. ▲

Alaska Outer Continental Shelf OCS EIS/EA 

 BOEMRE 2010-034 

 

Chukchi Sea Planning Area 

Oil and Gas Lease Sale 193 

In the Chukchi Sea, Alaska 

Revised Draft Supplemental Environmental Impact Statement 

U.S. Department of the Interior 

Bureau of Ocean Energy Management, 

Regulation and Enforcement 

Alaska OCS Region May 2011 

 
 

 
Alaska Outer Continental Shelf OCS EIS/EA 

 BOEMRE 2010-034 

Chukchi Sea Planning Area 

Oil and Gas Lease Sale 193 

In the Chukchi Sea, Alaska 

Revised Draft Supplemental Environmental Impact Statement 

Prepared by: 

Bureau of Ocean Energy Management, Regulation and Enforcement 

Alaska OCS Region

U.S. Department of the Interior 

Bureau of Ocean Energy Management, 

Regulation, and Enforcement 

Alaska OCS Region 

 May 2011 

COVER SHEET 

Chukchi Sea 

Lease Sale 193 

Supplemental Environmental Impact Statement 

 Draft (X) Final ( ) 

Type of Action: Administrative (X) Legislative ( ) 

Area of Potential Effect: Offshore marine environment, Chukchi Sea coastal plain, and the North Slope 

 Borough of Alaska. 

Agency Washington Contact Region Contacts 

Sharon Warren, 

Project Manager 

(907) 334-5272 

U.S. Department of the Interior 

Bureau of Ocean Energy Management, 

Regulation and Enforcement 

Alaska OCS Region 

3801 Centerpoint Drive Suite 500 

Anchorage, AK 99503-5823 

(907) 334-5200

James F. Bennett 

Bureau of Ocean Energy 

Management, 

Regulation and Enforcement 

381 Elden Street (MS 4042) 

Herndon, VA 20170-4817 

(703) 787-1660

Mike Routhier, 

NEPA Coordinator 

(907) 334-5265 

Abstract 

This Revised Draft Supplemental Environmental Impact Statement (EIS) addresses Outer Continental Shelf 

(OCS) Oil and Gas Lease Sale 193, Chukchi Sea, Alaska. 

Secretarial Order No. 3302 dated June 18, 2010, renamed the Minerals Management Service (MMS) as the 

Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE). 

The Outer Continental Shelf Lands Act of 1953 (OCSLA), as amended (43 U.S.C. 1331 et seq. [2008]), 

established Federal jurisdiction over submerged lands seaward of State boundaries. Under the OCSLA, the 

Department of the Interior (DOI) is required to manage the leasing, exploration, development, and production of 

oil and gas resources on the Federal OCS. The Secretary develops the five-year OCS oil and gas program to 

balance orderly resource development with protection of the human, marine, and coastal environments while 

simultaneously ensuring that the public receives an equitable return for these resources and that free-market 

competition is maintained. The OCSLA empowers the Secretary to grant leases to the highest qualified 

responsible bidder(s) on the basis of sealed competitive bids and to formulate such regulations as necessary to 

carry out the provisions of the Act. The Secretary has designated BOEMRE as the agency responsible for the 

mineral leasing of submerged OCS lands and for the supervision of offshore operations after lease issuance, in 

accordance with the provisions of the OCSLA. 

The OCSLA prescribes a four-stage process for oil and gas development. This four-level review process gives 

the Secretary a “continuing opportunity for making informed adjustments” (Sierra Club v. Morton, 510 F.2d 

813, 828 [5th Cir. 1975]) to ensure that all OCS oil and gas activities are conducted in an environmentally sound 

manner. In the first stage, the Secretary, through BOEMRE prepares a 5-year leasing program to identify the 

size, timing, and location of proposed lease sales and an environmental document under NEPA. In the second 

stage, BOEMRE conducts the prelease process for sale-specific NEPA reviews. If BOEMRE proceeds with a 

sale, BOEMRE conducts a sealed-bid auction, opens the bids it receives, evaluates the bids for fair market 

value, and issues the leases. The third stage involves exploration of the leased tracts. Prior to any exploratory 

drilling, a lessee must submit an exploration plan (EP) to BOEMRE for review and approval. The EP must 

comply with the OCSLA, implementing regulations, lease provisions, and other Federal laws, and is subject to 

environmental review under NEPA. The BOEMRE must disapprove an EP if the proposed activities would 

cause “serious harm or damage” to the marine, coastal, or human environment. If the EP is approved, the lessee 
must also apply for specific permits needed to conduct the activities as described in the EP. The fourth stage, 

development, is reached only if a lessee finds a commercially viable oil and/or gas discovery. A lessee must 

submit a detailed development and production plan (DPP) that BOEMRE must review under NEPA. If the DPP 

is approved, the lessee must also apply for specific pipeline, platform, and other permits for approval. 

In January 2008, the MMS issued a Final Notice of Sale for Chukchi Sea OCS Oil and Gas Lease Sale 193 to be 

conducted in February 2008. On January 31, 2008, a lawsuit was filed alleging violations pursuant to NEPA 

and the Endangered Species Act [Native Village of Point Hope v. Salazar, No. 1:08-cv-00004-RRB (D. 

Alaska)]. Sale 193 was held in February 2008. Although the lease-sale decision was challenged in the U.S. 

District Court for the District of Alaska (District Court), the plaintiffs did not request a preliminary injunction to 

stop the sale. On July 21, 2010, the District Court issued an Order remanding Sale 193 to BOEMRE to satisfy 

its obligations under NEPA in accordance with the Court’s opinion. This District Court’s Order was amended 

on August 5, 2010, and guidelines for compliance with the Order were established by the Court on September 2, 

2010. 

Pursuant to the amended Order, BOEMRE was instructed to address three concerns, as follows: 

 Analyze the environmental impact of natural gas development. 

 Determine whether missing information identified by BOEMRE in the 193 Final EIS was essential or 

relevant under 40 CFR 1502.22. 

 Determine whether the cost of obtaining the missing information was exorbitant, or the means of doing 

so unknown. 

On October 5, 2010, BOEMRE issued a Notice of Intent to Prepare a Supplemental EnvironmentalImpact 

Statement: Outer Continental Shelf, Alaska OCS Region, Chukchi Sea Planning Area, Oil and Gas Lease 193. 

