of recreation

 Has at least 5,000 acres or is of sufficient size as to make practicable its preservation and use in an 

unimpaired condition

 May also contain ecological, geological, or other features of scientific, educational, scenic, or 

historic value
3. Affected Environment and Environmental Consequences (Special Designations)

3-212 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

These qualities are found throughout the program area, except for certain tracts in the vicinity of 

Kaktovik. 

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

special designations from on-the-ground post-lease activities.

Marine Protected Areas

The Arctic Refuge MPA was accepted for inclusion in the national system of MPAs in 2005. MPAs have 

legally established goals, conservation objectives, and intended purposes, such as to conserve biodiversity 

in support of research and education, to protect benthic habitat in order to recover over-fished stocks, 

and to protect and interpret shipwrecks for maritime education. These descriptors of an MPA are 

reflected in the site’s conservation focus, which represents the characteristics of the area that the MPA 

was established to conserve (NOAA 2017).

Alternative A

Under Alternative A, no federal minerals in the program area would be offered for future oil and gas lease 

sales. Current management actions for the MPA would be maintained and resource trends would 

continue, as described in the Arctic Refuge CCP (USFWS 2015a). Alternative A would not meet the 

purpose of this EIS to inform the BLM’s implementation of PL 115-97, including the requirement to hold 

multiple lease sales and to permit associated post-lease activities. There would be no potential direct or 

indirect impacts on MPAs from post-lease oil and gas activities under this alternative.

Impacts Common to All Action Alternatives

Under all action alternatives, the natural heritage conservation focus of the MPA could be affected by 

activities or development that cause a loss of sea ice, changes in freshwater input, increased rates of 

coastal erosion or accretion, increased shipping activity, offshore development, oil spills, or an introduction 

of invasive species associated with marine shipping.

Alternative B

Under Alternative B, potential impacts from exploration and development could affect the MPAs’ natural 

biodiversity (see Section 3.3.2 and Section 3.3.5). Marine and coastal ecosystem impacts would likely 

occur in the northwestern portion of the program area. This is because exploration wells would be 

focused in this high potential zone for oil and gas development. Barge landings and staging areas used to 

transport materials and supplies for facilities could have potential indirect long-term impacts on the MPA 

by increasing rates of coastal erosion. Gibbs and Richmond (2017) examined shoreline change along 

Alaska’s arctic coast between 1947 and 2012. They found significant modification to coasts and beaches 

have occurred where production sites sit right on the coast. A more site-specific analysis would occur 

during the Application for Permit to Drill (APD) phase of development.
3. Affected Environment and Environmental Consequences (Special Designations)

Coastal Plain Oil and Gas Leasing Program 3-213

Draft Environmental Impact Statement

Lease Stipulation 9 would require lessees, operators, and contractors to conduct a coastline survey in the 

coastal area between the northern boundary of the Arctic Refuge and the mainland, and inland areas 

within 2 miles of the coast. The lessees, operators, and contractors would then be required to develop 

and implement an impact and conflict avoidance and monitoring plan to assess, minimize, and mitigate the 

effects of the infrastructure and its use on these coastal area habitats and their use by wildlife and people. 

This analysis would help reduce potential long-term impacts on the Arctic Refuge MPA natural heritage 

conservation focus that activities under this alternative could present. 

Alternative B includes 1,563,500 acres available for oil and gas leasing and the fewest restrictions on 

potential disturbances to marine and coastal environments through NSO requirements (359,400 acres). 

Impacts on the Arctic Refuge MPA would be greatest under Alternative B, compared with the action 

alternatives, as there would likely be more transportation of materials and supplies for oil and gas 

development in the coastal areas. A more site-specific analysis would occur during the APD phase of 

development.

Alternative C

Under Alternative C, potential impacts would be similar to those described under Alternative B, but more 

constraints would apply, thereby reducing the intensity of impacts on the Arctic Refuge MPA. 

Similar to Alternative B, the lessees, operators, and contractors would be required to develop and 

implement an impact and conflict avoidance and monitoring plan to assess, minimize, and mitigate the 

effects of the infrastructure and its use on these coastal area habitats and their use by wildlife and people. 

Under Alternative C, the Lease Stipulation 9 would also require NSOs, which would not permit 

exploratory well drill pads, production well drill pads, or CPFs for oil and gas development within 1 mile 

inland of the coast. The BLM Authorized Officer may approve infrastructure necessary for oil and gas 

activities in coastal habitats, such as barge landing, docks, spill response staging and storage areas, or 

pipelines, but approval would be on a case-by-case basis, in consultation with the USFWS or NMFS or 

both, as appropriate.

Alternative C presents the same number of acres available for oil and gas leasing as Alternative B, but 

more acres would be subject to restrictions on disturbances to marine and coastal environments (932,500 

acres). Potential impacts on the Arctic Refuge MPA would be greater than under Alternative A due to the 

increase in transportation of materials and supplies for oil and gas development in the coastal areas than is 

likely to occur under current management. A more detailed, site-specific analysis would occur during the 

APD phase of development.

Alternative D

Under Alternative D, 526,300 acres would not be offered for lease sale. Impacts would be similar to those 

as described under Alternative B, but more constraints would apply, thereby reducing the intensity of 

potential impacts on the Arctic Refuge MPA. Lease Stipulation 9 would require NSO 2 miles inland of the 

coast for exploratory well drill pads, production well drill pads, or CPFs for oil and gas development.

Alternative D presents the fewest number of acres available for oil and gas leasing of the action alternatives 

(1,037,200 acres). Impacts on the Arctic Refuge MPA would be more than under Alternative A due to the 

increase in transportation of materials and supplies for oil and gas development in the coastal areas than is 

likely to occur under current management. A more site-specific analysis would occur during the APD 

phase of development.
3. Affected Environment and Environmental Consequences (Special Designations) 

3-214 Coastal Plain Oil and Gas Leasing Program 

Draft Environmental Impact Statement 

Cumulative Impacts 

Past actions and events contributing to cumulative effects in and near the Arctic Refuge MPA have resulted 

primarily from surface-disturbing activities such as oil and gas exploration, development, production, and 

transportation for these uses, including shipping routes for delivery of development materials. Oil and gas 

development near the program area is expected to continue, which would also increase associated 

transportation activities, such as shipping and barging materials and supplies to the program area. The 

greatest contribution to cumulative impacts would be under Alternative B, which would include the largest 

area available for oil and gas leasing and would have the fewest protections for the Arctic Refuge MPA 

conservation focus. 

Wild and Scenic Rivers 

Alternative A 

Under Alternative A (No Action Alternative), no federal minerals in the program area would be offered 

for future oil and gas lease sales. Current management actions for WSRs would be maintained and 

resource trends would continue, as described in the Arctic Refuge CCP (USFWS 2015a). The USFWS 

would manage the four eligible or suitable rivers identified in Table 3-32 to maintain their preliminary 

classifications of wild. There would be no potential direct or indirect impacts on WSRs from post-lease oil 

and gas activities under Alternative A. 

Impacts Common to All Action Alternatives 

Under all alternatives, the BLM would maintain water quality and ensure that authorized uses comply with 

state water quality standards. Management actions that prohibit surface-disturbing activities, including 

NSO, CSU, and TLs near the eligible and suitable WSRs (Table 3-32) would provide varying protections 

for ORVs. This would also ensure that the free-flowing condition of the river remains intact. Any 

developing infrastructure that is installed within 0.5 mile of any eligible or suitable river, such as bridges, 

have the potential to downgrade a river’s eligibility and suitability of a wild river to that of a recreational 

river, which allows some development. General impacts resulting from oil and gas development in the 

program area could include potential soil erosion and habitat fragmentation, which could affect cultural, 

fish, geologic, recreation, and wildlife ORVs. The degree of impacts on WSRs would depend on the 

proximity of development to the WSR. Site-specific analysis would occur during the APD phase of 

development. Impacts on recreation uses are described under Section 3.4.6, Recreation. 

Alternative B 

Under Alternative B, Lease Stipulation 1 would require an NSO standard, which would prohibit permanent 

oil and gas facilities, including gravel pads, roads, airstrips, and pipelines, in the streambed and in the 

described setback distances outlined in Table 3-33. 

Table 3-33

Eligible and Suitable River Setback Distances Under Alternative B 

River Preliminary 

Classification Setback Distance

Canning Eligible From the western boundary of the Coastal Plain to 1 mile east of 

the eastern edge of the active floodplain

Hulahula Eligible and Suitable 1 mile in all directions from the active floodplain

Jago Eligible 1 mile from the banks’ ordinary high-water mark

Okpilak Eligible 1 mile from the banks’ ordinary high-water mark

Source: USFWS 2015b 
3. Affected Environment and Environmental Consequences (Special Designations)

Coastal Plain Oil and Gas Leasing Program 3-215

Draft Environmental Impact Statement

For streams entirely in the Coastal Plain (Map 3-46 in Appendix A), the setback extends to the head of 

the stream as identified in the National Hydrography Dataset.43 On a case-by case basis, essential pipeline 

and road crossings to the main channel would be permitted through setback areas. The setbacks may not 

be practical in river deltas. In these situations, permanent facilities would be designed to withstand a 200-

year flood. 

Overall, because this alternative offers the highest number of acres available for oil and gas leasing adjacent 

to WSRs (41,900 acres) and the fewest restrictions for disturbances to WSRs, Alternative B would have 

the greatest magnitude of impacts on WSRs of all the alternatives. Most of the acres available for oil gas 

leasing (41,700 acres) would be managed as NSO, but 200 acres would be subject only to standard terms 

and conditions and are areas of high HCP. A more site-specific analysis would occur during the APD phase 

of development to further analyze impacts on the free-flowing condition of rivers when locations of 

proposed developments, such as bridges, pilings, or any bank modifications, would be known.

Alternative C

Under Alternative C, the requirements of the Lease Stipulation 1 are the same as those described under 

Alternative B; however, under Alternative C, setback distances for oil and gas development would be 

increased to 2 miles for the Canning and Hulahula Rivers, thereby further reducing the potential for 

impacts on their preliminary classification, free-flowing condition, and ORVs.

Alternative D

Under Alternative D, potential impacts from requiring Lease Stipulation 1 would be similar as those 

described under Alternative B, but the setback distances would be larger for most of the eligible and 

suitable rivers outlined in Table 3-34. Alternative D would have 19,500 fewer acres of eligible and suitable 

WSR corridors in areas available for oil and gas leasing than under Alternative B, which reduces the 

potential for impacts on their preliminary classification, free-flowing condition, and ORVs.

Table 3-34

Eligible and Suitable River Setback Distances under Alternative D

River Preliminary 

Classification Setback Distance

Canning Eligible From the western boundary of the Coastal Plain to 3 miles east of 

the eastern edge of the active floodplain

Hulahula Eligible and Suitable 4 miles in all directions from the active floodplain

Jago Eligible 1 mile from the banks’ ordinary high-water mark

Okpilak Eligible 3 miles from the banks’ ordinary high-water mark

Source: USFWS 2015b

Alternative D would provide further protections to the fish and recreational ORVs of the Canning and 

Hulahula Rivers by implementing ROPs, such as preparing a gravel mine site design and reclamation plan, 

which excludes this activity in areas that support populations of freshwater, anadromous, or endemic fish.

Cumulative Impacts

Past actions and events contributing to cumulative effects in or next to rivers have resulted primarily from 

surface-disturbing activities, such as oil and gas exploration, development, production, and transportation 

for these uses. Activities of oil and gas development near the program area is expected to continue. As a 

 

43National Hydrography Dataset: https://nhd.usgs.gov/
3. Affected Environment and Environmental Consequences (Special Designations)

3-216 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

result, surface-disturbing activities, such as oil and gas development, transportation, and recreation 

affecting rivers, would continue; however, the BLM and USFWS would maintain discretionary authority 

over most land uses and would permit only those actions that would not impair or conflict with river 

systems, reducing cumulative effects on these areas. As development and transportation increases, access 

and use in or next to rivers would also increase. The types of reasonably foreseeable future actions that 

could affect WSRs would be similar to past and present actions. Cumulative impacts may be reduced or 

avoided if future actions or decisions in the program area incorporate measures to reduce or avoid 

impacts on river-related values. Examples are maintaining ORVs or the free-flowing nature of eligible or 

suitable segments in the program area, in accordance with the Wild and Scenic Rivers Act.

Wilderness Characteristics, Qualities, and Values

In general, discussions of potential impacts on wilderness characteristics, qualities, and values tend to be 

more qualitative in nature, measured by the overall visual quality, naturalness, and wildness of an area that 

may be affected by changes to the types and levels of recreation, management actions, and surrounding 

land use. Indicators of wilderness characteristics include changes to the untrammeled and naturalness of 

the program area opportunities for solitude or primitive and unconfined recreation or to other unique or 

supplemental values. 

Alternative A

Under Alternative A, no federal minerals in the coastal plain would be offered for future oil and gas lease 

sales. Current management actions for wilderness characteristics would be maintained and resource 

trends would continue, as described in the Arctic Refuge CCP (USFWS 2015a). Current USFWS 

management focuses on less manipulation of the environment and promoting actions that facilitate 

solitude, self-discovery, self-reliance, remoteness, and primitive or unconfined recreation that would have 

long-term effects on wilderness characteristics. There would be no potential direct or indirect impacts on 

wilderness characteristics from post-lease oil and gas activities under Alternative A.

Impacts Common to All Action Alternatives

Management actions associated with oil and gas activities that would affect the natural appearance of lands 

in the program area could include the presence or absence of roads and trails, use of motorized vehicles 

on those roads and trails, seismic data acquisition using vibroseis trucks, construction of facilities and 

infrastructure for energy development, or other actions that result in or prevent surface-disturbing 

activities. All of these activities affect the presence or absence of human activity and, therefore, could 

potentially affect an area’s naturalness and opportunities for solitude in the program area. 

Alternative B

Alternative B has the most acres available for oil and gas leasing and the fewest restrictions on surface 

disturbance. Potential impacts on wilderness characteristics under Alternative B from oil and gas 

development would be reduced in the areas being managed as NSO (359,400 acres) or areas with TLs 

(585,400 acres). Prohibiting surface-disturbing activities and new developments in certain locations through 

the NSO and TLs would maintain the program area’s apparent naturalness and opportunities for solitude 

or primitive and unconfined recreation. Wilderness characteristics would be eliminated on a site-specific 

basis should new roads be authorized; however, the area would likely retain its overall wilderness

character. Temporary and permanent access routes to a lease area traveled by developers would 

negatively impact the wilderness character of that area. The degree of potential impacts on wilderness 

character would depend on the intensity of development, which would be further analyzed during the sitespecific APD phase of development.
3. Affected Environment and Environmental Consequences (Special Designations)

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Draft Environmental Impact Statement

Alternative C

Under Alternative C, potential impacts would be reduced in the areas being managed as NSO (932,500 

acres) or areas with TLs (317,100 acres); however, wilderness characteristics could be affected by 

development in adjacent areas. Detrimental impacts on wilderness character would be similar to those 

described under Alternative B but to a lesser degree due to more areas not offered for a lease sale and 

being managed with NSO and TL requirements. Overall, Alternative C would make 1,563,500 acres 

available for oil and gas lease sales in the program area, which would affect wilderness characteristics more 

than Alternative A. 

Alternative D

Under Alternative D, there would be no direct impacts on wilderness characteristics from oil and gas 

development in the areas that are not offered for lease sale (526,300 acres), although wilderness 

characteristics could be affected by development in adjacent areas. Potential impacts would be reduced in 

the areas being managed as NSO (708,600 acres) or areas with TLs (204,700 acres). Detrimental impacts 

on wilderness characteristics would be similar as those described under Alternative B, but to a lesser 

degree due to more areas not offered for a lease sale and being managed with NSO and TL requirements. 

Alternative D would also implement the Lease Stipulation 10, which would further protect naturalness and 

opportunities for solitude from visual obstructions and noise in the program area and the adjacent Mollie 

Beattie Wilderness Area by prohibiting surface occupancy and planning to minimize aircraft operations 

flights below 2,000 feet and 3 miles of the southern and eastern boundaries of the Coastal Plain where 

they are next to the Mollie Beattie Wilderness Area.

Cumulative Impacts

Past actions and events contributing to cumulative effects in nearby Wilderness or lands with wilderness 

characteristics have resulted primarily from surface-disturbing activities, such as oil and gas exploration, 

development, production, and transportation on existing routes for these uses. Activities of oil and gas 

development near the program area is expected to continue. As a result, surface-disturbing activities 

affecting the indicators for wilderness characteristics would also continue. The greatest contribution to 

cumulative impacts under the action alternatives would be under Alternative B, which would include the 

most areas being available for oil and gas leasing and have the fewest protections for wilderness 

characteristics from surface-disturbing activities.

3.4.8 Visual Resources

Affected Environment

Visual resources are the visible physical features on a landscape, such as land, water, vegetation, animals, 

structures, and other features. The BLM completed a visual resource inventory (VRI) for the Central 

Yukon Planning Area (BLM 2018h) to the west of the Coastal Plain, using the process in its Visual 

Resource Inventory Handbook (H-8410-1). The VRI was based on physiographic provinces. Although the 

program area is not in the BLM’s Central Yukon Planning Area VRI, the VRI is used to characterize its 

visual resources because physiographic provinces span both areas. 

It is reasonable to characterize the program area using the Central Yukon Planning Area VRI because there 

are negligible differences between the two areas. The three physiographic provinces that span both areas 

are the Arctic Coastal Plain, Arctic Foothills, and Ambler-Chandalar Ridge and Lowland (Map 3-1 in

Appendix A). Physiographic provinces can span large geographic areas, regardless of landownership; the 

transitions between physiographic provinces are generally subtle.
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Scenic quality is a measure of the visual appeal of a tract of land. All public lands have scenic value, but 

areas with the most variety and harmonious composition have the greatest value (BLM 2018h). In the VRI, 

each physiographic province was evaluated to determine its scenic quality. The Arctic Foothills and the 

Ambler-Chandalar Ridge and Lowland divisions received the highest scenic quality rating and have a great 

deal of visual variety, contrast, and harmony. The Arctic Coastal Plain received the second highest scenic 

quality rating and has a moderate amount of visual variety, contrast, and harmony. These three 

physiographic provinces are described below.

The Arctic Coastal Plain physiographic province occurs in most of the program area and covers 1,341,200 

acres, 90 percent of the program area (BLM GIS 2018; Wahrhaftig GIS 1965). It is characterized by a 

smooth, poorly drained plain rising imperceptibly from the Arctic Ocean, with scattered groups of low hills 

to the east and a much flatter section to the west. An abrupt scarp between 50- and 200-feet high 

separates the Arctic Coastal Plain physiographic province from the Arctic Foothills to the south. Pingos 

are sufficiently abundant to give an undulatory skyline. 

All the rivers in this unit feed into the Arctic Ocean, crossing the program area in braided channels and 

deltas, creating contrast between the adjacent landform and vegetation and the barren soils of gravel bars 

and delta areas. Water is a major element of this landscape. This physiographic province has a low 

variation in topographic relief and a low variety of plant species found in the vegetation types of wet and 

moist tundra; low shrubs create some diversities in color, texture, and form between the low-growing 

heaths and shrubs to the tall shrubs of willow and alder.

This Arctic Foothills physiographic province is in the southern part of the program area and covers 

127,600 acres, 8 percent of the program area (BLM GIS 2018; Wahrhaftig GIS 1965). It is characterized by 

rolling plateaus and low linear mountains. It has broad east-west trending ridges, dominated locally by 

mesa-like mountains in the north, while the southern area displays irregular buttes, knobs, mesas, and eastwest trending ridges rising 2,500 feet above the surrounding intervening, gently undulating, tundra plains. 

Major rivers are swift, braided courses across broad gravel flats. There are a few small thaw lakes in the 

river valleys and morainal lakes closer to the program area. 

The Arctic Foothills are crossed by north-flowing braided rivers from sources in the Sadlerochit and 

Romanzof Mountains, creating contrast between the adjacent landform and vegetation and the barren soils 

of gravel bars. The entire area is underlain by permafrost, with ice wedges, stone stripes, polygonal ground, 

and other frost features creating contrast with different vegetation types and barren ground. This 

physiographic province has a moderate variation in topographic relief. It has a low variety of alpine and 

moist tundra species, such as low mat-like herbs, grasses, and heaths. High to medium shrub thickets 

create some diversities in color, texture, and form between the low-growing heaths and shrubs to the tall 

shrubs of willow.

This Ambler-Chandalar Ridge and Lowland physiographic province occurs in the southeast corner of the 

program area and covers 28,000 acres, or 2 percent of the program area (BLM GIS 2018; Wahrhaftig GIS 

1965). It is characterized by east-west trending lowlands with elevations of 600 feet and low passes 3 to 10 

miles wide, with elevations of 4,000 feet. Rolling to rugged ridges 25 to 75 miles long and 5 to 10 miles 

wide rise to 4,500 feet and are characteristic of the northern portion of this unit (Romanzof Mountains). 

Major rivers are tributaries of the Okerokovik and Angun Rivers. Large rock-basin lakes occur in the 

valleys, while floodplains of major streams have thaw and oxbow lakes. The entire area is underlain by 

permafrost. 
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All the rivers in this physiographic province feed into the Arctic Ocean, crossing the program area in 

braided channels and deltas, creating contrast between the adjacent landform and vegetation and the 

barren soils of gravel bars and delta areas. This physiographic province has a moderate variation in 

topographic relief and has a large variety of alpine tundra of low mat-like herbs, grasses, and heaths. It also 

features closed white spruce and birch forests, with high to medium shrubs, and open low-growing black 

spruce and willow shrubs. These create some diversities in color, texture, and form between the lowgrowing heaths and shrubs to the tall shrubs of willow.

Vegetation is an important component in determining the visual quality of an area, represented by species, 

variety, extent, and color. The more variety of species a landscape has, the higher the scenic quality. 

Vegetation visible in the program area is alpine tundra, closed spruce forests, moist tundra, open and lowgrowing spruce, shrub thicket, treeless bogs, and wet tundra.

Cultural modifications are also considered in determining the visual quality of an area. Cultural 

modifications can blend in with or stand out from the surrounding landscape. The program area is still 

primarily a natural landscape, where humans have not substantially changed the scenic quality; however, 

some areas have been modified by the activities of humans. Human-built structures are the most likely to 

be seen and have most modified the natural landscape. These structures primarily exist near the 

community of Kaktovik. 

Native allotments and isolated cabins can also be found in the program area. Most of the buildings outside 

a community are in relative harmony with the landscape, as they are small and made of local materials and 

have primarily natural colors. Other modifications are airports and airstrips. While an airport is more 

developed and has tall structures associated with the site, the profile of an airstrip is low, with landform 

changes that are introduced by brown colors in predominantly green vegetation and more regular lines 

than the surrounding irregular vegetation.

Artificial light sources are mainly limited to the community of Kaktovik along the coast. Dispersed cabins, 

overland travel, recreation, and occasional single- and twin-engine aircraft overflights can also create 

limited, intermittent points of artificial light.

Summer travel is primarily by watercraft; however, snowmachine trails and winter travel routes can be 

seen from elevated locations. Summer all-terrain vehicle travel is low to nonexistent and does not leave 

visible trails.

Seismic exploration, authorized by Congress, was conducted in the program area during the winters of 

1984 and 1985. Exploration during winter causes less damage to tundra vegetation and soils than in 

summer, but damage does occur. Because of the 1984–1985 seismic exploration, known as 2-D (twodimensional) seismic, 1,250 miles of trails made by drill, vibrator, and recording vehicles crisscrossed the 

Coastal Plain tundra. Additional trails were created by D-7 Caterpillar tractors that pulled ski-mounted 

trailer-trains between work camps. The trails were about 4 miles apart. While 90 percent of all trails 

recovered well during the first 10 years after exploration, 5 percent of trails had still not recovered by 

2009, 25 years after the disturbance. This indicates that about 125 miles of disturbed trail remained in 

2009, based on a total length of about 2,500 miles of original trails, both seismic lines and camp-move trails 

(USFWS 2014). These trails disrupt the visual continuity of the expansive, undeveloped landscape. 

Areas identified as having public concern for the scenic quality are known travel routes (especially rivers), 

areas of human habitation, areas of traditional use, and areas near Native allotments. Numerous areas are 
3. Affected Environment and Environmental Consequences (Visual Resources)

3-220 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

noted to have potentially high visual sensitivity. This is because area residents and visitors view the natural 

landscape as very important and have a high level of interest and sensitivity to changes to the natural 

landscape. Visual resources in the program area are viewed by various users of the Arctic Refuge. Views 

can be affected by weather conditions and time of day or year. 

Users include the following:

 Individuals participating in cultural activities (see Section 3.4.2)

 Individuals conducting subsistence activities (see Section 3.4.3)

 Individuals in the village of Kaktovik (see Section 3.4.4)

 Recreationists (see Section 3.4.6 and Section 3.4.7)

 Individuals in route to various destinations (see Section 3.4.9)

Climate Change

Changes to the presence and composition of vegetation and water sources resulting from changes to the 

climate would affect visual resources. Also, an increase in the active layer is expected from a warming 

climate, resulting in greater potential for areas of land subsidence. This would change landforms, as well as 

the vegetation and water sources that the land supports. In turn, the presence and behavior of animals 

viewed in the program area could also be affected. Changes to the physical characteristics of the 

environment and biological resources (i.e., resources that are visible) resulting from changes to the climate 

are described in more detail in the GMT2 Final SEIS (BLM 2018a).

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

visual resources from on-the-ground post-lease activities. Although the BLM administers the oil and gas 

leases, a BLM visual resource management system, VRI and contrast rating was not conducted; however, 

analysis that demonstrates contrast from current conditions would be conducted in subsequent NEPA 

analyses for oil and gas post-lease activities.

In the event of an oil spill, visual resources would be affected by the spill itself, cleanup activities, and any 

residual changes to the landscape. See Section 3.2.11 for more discussion on oil spills. The effects of 

climate change described under Affected Environment above, could influence the rate or degree of the 

potential direct and indirect impacts.

Alternative A

Under Alternative A, no federal minerals would be offered for future oil and gas lease sales. Current 

management actions would be maintained, and resource trends would continue. There would be no new 

direct or indirect impacts on visual resources from post-lease oil and gas activities. 
3. Affected Environment and Environmental Consequences (Visual Resources)

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Draft Environmental Impact Statement

Impacts Common to All Action Alternatives

There would be no impacts on visual resources common to all action alternatives, because actions would 

occur in different areas according to lease stipulations in Chapter 2 (Map 2-2; Map 2-4; Map 2-6; and

Map 2-8 in Appendix A).

Alternative B

Potential impacts on visual resources would occur from oil and gas actions, such as exploration, 

development, and operation. Appendix B identifies oil and gas actions that would likely occur. 

Surface disturbance would affect visual resources. Although the 2,000 acres of surface disturbance at any 

given time that could occur represents 0.13 percent of the program area, it would not be clustered in a 

specific area but would be spread out. There would be various discrete facilities connected by a network 

of gravel or ice roads and pipelines. Approximately 208 miles of gravel road would be needed to connect 

facilities.

In addition to the 2,000 acres of surface disturbance, there would be additional surface disturbance at 

gravel pits that would affect visual resources. Under Alternative B, gravel needs for future roads and pads 

would be approximately 12,818,000 cubic yards. In the low-disturbance case, factoring in additional acreage 

for side slopes and overburden storage, approximately 165 to 176 acres of surface disturbance would be 

required to supply all Coastal Plain gravel needs, in the maximum disturbance case, up to 320 acres of 

surface disturbance would be required to supply Coastal Plain gravel needs.

The future pipelines are supported by vertical members. Only the VSMs, and not the pipelines, are 

included in the 2,000 acres of surface disturbance. As a result, pipelines would add to the disturbance that 

would affect visual resources. Under Alternative B, there could be four CPFs, two in the high HCP area, 

one in the medium HCP area south of Kaktovik, and one in the low HCP area. Under this alternative, the 

assumption is that one CPF could be on state or native lands. Approximately 210 to 250 miles of pipeline 

would be constructed in the Coastal Plain, depending on field design. 

The potential impacts on visual resources from the 2,000 acres of surface disturbance, 12,818,000 cubic 

yards of mined gravel, and 210 to 250 miles of pipelines would affect visual resources. During construction, 

crews may be working concurrently at various locations. Views of the program area would be cluttered 

with construction equipment, construction materials, and temporary support infrastructure. The bold 

colors and geometric, boxy forms of artificial construction vehicles, materials, and equipment would not 

resemble the colors and forms of the surrounding terrain and vegetation. The contrast would be starker 

when the surrounding landscape is white with snow. Rigid vertical elements and horizontal pipelines would 

create various focal points on an open landscape and would not resemble other landscape elements, which 

is mostly short vegetation during the summer. These potential impacts would occur only when 

construction equipment, construction materials, and temporary support infrastructure are present.

Construction and operations would generate dust from vehicle movement, excavation, and wind. Fugitive 

dust would diminish atmospheric clarity. This potential impact on visual resources would persist until the 

dust settles or is blown elsewhere. Dust that settles on snow or ice would change the color of the surface 

from a light or white color to the color of the dust. This impact on visual resources would persist until the 

snow or ice melts and the dust is washed away.

Future construction would use vehicle lights and other lights to illuminate work sites for visibility and 

safety. Also, reflective surfaces on construction equipment and vehicles would create glare. During 
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operations, lights would also be used to illuminate sites for visibility and safety. Also, reflective surface 

structures would create glare. The intensity and amount of light and glare would vary, depending on the 

intensity and angle of sunlight and the time of day and year. This would add artificial points of illumination 

that are nearly absent in the program area. 

The potential impacts from construction lights would occur only when construction equipment and 

vehicles are present. The potential impacts from operations lights would be long term. The most 

noticeable operation lights would be at the pads, airstrip, and barge landing and on taller structures, such 

as the drill rigs. They would be more visible during nighttime and winter, when there are fewer daylight 

hours. Artificial light would, in turn, affect the presence and behavior of animals viewed in the program 

area. Given the negligible artificial light in the program area, operations lights would essentially be the only 

sources of light that would diminish the quality of dark skies.

The ground surface would be disturbed by covering it with gravel, such as for roads and pads. The flat and 

simple gravel base would not resemble the uneven and complex forms of the undisturbed areas 

immediately beyond the surface disturbance. It would also introduce linear and angular forms to a surface 

devoid of discernable forms. The gravel would create a sharp edge that boldly divides disturbed areas from 

undisturbed areas. The gravel roads would also introduce contrasting bands that divide the expansive 

landscape. These would be more prominent in areas where roads do not follow the slope of the terrain. 

Because of a lack of vegetation on the gravel base, the darker smooth gravel base would not resemble the 

rougher vegetation with muted greens and tans beyond the gravel. These changes would, in turn, affect the 

presence and behavior of animals viewed in the program area. These potential impacts would be long 

term.

Use of gravel pits would introduce points of disturbance on the landscape. Instead of adding gravel in the 

case of roads and pads, gravel would be removed from pits and relocated. Due to the number of outcrops 

and surface deposits in the Coastal Plain, pits would be constructed next to facilities or roads used for 

satellite access; additional road construction would not be needed to access gravel mines. The potential 

impacts on visual resources would be similar to the aforementioned impacts from ground disturbance for 

roads and pads; however, instead of having a flat form and straight lines, the pits would form sunken 

depressions and have curved lines. Also, the depth of the pits would allow for the collection of water, 

possibly creating new artificial lakes.

Similar to gravel roads, pipelines would impact visual resources. Pipelines would introduce linear and 

rounded forms to a landscape devoid of discernable forms. The pipelines would also introduce contrasting 

bands that divide the expansive landscape. These would be more prominent in areas where roads do not 

follow the slope of the terrain. The pipelines would stand out against the surrounding muted greens and 

tans. Depending on orientation, the texture of the pipelines would be smooth or bumpy, compared with 

the rougher vegetation. These changes would, in turn, affect the presence and behavior of animals viewed

in the program area. These potential impacts would be long term. 

The gravel pads would be developed with drills and facilities. The bold and rigid forms of the drills and 

facilities would contrast with the indistinct and soft forms of the surrounding undisturbed surface. The 

angular lines of the drills and facilities would create various focal points on an open landscape and would 

not resemble other landscape elements, which is mostly short vegetation during the summer. The vertical 

lines of the drills and facilities would be more visible during daytime and summer, when there are more 

daylight hours and opportunities for silhouetting to occur. The multiple colors of the drills and facilities 

would stand out against the muted greens and tans beyond the gravel pads. The contrast would be starker 
3. Affected Environment and Environmental Consequences (Visual Resources)

Coastal Plain Oil and Gas Leasing Program 3-223

Draft Environmental Impact Statement

during the winter when the surrounding landscape is white this snow. The dispersed drills and facilities 

would create a stippled texture across a landscape with no vertical elements. These changes would, in 

turn, affect the presence and behavior of animals viewed in the program area. These potential impacts 

would be long term. 

An example of what gravel roads, pads, drills, and facilities could look like is depicted in Figures 3-8, 

Visual Resources Photo 1, and 3-9, Visual Resources Photo 2, in Appendix A. 

The above potential impacts disrupt the visual continuity of the expansive, undeveloped, and open 

landscape by establishing dispersed, artificial structures and a network of roads and pipelines, none of 

which are found elsewhere in the program area. The locations of potential impacts on visual resources are 

shown in Map 2-1 in Appendix A. Surface occupancy prohibitions would minimize impacts on visual 

resources associated with, for example, rivers.

Best Management Practices for Reducing Visual Impacts of Renewable Energy Facilities on BLMAdministered Lands (BLM 2013) presents BMPs to avoid or reduce visual impacts associated with the 

siting, design, construction, operation, and decommissioning of utility-scale renewable energy generation 

facilities, including wind, solar, and geothermal facilities. Although the publication is for renewable energy 

generation facilities, the BMPs are also directly applicable to oil and gas facilities. Implementing the BMPs or 

using them as mitigation would reduce impacts on visual resources. 

Minimizing unnecessary disturbances through BMPs or mitigation is important to minimizing impacts on 

visual resources and, likely, other resources. This is because many impacts would persist until disturbed 

areas are reclaimed. Following the completion of reclamation, the reclaimed acreage would be regained 

against the 2,000-acre surface disturbance limit at any given time. This could allow for additional 

development of future fields as initial development is reclaimed; however, arctic vegetation does not 

regenerate quickly, extending the timeline for reclaiming disturbed areas, as evidenced by the time it is 

taking disturbances to recover from seismic testing in 1984 and 1985.

Alternative C

The potential impacts on visual resources would be similar to Alternative B; however, Alternative C would 

use approximately 12,643,000 cubic yards of gravel (175,000 cubic yards fewer than Alternative B) and, 

therefore, would involve less surface disturbance that would affect visual resources. Alternative C would 

also occur in different locations; see Map 2-3 in Appendix A. For example, in the long term, three CPFs 

would be built, two in the high HCP area and one in the medium HCP area south of Kaktovik. Also, 

approximately 213 miles of gravel road would be needed to connect facilities. Surface occupancy 

prohibitions would minimize impacts on visual resources associated with, for example, rivers, which is 

more than Alternative B.

Alternative D

The potential impacts on visual resources would be similar to Alternative B; however, Alternative D would 

use approximately 12,626,000 cubic yards of gravel (192,000 cubic yards fewer than Alternative B); 

therefore, it would involve less surface disturbance that would affect visual resources. Alternative D would 

also occur in different locations, compared with Alternative B; see Map 2-5 and Map 2-7 in Appendix 

A. For example, in the long term, two CPFs would be built, one in the high HCP area and one in the 

medium HCP area south of Kaktovik. Also, approximately 218 miles (Alternative D1) or approximately 

217 miles (Alternative D2) of gravel road would be needed to connect facilities. Surface occupancy 
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prohibitions would minimize impacts on visual resources associated with, for example, rivers and 

wilderness areas, which is more than Alternatives B and C.

Cumulative Impacts

The program area is the geographic scope of the analysis area for cumulative impacts. Impacts on visual 

resources in the program area from past actions occurred from the 1984–1985 seismic exploration. About 

125 miles of disturbed trail remained in 2009, based on a total length of about 2,500 miles of original trails 

(both seismic lines and camp-move trails) (USFWS 2014). The remaining trails create visible lines and faint 

variations in texture across the undeveloped landscape. Future seismic exploration would likely have more 

visible impacts on visual resources, because the trails would be several hundred feet apart, instead of 3 to 

4 miles apart during the 1984–1985 testing. 

Past and future actions and the action alternatives would have potential cumulative impacts on visual 

resources. Given the durations of actions and the extent of construction and operation, the cumulative 

impacts on visual resources from the action alternatives would overshadow all other impacts on visual 

resources. The effects of climate change described under Affected Environment above, could influence the 

rate or degree of the potential cumulative impacts. Alternative A would have no cumulative impacts on 

visual resources.

3.4.9 Transportation

Affected Environment

The affected environment for transportation in the program area is as described in the Arctic Refuge CCP 

(USFWS 2015a); a summary is provided below. 

Except for in the village of Kaktovik, there are no designated roads in the program area; cross-country 

motorized travel, other than over snow, is prohibited. Year-round access to and in the program area is 

primarily via aircraft. There is a gravel landing strip at Kaktovik that supports air travel from outside the 

program area and serves as the departure point for aircraft traveling inland. Arctic Village and Venetie have 

gravel runways, which are owned by the Native Village of Venetie Tribal Government. Aircraft are 

permitted to land in the program area. Several short airstrips are used by small fixed-wing aircraft for 

landing on wheels to transport recreationists and researchers. Landing opportunities depend on 

topography, water levels, snow conditions, and weather. Kaktovik, Arctic Village, and Venetie all have 

regularly scheduled air service, although the frequency of service varies.