The Draft SEIS augmented the analysis in the 193 Final EIS by analyzing the environmental impact of natural 

gas development and evaluating incomplete, missing, or unavailable information pursuant to 40 CFR 1502.22 

(Appendix A) to respond to the Court's remand. A Draft SEIS was made available to the public on October 15, 

2010, and a 45-day public review and comment period commenced. Many commenters requested that 

BOEMRE perform an analysis that takes into account the possibility of a blowout during exploration activities, 

in view of the Deepwater Horizon event. In March 2011, BOEMRE announced a Very Large Oil Spill (VLOS) 

analysis would be included the SEIS. The analysis was completed and integrated within this Revised Draft 

SEIS. 

The Revised Draft SEIS relies on the existing analysis provided by the 193 FEIS where appropriate, adds: (1) 

new analysis on environmental impact of natural gas development, (2) evaluates incomplete, missing, or 

unavailable information pursuant to 40 CFR 1502.22 (Appendix A), and (3) analyzes a hypothetical VLOS 

scenario. The Revised Draft SEIS also includes revisions in light of comments received on the Draft SEIS and 

analyzes additional information which has become available since the publication of the 193 Final EIS. 

In completing the NEPA process, the Final SEIS will satisfy the concerns addressed by the District Court in its 

remand order, provide a comprehensive VLOS analysis, and provide the Secretary with sufficient information 

to reaffirm or change the Department’s previous decision on Sale 193.
Sale 193 Revised Draft SEIS BOEMRE 

Acronyms and Abbreviations i

Acronyms and Abbreviations 

AAC ..............................Alaska Administrative Code 

ACIA .............................Arctic Climate Impact Assessment 

ACP ...............................Arctic Coastal Plain 

ADEC............................Alaska Department of Environmental Conservation 

ADF&G.........................Alaska Department of Fish and Game 

ADNR............................Alaska Department of Natural Resources 

AEWC ...........................Alaska Eskimo Whaling Commission 

AI/AN............................American Indian and Alaskan Native populations 

ANC ..............................Alaska Nanuuq Commission 

ANCSA .........................Alaska Native Claims Settlement Act 

ANILCA........................Alaska National Interest Land Conservation Act 

ANS...............................aquatic nuisance species 

ANWR...........................Arctic National Wildlife Refuge 

API ................................American Petroleum Institute 

APD...............................Application for Permit to Drill 

ARBO............................Arctic Region Biological Opinion 

ASRC ............................Arctic Slope Regional Corporation 

ASWG ...........................Alaska Shorebird Working Group 

atm.................................atmosphere (of pressure) 

bbls ................................barrels 

bbls/d .............................barrels per day 

Bcf .................................billion cubic feet 

Bcfg ...............................billion cubic feet of gas 

BCB...............................Bering-Chukchi-Beaufort Seas stock of bowhead whales 

BE..................................Biological Evaluation 

BLM ..............................Bureau of Land Management 

BO .................................Biological Opinion 

BOEM ...........................Bureau of Ocean Energy Management, Regulation, and Enforcement 

BOP ...............................blowout preventer (system) 

B.P.................................Before Present 

BP..................................British Petroleum 

BPXA ............................British Petroleum Exploration (Alaska) 

CAA ..............................Clean Air Act or Conflict Avoidance Agreement 

CAH ..............................Central Arctic (caribou) Herd 

CBD...............................Center for Biological Diversity 

CBS ...............................Chukchi/Bering Seas stock of polar bears 

CEQ...............................Council on Environmental Quality 

CER ...............................Categorical Exclusion Review 

CFCs..............................chlorofluorocarbons 

CFR ...............................Code of Federal Regulations 

CI...................................confidence interval 

CIAP..............................Coastal Impact Assistance Program 

CIP.................................Capital Improvement Program 

CO .................................carbon monoxide 

cp ...................................centipoise (measure of viscosity) 

CPAI..............................Conoco Phillips Alaska Incorporated 

CWA..............................Clean Water Act 

CZARA .........................Coastal Zone Act Reauthorization Amendments of 1990 

CZMA ...........................Coastal Zone Management Act 

CZMP............................Coastal Zone Management Program (or Plan) 

DEW..............................Distant Early Warning (system) 

DO .................................dissolved oxygen 

DPP................................Development and Production Plan 
BOEMRE Sale 193 Revised Draft SEIS 

ii Acronyms and Abbreviations

Draft EIS....................... Draft Environmental Impact Statement 

Draft SEIS .................... Draft Supplemental Environmental Impact Statement 

EA................................. Environmental Assessment 

EEZ............................... Exclusive Economic Zone 

EFH .............................. Essential Fish Habitat 

EIS................................ Environmental Impact Statement 

EJ.................................. Environmental Justice 

EO................................. Executive Order 

EP ................................. Exploration Plan 

ERA.............................. Environmental Resource Area 

ESA .............................. Endangered Species Act 

EWC ............................. Eskimo Walrus Commission 

FEIS.............................. Final Environmental Impact Statement 

Final SEIS..................... Final Supplemental Environmental Impact Statement 

FMP.............................. Fishery Management Plan 

FONSI .......................... Finding of No Significant Impact 

FOSC............................ Federal On-Scene Coordinator 

FR ................................. Federal Register 

FSB............................... Federal Subsistence Board 

FWPCA ........................ Federal Water Pollution Control Act 

FWS.............................. Fish and Wildlife Service 

G&G ............................. geological and geophysical 

Hz ................................. Hertz 

IAP................................ Integrated Activity Plan 

ICAS............................. Inupiat Community of the Arctic Slope 

IHA............................... Incidental Harassment Authorization 

IMO .............................. International Maritime Organization 

IPCC ............................. Intergovernmental Panel on Climate Change 

ISB................................ in-situ burn 

ISC................................ Ice Seal Committee 

ISER ............................. Institute for Social and Economic Research 

IWC .............................. International Whaling Commission 

ITA ............................... Incidental Take Authorization 

ITL................................ Information to Lessees (Clauses) 

IUCN ............................ International Union for Conservation of Nature 

LA................................. Launch Area 

LNG.............................. liquefied natural gas 

LOA.............................. Letter of Authorization 

LS ................................. Land Segment 

Mbbls............................ thousand barrels 

MBTA .......................... Migratory Bird Treaty Act 

Mcf ............................... thousand cubic feet 

Mcf/d ............................ thousand cubic feet per day 

Mcfg ............................. thousand cubic feet of gas 

md................................. millidarcy (measure of permeability) 