During the summer and fall, motorized and nonmotorized boats provide access along the program area’s 

northern boundary with the Beaufort Sea. Motorized and nonmotorized rafts are used on the Kongakut 

and Hulahula Rivers to access recreation and subsistence opportunities in the central portions of the 

program area. Improved boat technology, such as inflatable pack rafts that have shallow hulls, support river 

transportation in shallower areas that were previously unreachable by boat. 

In the winter and spring, as snow cover conditions permit, overland travel via snowmachines is possible, 

especially along frozen waterways and the edge of the Beaufort Sea. Most snowmachine travel in the 

program area originates and terminates at Kaktovik. Snowmachine use in the program area is primarily for 

subsistence use, local travel, and recreation.

Climate Change

Increasing climate temperatures and associated loss of snow cover would limit the locations and times of 

year when ice roads could be viable in the program area. Less snow cover and soft tundra surface 
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conditions could result in transportation infrastructure being concentrated in smaller areas. This could 

intensify traffic on those roads and increase the potential for conflicts with other modes as more visitors 

frequent the area.

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

transportation from on-the-ground post-lease activities.

Potential impacts on transportation would be from management that increases or decreases opportunities 

for new transportation infrastructure, management of the timing, location, and type of vehicle use, and 

from changes in the level of public and subsistence use access in the program area. The magnitude, 

duration, and spatial extent of impacts on transportation would vary, based on the location and extent of 

transportation infrastructure, season and snow cover conditions, and other management, such as seasonal 

TLs for certain uses that would modify the nature of travel via certain modes. 

Protective measures that specify the type and placement of new or expanded transportation infrastructure 

would affect the size, design, and location of the proposed infrastructure. For example, managing areas as 

NSO would preclude new transportation infrastructure. Lease stipulations that limit the placement of 

permanent transportation infrastructure, depending on season and snow cover conditions, would 

seasonally reduce private transportation opportunities for oil and gas development, while minimizing 

potential conflicts with the public and subsistence users. 

Management that limits vehicle use based on location, vehicle type, or season can limit or preclude access 

for certain travel modes while increasing access for others. For example, seasonal or location-specific 

limitations on vehicles used for mineral development would minimize the potential for impacts on other 

travel modes used for subsistence uses or recreation. 

New transportation infrastructure, such as seasonal or year-round roads, airstrips, or other facilities, 

would not be available for motorized public use. Accordingly, new infrastructure would have the potential 

to enhance nonmotorized public access only. The effects of climate change described under Affected 

Environment above, could influence the rate or degree of the direct and indirect impacts.

Alternative A

Under Alternative A, no oil and gas leasing program would take place in the program area; there would be 

no potential direct or indirect impacts on transportation from post-leasing oil and gas activities in the 

program area. Existing resource trends and impacts on transportation would continue to occur.

Impacts Common to All Action Alternatives

Under all action alternatives, lease sales would result in approximately the same number of subsequent 

gravel and ice roads, airstrips, fueling stations, and a barge landing area to support new oil and gas 

development. In areas subject to NSO, new roads, airstrips, and other transportation-related 
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infrastructure would be precluded. Under all alternatives, there would be no gravel roads constructed 

during the exploratory drilling phases; potential direct and indirect impacts described above associated 

with gravel roads would occur only in the long term. 

Under all alternatives, lease stipulations would limit the number of new roads to the amount necessary to 

support exploration and production activities. Protective measures would also require the free movement 

of caribou and subsistence users. These measures would maintain access for subsistence users; however, 

because transportation infrastructure would be closed to non-subsistence public users, there would be no 

increase in public access. In some areas, roads may obstruct cross country, over snow travel via other 

modes, or nonmotorized travel, such as skiing or hiking. Compared with Alternative A, there would be no 

change in public access from the construction of private landing strips.

Alternative B

Under Alternative B, anticipated transportation infrastructure development and associated potential 

impacts following lease sales would be as described under Impacts Common to All Acton Alternatives. Making 

available 1,563,500 acres for lease sales, 77 percent (1,204,000 acres) of which would be available for 

surface use, would allow for the construction of program-related roads throughout nearly the entire 

program area. Up to 208 miles of new gravel roadways would support private travel for oil and gas 

production, while ice roads would provide additional private access for exploratory drilling and would be 

the primary means of overland access during the winter and spring for developers. 

Alternative C

The nature and types of potential impacts under Alternative C would be as described under Impacts 

Common to All Action Alternatives, above. Applying NSO to 59 percent (922,500 acres) of the area available 

for lease would limit the locations where new roads and other transportation infrastructure could be 

placed. This would minimize the areas where new transportation infrastructure associated with oil and gas 

development would conflict with public access; however, because approximately 213 miles of gravel roads 

are anticipated, there would be a higher density of roads in areas available for surface use. 

Alternative D

Under both subalternatives of Alternative D, not offering 526,300 acres for lease sale and applying an NSO 

stipulation to 68 percent (708,600 acres) of the area available for lease would limit the locations where 

new roads and other transportation infrastructure could be placed. Compared with Alternative A, there 

would be no change in transportation conditions on approximately 1,251,900 acres (79 percent) of the 

program area that would either not be offered for lease sale or offered but managed as NSO. The nature 

and types of potential impacts described under Impacts Common to All Action Alternatives would be in the 

328,600 acres (32 percent of leased areas; 21 percent of the program area) available for leasing with 

surface use.

Cumulative Impacts

Cumulative impacts on transportation would be the result of past, present, and reasonably foreseeable 

future actions that would increase or decrease opportunities for new transportation infrastructure, change 

the types of vehicles available for use, or change the level of public and subsistence use access in the 

program area. Past, present, and reasonably foreseeable future actions described in Appendix F that 

would cumulatively affect recreation include increasing visitation to the program area for recreation and 

mineral exploration, energy and infrastructure development, and climate variability. 
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Under all action alternatives, future oil and gas exploration and development, combined with increased 

visitation, would increase the potential for roads and other infrastructure to conflict with public access. 

These potential conflicts would be more likely along river corridors and the Beaufort Sea coastline, where 

visitor concentrations are highest. The effects of climate change described under Affected Environment

above, could influence the rate or degree of the potential cumulative impacts.

3.4.10 Economy

Affected Environment

This section describes the existing socioeconomic conditions in areas that could be affected by 

exploration, development, and production in the Coastal Plain from the leasing program. All NSB 

communities, the NSB, and the state of Alaska are included for comparison purposes. Arctic Village and 

Venetie, which are communities outside the NSB, are also included in the discussion due to their reliance 

on subsistence resources in the program area.

This section provides baseline information on the following socioeconomic indicators: employment, 

income, population, and fiscal conditions (government revenues and expenditures). In addition, information 

on regional and village corporations and a description of local businesses, local facilities, and public

infrastructure is presented. 

Population

Table O-1 in Appendix O shows population estimates by the Alaska Department of Labor and 

Workforce Development (ADOLWD) by community/area from 2010 to 2017 (ADOLWD 2018a). At the 

NSB and state levels, population growth from 2010 to 2017 has been modest, at 4 percent. The 

communities of Kaktovik and Atqasuk have seen a slight decline in population, while all other communities 

in the NSB have experienced varying degrees of population growth. Arctic Village, Nuiqsut, and Point Lay 

have seen the most growth, each with more than 20 percent growth in population over this time frame.

Local Employment and Income

Table O-2 in Appendix O provides employment and wage data by community (ADOLWD 2018b). The 

local government sector employs the highest number of workers in all communities. Private sector 

employment is highest in Utqiaġvik, accounting for 43 percent of total resident employment, followed by 

Point Hope and Nuiqsut, where the private sector employs 39 and 38 percent of the resident workers. 

These communities also have the highest total wages in the region. Venetie has the highest rate of 

unemployment, with only 57 percent of residents employed. Artic Village and Venetie both show total 

community wages much lower than communities in the NSB. Employment and income at the borough and 

state levels are discussed in the regional economy and state economy sections, below.

Local Economy: Kaktovik

Kaktovik lies on the north shore of Barter Island on the Beaufort Sea coast, in the Arctic Refuge. It is the 

community closest to the program area. The following provides more details on the economy, 

infrastructure, and fiscal conditions of Kaktovik. 

Kaktovik is the easternmost village in the NSB and is situated on approximately 1 square mile of land (630 

acres) and water on the northeastern shore on the Kaktovik Lagoon. A detailed description of Kaktovik’s 

history is provided in the Kaktovik Comprehensive Development Plan (NSB 2015a). Residents in Kaktovik 

are predominantly Iñupiat (88 percent of the population). According to population estimates published by 

ADOLWD (2018a), 234 people lived in Kaktovik in 2017. The NSB’s most recent census report indicated 
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there were 262 residents in Kaktovik in 2015, while ADOLWD estimated 243 residents in that same year 

(NSB 2015b).

Economic and employment opportunities are limited in Kaktovik because of its remoteness. Sixty-seven 

percent of the working residents are employed by the local government sector, and 33 percent work in 

the private sector, primarily by Native corporations and their affiliates (ADOLWD 2018c). The Borough 

and NSB School District provide most of the local employment, and the Village Corporation and city 

government also provide some employment opportunities. Besides the local government sector, residents 

are also employed in construction, finance, leisure and hospitality, and other sectors (Table O-3 in

Appendix O). Short-term construction or skilled labor jobs with the oil industry, private construction 

firms, and the ASRC and its subsidiaries and summer jobs related to tourism can also be found. 

Subsistence hunting, fishing, and whaling play a major role in the local economy (NSB 2018b).

There are 15 active businesses operating in Kaktovik, including the KIC, a hotel, a bed and breakfast, a 

store, and several tour and adventure businesses (ADCCED 2018a). The KIC runs the local store, which 

provides groceries, clothing, first-aid, hardware, camera film, and sporting goods. Fishing and hunting 

licenses, guide services, and aircraft and repair services for autos and aircrafts are locally available (NSB 

2018b).

The KIC is the Village Corporation established pursuant to ANCSA. KIC owns approximately 92,000 

acres of surface lands in and around the community. All of the corporation’s land is in the Arctic Refuge 

boundary. Kaktovik Holdings, LLC is wholly owned by KIC and has three subsidiaries—Kaktovik 

Enterprises, LLC (which provides services on power generation, storage, and control), Kaktovik 

Environmental, LLC (which provides a variety of environmental engineering, consulting, and construction 

services), and Kaktovik Telecom, LLC (which provides full-service, turn-key solutions for all 

telecommunications and tower needs). The company’s operations are in Alaska, the lower 48, and Guam 

(Kaktovik Holdings, LLC 2018).

The estimated per capita income in Kaktovik in 2016 was $21,925, which was lower than the $34,191 per 

capita income for the state (ADOLWD 2018d). The median family income was $66,250 compared to 

$87,365 for the state. The disparity between Alaska and Kaktovik income is important to note, given the 

high cost of living in Kaktovik.

The community incorporated as a second-class city in 1971.44 For fiscal year (FY) 2018, Kaktovik adopted a 

$1.46 million operating budget (ADCCED 2018a) (Table O-4 in Appendix O). Seventy-six percent of 

the City’s operating revenues are generated by local funds, such as taxes, services, and enterprise 

revenues, which account for 57 percent of the locally generated revenues. Outside sources, including the 

community revenue sharing from the State and other grants contribute, 24 percent to their operating 

budget.

The NSB provides public electricity, piped water, sewer services, and trash pickup to the community. 

Kaktovik has a public safety building and a fire station equipped with fire engines and an ambulance. The 

Harold Kaveolook School offers education from pre-school through grade 12 and adult basic education. 

 

44A type of general law municipality or city that has taxation powers but with certain limitations. Section 29.45.100 

of the Alaska Statutes provides that limitations on the amount of property tax that may be collected apply only to 

taxes for operating expenses and not to taxes collected to pay for bonded indebtedness. A special limitation on 

taxation by second-class cities is that the city cannot levy property taxes exceeding 2 percent (20 mills) of the 

assessed value of property in the city in any one year (Office of the State Assessor 2017; ADCCED 2018a).
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Communications include phones, internet, mail, public radio, and cable television. The community also has 

a health clinic staffed by community health aides. 

Transportation to the village is provided by scheduled airlines and air taxi service from Barrow and 

Fairbanks. Freight arrives by cargo plane and barge (during the summer). Air travel provides the only yearround access to Kaktovik. Marine transportation provides seasonal access to Kaktovik. 

Regional Economy

The program area is in the NSB jurisdiction. Its population is predominantly Iñupiat. In 2017, the NSB was 

estimated to have a population of 7,248 living year-round in its eight communities. In addition to the 

permanent local population, 2,601 oilfield workers lived in Prudhoe Bay in 2017, contributing to the total 

regional population of 9,848.

Oil and gas exploration and development is the primary industry in the NSB and the largest employer of 

the region’s industrial workforce, including nonresidents. In 2016, approximately 14,000 oil and gas jobs 

(including oilfield services companies) were reported in the NSB (McDowell Group 2017). These jobs are 

based in the North Slope, in self-contained work sites that are far from the NSB communities; however, 

few of the jobs are held by residents of the NSB. In 2016, 55 oil and gas jobs were held by NSB residents, 

which amounts to less than 0.5 percent of the total oil and gas jobs based in the North Slope. Total 

earnings from the oil and gas extraction sector, which amounted to about $864 million, accounted for 69 

percent of the total wages earned for all industries in the North Slope in 2016 (ADOLWD 2018e); 

however, a large portion of the earnings are not spent in the local and regional economy, as most workers 

reside permanently outside the NSB.

The unemployment rate in the NSB in 2016 was 6.5 percent, which was roughly the same as the statewide 

unemployment rate of 6.6 percent (ADOLWD 2018f). 

The local government sector (primarily the NSB government) is the largest employer of North Slope 

residents. In 2016, the local government sector employed 1,988 residents, accounting for 61 percent of the 

resident workers in the region.

The NSB government was formed in 1972. It provides a wide range of public services to all of its 

communities, including capital projects. Its total general fund revenue for the FY 2017 to 2018 is 

approximately $376 million; 97 percent of the total general fund is sourced from property and sales taxes 

(ADCCED 2018b). Oil and gas property taxes are the primary source of revenue for the NSB 

government. In 2016, State-assessed oil and gas property in the NSB was valued at approximately $20.27 

billion. The NSB received about $373 million in oil and gas property taxes (a tax levied on oil and gas 

infrastructure), accounting for 97 percent of the total property tax ($386 million) collected by the NSB 

that year (Office of the State Assessor 2017).

The ANCSA regional and village corporations in the North Slope are also important economic players in 

the region, employing residents participating in the oil and gas service industry and creating additional 

wealth in the region. ASRC is the regional ANCSA corporation that is owned by and represents the 

business interests of the North Slope Iñupiat. ASRC provides an array of oilfield engineering, operations, 

maintenance, construction, fabrication, regulatory and permitting, and other services for oil and gas 

companies. 
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Village ANCSA corporations in the NSB also are active in the oil and gas sector. For additional details on 

the North Slope ANCSA corporations, see the GMT2 Final SEIS, which is incorporated here by reference 

(BLM 2018a).

State Economy

The petroleum industry is a major sector in the Alaska economy. Economic events related to the 

petroleum industry have pervasive effects across the state’s economy. The drop in oil prices in late 2014 

resulted in a significant decline in State government revenues. In early 2015 and in 2016, the State 

government lost 1,200 jobs, while the oil and gas sector lost 2,900 jobs. Other sectors were also affected; 

for example, the professional and business services sector lost 1,600 jobs and the construction sector lost 

1,400 jobs (Wiebold 2018).

In 2016, the oil and gas extraction sector contributed 10 percent of the state’s total gross domestic 

product ($50 billion), the highest among all industries in Alaska (Bureau of Economic Analysis 2018). This 

does not include the oil and gas support industries and the oil pipeline transportation sector.

In 2016, there were 11,100 direct oil and gas jobs in the state (Fried 2017). In addition to the direct jobs, 

there are thousands of indirect jobs in security, catering, accommodations, facilities management, 

transportation, engineering services, and logistics, which support the oil and gas industry but are not 

categorized as oil and gas jobs. The most recent estimate for total direct and indirect jobs associated with 

the oil and gas industry in Alaska was 45,575 jobs in 2016; these jobs contributed $3.1 billion in total 

annual wages in Alaska (McDowell Group 2017).

The State government is highly dependent on oil revenue; its budget is sensitive to oil price and oil 

production. Petroleum-related revenues include oil and gas property tax, petroleum corporate income tax, 

oil and gas production taxes, mineral bonuses and rents, and oil and gas royalties (State and federal). The 

State’s Unrestricted General Fund revenue is now forecast to be $2.3 billion in FY 2018 and $2.3 billion in 

FY 2019. The revenue forecast is based on an annual Alaska North Slope oil price of $61 per barrel for FY 

2018 and $63 for FY 2019. The State expects oil prices to stabilize in the low $60s per barrel in real 

terms. The revenue forecast is also driven by an expectation for North Slope oil production to average 

521,800 barrels per day in FY 2018 and increasing to an average of 526,600 barrels per day in FY 2019 

(ADOR 2018). 

In FY 2017, the State of Alaska received $12.9 billion in revenues from all sources: petroleum45 ($1.7 

billion), non-petroleum46 ($1.2 billion), investment ($6.8 billion), and federal revenues ($3.2 billion). The 

General Fund Unrestricted Revenues (GFUR), the funds that are available for general state activities and 

capital projects, amounted to $1.35 billion, with petroleum revenues accounting for 65 percent of the 

unrestricted revenue. Petroleum royalties contributed $681 million to the GFUR, while petroleum 

property and oil and gas production taxes contributed $120 million and $134 million (ADOR 2018). 

National Economy

Development in the Coastal Plain is anticipated to contribute to the nation’s economy through job 

creation, increase in federal revenues, and increase in energy security (or reduced reliance on imported 

petroleum products). Comments from the public scoping for this EIS stated the importance of the 

 

45Petroleum revenues include State taxes and royalties from oil production on both State and federal lands.

46Non-petroleum revenues include excise taxes, non-petroleum corporate income tax, fisheries tax, and other 

State taxes.
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economic contributions of a leasing program in the Coastal Plain to the national economy and also the 

importance of preserving the region for its unique wildlife, wilderness, and recreation values.

Climate Change

Climate change could negatively affect the economy of the North Slope because villages are primarily 

located at or near sea level; any increase in mean sea level or violent storms may require relocating part or 

all of villages and subsistence camps. This would have a negative economic impact on the villages, the NSB, 

and the State if villages had to be relocated.

Direct and Indirect Impacts

Direct impacts from issuing oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 

would include the federal government receiving bonus bids and rental payments from leasing; however, 

these payments cannot be quantified because there is not enough specificity at this time regarding the lease 

terms. There would be no other direct impacts on the environment from leasing because by itself a lease 

does not authorize any on the ground oil and gas activities; however, a lease does grant the lessee certain 

rights to drill for and extract oil and gas subject to further environmental review and reasonable 

regulation, including applicable laws, terms, conditions, and stipulations of the lease. The impacts of such 

future exploration and development activities that may occur because of the issuance of leases are 

considered potential indirect impacts of leasing. Such post-lease activities could include seismic and drilling 

exploration, development, and transportation of oil and gas in and from the Coastal Plain. Therefore, the 

analysis is of potential direct and indirect impacts on the economy from on-the-ground post-lease 

activities.

The potential economic impacts are evaluated with respect to jobs, income, and government revenues at 

the local, regional, and statewide level. As noted in Affected Environment, quantifying nonmarket values 

associated with the Arctic Refuge is not part of this analysis. The temporal scope of the analysis covers 

potential impacts of leasing activities as well as the subsequent exploration, development, and production 

activities that could ensue following the leasing program through 2050. The effects of climate change 

described under Affected Environment above, could influence the rate or degree of the potential direct and 

indirect impacts.

Alternative A

Under Alternative A, no federal minerals in the Coastal Plain would be offered for future oil and gas lease 

sales. The economic conditions at the local, regional, and state level, as discussed in Affected Environment, 

are therefore expected to continue. Alternative A would not meet the purpose of this EIS to inform BLM’s 

implementation of PL 115-97, including the requirement to hold multiple lease sales and to permit 

associated post-lease activities. There would be no potential direct or indirect economic impacts under 

this alternative from post-leasing oil and gas activities.

Impacts Common to All Action Alternatives

The potential economic effects of the proposed leasing program are evaluated based on the hypothetical 

development scenario (Appendix B), which is a set of assumptions that reflect possible industry-wide 

exploration, development, and production activities. The scenario represents only a possible picture of the 

future. It is likely that different activities and timing would occur in the future, as each company that would 

participate in the leasing program would have its own unique plans about how to identify and recover oil 

and natural gas resources. Furthermore, market conditions change over time and can affect outcomes. It is 
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difficult to anticipate what the actual development pattern would be, but the assumptions used in this 

analysis provide a reasonable basis to evaluate potential future economic effects.

PL 115-97 mandates that the first lease sale occur within the first 4 years of the implementation of the law 

and a second lease sale be held within 7 years. The hypothetical development scenario assumes that the 

first lease sale would occur within one year of the ROD and that industry would aggressively lease and 

explore the tracts offered in the lease sales. Several industry groups would likely independently explore 

and develop new fields. 

The hypothetical development scenario also assumes that oil deposits of significant volumes would be 

discovered in the program area, resulting in the construction of up to 3 CPFs—one in the western portion 

of the high HCP area, one in the eastern portion of the high HCP area, and one in the medium HCP area 

south of Kaktovik (this CPF could be on Native lands). Development in distant and remote areas like the 

program area would take time; this analysis assumes that first oil production from the first CPF would 

occur 10 years from the first lease sale.

The exploration phase of each anchor field and associated satellite fields can occur over a span of 10 years.

Exploration includes seismic surveys, well-site surveys, and drilling of exploration wells. Following 

discovery, the development phase normally takes 3 to 6 years. Development includes obtaining permits, 

fabricating production modules, constructing roads, pipelines, and other on-site facilities, transporting 

materials and facilities to the site, and implementing environmental studies and monitoring. 

The production phase can start after development of a CPF and would continue until the end of life of 

each oil field. Production activities are the continued development-well drilling, production ramp-up, 

operations and maintenance of processing and other on-site facilities, well-workovers, infill drilling, and 

other support activities, including environmental monitoring. For a more detailed discussion of the typical 

exploration, development, and production activities occurring in the Alaska North Slope, see the NPR-A 

IAP/EIS (BLM 2012), which is incorporated here by reference.

For the purposes of this analysis, the projections based on the hypothetical development scenarios on 

potential economic impacts are carried through 2050 only. Within this time frame, only two anchor fields 

would be developed, with each one having its own CPF. A third CPF could be developed but would occur 

after 2050. Abandonment activities would also occur after this time frame. The first anchor field is 

assumed to have about 400 million barrels of proven producible reserves. 

Six smaller satellite fields would be developed around this first anchor field, with more modest producible 

reserves of about 100 million barrels each. The assumption is that the second anchor field would be 

discovered and developed several years after the first anchor field and would have four smaller satellite 

fields that would be developed by 2050 and tie into its CPF.

A future natural gas transport pipeline from the North Slope to southcentral Alaska could be expected, 

where the gas would be transformed into liquefied natural gas. Liquified natural gas transported to global 

markets from the North Slope would be expected to come from established fields with proven reserves 

initially. If proven gas resources are discovered in the Coastal Plain, they would be transported to the 

pipeline to maintain pipeline capacity as the primary fields are depleted. Companies exploring the Coastal 

Plain would likely focus on crude oil discoveries, which are of higher value than natural gas. Any cooccurring gas produced with oil would be reinjected to maintain reservoir pressure or used to 

manufacture natural gas liquids to blend and transport with the oil (Appendix B).
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Potential indirect effects related to oil or natural gas development would include the spin-off effects of 

spending; these are also referred to as multiplier effects. They include additional economic effects that 

would result from in-state industry spending on goods and services, workers’ spending of wages, and 

government spending of royalties and tax payments during the construction and operations phases. 

Like other development projects in the North Slope, many of the materials and equipment are expected to 

be purchased outside Alaska and would be shipped to the specific job site. Still, a significant portion of the 

total future development costs, both capital and operating costs, would be paid to companies in Alaska for 

construction, transportation, logistics, and other oilfield services.47 Some of the contracts for construction 

and operations and maintenance of the facilities are expected to be awarded to Alaska owned and 

operated companies, including the North Slope regional and village corporations. These payments to local 

businesses would in turn generate additional economic activity in the state, resulting in indirect economic 

effects in the form of additional business sales, employment, and labor income. Likewise, potential local 

spending by workers as well as government spending of revenues would also generate multiplier effects 

statewide.

Potential impacts on subsistence activities could have impacts on cost of living for some families through 

the need to substitute store-bought foods for subsistence obtained foods. The potential impacts on 

subsistence are discussed in Section 3.4.3.

The following are some of the major assumptions and data sources used in the economic impact analysis:

 The hypothetical development baseline scenario provided the basis for modeling the potential oil 

and gas activities and time frames, which included assumptions of the number of CPFs, gravel 

roads and ice road construction, other on-shore facilities, including pipelines, and size of oil field 

discoveries.

 Estimates of production volumes by year were based on the size of each oil field and a production 

decline rate of 8 percent per year. This information was used to calculate potential royalty 

payments and other State and the federal government tax payments.

 Oil price projections were obtained from the Energy Information Administration’s 2018 Annual 

Energy Outlook (EIA 2018). This information was used to quantify potential royalty payments and 

other fiscal effects.

 Construction costs were estimated based on costs provided in Attanasi and Freeman (2009) and 

cost data from other North Slope development projects. This information was used to calculate 

direct and indirect employment and income effects of construction spending as well as potential 

government revenues, including oil and gas property taxes and state corporate income taxes.

 Estimates of annual operating expenditures are based on the prevailing operating costs in the 

Alaska North Slope—a fixed $/well/year estimate of $300,000 and a variable operating cost 

component of $10 per barrel of oil. These were default values in the ADNR cash flow model 

 

47The amount of direct in-state industry spending is based on purchase coefficients contained in the Alaska 

IMPLAN model. These in-state purchase coefficients reflect the availability of locally produced products in the state 

and are calculated from the trade model for the state in IMPLAN. The extraction of natural gas and crude 

petroleum sector, drilling oil and gas wells sector, and support activities for oil and gas operations sector require 

or demand different goods and services from other sectors of the economy. All have varying percentages of instate purchases, with the highest percentages in the services sector and the least in the manufacturing sectors. 

There is not one specific in-state purchase percentage applied to the total direct oil and gas industry spending; 

rather the purchase coefficients in the model vary by the type of goods and services purchased. 
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(ADNR 2018b). This information was used to calculate the direct and indirect employment and 

income effects, as well as tax revenues during the production phase.

 Tariffs and transportation costs were used to calculate netback prices which are the bases for 

calculating royalty payments. Data on existing tariffs and transportation costs are from the ADNR 

Revenue Sources Book (ADNR 2018b).

The IMPLAN model for Alaska was used to estimate the potential direct and indirect employment and 

income effects of the various exploration, development, and production activities (MIG, Inc. 2018). The 

cash flow model developed by the ADNR (modified to fit the development and production assumptions 

used in this analysis) was used to generate the projected royalties and government taxes.

Jobs

Future exploration, development, and production activities in the program area for the two anchor fields 

and their associated satellite fields are estimated to generate about 250 direct jobs per year during 

exploration activities, 480 direct jobs per year during the development phase, and 730 direct jobs per year 

during the production phase. Exploration activities are anticipated to peak on the fifth year of the 

exploration phase, generating an estimated 650 jobs that year. The peak year of the development phase is 

estimated to generate 680 jobs, and 1,150 jobs are estimated to be required during the peak production 

year. Jobs during the exploration and development phases are seasonal and temporary, while production 

phase jobs are year-round and would last through the economic limit of the life of each oil field.

Table 3-35 also provides estimates of the indirect jobs that could be generated as a result of industry 

spending on exploration, development, and production activities.

Table 3-35

Projected Direct and Indirect Jobs: Exploration, Development, and Production Phases

Effects Jobs (Average Number of Part-Time and 

Full-Time Jobs)

Annual 

Average Peak

Direct Exploration 250 650

Development 480 680

Production 730 1,150

Indirect Exploration 190 560

Development 3,180 4,570

Production 3,160 4,970

Source: Northern Economics, Inc 2018 estimate

The assumed future exploration, development, and production activities are expected to generate job 

opportunities for workers residing in the North Slope, other areas of Alaska, and outside Alaska. The jobs 

shown in Table 3-35 are total jobs that could be available for workers from any region, including outside 

Alaska. It is uncertain at this time how many workers from North Slope communities would participate in 

the direct oil and gas activities. Historically, very few North Slope residents participate in direct oil and gas 

activities in the North Slope. As noted in Affected Environment, above, less than 0.5 percent of the total oil 

and gas jobs in the North Slope in 2016 were held by NSB residents.

In 2016, 27.5 percent of the workers in the oil and gas extraction sector and 36.8 percent of the workers 

in oilfield services sector were from out of state (ADOLWD 2018g). These nonresident percentages have 

been consistent in the last decade, and it is possible that these levels would continue; however, it is also 
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possible that, with more education and training, the future composition of the oil and gas workforce could 

be different. 

Oil field development projects in the North Slope typically require specialty tradesmen and construction 

workers with the skills and experience in ice roads, pipeline construction, facilities construction, and 

drilling. North Slope residents who live near existing oil developments have participated in oil and gas jobs, 

such as ice road monitors, camp security and facilities operators, and subsistence representatives. The 

ADOLWD and the oil and gas industry have training programs geared to developing special skills required 

in oilfield services. This is expected to create more employment opportunities for residents of Kaktovik, 

given their proximity to the program area.

Population

No changes to population growth rates or increased population are expected in Kaktovik as a result of 

migration of industry workers for post-lease oil and gas activities. Workers are expected to commute to 

the work camps on a rotational basis and are not expected to relocate to Kaktovik or other North Slope 

communities.

At the state level, there could be potential increases in population, particularly in south-central Alaska, as 

nonresidents who would be working year-round at the oil company headquarters in Anchorage are 

expected to relocate to the region. Statewide population, however, would be affected by other economic 

and demographic factors and would be hard to predict.

Labor Income

The estimated labor income effects resulting from future exploration, development, and production of oil 

resources in the Coastal Plain region are presented in Table 3-36. The table shows projected direct and 

indirect annual average and peak labor income by phase.

Table 3-36

Projected Direct and Indirect Labor Income: Exploration, Development, and 

Production Phases

Effects Labor Income (Millions of Dollars 2017) Annual Average Peak

Direct Exploration $29 $77

Development $97 $140

Production $125 $197

Indirect Exploration $10 $30

Development $214 $307

Production $212 $307

Source: Northern Economics, Inc 2018 estimate

As noted above, it is uncertain at this time how much of this total potential labor income would accrue to 

the local workforce, regional workforce, and Alaska workforce. Currently, about 36 percent of the total 

wages and salaries in the oil and gas extraction sector and 28 percent of wages and salaries in the oilfield 

services sector go to out-of-state workers (ADOLWD 2018g). It is possible that these percentages could 

change over time.
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Economic Sectors

Industry spending during future exploration, development, and production phases would increase the level 

of activity in the Alaska economy, not just in the oil and gas extraction sector but also in other economic 

sectors, including oil field support services; construction, engineering, environmental, and other 

professional technical services; air, water, ground, and pipeline transportation sectors; retail and wholesale 

trade sectors; rental and leasing sectors; warehousing; accommodations and food services; and 

communications, IT support, management, and other business support sectors.

Government Revenues

Future petroleum development in the program area is expected to generate revenues to the NSB 

government, the State, and the federal government from royalties, income taxes, production taxes, and 

property taxes. The projected annual average and total government revenues by type of revenue are 

presented in Table 3-37. The total represents the estimated revenues through 2050. Property taxes 

would start accruing during the development or construction phase, while royalties and other taxes would 

be generated during the production phase.

At the local level, the City of Kaktovik could receive increased bed tax revenues with higher hotel 

occupancy during the initial years of development. Also, local consultations are likely going to occur and 

while mobilization of construction equipment would be occurring, and even during operations. The City of 

Kaktovik has just started implementing a 12 percent bed tax for hotel/motel accommodations. The change 

in the level of hotel occupancy is difficult to quantify at this point because the timing and amount of local 

consultations and mobilization activities are uncertain and may vary.

Table 3-37

Projected North Slope Borough, State, and Federal Government Revenues

Government Revenues (in Millions of Dollars, 2017) Annual Average Total

NSB Property Taxes $52 $1,192

State Royalties $894 $21,463

State Taxes $2,151 $49,473

Federal Royalties $894 $21,463

Federal Taxes $462 $11,082

Source: Northern Economics, Inc 2018 estimate

At the regional level, the NSB government is anticipated to receive increased property tax revenues. 

Property tax payments would start to accrue during the construction phase. The State imposes oil and gas 

property taxes at a rate of $20 million. A local tax is levied on the State’s assessed value for oil and gas 

property in the borough and is subject to local property tax limitations. The current NSB property tax 

rate is $18.5 million (the state portion of the property tax is $1.5 million). Total NSB property tax 

revenues through 2050 are estimated to amount to about $1,192 million (in 2017 dollars).

At the State level, there are several potential sources of revenues that could be generated from petroleum 

development in the program area. State government revenues during the production phase would include 

royalty payments, corporate income tax payments, severance tax payments, and continuation of property 

tax payments. The property tax payments would be based on the assessed valuation of the facilities 

developed on-site. 

The state property tax rate is $20 million. A local tax is levied on the State’s assessed value for oil and gas 

property in a city or borough and is subject to local property tax limitations. The current NSB property 
3. Affected Environment and Environmental Consequences (Economy)

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tax rate is $18.5 million; hence, the State portion of the property tax is $1.5 million. State corporate 

income tax is calculated as 9.4 percent of the Alaska share of worldwide income for each corporation. The 

model, however, does not take into consideration corporate worldwide income (which is unknown at this 

time) but simply evaluates all the costs and revenues and the resulting State income tax, given the 9.4 

percent income tax rate. 

Severance tax or production tax payments are based on the current tax rate of 35 percent of the 

production value, which is the value at the point of production, less all qualified lease expenditures (net 

value). Qualified lease expenditures include certain qualified capital and operating expenditures. Total 

estimated state taxes and royalties are shown in Table 3-37.

Any additional oil production in the North Slope extends the life of the TAPS and increased revenues for 

the State. Oil revenues depend on the oil production levels and the price of oil at the wellhead. Higher 

TAPS throughput results in lower pipeline tariffs and higher wellhead value. The State would receive higher 

revenues resulting from oil production in the region.

The assumed federal royalty rate is 16.67 percent of the wellhead value for oil. The expectation is that 50 

percent of the federal royalties are shared with the State. Potential annual average State royalties could 

amount to about $894 million.

Other government revenues expected to accrue during the construction phase include ROW payments 

and gravel royalties; these estimates are not available at this time.

Local Public Infrastructure and Local Businesses

Given that the oilfield workers would be housed in work camps located at the CPFs and drill pads and 

away from the community of Kaktovik, there would be no anticipated increase in demand for local services 

and other public infrastructure in the community of Kaktovik.

Consultations and mobilization during leasing, permitting, and exploration and through the development 

phase could increase the number of people going in and out of the community. These could create 

temporary increases in demand for accommodations, travel services, retail services, and other personal 

services.

Local businesses, including KIC and its subsidiaries, could receive greater revenues during the exploration, 

development, and production of petroleum resources in the program area.

Alternative B

The potential economic effects under Alternative B would be similar in magnitude to the economic effects 

discussed in the section above. There could be unquantifiable differences in the level of economic effects, 

however, because of the lease stipulations and ROPs under Alternative B, as follows: 

 Additional consultations with local, state, and federal stakeholders

 Additional studies that would be required for permitting

 Delays in exploration and development due to closures of certain environmentally sensitive areas

 Reductions in surface disturbance

 Additional facilities that could be required to address limited road access to the CPFs

 Additional infrastructure, such as bridges, that could be required to avoid environmentally 

sensitive areas
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Some of these actions could result in higher employment and income effects due to additional 

expenditures that would have to be in compliance with the standard operating procedure, including 

additional spending on consultation, studies, and required orientation programs. Some of these actions 

could also result in delays in exploration, development, and production and would therefore also delay 

potential employment and income effects, as well as revenues that could accrue to the local, State, and 

federal governments. For example, some of the lease stipulations could result in deferred revenues and 

taxes due to delays in drilling or lower taxes and revenues due to increased costs, which reduce severance 

taxes and profits.

Alternative C

The potential economic effects under Alternative C would be similar to the economic effects discussed in 

the section above. As noted above, there could be differences in economic effects from the lease 

stipulations, but these effects would be difficult to quantify at this time; this is because the level and timing 

of activities could vary, depending on how each industry player would react under this alternative.

Alternative D

The potential economic effects under Alternative D would be similar in magnitude to the economic effects 

discussed in the section above; however, the higher level of restrictions under this alternative could reduce 

the amount of oil produced, could defer or reduce potential government revenues and taxes, and could 

result in lower economic revenues, relative to the other action alternatives. 