MFCMA ....................... Magnuson Fishery Conservation Management Act 

MMbbls ........................ million barrels 

MMC ............................ Marine Mammal Commission 

MMcf............................ million cubic feet 

MMcfg.......................... million cubic feet of gas 

MMPA.......................... Marine Mammal Protection Act 

MMS............................. Minerals Management Service 

MOU............................. Memorandum of Understanding 

MSA ............................. Magnuson-Stevens Act 

NAAQS ........................ National Ambient Air Quality Standards 

NEPA............................ National Environmental Policy Act 
Sale 193 Revised Draft SEIS BOEMRE 

Acronyms and Abbreviations iii

NPFMC .........................North Pacific Fisheries Management Council 

NHPA............................National Historic Preservation Act 

NISA..............................National Invasive Species Act of 1996 

NMFS............................National Marine Fisheries Service 

NOx................................nitrogen oxides 

NOAA ...........................National Oceanographic and Atmospheric Administration 

NOI................................Notice of Intent 

NPDES ..........................National Pollutant Discharge Elimination System 

NPR-A...........................National Petroleum Reserve in Alaska 

NPS................................National Park Service 

NRC...............................National Research Council 

NSB ...............................North Slope Borough 

NSBMC.........................North Slope Borough Municipal Code 

NSBSAC .......................North Slope Borough Science Advisory Committee 

NSIDC...........................National Snow and Ice Data Center 

NTAC’s .........................Nondiscretionary Terms and Conditions 

NTL ...............................Notice to Lessees 

O3...................................ozone 

OCRM ...........................Ocean and Coastal Resource Management 

OCS ...............................Outer Continental Shelf 

OCS Lands Act..............Outer Continental Shelf Lands Act 

OPA/OPA-90.................Oil Pollution Act of 1990 

OSFR.............................Oil Spill Financial Responsibility 

OSRA ............................Oil Spill Risk Analysis 

OSRP.............................Oil Spill Response Plan 

PAC’s ............................polyaromatic compounds 

PAH’s............................polycyclic aromatic hydrocarbons 

PEA ...............................Programmatic Environmental Assessment 

PM .................................particulate matter 

PM10 ..............................particulate matter less than 10 microns in diameter 

PSD................................Prevention of Significant Deterioration 

RCRA............................Resource Conservation and Recovery Act 

RD .................................Regional Director 

ROD ..............................Record of Decision 

ROI................................record of increase 

ROW..............................right-of-way 

RP..................................Responsible Party or Recommended Practice 

RPM’s............................Reasonably Prudent Measures 

RS/FO............................Regional Supervisor/Field Operations 

RSV ...............................Royalty Suspension Volume 

Sale 193.........................Chukchi Sea OCS Lease Sale 193 

SBS................................southern Beaufort Sea stock of polar bears 

scf ..................................standard cubic foot 

SDH...............................social determinants of health 

Secretary........................Secretary of the Interior 

SEIS...............................Supplemental Environmental Impact Statement 

SIP .................................State Implementation Plan 

SLA ...............................Submerged Lands Act 

SLS................................Spring Lead System 

SO2 ................................sulfur dioxide 

SO4 ................................sulfate 

stb ..................................stock-tank or standard barrel 

TAPS .............................Trans-Alaska Pipeline System 

Tcf .................................trillion cubic feet 

Tcfg ...............................trillion cubic feet of gas 

TEK ...............................traditional environmental knowledge 
BOEMRE Sale 193 Revised Draft SEIS 

iv Acronyms and Abbreviations

TLH .............................. Teshekpuk Lake (caribou) Herd 

UAF.............................. University of Alaska, Fairbanks 

U.S.C. ........................... United States Code 

USDOC ........................ U.S. Department of Commerce 

USDOI.......................... U.S. Department of the Interior 

USEPA ......................... U.S. Environmental Protection Agency 

USFDA......................... U.S. Food and Drug Administration 

USGS............................ U.S. Geological Survey 

UV ................................ ultraviolet 

VLOS............................ very large oil spill 

VOC.............................. volatile organic compounds 

WAH ............................ Western Arctic (caribou) Herd 

 
Sale 193 Revised Draft SEIS BOEMRE 

Table of Contents i

Table of Contents 

CHAPTER I. The Proposed Action .................................................................1

I.A. Background........................................................................................................................ 1 

I.B. Purpose and Need for the Proposed Action ...................................................................... 3 

I.C. Description of the Proposed Action.................................................................................. 3 

I.D. Regulatory and Administrative Framework ..................................................................... 5 

I.D.1. Outer Continental Shelf Lands Act........................................................................ 5 

I.D.2. National Environmental Policy Act and Council on Environmental Quality........ 6 

I.D.3. Land Use and Coastal Management ...................................................................... 6 

I.D.4. Notices and Information Provided to Lessees ....................................................... 7 

I.E. Prelease Processes and Activities.................................................................................... 10 

I.F. Postlease Processes and Activities .................................................................................. 10 

I.F.1. Ancillary Activities .............................................................................................. 10 

I.F.2. Exploration Plans, and Development and Production Plans ................................ 11 

I.F.3. Pipeline Regulations............................................................................................. 11 

I.F.4. Best Available and Safest Technology Requirements.......................................... 12 

I.F.5. BOEMRE Technical and Safety Review ............................................................. 12 

I.F.6. Pollution Prevention and Oil-Spill Response....................................................... 12 

I.F.7. BOEMRE Inspection Program............................................................................. 13 

I.F.8. Structure Removal and Site Clearance................................................................. 13 

I.F.9. Training Requirements for Offshore Personnel ................................................... 13 

I.G. New Information and Analysis Provided by this SEIS .................................................. 14 

CHAPTER II. Alternatives, Mitigation, and Issues.....................................15

II.A. Sale 193 ......................................................................................................................... 15 

II.B. Alternatives.................................................................................................................... 15 

II.B.1. Alternatives Carried Forward in the SEIS.......................................................... 15 

II.B.2. Alternatives Considered But Not Analyzed ....................................................... 16 

II.C. Mitigation Measures and Issues .................................................................................... 16 

II.C.1. Mitigation Measures ........................................................................................... 16 

II.C.2. Issues .................................................................................................................. 16 

II.C.3. Issues Considered But Not Analyzed ................................................................. 18 

II.D. Summary of Environmental Impacts............................................................................. 20 

II.D.1. Summary of Impacts: Alternative I – Proposed Action .................................... 20 