Cumulative Impacts

Oil production from the North Slope is projected to decline from 522,000 barrels per day in FY 2018 to 

493,000 barrels per day in FY 2027, as production from existing fields continues to decline (ADNR 2018b). 

Production from newer development projects, such as Point Thomson, GMT1, GMT2, and Willow, are 

expected to contribute to oil production in the next 10 years. 

Point Thomson was brought online in April 2016, with production facilities designed to produce and 

reinject (cycle) 200 million cubic feet per day of gas and produce up to 10,000 barrels per day of natural 

gas condensate. This project opens the eastern North Slope to development and would lead to increased 

production into TAPS. 

Project construction for GMT1 is well underway and is already producing oil. Peak workforce at GMT1 

during construction is estimated to be 700 and the estimated peak monthly production is estimated to be 

between 25,000 to 30,000 barrels of oil per day (BOPD) (gross). GMT2 could begin construction in early 

2019, with first oil planned for late 2021. The development plan is for up to 48 wells, with 36 wells being 

permitted initially. The project is estimated to cost $1.5 billion to develop, and peak production is 

expected to be 35,000 to 40,000 BOPD. The master development plan for the Willow Project was 

submitted to the BLM in 2018 to start the EIS process. The proposed action includes the construction, 

operation, and maintenance of a CPF; the construction of up to five well pads, with up to 50 wells on each 

pad; roads for field access and in-field transportation; an airstrip; a system of pipelines; and a temporary 

island in the Beaufort Sea to facilitate the delivery of modules for the project. 

Willow is estimated to hold between 400 and 750 million barrels of recoverable oil equivalent, with peak 

production rates of about 100,000 barrels per day. The development is estimated to cost $2 billion to $3 

billion over 4 to 5 years after a final investment decision is made. Oil production could start in the 2024 to 

2025 timeframe (Bailey 2018).
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The oil and gas leasing program and subsequent exploration, development, and production activities in the 

program area would increase oil production in the North Slope and, increase TAPS throughput, increase 

economic activity at the local, regional, and State level due to direct industry spending on labor, materials, 

and services, increase government revenues from shared royalties, tax payments such as property taxes, 

corporate income taxes, severance taxes, and other local taxes, increase job opportunities for Alaskans, 

including residents of communities in the NSB, and increase labor income in regions where industry 

spending would occur and where the oil and gas workforce resides.

There would be no additional economic effects under Alternative A since there would be no petroleum 

development without leasing. The non-use and passive use values of the Coastal Plain and its other 

ecosystem service values (although not quantified in this analysis) would maintain their current value and 

would not be diminished by oil and gas leasing development.

The potential cumulative impacts on the economy under the action alternatives would be similar; however, 

there may be differences in employment, income, and revenues due to differences in how the various lease 

stipulations under each of the action alternatives would affect industry response and spending. The nonuse and passive use values of the Coastal Plain and its other ecosystem service values (although not 

quantified in this analysis) would be diminished from their current value by oil and gas leasing development.

The effects of climate change described under Affected Environment above, could influence the rate or 

degree of the potential cumulative impacts.

3.4.11 Public Health

Affected Environment

The BLM NPR-A IAP/EIS (2012, Section 3.4.12) analyzed the public health status in the NSB, based on 

demographic and health infrastructure through 2010; it is incorporated by reference in this EIS. The BLM 

analysis considers all eight villages of the NSB, a broader perspective than the analysis for this EIS, which 

focuses primarily on the village of Kaktovik, due to its proximity to the program area. 

Under NEPA regulations, projects that require an EIS must include an analysis of health impacts associated 

with federal actions. The discussion below is consistent with recent NEPA analyses on the North Slope by 

including a broad description of health conditions (BLM 2012). The wider scope of analysis results from 

changing expectations for what constitutes a sufficient examination of human health in the regulatory 

process. North Slope residents, the NSB municipality, and others have advocated strongly for the inclusion 

of a more systematic and broad-based appraisal of human health-related issues in the EIS process. This was 

corroborated by comments received during the scoping period. This EIS does not analyze specific 

developments in the program area; therefore, a health impact assessment was not completed for this 

analysis. Health impact assessments are expected to be developed for future development projects that 

would require additional NEPA analysis. 

Oil and gas development has had mixed impacts on the North Slope. Specific to oil and gas development, 

the NSB Baseline Community Health Analysis Report (NSB 2012, page 45) provides the following 

commentary:

The health impacts of oil and gas development in the NSB are complex, as it has touched 

many aspects of community life in the region. Following the formation of the NSB, oil and 

gas revenues have created employment opportunities, provided money for essential 

services and infrastructure, and raised the average household income. An influx of outside 

interests and money can also create conflict, alter social structure, and divide 
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communities, affecting community well-being. Real and potential impacts on the 

environment and subsistence are also ongoing sources of tension and concern.

The following descriptions summarize baseline public health data for the NSB and Kaktovik, the 

community closest to the program area.

Accidents and Injuries

Accidents are an important cause of injury and death in Kaktovik and the North Slope in general. Off-road 

vehicles accounted for 18 percent of injury deaths among North Alaska Natives, most which are 

snowmachine accidents (AN EpiCenter 2009). Motor vehicle accidents are not common in Kaktovik, due 

to the limited road system (NSB 2015a).

Suicide was the leading cause of injury death for the NSB between 1999 and 2005, comprising 39 percent 

of all injury deaths. This is among the highest suicide rates in Alaska, at 73.5 deaths per 100,000 (AN 

EpiCenter 2009). 

Food, Nutrition, and Subsistence Activity

Subsistence is important for the people of Kaktovik for both food and cultural sustenance (see Section 

3.4.3). The village’s subsistence area extends into the program area and adjacent land and waters bounded 

on the south by the headwaters and the tributaries of the Hulahula, Jago, and Salderochit Rivers, west to 

the Sagavanirktok River and Dalton Highway, east to Demarcation Bay, and north about 60 miles in the 

Beaufort Sea. 

Kaktovik’s primary subsistence resources are caribou, sheep, bowhead whale, bearded seal, fish, and 

waterfowl (NSB 2015a). Approximately 60 percent of the subsistence harvest consists of marine mammals. 

Kaktovik residents hunt for bowhead whales from July to September in offshore areas between 15 and 30 

miles from shore, between Camden Bay and Tapkaurak Lagoon. Bearded seal and ringed seal are other 

marine mammal sources. Hunting occurs from March to September, with most success in July and August 

between Prudhoe Bay and Demarcation Bay, with a maximum distance of 30 miles from the shore. 

Caribou are another primary source of subsistence harvest and are hunted along the coast during the 

summer by boat and inland during the winter by snowmachine. Caribou can be hunted year-round, but 

mostly during July and August, when they are in their prime condition. Arctic cisco and Arctic char/Dolly 

Varden are the primary fish species and are harvested primarily in July and August, during the summer 

migration of the fish along the coast from the Mackenzie River to the Colville River (NSB 2015a).

According to 2015 NSB census data, 42 percent of Kaktovik Iñupiat residents depended on subsistence 

foods for over half of their diet, and 13 percent of Kaktovik Iñupiat households depended on subsistence 

foods for almost all their diet. Sharing the harvest is an important objective in subsistence lifestyles; 42 

percent of households shared half or more of their harvests with others in the community (NSB 2015b). 

Food security can be a source of stress in NSB households, particularly Iñupiat households. In the 2015 

NSB census, 37 percent of household heads reported difficulty getting healthy food for meals, and 25 

percent reported that there were times when there was not enough food to feed the household (NSB 

2015b). For Kaktovik residents, 10 percent of household heads reported there were times when there 

was not enough food for the household. Most NSB household heads (71 percent) indicated that this was 

due to a lack of store-bought foods (NSB 2015b). 
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Exposure to Potentially Hazardous Materials

Residents of the NSB are concerned about environmental contamination, particularly as it relates to 

contamination of subsistence food sources. In a recent survey, 44 percent of Iñupiat village residents 

reported concerns that fish and animals could be unsafe to eat (Poppel et al. 2007).

Air quality issues in rural Alaska villages include diesel emissions, indoor air quality, road dust, solid waste 

burning, and wood smoke. NSB residents are also concerned about air pollution generated by oil and gas 

activities. Assessments of air pollution in Nuiqsut, 173 miles west of Kaktovik, have found that pollutant 

concentrations are generally well below the NAAQS (BLM 2018a). Researchers also sampled air and water 

for VOCs in Nuiqsut. Over half of the air samples included VOCs, but none exceeded federal and Alaska 

air quality standards. None of the water samples had VOC levels that exceeded ADEC standards (BLM 

2018a).

The ADEC identified 22 potentially contaminated sites in Kaktovik. These were former landfills and dump 

sites, the tank farm terminal, and DEW Line network facilities. Five of the sites are still active; the cleanup 

for the remaining 17 sites has been completed (ADEC 2018c), although cleanup thresholds could have 

changed since the date of closure (ADEC 2017b).

Public Utilities and Services

Public utilities are an important component of community health and wellness. Safe drinking water and 

sewage treatment prevent the spread of many serious transmissible diseases. Insufficient heating has been 

linked with poor health outcomes, particularly in children and older people (BLM 2012). 

The NSB provides utilities for all Kaktovik. Public facilities include water and sewer treatment plants and a 

landfill. Kaktovik’s infrastructure has had several upgrades in recent years. A buried water and sewer 

treatment system for the village was completed in 2003. Freshwater sources are small thaw lakes and 

ponds, a few deep stream channels, and Fresh Water Lake, which is about 0.7 mile from the village. Water 

is pumped in the summer into the treatment plant and then into two storage tanks for winter use (NSB 

2015a). Ninety-nine percent of Kaktovik residents have running water, compared to 92 percent for the 

NSB (NSB 2012).

The NSB operates a small power plant on the west side of Kaktovik. The facility generates electricity using 

diesel fuel and distributes electricity to the village through aboveground utility lines. The power plant is 

relatively new and should be sufficient for the next 15 to 25 years, assuming normal maintenance and 

upgrades (NSB 2015a).

Health Services Infrastructure

The NSB and the Arctic Slope Native Association are jointly responsible for delivering health services to 

residents. Kaktovik maintains a clinic that is staffed by medical personnel via the Community Health Aide 

Program. This clinic does not have a physician or physician’s assistant in residence. The closest hospital to 

Kaktovik is the Samuel Simmonds Memorial Hospital in Utqiaġvik, 311 miles northwest. Cases are referred 

to Fairbanks or Anchorage if they cannot be adequately treated in Utqiaġvik (BLM 2012). 

The leading clinical assessments made by community health aides in the NSB villages including Kaktovik in 

2005–2006 include respiratory or ear-nose-throat problems, injuries, and preventative care (NSB 2012). 

The primary outpatient visit diagnoses at Samuel Simmonds Memorial Hospital were managing chronic 

health conditions, such as high blood pressure, diabetes, and arthritis, and treating acute respiratory 

infections (NSB 2012). 
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Climate Change

Further disruptions to subsistence patterns from global environmental and climatic changes could 

foreseeably have adverse effects on Kaktovik resident health, including changes to subsistence harvests; see 

Section 3.4.3. Changes to subsistence migration patterns and changing weather patterns and sea ice 

conditions could make travel more hazardous, increasing the risk of injury and trauma. Widespread 

thawing of permafrost would affect Kaktovik residents’ ability to store meat in deep cellars. This would 

increase the amount of spoiled food and the potential for food-borne illness (USACE 2012).

Direct and Indirect Impacts

Issuance of oil and gas leases under the directives of Section 20001(c)(1) of PL 115-97 would have no 

direct impacts on the environment because by itself a lease does not authorize any on the ground oil and 

gas activities; however, a lease does grant the lessee certain rights to drill for and extract oil and gas 

subject to further environmental review and reasonable regulation, including applicable laws, terms, 

conditions, and stipulations of the lease. The impacts of such future exploration and development activities 

that may occur because of the issuance of leases are considered potential indirect impacts of leasing. Such 

post-lease activities could include seismic and drilling exploration, development, and transportation of oil 

and gas in and from the Coastal Plain. Therefore, the analysis is of potential direct and indirect impacts on 

public health from on-the-ground post-lease activities.

Potential impacts to public health and safety from post-lease activities could stem from a number of 

different pathways: safety, diet and nutrition, environmental contaminants, economic impacts, and public 

health services. 

Alternative A

Under Alternative A, no federal minerals in the Coastal Plain would be offered for future oil and gas lease 

sales. Alternative A would not establish and administer a competitive oil and gas program for the leasing, 

development, production, and transportation of oil and gas in and from the Coastal Plain in the Arctic 

Refuge. Current management actions would be maintained, and resource trends would continue, as 

described in the Arctic Refuge CCP (USFWS 2015a). Under Alternative A, no impacts on public health and 

safety would occur from oil and gas development in the program area.

Impacts Common to All Action Alternatives

This section discusses potential impacts on public health and safety that are common to all alternatives. 

Common types of direct and indirect effects on public health associated with oil and gas development in 

the program area are changes in subsistence harvest patterns; increased travel time for subsistence 

harvesting; changes in air and water quality and noise pollution; increases in Kaktovik resident, village of 

Kaktovik, and NSB revenue; and changes in public health service use and access.

This section does not assess health impacts. It analyzes various leasing alternatives and does not analyze 

specific developments. Health impact assessments would be used during future NEPA analyses of specific 

development projects after the lease sales are complete.

Safety

Indigenous populations in the Arctic and elsewhere have very high rates of accidents and trauma. Clinical 

assessments at the Kaktovik clinic include a high percentage of injuries and accidents (NSB 2012). The high 

incidence of accidents is partly due to the risks associated with subsistence activities, especially given the 

hostile environment of northern Alaska (BLM 2012).
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Future oil and gas development in the program area has the potential to increase the risk of injuries and 

accidents during subsistence activities. Oil and gas development in the program area is expected to affect 

caribou herd movements and to alter subsistence hunting patterns for Kaktovik residents (see Section 

3.4.3). The disturbance of wildlife by industrial activity is likely to result in hunters traveling farther afield 

and possibly into unfamiliar terrain to harvest stocks. 

Future oil and gas development is not expected to increase the Kaktovik road system from its current 

extent but would develop permanent and seasonal roads in the program area. If Kaktovik residents have 

easy access to program-related roads, it is likely that some would use the roads to access subsistence 

harvesting areas, particularly when overland snowmachine travel is difficult. As oil and gas development 

expands and access to program roads increases, so would the risk of accidents and injuries (BLM 2012). 

Access approvals for recreation or non-subsistence uses in the program area would be dealt with at the 

APD phase when users apply for use permits.

Under all the action alternatives, the main impact on accidental injuries would result from either altered 

travel patterns or increased travel time for subsistence activity. Under all the action alternatives, future 

development of fixed facilities in areas of traditional use is likely to result in voluntary displacement of 

subsistence. This potential impact would be most significant if large numbers of hunters avoid territory 

close to Kaktovik. All action alternatives have the same potential for development close to the village of 

Kaktovik.

Diet and Nutrition

Health impacts could result from changes in diet and nutrition when future oil and gas developments affect 

populations reliant on subsistence resources. Dietary changes could result from the displacement or 

contamination of food sources, avoidance or loss of traditional harvesting lands, and increased reliance on 

store-bought foods. Consumption of traditional foods is associated with reduced risk of chronic diseases, 

such as diabetes, hypertension, cardiovascular disease, and stroke (BLM 2012). Store-bought food in rural 

Alaskan villages tends to have low nutritional value, and the cost of buying nutritious foods is often 

prohibitively expensive. When subsistence resources become less accessible and people rely more heavily 

on store-bought foods, the nutritional value of the diet decreases, and the risk of chronic diseases 

increases.

In addition, 10 percent of Kaktovik household heads reported times when there was not enough food for 

their household (NSB 2015b). Studies have found a variety of adverse health impacts from food insecurity, 

including obesity, poor psychological functioning among children, poor cardiovascular health, and lower 

physical and mental health ratings. The costs associated with harvesting subsistence resources, the year-toyear variability in subsistence harvest, and the high cost of store-bought food all contribute to high rates of 

food insecurity.

The likelihood of impacts on subsistence harvests under all action alternatives is discussed in Section 

3.4.3. Impacts on caribou migratory patterns and avoidance of development areas are expected from oil 

and gas development. Kaktovik residents are also likely to avoid areas of heavy development. Threats to 

subsistence activities and harvest patterns are a primary source of ongoing stress in North Slope 

communities. Avoidance of productive land could reduce harvests and exacerbate dietary and nutritional 

outcomes independent of any direct impact on the animals themselves. Any reductions in the success of 

subsistence harvests for Kaktovik residents would accelerate the transition from subsistence resources to 

store-bought foods, worsening nutritional outcomes and food insecurity.
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Environmental Contaminants

Activities associated with future oil and gas exploration and development can affect human health via 

changes to air and water quality or an increase in noise pollution. 

AIR QUALITY 

Air quality impacts are similar for all action alternatives, as each alternative permits up to 2,000 acres of 

disturbance and the point sources and their locations are unknown at this point. Section 3.2.2, Air 

Quality, describes the impacts of potential oil and gas development on air quality. The primary sources of 

airborne emissions are construction dust, road dust, vehicle and machinery emissions, flaring and venting 

of gas, burning of refuse, and emissions from power generation and other sources. The air pollutants 

emitted by these activities have been linked with a range of health effects, including asthma, chronic 

bronchitis, decreased pulmonary function, and cardiovascular events (BLM 2012).

Both the EPA and the State of Alaska have established legal limits for air pollution to protect public health 

(Section 3.3.2). Air quality changes are most likely to occur at and near the areas of oil and gas 

development. If the development areas are distant from Kaktovik, potential impacts on the health of 

Kaktovik residents as a whole are unlikely to be seen and overall impact on human health is likely to be 

low. Those most likely to be affected are those who stay in cabins or other residences near development 

areas. In particular, dust from construction or traffic could be an issue. 

Based on previous development projects and studies on the North Slope, the overall potential impact on 

human health is likely to remain low as all action alternatives are likely to be below applicable air quality 

standards for all phases of development (Section 3.2.2); however, people who are particularly vulnerable 

to respiratory problems (such as children, the elderly, and people with certain chronic illnesses) could 

experience health problems at locations or during episodes with poorer air quality.

WATER QUALITY 

As described in Section 3.2.10, future oil and gas development could affect water quality through 

accidental spills or releases or as the byproduct of construction, excavation, or human habitation. Water 

quality has the potential to affect the health of Kaktovik residents through contamination of drinking water 

or through contamination of rivers and waterways near subsistence cabins or camps. 