II.D.2. Summary of Impacts: Alternative II – No Lease Sale....................................... 31 

II.D.3. Summary of Impacts: Alternative III – Corridor I Deferral.............................. 31 

II.D.4. Summary of Impacts: Alternative IV – Corridor II Deferral ............................ 35 

CHAPTER III. Description of the Environment..........................................41

III.A. Physical Environment .................................................................................................. 41 

III.A.1. Physiography..................................................................................................... 41 

III.A.2. Climate and Meteorology.................................................................................. 42 
BOEMRE Sale 193 Revised Draft SEIS 

ii Table of Contents 

III.A.3. Physical Oceanography..................................................................................... 43 

III.A.4. Sea Ice ............................................................................................................... 43 

III.A.5. Water Quality.................................................................................................... 45 

III.A.6. Air Quality ........................................................................................................ 46

III.A.7. Acoustic Environment....................................................................................... 46 

III.B. Biological Environment ............................................................................................... 46

III.B.1. Lower Trophic Level Organisms ...................................................................... 46 

III.B.2. Fish Resources................................................................................................... 49 

III.B.3. Essential Fish Habitat........................................................................................ 50 

III.B.4. Threatened and Endangered Species................................................................. 51 

III.B.5. Marine and Coastal Birds.................................................................................. 58 

III.B.6. Other Marine Mammals .................................................................................... 62 

III.B.7. Terrestrial Mammals ......................................................................................... 67 

III.B.8. Vegetation and Wetlands................................................................................... 68 

III.C. Social Systems.............................................................................................................. 69 

III.C.1. Economy............................................................................................................ 69

III.C.2. Subsistence-Harvest Patterns ............................................................................ 70 

III.C.3. Sociocultural Systems ....................................................................................... 71 

III.C.4. Archaeological Resources ................................................................................. 73 

III.C.5. Environmental Justice ....................................................................................... 73 

CHAPTER IV. Environmental Consequences............................................. 74

IV.A. Basic Assumptions for Effects Assessment................................................................. 74 

IV.A.1. Significance Thresholds..................................................................................... 74 

IV.B. Natural Gas Development and Production Scenario.................................................... 75 

IV.B.1. Summary ........................................................................................................... 75 

IV.B.2. Background ....................................................................................................... 77 

IV.B.3. Infrastructure..................................................................................................... 78 

IV.B.4. Development, Production, and Transportation of Natural Gas......................... 79 

IV.B.5. Potential for Natural Gas Releases.................................................................... 82 

IV.C. Effects of Natural Gas Development and Production.................................................. 83 

IV.C.1. Water Quality.................................................................................................... 85 

IV.C.2. Air Quality ........................................................................................................ 87 

IV.C.3. Lower Trophic Level Organisms ...................................................................... 89 

IV.C.4. Fish Resources .................................................................................................. 91 

IV.C.5. Essential Fish Habitat........................................................................................ 94 

IV.C.6. Whales – Threatened and Endangered.............................................................. 95 

IV.C.7. Polar Bears – Threatened and Endangered ..................................................... 100 

IV.C.8. Marine and Coastal Birds – Threatened and Endangered............................... 102 

IV.C.9. Marine and Coastal Birds................................................................................ 103 

IV.C.10. Other Marine Mammals ................................................................................ 105 

IV.C.11. Terrestrial Mammals ..................................................................................... 107 

IV.C.12. Vegetation and Wetlands .............................................................................. 110 

IV.C.13. Economy ....................................................................................................... 112 
Sale 193 Revised Draft SEIS BOEMRE 

Table of Contents iii

IV.C.14. Subsistence-Harvest Patterns ........................................................................ 113 

IV.C.15. Sociocultural Systems ................................................................................... 117 

IV.C.16. Archaeological Resources............................................................................. 118 

IV.C.17. Environmental Justice ................................................................................... 119 

IV.D. Very Large Oil Spill (VLOS) .................................................................................... 121 

IV.D.1. Background..................................................................................................... 122 

IV.D.2. Very Large Oil Spill (VLOS) Scenario .......................................................... 126 

IV.D.3. Opportunities for Intervention and Response ................................................. 138 

IV.E. Effects of a VLOS...................................................................................................... 140 

IV.E.1. OSRA Model (Oil Spill Trajectories) ............................................................. 141 

IV.E.2. Water Quality .................................................................................................. 143 

IV.E.3. Air Quality....................................................................................................... 149 

IV.E.4. Lower Trophic-Level Organisms .................................................................... 155 

IV.E.5. Fish Resources................................................................................................. 160 

IV.E.6. Essential Fish Habitat...................................................................................... 173 

IV.E.7. Cetaceans......................................................................................................... 180 

IV.E.8. Polar Bears ...................................................................................................... 209 

IV.E.9. Marine and Coastal Birds................................................................................ 215 

IV.E.10. Ice Seals......................................................................................................... 224

IV.E.11. Pacific Walrus ............................................................................................... 233 

IV.E.12. Terrestrial Mammals ..................................................................................... 239 

IV.E.13. Vegetation and Wetlands............................................................................... 246 

IV.E.14. Economy........................................................................................................ 249 

IV.E.15. Subsistence Harvest Patterns......................................................................... 252 

IV.E.16. Sociocultural Systems ................................................................................... 267 

IV.E.17. Archaeological Resources ............................................................................. 271 

IV.E.18. Environmental Justice ................................................................................... 276 

IV.E.19. Conclusion – Effects of a VLOS................................................................... 282 

IV.F. Unavoidable Adverse Effects..................................................................................... 283 

IV.G. Relationship Between Local Short-Term Uses and Maintenance and Enhancement of 

Long-Term Productivity ........................................................................................... 283 

IV.H. Irreversible and Irretrievable Commitment of Resources.......................................... 284 

CHAPTER V. Cumulative Effects .............................................................. 285

V.A. Introduction................................................................................................................. 285 

V.A.1. Structure of the Analysis.................................................................................. 285 

V.A.2. General Conclusions ........................................................................................ 286 

V.B. Analysis of Cumulative Effects................................................................................... 287 

V.B.1. Water Quality ................................................................................................... 287 

V.B.2. Air Quality........................................................................................................ 288 

V.B.3. Lower Trophic Level Organisms...................................................................... 289 

V.B.4. Fish Resources.................................................................................................. 289 

V.B.5. Essential Fish Habitat....................................................................................... 289 

V.B.6. Threatened and Endangered Species................................................................ 290 
BOEMRE Sale 193 Revised Draft SEIS 

iv Table of Contents 

V.B.7. Marine and Coastal Birds ................................................................................. 292 

V.B.8. Other Marine Mammals ................................................................................... 293 

V.B.9. Terrestrial Mammals ........................................................................................ 293 

V.B.10. Vegetation and Wetlands................................................................................ 294 

V.B.11. Economy......................................................................................................... 295 

V.B.12. Subsistence-Harvest Patterns ......................................................................... 296 

V.B.13. Sociocultural Systems .................................................................................... 297 

V.B.14. Archaeological Resources .............................................................................. 298 

V.B.15. Environmental Justice .................................................................................... 298 

CHAPTER VI. Consultation and Coordination ........................................ 300

VI.A. Development of the Proposed Action, DEIS, and FEIS............................................ 300 

VI.B. Development of the SEIS........................................................................................... 300 

VI.C. Consultation ............................................................................................................... 301 

VI.C.1. ESA Section 7 ................................................................................................. 301 

VI.C.2. Essential Fish Habitat Consultation ................................................................ 302 

VI.C.3. Section 106 Consultation ................................................................................ 302 

VI.C.4. CZMA Consistency Review ........................................................................... 303 

VI.D. Authors, Reviewers, and Supporting Staff ................................................................ 303 

LITERATURE CITED ................................................................................. 306

APPENDIX A. Analysis of Incomplete or Missing Information.............. A1

APPENDIX B. Very Large Oil Spill Information ......................................B1

APPENDIX C. Fish Resources and EFH - Tables and Figures ............... C1

APPENDIX D. Estimate for a Very Large Oil Spill. ................................. D1

List of Figures 

Figure 1. Sale 193 proposed action area, excluding sale blocks within a 25 mi coastal buffer 

(deferred in the 2007–12 Five-Year Program). Corridor 1 and Corridor 2 deferrals 

for Alternatives III and IV, respectively, and Ledyard Bay Critical Habitat Unit for 

spectacled eider are also shown. .............................................................................. 4 

Figure 2. Scenario for gas production in the Chukchi OCS begins as oil production decreases 

(illustrated below in Figure 3 and by the squares in the graph above). ................. 76 

Figure 3. Sale 193 FEIS scenario for oil production, with the addition of offshore pipelines 

for gas now indicated in years 2032–2034. It is acknowledged that oil and gas 

activities in the Chukchi Sea have not come to pass as projected in the scenario for 

the Sale 193 FEIS................................................................................................... 78 

Figure 4. Decline in daily discharge rates and rising cumulative oil discharge for a 74-day 

period after a blowout at a hypothetical exploration well in the central Chukchi Sea 

planning area. ....................................................................................................... 127 
Sale 193 Revised Draft SEIS BOEMRE 

Table of Contents v

List of Tables 

Table 1. Projected greenhouse gas emissions from the production activities associated with 

the Proposed Action. .............................................................................................. 88 

Table 2. Results of AVALON/MERLIN discharge model for Chukchi Sea hypothetical 

VLOS well over maximum (74-day) time period estimated for mobilization, 

drilling, and completion of a relief well............................................................... 128 

Table 3. Estimates for time periods required to drill a relief well and to kill the discharge at 

the Chukchi Sea VLOS well (provided by BOEMRE AKOCSR Field Operations).

.............................................................................................................................. 130 

Table 4. Properties and persistence for light-weight crude oil. (Sources: Michel, 1992; 

Reed et al. 2005 [Sintef OWM]; Brandvik et al., 2010). ..................................... 132 

Table 5. Length of discontinuous shoreline contacted in winter and summer within a 360 

day period (estimated from OSRA model). ......................................................... 133 

Table 6. Blowout scenarios and key differences in impacts, response, and/or intervention.

.............................................................................................................................. 140 

Table 7. Anadromous waters in Northwest Alaska from Bering Strait to Nuiqsut............ 163 

Table 8. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting 

from a given location that will contact Alaska coastal land segments (LS) within 

60 or 360 days. ..................................................................................................... 170 

Table 9. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting 

from a given location that will contact Russia coastal land segments (LSs) with 60 

or 360 days. .......................................................................................................... 170 

Table 10. Target species and life stage for which EFH has been described in the Arctic 

Fishery Management Plan for the Chukchi Sea................................................... 174 

Table 11. The effects of a VLOS on EFH of Arctic cod, saffron cod, oplio crab and salmon in 

the Alaska Chukchi Sea. ...................................................................................... 177 

Table 12. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting 

from a given location that will contact a portion of Opilio Crab EFH within 60 or 

360 days. .............................................................................................................. 178 

Table 13. Range of fractions of a VLOS (expressed as percentages) starting from a given 

location that will contact a portion of Saffron Cod EFH within 60 or 360 days. 178 

Table 14. Range of fractions of a VLOS (expressed as percentages) starting from a given 

location that will contact a portion of Arctic cod or salmon (marine) EFH within 

60 or 360 days. ..................................................................................................... 179 

Table 15. Polar bear habitat areas analyzed in the VLOS OSRA analysis........................... 213 

Table 16. Walrus habitat areas analyzed in the VLOS OSRA analysis................................ 238 

Table 17. Consultation or conference with respect to potential impacts to Endangered, 

Threatened, and Candidate species present within the affected area................... 302 
BOEMRE Sale 193 Revised Draft SEIS 

vi Table of Contents 

Table 18. List of the primary individuals contributing to development and analysis in the 

SEIS ..................................................................................................................... 303 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER I. The Proposed Action 1

CHAPTER I. The Proposed Action 

I.A. Background 

On June 30, 2002, the Secretary of the U.S. Department of the Interior (USDOI) approved a Final 

Outer Continental Shelf (OCS) Oil and Gas Leasing Program for 2002–2007 (2002–2007 Five-Year 

Program). In compliance with the National Environmental Policy Act (NEPA), the USDOI, Minerals 

Management Service (MMS) in September 2005 published a Notice of Intent to Prepare an 

Environmental Impact Statement analyzing a proposed lease sale known as Chukchi Sea OCS Lease 

Sale 193. MMS released in October 2006, a document entitled “Draft Environmental Impact 

Statement for Oil and Gas Lease Sale 193 and Seismic-Surveying Activities in the Chukchi Sea” 

(USDOI, MMS, 2006). In June 2007, the final document was released and entitled “Final 

Environmental Impact Statement for Oil and Gas Lease Sale 193 and Seismic-Surveying Activities in 

the Chukchi Sea” (Sale 193 FEIS)(USDOI, MMS, 2007a). This document is hereby incorporated by 

reference (USDOI, MMS, 2007a; available at http://www.alaska.boemre.gov/ref/EIS%20EA/ 

Chukchi_FEIS_193/feis_193.htm. 