Water could be contaminated through accidental discharges into watercourses that supply human water 

sources, particularly in areas of cabins or transient subsistence uses of the land; however, the likelihood of 

any such discharge occurring with the resultant human exposure is low, given the lease stipulations and 

BMPs around waste prevention, handling, disposal, spills, and public safety. If exposure occurred under 

these circumstances, the exposure would likely be short term and intermittent and would be unlikely to 

lead to significant health effects. No development is allowed on Barter Island, so no impacts on Kaktovik’s 

drinking water supply are expected.

CONTAMINATION OF FOOD SOURCES

Section 3.4.3 states that there is a low likelihood of contamination of subsistence food sources, with the 

possible exception of contamination through an oil spill. This is supported by current low measurable 

impacts, despite high levels of oil and gas activities on the North Slope in the past. Although studies have

found elevated levels of contaminants in several species, the levels found in subsistence foods in the North 

Slope area appear at present to be generally low and are lower than what would trigger public health 

concern (NSB 2006). Except in the event of a major spill (see Section 3.2.11), there are likely to be only 

negligible health effects from contamination of food sources as a result of any of the action alternatives. 
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Despite the current safety of traditional foods in the program area, Kaktovik residents remain concerned 

that oil and gas activities could potentially increase contaminant loads of subsistence foods to a level that 

would threaten human health. The perception of contamination may result in stress and anxiety about the 

safety of subsistence foods and avoidance of subsistence food sources, with potential changes in nutritionrelated diseases as a result. These health impacts (perceived or real) arise regardless of whether or not 

there is any contamination at levels of toxicological significance; the impacts are linked to the perception of 

contamination, not to measured levels. Monitoring contaminants in subsistence foods (ROP 8) would help 

address subsistence user concerns related to contaminants and identify potential human health issues.

NOISE

Noise levels could increase due to future construction or operation of oil and gas facilities, resulting in 

potential effects, ranging from minor irritation and annoyance to more severe health outcomes. Given the 

likely location of development away from Kaktovik, individuals at cabins or camps near developments 

would be most affected. Noise from future air traffic and other sources could create a nuisance around 

camps and cabins, possibly reducing their use as a base for subsistence harvests. Development-related 

noise could cause irritation, annoyance, or sleep disturbance among individuals who experience it (BLM 

2012). Until site-specific development activities are proposed, the extent of this effect is not possible to 

determine.

Economic Impacts on Health

Economic growth and employment that are associated with future resource development can exert 

impacts on the health of populations. Increased income for Kaktovik residents and families has the 

potential to improve health through increases in the standard of living, reductions in stress, and 

opportunities for personal growth and social relationships (BLM 2012); however, there are negative 

impacts of economic growth as well. With other oil and gas development in the NSB, income and 

employment have been found to be associated with an increased prevalence of social pathologies, including 

substance abuse, assault, domestic violence, and unintentional and intentional injuries (BLM 2012).

Most oil and gas industry jobs in the North Slope have gone to transient workers, and oil and gas 

development in the program area is not expected to directly employ a large proportion of Kaktovik 

residents. The primary employment and income impacts on Kaktovik residents is anticipated to be indirect 

as a result of increased revenues to the NSB and village of Kaktovik, which allows for increased program 

spending and hiring. For a full description of socioeconomic impacts, see Sections 3.4.4.

Under all action alternatives, the increased revenue for the NSB and village of Kaktovik would allow for 

increased funding of existing health and social programs and an increase in indirect employment of 

Kaktovik residents (Section 3.4.10). Improvements to Kaktovik infrastructure would also be expected as 

a result of increased funding; possible capital projects are listed in Kaktovik’s comprehensive development 

plan (NSB 2015a).

Public Health Services

Future oil and gas development would occur outside of Kaktovik and would be fully self-contained. Local 

Kaktovik health care services would not be affected by an influx of oil and gas workers because the worker 

camps would provide health services to them. There could be a slight increase in accidents due to changes 

in subsistence harvesting patterns, but these would be sporadic and well in the capacity of the Kaktovik 

local clinic and Samuel Simmonds Memorial Hospital in Utqiaġvik.
3. Affected Environment and Environmental Consequences (Public Health)

3-246 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Anticipated tax revenues from oil and gas development under all action alternatives would support the 

current level of health care services in Kaktovik and should not affect demand. Episodic increases in 

disease occurrence, such as respiratory disease resulting from poor air quality, have the potential to cause 

short-term strain on the health care system; however, no such occurrences are likely under any of the 

action alternatives.

Alternative B

Under Alternative B, the types of potential impacts on public health and safety would be the same as those 

described above (Impacts Common to All Action Alternatives). The duration of all types of impacts would be 

long term for the duration of operation in the program area. 

Under Alternative B, 721,200 acres of PCH calving habitat area would be available for leasing, which would 

result in the greatest potential impact on calf survival and overall PCH numbers out of all alternatives. 

Caribou is a primary subsistence species for Kaktovik residents. Any threat to herd numbers or 

contamination of meat would increase the likelihood and severity of health impacts resulting from changes 

in diet and nutrition and would exacerbate the current trends away from a traditional diet. In addition, 

changes to caribou herd numbers or movement could increase the distance and time that Kaktovik 

hunters travel and increase the potential for accidents or injury.

Alternative C

The types of potential impacts under Alternative C would be the same as those described under 

Alternative B. Under Alternative C, 476,600 acres of PCH calving habitat area would be NSO. In addition, 

Alternative C would impose greater TLs on human activity in the PCH post-calving habitat area than 

Alternative B. Potential impacts on PCH numbers would be reduced under Alternative C, compared with 

Alternative B, reducing the potential for impacts on diet and nutrition from reductions in subsistence 

harvests.

Alternative D

The types of potential impacts under Alternatives D1 and D2 would be the same as those described under 

Alternative B; however, the intensity of subsistence impacts would be substantially less under Alternatives 

D1 and D2. Less than half of the calving grounds offered for sale under Alternative B would be offered for 

sale under Alternatives D1 and D2, and more lands would be subject to development and TLs. Alternative 

D2 would be somewhat less likely to affect subsistence uses and resources, when compared with 

Alternative D1. This is because of the greater restrictions under Alternative D2 on development in 

caribou summer habitat. Protection of caribou calving areas would decrease the likelihood of diet changes 

and slow the trend from traditional foods to store-bought food.

Cumulative Impacts

As described in Appendix F, there are a significant number of activities planned or approved on the NSB 

and the program area. The village of Kaktovik and its residents have been buffered by the surrounding 

Arctic Refuge, which has limited oil and gas development in the immediate vicinity. Air and water quality in 

and around the village remains relatively untouched, subsistence harvests have not been noticeably 

affected, and the influx of oil and gas revenue for the NSB has improved infrastructure in the village. There 

is still a high rate of accidents and injury, primarily because subsistence activities and food security for 

Kaktovik households remain a concern.

Future development offshore in the Beaufort Sea could affect Kaktovik residents by interfering with marine 

mammal movement patterns. This could increase the risk of accident and injury by changing the 
3. Affected Environment and Environmental Consequences (Public Health)

Coastal Plain Oil and Gas Leasing Program 3-247

Draft Environmental Impact Statement

subsistence harvest patterns and requiring more time on the water to harvest animals. In addition, the 

success rate for harvesting marine mammals could decline, reducing subsistence food for Kaktovik 

households and increasing food security concerns.

The action alternatives would have similar contributions to the cumulative effects on public health for 

Kaktovik residents with the pathways described above. All action alternatives would continue the ongoing 

transition from a subsistence-based diet to one that includes store-bought food. This is because oil and gas 

development could interfere with the success of subsistence activities. Alternatives C and D would lessen 

the potential negative impacts of oil and gas development by protecting the PCH calving range, including 

TLs in post-calving range and insect relief areas and larger buffers on important waterways and the coastal 

area. Alternative B would allow the most widespread industrial activity, with resulting potential impacts on 

subsistence harvest efforts, and could accelerate the transition away from a traditional diet and the 

subsequent increases in health risks.

Current levels of contamination of traditional food and water supplies in the region are low and, in the 

absence of major spills or accidents, are unlikely to significantly change under any action alternative. 

Rates of accident injury are very high for Kaktovik residents. Disruptions to subsistence harvest patterns 

and conflicts between uses of the land can lead to an increased risk of injury in hunters. This is in addition 

to the risk of unpredictable weather and sea ice conditions associated with climate change. All action 

alternatives would increase the likelihood of potential injury due to industrial use of land previously used 

only for subsistence activity.

Increasing economic development and revenues to the local governments under all the action alternatives 

would support maintenance and improvement of Kaktovik infrastructure and systems. The direct and 

indirect employment resulting from oil and gas exploration and development, combined with the 

government and Native corporation revenues, are all major contributors to the positive health changes in 

the NSB over the last few decades. The activities under all action alternatives would contribute 

substantially to these ongoing impacts, with greater levels of employment generally more likely to be 

associated with good health.

3.5 UNAVOIDABLE ADVERSE EFFECTS

Unavoidable adverse effects would be expected to occur during oil and gas exploration, development, and 

production. Many adverse impacts could be lessened by mitigation but would not be completely eliminated 

or reduced to negligible levels. Some are short-term impacts, while others may be long-term impacts. 

These have been described for each resource in Sections 3.1 to 3.4. Depending on the location and 

extent of oil and gas operations and adopted mitigation, unavoidable adverse impacts could include the 

following:

 Loss of soil productivity and sand and gravel resources, largely from construction of roads and 

pads and gravel mine development

 Loss of petroleum resources

 Increased risk of spills

 Changes in surface flow and drainage patterns due to construction of roads and pads and surface 

water withdrawal for ice roads, dust abatement, and operations

 Loss of vegetation habitat, including wetlands, due to construction of roads and pads and gravel 

mine development
3. Affected Environment and Environmental Consequences (Unavoidable Adverse Effects)

3-248 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

 Loss, alteration, or fragmentation of wildlife habitat

 Changes in wildlife migration or travel patterns

 Continued change in access to and availability of subsistence resources

Before surface-disturbing activities begin, oil and gas leasing regulations (43 CFR 3104) require the 

operator on the ground to be covered by a bond. This bond provides monetary assurance to the BLM that 

the company would reclaim the pads, wells, and any associated surface disturbance to the standards of the 

BLM Authorized Officer. This is determined at the time of reclamation, thus allowing the BLM to take an 

adaptive management approach. On abandonment, the BLM would consider current data, technologies 

available, and the current resource situation in its determinations on specific reclamation. Additionally, the 

BLM retains the ability to increase the bond amount at any time during the lease, based on a recalculation 

of liability, such as an increased number of wells or a history of noncompliance with its operational 

standards.

3.6 RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES AND LONG-TERM 

PRODUCTIVITY

This section discusses the short-term effects of the leasing alternatives, including the potential use of the 

program area for oil and gas exploration and development, versus the maintenance and enhancement of 

potential long-term productivity of the program area’s environmental resources. 

Short-term in this discussion refers to the total duration of activities that could occur as a result of the 

leasing alternatives, primarily oil and gas exploration and production, whereas long-term refers to an 

indefinite period extending beyond the termination of the action. Specific impacts vary in kind, intensity, 

and duration according to the activities occurring at any given time. Activities during the production life of 

oil and gas leases executed based on the decision in the ROD for this EIS may result in chronic impacts 

over a longer period. Over the long term—several decades after completion of abandonment activities—

natural environmental balances are generally expected to be restored, though that balance would not for 

all resources mean a return to the exact state prior to original disturbance. 

For a discussion of short-term uses of the program area for hydrocarbon development and production 

activities versus the maintenance and enhancement of potential long-term productivity of environmental 

resources of the program area, see Sections 3.1 to 3.4 of this document, and see Section 4.9 of the 

NPR-A EIS (BLM 2012) for a description of environmental resources on the North Slope.

3.7 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES

Irreversible or irretrievable commitments of resources refer to impacts on or losses of resources that 

cannot be reversed or recovered. These distinctions refer primarily to nonrenewable resources. A 

detailed description of irreversible or irretrievable commitments of resources from oil and gas 

development on the North Slope is in Section 4.10 of the NPR-A EIS (BLM 2012). There would be some 

irreversible or irretrievable commitments of resources that are described in greater detail in Sections 3.1

to 3.4, as follows:

 Removal of hydrocarbons from the reservoir

 Energy consumption associated with construction and operation phases

 Ground disturbance and permanent change resulting from gravel removal

 Surface water consumption for drilling and other industrial purposes with wastewater disposal via 

underground injection
3. Affected Environment and Environmental Consequences (Irreversible and Irretrievable 

Commitments of Resources)

Coastal Plain Oil and Gas Leasing Program 3-249

Draft Environmental Impact Statement

 Loss or change in vegetation and wetlands where gravel is placed, regardless of whether it is 

removed at abandonment

 Loss or abandonment of wildlife habitat

 Loss or change in subsistence use of the program area, depending on final abandonment plans
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Coastal Plain Oil and Gas Leasing Program References-1

Draft Environmental Impact Statement

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eagles on the North Slope of the Brooks Range in northeastern Alaska.” Journal of Field 

Ornithology 66 (3): 373–379.

Young, D. D., and T. R. McCabe. 1997. “Grizzly bear predation rates on caribou calves in northeastern 

Alaska.” Journal of Wildlife Management 61: 1056–1066.

_____. 1998. “Grizzly bears and calving caribou: What is the relation with river corridors?” Journal of 

Wildlife Management 62: 255–261. Internet website: https://doi.org/10.2307/3802286.

Young, D. D., T. R. McCabe, and M. S. Udezitz. 2002. Section 6: Predators. Pp. 51–53. In: D. C. Douglas, 

P. E. Reynolds, and E. B. Rhode, editors. Arctic Refuge Coastal Plain Terrestrial Wildlife 

Research Summaries. US Geological Survey, Biological Resources Division, Biological Science 

Report USGS/BRD/BSR-2002-0001.

Yukon Environmental GIS. 2018. GIS data provided by Yukon Environmental, Mike Suitor, July 2018.
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Coastal Plain Oil and Gas Leasing Program Glossary-1

Draft Environmental Impact Statement

Glossary

Acidophilus: Acid-loving (as in bacteria or plants); growing well in an acid medium.

Active floodplain: The flat area along a water body where sediments are deposited by seasonal or 

annual flooding; generally demarcated by a visible high water mark.

Aerial: Consisting of, moving through, found in, or suspended in the air.

Alluvial: Sedimentary material consisting mainly of coarse sand and gravel.

Alternatives: The different means by which objectives or goals can be attained. One of several policies, 

plans, or projects proposed for decision-making.

Ambient: Used to describe the environment as it exists at the point of measurement and against which 

changes (impacts) are measured.

Ambient air quality standard: Air pollutant concentrations of the surrounding outside environment 

that cannot legally be exceeded during fixed time intervals and in a specific geographic area. 

Amphidromous: Describes fish that spawn and overwinter in rivers and streams but migrate during 

the ice-free summer from these freshwater environments into coastal waters for months to feed.

Anadromous: Describes fish that mature in the sea and swim up freshwater rivers and streams to 

spawn. Salmon, steelhead, and sea-run cutthroat trout are examples. 

Anchor field: An oil and gas field containing sufficient quantities of recoverable oil and gas to support 

the construction of infrastructure and processing facilities; satellite fields can then be constructed using 

the anchor field facilities. 

Anoxic: The condition of an environment in which free oxygen is lacking or absent. 

Anthropogenic: Of, relating to, or resulting from the influence of humans on nature.

Anticline: An inverted bowl-shaped structure formed when sedimentary rock layers are folded to 

produce an arch or elongated dome. 

Aquatic: Growing, living in, frequenting, or taking place in water; in this Leasing EIS, used to indicate 

habitat, vegetation, and wildlife in freshwater. 

Archaeological resource: Places where remnants, such as artifacts, of a past culture survive in a 

physical context that allows for their interpretation. Archaeological resources can be districts, sites, 

buildings, structures, or objects and can be prehistoric or historic. 

Aufeis: Thick ice that builds up as a result of repeated overflow.
Glossary

Glossary-2 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Authorized Officer (BLM): Designated BLM personnel responsible for a certain area of a project; for 

the Leasing EIS, generally this would be the BLM State Director. 

Available: When referring to oil and gas leasing, available lands could be offered. Lands that are already 

leased could be offered for leasing if the existing lease ends.

Bank: (1) The rising ground bordering a lake, river, or sea; or of a river or channel, for which it is 

designated as right or left as the observer is facing downstream. (2) An elevation of the sea floor or 

large area, located on a continental (or island) shelf and over which the depth is relatively shallow but 

sufficient for safe surface navigation (e.g., Georges Bank); a group of shoals. (3) In its secondary sense, 

used only with a qualifying word such as “sandbank,” “gravel bank,” or “spoil bank,” a shallow area 

consisting of shifting forms of silt, sand, mud, and gravel.

Barrel: Unit of measurement consisting of 42 gallons of oil or other fluid. 

Baseline data: Data gathered before a proposed action to characterize pre-development site 

conditions. 

Biodegradable: Capable of being broken down by the action of living organisms, such as 

microorganisms. 

Biological assessment (BA): A document prepared by or under the direction of a federal agency; 

addresses listed and proposed species and designated and proposed critical habitat that may be in the 

action area and evaluates the potential effects of the action on such species and habitat. 

Black water: Discharge that includes wastewater from any or all of the following: toilets, urinals, and 

sewage treatment systems. 

Bonding capacity: An amount, determined by market analysts, based on a government entity’s prior 

bonding experience, actual repayment performance, and its ability to service future, periodic debt. It 

affects the ability of municipalities to issue and sell bonds to generate funds for capital improvements. 

Bottom-fast ice: Ice that is firmly attached or grounded to the bottom of a water body, which is often 

frozen from top to bottom. 

Brackish: Water that is intermediate between salt water and freshwater; often occurs at the mouths of 

rivers, where freshwater mixes with salt water. 

Brine: General description of water that is produced with oil. The water is associated with the oilproducing formation and can have varying amounts of dissolved salts. 

Brood: A group of young birds being cared for by an adult bird; typically the surviving hatchlings from 

one or more clutches of eggs. 

Bureau of Land Management (BLM): An agency of the United States government, under the US 

Department of the Interior, responsible for administering certain public lands of the United States. 

Burin: A tool flaked into a chisel point for inscribing or grooving bone, wood, leather, stone, or antler.
Glossary

Coastal Plain Oil and Gas Leasing Program Glossary-3

Draft Environmental Impact Statement

Calving area: A large area where large mammals, particularly ungulates such as caribou, congregate to 

give birth to their young. 

Capital expenses: The money spent to purchase or upgrade physical assets, such as buildings or 

machinery. 

Caribou Study Community: Any community that is in game management subunits that overlap with 

the PCH or CAH herd ranges, and which have Federal Subsistence Board customary and traditional use 

determinations for those herds.

Carrion: Dead or dying animal flesh. 

Class I air quality area: One of 156 protected areas, such as national parks over 6,000 acres, 

wilderness areas over 5,000 acres, national memorial parks over 5,000 acres, and international parks 

that were in existence as of August 1977, where air quality should be given special protection. Federal 

Class I areas are subject to maximum limits on air quality degradation called air quality increments (often 

referred to as prevention of significant deterioration [PSD] increments). All areas of the United States 

not designated as Class I are Class II areas. The air quality standards in Class I areas are more stringent 

than national ambient air quality standards. 

Council on Environmental Quality (CEQ): An advisory council to the president, established by the 

National Environmental Policy Act of 1969. It reviews federal programs for their effect on the 

environment, conducts environmental studies, and advises the president on environmental matters. 

Comprehensive Environmental Response Compensation and Liability Act of 1980 

(CERCLA): Authorizes funds administered by the Environmental Protection Agency to identify and 

clean up hazardous waste sites; also known as Superfund. 

Code of Federal Regulations (CFR): A codification of the general and permanent rules published in 

the Federal Register by the executive departments and agencies of the federal government. 

cfs: Cubic feet per second; 1 cfs equals 448.33 gallons per minute. 

Commercial field: Oil or natural gas fields that can be produced such that they provide a suitable 

return on investment. 

Commercial oil or natural gas reserves: Resources that can be produced such that they provide a 

suitable return on investment. 

Commercially recoverable: See Commercial oil or natural gas reserves, above.

Concern: A point, matter, or question raised by management or the public that must be addressed in 

the planning process. 

Conglomerate: Sedimentary rock consisting of gravel and small boulders. 
Glossary

Glossary-4 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Consistency determination: A finding by a state or federal agency that a project or agency action is 

consistent with a required agency program, guideline, or regulation, such as the Alaska Coastal Zone 

Management Program.

Consultation: Exchange of information and interactive discussion; when capitalized it refers to 

consultation mandated by statute or regulation that has prescribed parties, procedures, and timelines,

such as Consultation under NEPA or Section 7 of the Endangered Species Act. 

Controlled surface use (CSU): A category of moderate constraint stipulations that allows some use 

and occupancy of public land, while protecting identified resources or values and is applicable to fluid 

mineral leasing and all activities associated with fluid mineral leasing, such as truck-mounted drilling and 

geophysical exploration equipment off designated routes and construction of wells and pads. CSU areas 

are open to fluid mineral leasing, but the stipulation allows the BLM to require special operational 

constraints, or the activity can be shifted more than 656 feet to protect the specified resource or value.

Criteria: Data and information that are used to examine or establish the relative degrees of desirability 

of alternatives or the degree to which a course of action meets an intended objective. 

Criteria air pollutants: The six most common air pollutants in the US: carbon monoxide (CO), lead 

(Pb), nitrogen dioxide (NO2), ozone (O3), particulate matter (both PM10 and PM2.5 inhalable and 

respirable particulates), and sulfur dioxide (SO2). Congress has focused regulatory attention on these six 

pollutants because they endanger public health and the environment, are widespread throughout the US, 

and come from a variety of sources. Criteria air pollutants are typically emitted from many sources in 

industry, mining, transportation, electricity generation, energy production, and agriculture. 

Cultural resources: The remains of sites, structures, or objects used by humans in the past, historic 

or prehistoric.

Cumulative effect or impact: The impact on the environment that results from the incremental 

impact of the action when added to other past, present, and reasonably foreseeable future actions, 

regardless of what agency (federal or non-federal) or person undertakes such actions. Cumulative 

impacts can result from individually minor but collectively significant actions taking place over time.

Deferred: When referring to oil and gas leasing, indicates that lands would not be offered for lease 

until a specified period has expired. For example, a 10-year deferral would mean that the deferred lands 

would not be offered for leasing until for 10 years after the Record of Decision establishes the 10-year 

deferral. 

Demersal: Living near, deposited on, or sinking to the seabed. 

Density: The number of individuals per a given unit area. 

Deposit: A natural accumulation, as of precious metals, minerals, coal, gas, and oil, that may be pursued 

for its intrinsic value, such as a gold deposit. 
Glossary

Coastal Plain Oil and Gas Leasing Program Glossary-5

Draft Environmental Impact Statement

Development: The phase of petroleum operations that occurs after exploration has proven successful 

and before full-scale production. The newly discovered oil or gas field is assessed during an appraisal 

phase, a plan to fully and efficiently exploit it is created, and additional wells are usually drilled. 

DEW-Line: Distant Early Warning Line. A site designed and built during the Cold War as the primary 

line of air defense warning of an “over the pole” invasion of North America. 

Dilution: Mixing or thinning and therefore decreasing a certain strength or concentration.

Dispersion: Distributing or separating into lower concentrations or less dense units. 

Dissociable: Able to break up into simpler chemical constituents. 

Diversity: An expression of community structure; high, if there are many equally abundant species; low,

if there are only a few equally abundant species; the distribution and abundance of different plant and 

animal communities and species in the area covered by a land and resource management plan. 

Draft Environmental Impact Statement (DEIS): The draft statement of the environmental effects 

of a major federal action, which is required under section 102 of the National Environmental Policy Act 

and released to the public and other agencies for comment and review. 

Drill pad: A drilling site, usually constructed of local materials such as gravel.

Drilling fluid (mud): A preparation of water, clay, and chemicals circulated in a well during drilling to 

lubricate and cool the drill bit, flush rock cuttings to the surface, prevent sloughing of the sides of the 

hole, and prevent the flow of formation fluids into the bore-hole or to the surface. 

Duck pond: A small, flat-bottomed plastic receptacle placed under a vehicle to catch and contain any 

contaminated fluids that may melt or drip from the underside of the vehicle.

Economically recoverable: See Commercial oil or gas reserves, above. 

Effect: Environmental change resulting from a proposed action. Direct effects are caused by the action 

and occur at the same time and place, while indirect effects are caused by the action but are later in 

time or farther removed in distance, although still reasonably foreseeable. Indirect effects may include 

growth-inducing and other effects related to induced changes in the pattern of land use, population 

density, or growth rate and related effects on air and water and other natural systems, including 

ecosystems. Effect and impact are synonymous, and both are used in this document. 

Employment: Labor input into a production process, measured in the number of person-years or jobs; 

the number of jobs required to produce the output of each sector. A person-year is approximately 

2,000 working hours by one person working the whole year or by several persons working seasonally. A 

job may be 1 week, 1 month, or 1 year. 

Endangered species: Any species of animal or plant that is in danger of extinction throughout all or a 

significant portion of its range; plant or animal species identified by the Secretary of the Interior as 

endangered in accordance with the 1973 Endangered Species Act.
Glossary

Glossary-6 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Energy budget: The flow of energy through an organism or ecosystem. For an organism, it is the 

amount of energy being absorbed (e.g., food) in relation to the amount of energy expended and lost as 

heat. 

Environment: The physical conditions that exist in an area, such as the area that would be affected by 

a proposed project, including land, air, water, minerals, flora, fauna, ambient noise, and objects of 

historic or aesthetic significance; the sum of all external conditions that affect an organism or community 

to influence its development or existence. 

Environmental assessment (EA): A concise public document, for which a federal agency is 

responsible, that serves to (1) briefly provide sufficient evidence and analysis for determining whether to 

prepare an environmental impact statement or a finding of no significant impact; (2) aid an agency’s 

compliance with the National Environmental Policy Act when no environmental impact statement is 

necessary; and, (3) facilitate preparation of an environmental impact statement when one is necessary. . 

Environmental impact statement (EIS): An analytical document prepared under the National 

Environmental Policy Act that portrays the potential impacts of the environment of a preferred action 

and its possible alternatives. An ElS is developed for use by decision-makers to weigh the environmental 

consequences of a potential decision.

Environmental justice: The fair treatment and meaningful involvement of all people, regardless of 

natural origin or income, with respect to the development, implementation, and enforcement of 

environmental laws, regulations, and policies. Fair treatment means that no group of people, including 

racial, ethnic, or socioeconomic groups, should bear a disproportionate share of the negative 

environmental consequences resulting from industrial, municipal, and commercial operations or the 

execution of federal, state, local, and tribal programs and policies. Executive Order 12898 directs federal 

agencies to achieve environmental justice as part of their missions by identifying and addressing 

disproportionately high adverse effects of agency programs, policies, and activities, on minority and lowincome populations 

Erosion: The wearing away of the land surface by running water, wind, ice, or other geologic agents, 

including gravitation creep. 

Eskimo: An ethnonym (name given to a group by another group) referring to speakers of the Inuit 

language family who live in the Arctic and Subarctic regions of North America—Canada, Greenland, and 

Alaska—and eastern Siberia. 

Essential fish habitat (EFH): As defined by Congress in the interim final rule (62 FR 66551), “those 

waters and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity.” For the 

purpose of interpreting the definition of EFH habitat, “waters” are aquatic areas and their associated 

physical, chemical, and biological properties; “substrate” is sediment underlying the waters; “necessary” 

refers to the habitat required to support a sustainable fishery and the managed species contribution to a 

healthy ecosystem; and “spawning, breeding, feeding, or growth to maturity” covers all habitat types that

a species uses throughout its life cycle.
Glossary

Coastal Plain Oil and Gas Leasing Program Glossary-7

Draft Environmental Impact Statement

Estuary: A partially enclosed body of water formed where freshwater from rivers and streams flows 

into the ocean, mixing with the salty seawater. Estuaries and the lands surrounding them are places of 

transition from land to sea, and from freshwater to salt water. 

Ethnographic: Of or pertaining to the descriptive and analytical study of the culture of particular selfdefined groups or communities. 

Exception: A one-time exemption to a lease stipulation, determined on a case-by-case basis. 

Exploration: The search for economic deposits of minerals, gas, oil, or coal through the practices of 

geology, geochemistry, geophysics, drilling, shaft sinking, and mapping. 

Exploratory unit: Normally embrace a prospective area delineated on the basis of geological or 

geophysical inference and permit the most efficient and cost-effective means of developing underlying oil 

and gas resources.

Fast-ice zone: Area along the coast covered by sea ice that is continuous with and attached to the 

shoreline. 

Feasible: Capable of being accomplished in a successful manner within a reasonable time, taking into 

account economic, environmental, legal, social, and technological factors. 

Final environmental impact statement (final EIS): A revision of the draft environmental impact 

statement that includes public and agency comments on the draft. 

Fisheries habitat: Streams, lakes, and reservoirs that support fish populations. 

Fishery: The act, process, occupation, or season of taking an aquatic species. 

Floodplain: The lowland and relatively flat area adjoining inland waters, including, at a minimum, that 

area subject to a 1 percent or greater chance of flooding in any given year. 

Fluvial: Of or relating to a stream or river. 

Fossil: Evidence or remnant of a plant or animal preserved in the earth’s crust, such as a skeleton, 

footprint, or leaf print. 

Fossil fuel: Petroleum, natural gas, and coal; fuel derived from biological material that was deposited 

into sedimentary rocks. 

Frequency: The number of samples in which a plant or animal species occurs, divided by the total 

number of samples. 

Fugitive dust: Particles suspended randomly in the air, usually from road travel, excavation, or rock 

loading operations.
Glossary

Glossary-8 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Game management unit (GMU): A geographic division made by the Alaska Department of Fish and 

Game for the management of fish and wildlife in the State. Different GMUs have different hunting and 

fishing seasons, bag limits, and other harvest rules. 

Geology: The scientific study of the origin, history, and structure of the earth; the structure of a 

specific region of the earth’s surface. 

Geomorphic: Pertaining to the structure, origin, and development of the topographical features of the 

earth’s crust. 

Gill net: Made of one or more layers of mesh, used to catch fish by entanglement as they attempt to 

swim through the net. 

Glacial drift: Unsorted sediments deposited by glaciers and not subsequently reworked by water; 

coarse-grained materials, such as rock and sand, suspended in a fine-grained matrix, such as silt. The 

term applies to all mineral material transported by a glacier and deposited directly by or from the ice or 

by running water emanating from a glacier. 

Global warming: An increase over time of the average temperature of the earth’s atmosphere and 

oceans. It is generally used to describe the temperature rise over the past century or so and the effects 

of humans on the temperature rise. 

Gray water: Discharge that includes wastewater from any or all of the following: kitchen sink, shower, 

drinking water, and laundry. 

Greenhouse effect: A process by which thermal radiation from a planetary surface is absorbed by 

atmospheric greenhouse gases and is reradiated in all directions. Since part of this reradiation is toward 

the earth’s surface and the lower atmosphere, it elevates the average surface temperature above what it 

would be in the absence of the gases. 

Greenhouse gas (GHG): A gas that absorbs and emits thermal radiation in the lowest layers of the 

atmosphere. This process is the fundamental cause of the greenhouse effect. The primary greenhouse 

gases that are considered air pollutants are carbon dioxide, (CO2), methane (CH4), nitrous oxide (N2O), 

and chlorofluorocarbons (CFCs). 

Groundwater: Water found beneath the land surface in the zone of saturation below the water table.

Habitat: The natural environment of a plant or animal, including all biotic, climatic, and soil conditions, 

or other environmental influences affecting living conditions. The place where an organism lives. 

Hazardous air pollutants (HAPs): Also known as toxic air pollutants, those that cause or may cause 

cancer or other serious health effects, such as reproductive effects or birth defects, or adverse 

environmental and ecological effects. The Environmental Protection Agency is required to control 187 

hazardous air pollutants. Examples of HAPs are benzene (found in gasoline), perchlorethlyene (emitted 

from dry cleaning facilities), and methylene chloride (used as a solvent). 
Glossary

Coastal Plain Oil and Gas Leasing Program Glossary-9

Draft Environmental Impact Statement

Hazardous waste: As defined by the Environmental Protection Agency, a waste that exhibits one or 

more of the following characteristics: ignitability, corrosivity, reactivity, or toxicity. Hazardous wastes 

are listed in 40 CFR 261.3 and 171.8. 

Headwaters: The upper reaches of a stream where it forms. 

Hydrocarbon: A naturally occurring organic compound composed of hydrogen and carbon. 

Hydrocarbons can occur in molecules as simple as methane (one carbon atom with four hydrogen 

atoms), but also as highly complex molecules, and can occur as gases, liquids, or solids. The molecules 

can have the shape of chains, branching chains, rings, or other structures. Petroleum is a complex 

mixture of hydrocarbons. 

Hydrologic system: The combination of all physical factors, such as precipitation, stream flow, 

snowmelt, and groundwater that affect the hydrology of a specific area.

Impermeable: Not permitting passage of fluids through its mass. 

Impoundment: The collection and confinement, usually of water (in the case of mining, tailings 

materials), in a reservoir or other storage area. 

Increment: An amount of change from an existing concentration or amount, such as air pollutant 

concentrations. 

Indigenous: Having originated in and being produced, growing, living, or occurring naturally in a 

particular region or environment. 

Indirect impact: Impact caused by an action but later in time or farther removed in distance, although 

still reasonably foreseeable. 

Infrastructure: The underlying foundation or basic framework; substructure of a community, such as 

schools, police, fire services, hospitals, water, and sewer systems. 

Insect-relief area: An area of the North Slope with relatively low numbers of insects that caribou use

for relief from insects. 

Interstitial ice: Found in cavities or lodged between soil grains or rock crevices. 

Irretrievable: Applies to losses of production, harvest, or commitment of renewable natural 

resources. For example, some or all of the wildlife forage production from an area is irretrievably lost 

during the time an area is used as an oil or gas development site. If the use changes, forage production 

can be resumed. The production lost is irretrievable, but the act is not irreversible. 

Irreversible: A term that applies primarily to the use of nonrenewable resources, such as minerals or 

cultural resources, or to those factors that are renewable only over long time spans, such as soil 

productivity. Irreversible also includes loss of future options. 

Isobath: Depth interval contour, as commonly mapped for lake or ocean bottoms.
Glossary

Glossary-10 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Jurisdictional wetland: A wetland area delineated and identified by specific technical criteria, field 

indicators, and other information, for the purposes of public agency jurisdiction. The US Army Corps of 

Engineers regulates “dredging and filling” activities associated with jurisdictional wetlands. Other federal 

agencies that can become involved with matters that concern jurisdictional wetlands include the US Fish 

and Wildlife Service, the Environmental Protection Agency, and the Natural Resource Conservation 

Service.

Landfast ice: Stationary ice that is continuous with, and attached to, the shoreline and extends out into 

the waterbody. 

Landform: Any physical, recognizable form or feature on the earth’s surface having a characteristic 

shape, which is produced by natural causes. Landforms provide an empirical description of similar 

portions of the earth’s surface. 

Land management: The intentional process of planning, organizing, programming, coordinating, 

directing, and controlling land use actions. 

Landscape: The sum total of the characteristics that distinguish a certain area on the earth’s surface 

from other areas; these characteristics are a result not only of natural forces, but also of human 

occupancy and use of the land. An area composed of interacting and interconnected patterns of habitats

(ecosystems), which are repeated because of geology, landforms, soils, climate, biota, and human 

influences throughout the area. 

Land status: The ownership status of lands. 

Land use allocation: The assignment of a management emphasis to particular land areas with the 

purpose of achieving the goals and objectives of some specified use(s) (e.g., campgrounds, wilderness, 

logging, and mining). 

Laterally discontinuous: Not continuous in the horizontal plane. For example, in an area with 

laterally discontinuous permafrost, the permafrost is not uniformly found across the entire area without 

interruption. 

Lead: Long cracks in the ice, used by both whales and boats to travel through the water. 

Listed species: Species that are listed as threatened or endangered under the Endangered Species Act 

of 1973 (as amended).

Long-term impacts: Impacts that normally result in permanent changes to the environment. An 

example is the loss of habitat due to development of a gravel pit. For each resource, the definition of 

long-term may vary.

Management activity: A human activity imposed on a landscape for the purpose of harvesting, 

traversing, transporting, or replenishing natural resources. 

Management area: An area delineated on the basis of management objective prescriptions. 
Glossary

Coastal Plain Oil and Gas Leasing Program Glossary-11

Draft Environmental Impact Statement

Management concern: An issue, problem, or condition that influences the range of management 

practices identified in a planning process. 

Management direction: A statement of multiple use and other goals and objectives, and the 

associated management prescriptions, standards, and guidelines for attaining them (36 CFR 219.3). 

Marine: Of, found in, or produced by the sea. 

Masu: A starchy tuber found in arctic and subarctic regions (vernacular is “Eskimo potato”). 

Mean: A statistical value calculated by dividing the sum of a set of sample values by the number of 

samples. Also referred to as the arithmetic mean or average. 

Mean high water mark: With respect to ocean and coastal waters, the line on the shore established 

by the average of all high tides. It is established by survey based on available tidal data (preferably 

averaged over a period of 18.6 years because of the variations in tide). In the absence of such data, less 

precise methods to determine the mean high water mark are used, such as physical markings, lines of 

vegetation or comparison of the area in question with an area having similar physical characteristics for 

which tidal data are readily available.