The prelease process was not completed in time for Chukchi Sea OCS Lease Sale 193 to be 

conducted within the 2002-2007 Five Year Program which expired on June 30, 2007. Chukchi Sea 

OCS Oil and Gas Lease Sale 193 was included in the 2007-2012 Five Year Oil and Gas Leasing 

Program approved by the Secretary of the U.S. Department of the Interior (Secretary) on June 29, 

2007. 

The 2007-2012 Outer Continental Shelf Oil and Gas Program was subject to litigation in the U.S. 

Court of Appeals for the District of Columbia (Center for Biological Diversity v. DOI, Nos. 07-1247, 

07-1433 [D.C. Cir.]). In April 2009 the D.C. Circuit Court found that the Environmental Sensitivity 

Analysis was insufficient. On July 29, 2009, the Court limited its mandate to the Beaufort, Chukchi, 

and Bering Sea Planning Areas. In response, the Department conducted a more complete 

environmental sensitivity analysis beyond the shoreline that compares the environmental sensitivity 

of all 26 OCS planning areas and identifies those areas whose environments are most and least 

sensitive to OCS activity. After reviewing the new analysis and rebalancing the factors required by 

the OCS Lands Act, the Secretary announced the Preliminary Revised Program (PRP) for 2007-2012 

on March 31, 2010, which included a sale in the Chukchi Sea Planning Area. The Department 

submitted the PRP to the Court, President, and the Congress. The Department announced a 30-day 

public comment period, to May 3, 2010. During the comment period, the Department received over 

118,000 comments for the Secretary’s consideration. On December 23, 2010, the Secretary submitted 

the Revised Program to the Court. The Revised Program superseded the original program decision 

made in 2007. Sale 193 remained in the Five-Year Program as did a special interest sale in Cook 

Inlet. The North Aleutian Basin Sale 214, Beaufort Sea Sales 209 and 217, and Chukchi Sea Sales 

212 and 221, were removed from the Revised Program. On March 4, 2011, the government filed a 

motion with the court to dismiss the case. On April 26, 2011, the Court issued an Order acknowleging 

that no party had opposed dismissal or challenged the Secretary's Revised Program, and requiring that 

its mandate, previously stayed, be issued. The mandate, issued on May 5, 2011, vacated the original 

2007-2012 Program, leaving the unchallenged 2007-2012 Revised Program in its place. The parties 

filed a motion with the Court to dismiss the case. 

In January 2008, the MMS issued a Final Notice of Sale for Chukchi Sea OCS Oil and Gas Lease 

Sale 193 to be conducted in February 2008. On January 31, 2008, a lawsuit was filed alleging 

violations pursuant to NEPA and the Endangered Species Act [Native Village of Point Hope v. 

Salazar, No. 1:08-cv-00004-RRB (D. Alaska)]. Plaintiffs in the case included Native Village of Point 

Hope, the City of Point Hope, the Inupiat Community of the Arctic Slope, REDOIL, the Alaska 

Wilderness League, Center for Biological Diversity, National Audubon Society, Natural Resources 
BOEMRE Sale 193 Revised Draft SEIS 

2 CHAPTER I. The Proposed Action 

Defense Council, Northern Alaska Environmental Center, Oceana, Pacific Environment, Sierra Club, 

and The Wilderness Society. Sale 193 was held in February of 2008. The BOEMRE received high 

bids totaling approximately $2.6 billion and issued 487 leases, covering approximately 2.8 million 

acres. 

By Secretarial Order No. 3302 dated June 18, 2010, MMS was renamed as the Bureau of Ocean 

Energy Management, Regulation and Enforcement (BOEMRE). 

On July 21, 2010, two years after the lawsuit was filed, the United States (U.S.) District Court for the 

District of Alaska (District Court) issued an Order remanding the Sale 193 matter to BOEMRE to 

satisfy its obligations under NEPA in accordance with the District Court’s opinion. This District 

Court’s Order was amended on August 5, 2010, and guidelines for compliance with the Order were 

established by the Court on September 2, 2010. 

Pursuant to the amended Order, BOEMRE was instructed to address three concerns, as follows: 

 Analyze the environmental impact of natural gas development. 

 Determine whether missing information identified by BOEMRE in the Sale 193 FEIS was 

essential or relevant under 40 CFR 1502.22. 

 Determine whether the cost of obtaining the missing information was exorbitant, or the 

means of doing so unknown. 

On October 5, 2010, BOEMRE issued a Notice of Intent to Prepare a Supplemental Environmental 

Impact Statement: Outer Continental Shelf, Alaska OCS Region, Chukchi Sea Planning Area, Oil and 

Gas Lease 193. On October 15, 2010, a Draft Supplemental Environmental Impact Statement (Draft 

SEIS) was released to the public for a 45-day comment period ending November 30, 2010. In 

November 2010, BOEMRE held public hearings and government-to-government consultations with 

affected tribes. By the end of the public comment period, BOEMRE Alaska Region received over 

150,000 comments on the Draft SEIS, some of which raised matters requiring significant technical 

review. Many commenters requested that BOEMRE perform an analysis that takes into account the 

possibility of a blowout during exploration activities, in view of the Deepwater Horizon event (DWH 

event). 

Neither the Sale 193 FEIS of May 2007 nor the Draft SEIS of October 2010 analyzed a Very Large 

Oil Spill (VLOS)—that is, a spill more than or equal to 150,000 barrels of oil. The Sale 193 FEIS did 

analyze a large spill from hypothetical development activities of 1,500 barrels from a platform or 

4,600 barrels from a pipeline. The BOEMRE did not analyze the environmental effects of a VLOS in 

the Draft SEIS, for two reasons. First, such analysis was not specifically required by the District 

Court’s remand. Second, prior to the DWH event, BOEMRE did not consider an exploration well 

blowout as a statistically foreseeable event and BOEMRE found that many of the geologic, drilling, 

and water depth conditions associated with the DWH event were not germane to likely conditions in 

the Chukchi Sea. 

Subsequent to releasing and receiving public comments on the Draft SEIS, BOEMRE conducted an 

analysis of possible flow rates throughout the most prospective Chukchi Sea Planning Area. This 

analysis determined a high possible flow rate that, unimpeded, could result in an oil spill volume 

much larger than had been analyzed in the Sale 193 FEIS. In March of 2011, BOEMRE decided to 

incorporate a VLOS analysis into its ongoing SEIS process. The VLOS analysis is based on the 

estimated size of an unlikely but possible oil spill resulting from a hypothetical blowout scenario. 

Further discussion of the estimate for a VLOS event from an exploration well is provided in 

Appendix D. To ensure sufficient opportunity for public and agency comment on its VLOS analysis, 

BOEMRE decided to issue a Revised Draft SEIS. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER I. The Proposed Action 3

This Revised Draft Supplemental EIS augments the analysis of the Sale 193 FEIS to address the 

District Court’s remand and to analyze the potential environmental impacts of VLOS. This Revised 

Draft SEIS relies on the existing analysis provided by the Sale 193 FEIS where appropriate, adds new 

analysis with respect to the District Court’s three concerns (including analysis of natural gas 

development), and analyzes a hypothetical VLOS scenario. This Revised Draft SEIS also includes 

revisions in light of comments received on the Draft SEIS. 

After a formal public and agency comment period, BOEMRE will make necessary revisions to this 

Revised Draft SEIS and develop a Final Supplemental Environmental Impact Statement (Final SEIS) 

that satisfies the concerns addressed in the District Court’s remand order, responds to substantive 

public and agency comments, and provides analysis of a VLOS. In accordance with Council on 

Environmental Quality (CEQ) regulations and guidelines, BOEMRE also intends that further analysis 

of specific proposed activities may tier from the Final SEIS, such that the facts and analysis presented 

in the Final SEIS may be incorporated by reference into future, proposal-specific environmental 

reviews 

I.B. Purpose and Need for the Proposed Action 

The purpose of the proposed action addressed in the Sale 193 FEIS and the SEIS is to (1) offer for 

lease areas in the Chukchi Sea Planning Area (see Figure 1) of the Alaska Outer Continental Shelf 

(OCS) that might contain economically recoverable oil and gas resources and (2) provide analyses for 

exploration seismic-survey activities. The Revised Draft SEIS augments the analysis in the Sale 193 

FEIS by analyzing the environmental impact of natural gas development, evaluating (in Appendix A) 

incomplete, missing, or unavailable information pursuant to 40 CFR 1502.22, and analyzing the 

environmental impact of a low probability VLOS event. At the completion of the NEPA process, the 

Final SEIS will provide the Secretary with sufficient information to reaffirm, modify, or cancel the 

Department’s previous decision on Sale 193. 

The Outer Continental Shelf Lands Act of 1953 (OCSLA), as amended (43 U.S.C. 1331 et seq. 

[2008]), established Federal jurisdiction over submerged lands seaward of State boundaries. Under 

the OCSLA, the Department of the Interior is required to manage the leasing, exploration, 

development, and production of oil and gas resources on the Federal OCS. The Secretary develops 

the five-year OCS oil and gas program and is required to balance orderly resource development with 

protection of the human, marine, and coastal environments while simultaneously ensuring that the 

public receives an equitable return for these resources and that free-market competition is maintained. 

The OCSLA empowers the Secretary to grant leases to the highest qualified responsible bidder(s) on 

the basis of sealed competitive bids and to formulate such regulations as necessary to carry out the 

provisions of the Act. The Secretary has designated BOEMRE as the agency responsible for the 

mineral leasing of submerged OCS lands and for the supervision of offshore operations after lease 

issuance, in accordance with the provisions of the OCSLA. 

The Chukchi OCS is viewed as one of the most petroleum-rich offshore provinces in the country, 

with geologic plays extending offshore from some of the largest oil and gas fields on Alaska’s North 

Slope. The BOEMRE’s current petroleum assessment indicates a mean technically recoverable oil 

resource of 12 billion barrels (Bbbl) with a 5% chance of 29 Bbbl (USDOI, MMS, 2006). The mean 

undiscovered gas resources total 76.77 trillion cubic feet (Tcf) with a 5% chance of 209.53 Tcf. At 

these levels, the leasing of offshore areas within the Chukchi Sea may lead to development and 

production, and could contribute significantly to the national energy supply. 

I.C. Description of the Proposed Action 

The proposed action is to affirm the issuance of leases pursuant to the Chukchi Sea OCS Oil and Gas 

Lease Sale 193, as analyzed in “Final Environmental Impact Statement for Oil and Gas Lease Sale 
BOEMRE Sale 193 Revised Draft SEIS 

4 CHAPTER I. The Proposed Action 

Figure 1. Sale 193 proposed action area, excluding sale blocks within a 25 mi coastal buffer (deferred in 

the 2007–12 Five-Year Program). Corridor 1 and Corridor 2 deferrals for Alternatives III and 

IV, respectively, and Ledyard Bay Critical Habitat Unit for spectacled eider are also shown. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER I. The Proposed Action 5

193 and Seismic-Surveying Activities in the Chukchi Sea” (Sale 193 FEIS)(USDOI, MMS, 2007a). 

The sale area encompasses approximately 6,156 whole and partial blocks (about 34 million acres) 

within the Chukchi Sea portion of Alaska’s OCS (Figure 1). In the 2007-2012 Five-Year Program, 

the Secretary excluded from the sale a corridor near the State of Alaska’s northern coast, a distance of 

up to approximately 50 miles from shore that is known as the polynya or spring lead system. Water 

depths in the majority of the sale area vary from about 95 feet (ft) to approximately 262 ft. A small 

portion of the northeast corner of the area deepens to approximately 9,800 ft. 

After releasing the Sale 193 FEIS in June 2007, BOEMRE held Sale 193 in February of 2008. The 

BOEMRE received high bids totaling approximately $2.6 billion and issued 487 leases, covering 

approximately 2.8 million acres. 

I.D. Regulatory and Administrative Framework 

Federal laws establish the OCS leasing program (i.e., Outer Continental Shelf Lands Act) and the 

environmental review process (i.e., NEPA). Several Federal statutes and their implementing 

regulations establish specific consultation and coordination processes with Federal, State, and local 

agencies (i.e., Coastal Zone Management Act [CZMA], National Historic Preservation Act [NHPA], 

Endangered Species Act [ESA], the Magnuson-Stevens Fishery Conservation and Management Act, 

and the Marine Mammal Protection Act [MMPA]). In addition, the OCS leasing process and all 

activities and operations on the OCS must comply with other Federal, State, and local laws and 

regulations. 