Modification: A change to a lease stipulation either temporarily or for the life of the lease.

Migratory: Moving from place to place, daily or seasonally. 

Mitigation: Steps taken to: (1) avoid an impact altogether by not taking a certain action or parts of an 

action; (2) minimize an impact by limiting the degree or magnitude of the action and its implementation; 

(3) rectify an impact by repairing, rehabilitating, or restoring the affected environment; (4) reduce or 

eliminate an impact over time by preserving and maintaining operations during the life of the action; and, 

(5) compensate for an impact by replacing or providing substitute resources or environments (40 CFR 

Part 1508.20). 

Memorandum of Understanding (MOU): Usually documents an agreement reached among federal 

agencies.

Muktuk: Eskimo delicacy consisting of the skin and the thin layer of subcutaneous fat of whales. 

National Environmental Policy Act (NEPA): An act declaring a national policy to encourage 

productive and enjoyable harmony between humankind and the environment; promote efforts to 

prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of 

humanity; enrich the understanding of the ecological systems and natural resources important to the 

nation; and establish a Council on Environmental Quality. 

Net present value (NPV): The difference between the discounted value (benefits) of all outputs to 

which monetary values or established market prices are assigned and the total discounted costs of 

managing the planning area.

National Pollutant Discharge Elimination System (NPDES): A program authorized by sections 

318, 402, and 405 of the Clean Water Act, and implemented by regulations 40 CFR 122. The NPDES 
Glossary

Glossary-12 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

program requires permits for the discharge of pollutants from any point source into waters of the 

United States. 

Nearshore: Marine waters within the boundary of the Arctic Refuge boundary.

No-Surface-Occupancy (NSO): An area that is open for mineral leasing but does not allow the 

construction of surface oil and gas facilities in order to protect other resource values. 

Non-Associated Gas: Gas in a reservoir having little or no crude oil. 

NOx: Mono-nitrogen oxides, including nitric oxide (NO) and nitrogen dioxide (NO2). It is formed when 

naturally occurring atmospheric nitrogen and oxygen are combusted with fuels in automobiles, power 

plants, industrial processes, and home and office heating units.

Objective: A concise, time-specific statement of measurable planned results that respond to preestablished goals. An objective forms the basis for further planning to define the precise steps to be 

taken and the resources to be used to achieve identified goals. 

Offshore: (1) In beach terminology, the comparatively flat zone of variable width, extending from the 

shoreface to the edge of the continental shelf. It is continually submerged. (2) The direction seaward 

from the shore. (3) The zone beyond the nearshore zone where sediment motion induced by waves 

alone effectively ceases and where the influence of the sea bed on wave action is small in comparison 

with the effect of wind. (4) The breaker zone directly seaward of the low tide line.

Oiled: Having oil on skin, fur, or feathers after coming into contact with an oil spill.

Ordinary High Water Mark: The line on the shore established by the fluctuations of water and 

indicated by physical characteristics such as a clear, natural line impressed on the bank, shelving, changes 

in the character of soil, destruction of terrestrial vegetation, the presence of litter and debris, or other 

appropriate means that consider the characteristics of the surrounding areas.

Ozone: Form of oxygen found largely in the stratosphere; a product of the reaction between ultraviolet 

light and oxygen.

Particulates: Small particles suspended in the air, generally considered pollutants. 

Pelagic: Pertaining to the ocean and especially to animals (typically marine mammals, birds, or fish) that 

live at the surface of the ocean away from the coast. 

Per capita income: Total income divided by the total population. 

Performance-based stipulation: A stipulation applied to a lease that provides a stated objective that 

must be met, along with requirements and guidelines, but provides some leeway as to how that 

objective can be met and maintained by the lessee; compare to prescriptive-based stipulation. 

Permafrost: Permanently frozen ground. 
Glossary

Coastal Plain Oil and Gas Leasing Program Glossary-13

Draft Environmental Impact Statement

Permanent oil and gas facilities: Production facilities, pipelines, roads, airstrips, production pads, 

docks, seawater treatment plants, and other structures associated with oil and gas production that 

occupy land for more than one winter season. Material sites and seasonal facilities, such as ice roads, are 

excluded, even when the pads are designed for use in successive winters. 

Permeability: The property or capacity of a porous rock, sediment, or soil for transmitting a fluid; a 

measure of the relative ease of fluid flow under unequal pressure.

Photoperiod: In reference to cycles of light and darkness, the length of time that uninterrupted light is 

present, generally the length of daylight in a given 24-hour period. 

Physiographic province: A region having a particular pattern of relief features or land forms that 

differs significantly from that of adjacent regions (e.g., Arctic Coastal Plain). 

Pingo: A low conical hill or mound forced up by hydrostatic pressure in an area underlain by 

permafrost and consisting of an outer layer of soil covering a core of solid ice. Pingos range from 6 to 

160 meters in height. 

Plant community: A vegetation complex, unique in its combination of plants, which occurs in 

particular locations under particular influences. A plant community is a reflection of integrated 

environmental influences on the site, such as soils, temperature, elevation, solar radiation, slope aspect, 

and precipitation. 

Pollution: Human-caused or natural alteration of the physical, biological, and radiological integrity of 

water, air, or other aspects of the environment that produce undesired effects. 

Polygon: A surface landform resulting from repeated freeze-thaw cycles common in permafrost areas. 

Polygons are bounded by troughs of ice or water and generally occur in networks that form regular 

geometric designs with multiple square sides of nearly equal lengths. 

Polynyas: Non-linear openings in the sea ice. 

Pool: A subsurface oil accumulation.

Porosity: The ratio of the volume of void space in a material (e.g., sedimentary rock or sediments) to 

the volume of its mass. 

Potable: Suitable, safe, or prepared for drinking, as in potable water. 

Pot hunting: The removal or theft of artifacts from cultural resource sites by untrained individuals for 

profit and recreation. 

Prescriptive-based stipulation: A stipulation applied to leases with exacting requirements applying to 

lessee activities; compare to performance-based stipulation. 

Prevention of significant deterioration (PSD): A special permit procedure established in the Clean 

Air Act, as amended, used to ensure that economic growth occurs in a manner consistent with the 

protection of public health and preservation of air quality related values in national special interest areas. 
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Glossary-14 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Pristine: Pure, original, and uncontaminated. 

Prospect: An area of exploration in which hydrocarbons have been predicted to exist in commercially 

recoverable quantities.

Public scoping: A process whereby the public is given the opportunity to provide oral or written 

comments about the influence of a project on an individual, the community, and/or the environment. 

Pulse: A group of whales; the term is applied to whales migrating across the Chukchi and Beaufort seas, 

when there are more individuals in each pod of whales and more pods than usual. 

Putrescible: Liable to decay. 

Pyrogenic: Producing or produced by heat.

Raptor: Bird of prey; includes eagles, hawks, falcons, and owls. 

Recharge: Absorption and addition of water into the zone of saturation. 

Record of Decision (ROD): A document separate from, but associated with, an environmental impact 

statement, which states the decision, identifies alternatives (specifying which were environmentally 

preferable), and states whether all practicable means to avoid environmental harm from the alternative 

have been adopted, and, if not, why not (40 CFR 1505.2). 

Recoverable reserves: Oil and gas reserves that may be recoverable by the application of technology, 

but not necessarily commercially recoverable. 

Regulated air pollutants: Pollutants first set forth in the Clean Air Act of 1970 and are the basis 

upon which the Federal government and state regulatory agencies have established emission thresholds 

and regulations. Regulated air pollutants include criteria air pollutants, hazardous air pollutants (HAPs), 

volatile organic compounds (VOCs), and greenhouse gases. The same pollutant may be regulated under 

more than one of the regulatory standards.

Reservoir (oil or gas): A subsurface body of rock having sufficient porosity and permeability to store 

and transmit fluids. Sedimentary rocks are the most common reservoir rocks because they have more 

porosity than most igneous and metamorphic rocks and form under temperature conditions at which 

hydrocarbons can be preserved. A reservoir is a critical component of a complete petroleum system. 

Resident: A species that is found in a particular habitat for a particular time period (e.g., winter 

resident or summer resident) as opposed to a species found only when passing through during 

migration. 

Required Operating Procedure (ROP): Procedures carried out during proposal implementation 

which are based on laws, regulations, executive orders, BLM planning manuals, policies, instruction

memoranda, and applicable planning documents. 

Rideup: A raised-relief ice formation that is formed when a moving ice sheet is forced up and over 

other structures such as land or ice.
Glossary

Coastal Plain Oil and Gas Leasing Program Glossary-15

Draft Environmental Impact Statement

Riffles: Stream segments where the water is relatively shallow, current velocity is relatively high, and 

sediments are coarse; riffles are located in between areas of deeper, slower water (pools). 

Rift zone: Zone of faulting where rocks are pulled apart.

Right-of-way (ROW): Public lands that the BLM authorizes a holder to use or occupy under a grant; 

examples are roads, pipelines, power lines, and fiber optic lines.

Riparian: Occurring adjacent to streams and rivers and directly influenced by water. A riparian 

community is characterized by certain types of vegetation, soils, hydrology, and fauna and requires free 

or unbound water or conditions more moist than that normally found in the area. 

Risked mean: The arithmetic average of all possible resource outcomes weighted by their 

probabilities. Risked (unconditional) estimates of resources such as oil or natural gas consider the 

possibility that the area may be devoid of those resources. Statistically, the risked mean may be 

determined through multiplication of the mean of a conditional distribution by the related probability of 

occurrence. 

Rolligon: A brand name or make of wheeled vehicle that exerts low pressure on the ground and is 

designed to travel across sensitive areas such as tundra with minimal disturbance.

Satellite field: An oil reserve located near an existing oil development, allowing shared use of the 

infrastructure. 

Scenic River: River designation, under the Federal Wild and Scenic Rivers Program, on the basis of 

undisturbed and scenic character. Scenic rivers are given special management criteria by federal 

agencies. 

Scoping process: A part of the National Environmental Policy Act process; early and open activities 

used to determine the scope and significance of the issues, and the range of actions, alternatives, and 

impacts to be considered in an Environmental Impact Statement (40 CFR 1501.7). 

Sediments: Unweathered geologic materials generally laid down by or within waterbodies; the rocks, 

sand, mud, silt, and clay at the bottom and along the edge of lakes, streams, and oceans. 

Seismic: Relating to or denoting geological surveying methods involving vibrations produced artificially 

by explosions.

Sensitive species: Plant or animal species that are susceptible or vulnerable to activity impacts or 

habitat alterations. Species that have appeared in the Federal Register as proposed for classification or are 

under consideration for official listing as endangered or threatened species. 

Setback: A distance by which a structure or other feature is set back from a designated line. 

Short-term impacts: Impacts occurring during project construction and operation, and normally 

ceasing upon project closure and reclamation. For each resource, the definition of short-term may vary. 
Glossary

Glossary-16 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Significant: The description of an impact that exceeds a certain threshold level. Requires consideration 

of both context and intensity. The significance of an action must be analyzed in several contexts, such as 

society as a whole, and the affected region, interests, and locality. Intensity refers to the severity of 

impacts, which should be weighted along with the likelihood of its occurrence. 

SOx: Sulfur oxides, including sulfur dioxide (SO2). A product of vehicle tailpipe emissions. 

Sociocultural: Of, relating to, or involving a combination of social and cultural factors.

Socioeconomic: Pertaining to or signifying the combination or interaction of social and economic 

factors. 

Soil horizon: A layer of soil material approximately parallel to the land surface that differs from 

adjacent genetically related layers in physical, chemical, and biological properties. 

Solid waste: Garbage, refuse, and/or sludge produced during oil and gas exploration and development 

activities. 

Spawning: Production, deposition, and fertilization of eggs by fish. 

Special use permit: A permit issued under established laws and regulations to an individual, 

organization, or company for occupancy or use of federal or state lands for some special purpose. 

Spill Prevention Control and Countermeasure Plan (SPCC): A plan that the Environmental 

Protection Agency requires to be on file within six months of project inception. It is a contingency plan 

for avoidance of, containment of, and response to spills or leaks of hazardous materials. 

Standard: A model, example, or goal established by authority, custom, or general consent as a rule for 

the measurement of quantity, weight, extent, value, or quality. 

Stipulation: A requirement or condition placed by the Bureau of Land Management on the leaseholder 

for operations the leaseholder might carry out within that lease. The Bureau of Land Management 

develops stipulations that apply to all future leases within the Arctic Refuge Coastal Plain. 

Stratigraphic trap: An oil or gas reservoir in which the hydrocarbons are trapped because of a lateral 

change in the physical characteristics of the reservoir or a change in the lateral continuity of the rocks. 

Strike: The act of throwing a darting gun harpoon with a black powder or penthrite bomb into a whale. 

A strike may or may not result in a dead whale, which may or may not result in a landed whale. The 

International Whaling Commission considers and counts the number of strikes and landed whales in 

their quota allocation to the US government (and hence to the Alaska Eskimos). Unused strikes can be 

transferred to other individuals or groups harvesting whales.

Subsistence: Harvesting of plants and wildlife for food, clothing, and shelter. The attainment of most of 

one’s material needs (e.g., food and clothing materials) from wild animals and plants.

Talik: An unfrozen section of ground found above, below, or within a layer of discontinuous 

permafrost. These layers can also be found beneath waterbodies in a layer of continuous permafrost. 
Glossary

Coastal Plain Oil and Gas Leasing Program Glossary-17

Draft Environmental Impact Statement

Technically recoverable: Amount of oil or gas that can be recovered from a formation using current 

technology and practices. 

Terrestrial: Of or relating to the earth, soil, or land; inhabiting the earth or land. 

Thermokarst: Land-surface configuration that results from the melting of ground ice in a region 

underlain by permafrost. In areas that have appreciable amounts of ice, small pits, valleys, and hummocks 

form when the ice melts and the ground settles unevenly. 

Threatened species: A plant or animal species likely to become an endangered species throughout all 

or a significant portion of its range within the foreseeable future. 

Timing limitation (TL): This stipulation, a moderate constraint, is applicable to fluid mineral leasing, 

all activities associated with fluid mineral leasing (e.g., truck-mounted drilling and geophysical exploration 

equipment off designated routes, and construction of wells and pads), and other surface-disturbing 

activities (i.e., those not related to fluid mineral leasing). Areas identified for TL are closed to fluid 

mineral exploration and development, surface-disturbing activities, and intensive human activity during 

identified time frames. This stipulation does not apply to operation and basic maintenance, including 

associated vehicle travel, unless otherwise specified. Construction, drilling, completions, and other 

operations considered to be intensive are not allowed. Intensive maintenance, such as workovers on 

wells, is not permitted. TLs can overlap spatially with no surface occupancy and controlled surface use, as 

well as with areas that have no other restrictions.

Total petroleum system: The combination of geologic components and processes necessary to 

generate and store hydrocarbons, including a mature source rock, migration pathway, reservoir rock, 

trap, and seal. Includes all the petroleum generated by related source rocks and resides in a volume of 

mappable rocks. Geologic processes act upon the petroleum system and control the generation, 

expulsion, migration, entrapment, and preservation of petroleum. 

Traditional knowledge: An intimate understanding by indigenous peoples of their environment, which 

is grounded in a long-term relationship with the surrounding land, ocean, rivers, ice, and resources. This 

understanding includes knowledge of the anatomy, biology, and distribution of resources; animal 

behavior; seasons, weather, and climate; hydrology, sea ice, and currents; how ecosystems function; and 

the relationship between the environment and the local culture. 

Transfer payment: Money given by the government to citizens, such as Social Security, welfare, and 

unemployment compensation. 

Trophic system: The process and organisms that move food energy through the ecosystem, often 

termed a food chain. 

Tundra: Level or undulating treeless plain characteristic of northern Arctic regions, consisting of black 

mucky soil with permanently frozen subsoil and a dense growth of mosses, lichens, dwarf herbs, and 

shrubs. 

Turbidity: A measure of the amount of suspended sediment in water.
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Glossary-18 Coastal Plain Oil and Gas Leasing Program

Draft Environmental Impact Statement

Tussock: A small area of grass that is thicker or longer than the grass growing around it.

Unavailable: When referring to oil and gas leasing, unavailable lands would not be offered for oil and 

gas leasing. 

Unconventional oil and gas: Reservoir oil and gas that cannot be efficiently extracted using 

conventional methods, examples include shale gas and tar sands. 

Vibroseis: A device which uses a truck-mounted vibrator plate coupled to the ground to generate a 

wave train up to seven seconds in duration and comprising a sweep of frequencies. The recorded data 

from an upsweep or downsweep (increasing or decreasing frequency respectively) are added together 

and compared with the source input signals to produce a conventional-looking seismic section. The 

device is used increasingly in land surveys instead of explosive sources.

Volatile Organic Compounds (VOCs): A group of chemicals that react in the atmosphere with 

nitrogen oxides in the presence of sunlight and heat to form ozone. VOCs contribute significantly to 

photochemical smog production and certain health problems. Examples of VOCs are gasoline fumes and 

oil-based paints.

Waiver: A permanent exemption to a stipulation or lease. 

Waterbody: A jurisdictional Water of the United States (see 33 CFR 328.4). Examples of 

‘‘waterbodies’’ include streams, rivers, lakes, ponds, and wetlands.

Waterflooding: The injection of water into geological reservoirs to maintain or increase pressure in 

the reservoir and thereby assist in the extraction of oil. 

Water quality: The interaction between various parameters that determines the usability or nonusability of water for on-site and downstream uses. Major parameters that affect water quality include: 

temperature, turbidity, suspended sediment, conductivity, dissolved oxygen, pH, specific ions, discharge, 

and fecal coliform. 

Wetlands (biological wetlands): Those areas that are inundated or saturated by surface water or 

groundwater at a frequency and duration sufficient to support, and that under normal circumstance do 

support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands 

include habitats such as swamps, marshes, and bogs (see jurisdictional wetlands).

Wild and Scenic Rivers: Those rivers or sections of rivers that are free of impoundments, with 

shorelines or watersheds still largely primitive and shorelines largely undeveloped, but accessible in 

places by roads.

Wilderness: A wilderness, in contrast with those areas where man and his works dominate the 

landscape, is hereby recognized as an area where the earth and its community of life are untrammeled 

by man, where man himself is a visitor who does not remain. An area of wilderness is further defined to 

mean in this Act an area of undeveloped Federal land retaining its primeval character and influence, 

without permanent improvements or human habitation, which is protected and managed so as to 

preserve its natural conditions and which (1) generally appears to have been affected primarily by the 
Glossary

Coastal Plain Oil and Gas Leasing Program Glossary-19

Draft Environmental Impact Statement

forces of nature, with the imprint of man's work substantially unnoticeable; (2) has outstanding 

opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand 

acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired 

condition; and (4) may also contain ecological, geological, or other features of scientific, educational, 

scenic, or historical value.
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