A complete treatment of the regulatory and administrative framework can be reviewed in the Sale 193 

FEIS available online at: http://www.alaska.boemre.gov/ref/EIS%20EA/Chukchi_FEIS_193/ 

feis_193.htm and the 2007-2012 Five-Year Program EIS (OCS EIS/EA MMS 2007-003), which is 

available online at http://www.boemre.gov/5-year/2007-2012FEIS, and the Arctic Multi-Sale Draft 

EIS available online at: http://alaska.boemre.gov/ref/EIS%20EA/ArcticMultiSale_209/ 

2008_0055_deis/vol1.pdf. 

I.D.1. Outer Continental Shelf Lands Act 

Under the OCSLA, the Department of the Interior is required to manage the orderly leasing, 

exploration, development, and production of oil and gas resources on the Federal OCS, while 

simultaneously ensuring the following: the protection of the human, marine, and coastal 

environments; a fair and equitable return for OCS resources; and maintenance of free market 

competition in the leasing process. The OCSLA also requires coordination with affected States as 

well as local governments affected by OCS development activities. BOEMRE seeks and encourages 

participation from affected States and other interested parties at each procedural step leading to lease 

issuance. 

The OCSLA creates a four-stage process for planning, leasing, exploration, and production of oil and 

gas resources in Federal waters. In the first stage, the Secretary, through BOEMRE prepares a fiveyear leasing program to identify the size, timing, and location of proposed lease sales and an 

environmental document under NEPA. In the second stage, BOEMRE conducts the prelease process 

for sale-specific NEPA reviews. If BOEMRE proceeds with a sale, BOEMRE conducts a sealed-bid 

auction, opens the bids it receives, evaluates the bids for fair market value, and issues the leases. 

Under that four-stage process, an OCS lease authorizes a lessee to engage only in “ancillary 

activities” that do not harm the environment pending further review and approvals (30 CFR 250.105, 

250.202, and 250.209; see also, 43 U.S.C. 1340[c][approval required prior to exploration]; 43 U.S.C. 

1351 [approval required prior to development and production]). The Supreme Court has recognized 

that “[u]nder OCSLA’s plain language, the purchase of a lease entails no right to proceed with full 

exploration, development, or production . . . ; the lessee acquires only a priority in submitting plans to 
BOEMRE Sale 193 Revised Draft SEIS 

6 CHAPTER I. The Proposed Action 

conduct these activities" (Secretary of the Interior v. California, 464 U.S. 312, 339 [1984]). The third 

stage involves exploration of the leased tracts. Prior to any exploratory drilling, a lessee must submit 

an exploration plan (EP) to BOEMRE for review and approval. The EP must comply with the 

OCSLA, implementing regulations, lease provisions, and other Federal laws, and is subject to 

environmental review under NEPA. The BOEMRE must disapprove an EP if the proposed activities 

would cause “serious harm or damage” to the marine, coastal, or human environment. If the EP is 

approved, the lessee must also apply for specific permits needed to conduct the activities as described 

in the EP. The fourth stage, development, is reach only if a lessee finds a commercially viable oil 

and/or gas discovery. A lessee must submit a detailed development and production plan (DPP) that 

BOEMRE must review under NEPA. If the DPP is approved, the lessee must also apply for specific 

pipeline, platform, and other permits for approval. 

The OCSLA four-stage review process gives the Secretary a “continuing opportunity for making 

informed adjustments” in developing offshore energy resources to ensure all activities are conducted 

in an environmentally sound manner (Sierra Club v. Morton, 510 F.2d 813, 828 [5th Cir.1975]). 

I.D.2. National Environmental Policy Act and Council on Environmental 

Quality 

The National Environmental Policy Act (42 USC 4321 et seq.) requires Federal agencies to use a 

systematic, interdisciplinary approach to protecting the human environment. This approach ensures 

the integrated use of the natural and social sciences in any planning and decision-making that may 

have an impact on the environment. In furtherance of these policies, NEPA also requires Federal 

agencies to prepare a detailed EIS on any major Federal action that may have a significant impact on 

the environment. This EIS must analyze any adverse environmental effects that cannot be avoided or 

mitigated, alternatives including the Proposed Action, the relationship between short-term uses and 

long-term productivity of the environment, and any irreversible and irretrievable commitments of 

resources. In 1979, the CEQ established uniform procedures for implementing NEPA. These 

regulations (40 CFR 1500.1–1508.28) provide for the use of the NEPA process to identify and assess 

the alternatives to proposed actions that avoid and minimize adverse effects on the human 

environment. The DOI regulations implementing NEPA are at 43 CFR Part 46. 

I.D.3. Land Use and Coastal Management 

Land Status and Use 

This section describes the status of land adjacent to the U.S. Chukchi Sea. The land adjacent to the 

U.S. Chukchi Sea is within the North Slope Borough (NSB), a political subdivision of the State of 

Alaska. Land-ownership in the NSB is complex. The Federal Government is the predominant land 

owner of onshore lands, with more than half of the Borough’s land area encompassed by the National 

Petroleum Reserve-Alaska (NPR-A) and the Arctic National Wildlife Refuge (ANWR). Other major 

landholders include the State of Alaska, Arctic Slope Regional Corporation (ASRC), Nunamuit 

Corporation, Atqasuk Corporation, Ukpeagvik Inupiat Corporation, Kaktovik Inupiat Corporation, 

Kuukpik Village Corporation, Tikigaq Corporation, Cully Corporation, and Olgoonik Corporation. 

Coastal Zone Management 

Pursuant to the Coastal Zone Management Act (CZMA) and the Coastal Zone Reauthorization 

Amendments of 1990, all Federal activities, including OCS oil and gas lease sales and post-lease 

activities, must be consistent to the maximum extent practicable with the enforceable policies of each 

affected State’s coastal zone management program (CZMP). Each State’s CZMP sets forth 

objectives, policies, and standards relative to public and private use of land and water resources in the 

coastal zone. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER I. The Proposed Action 7

The Statewide standards for “uses and activities” and “resources and habitats” may be relevant to the 

natural gas development and production activities evaluated in this SEIS. Under the uses and 

activities category, the policies relevant to Chukchi Sea natural gas development and production are 

coastal development, natural hazard areas, coastal access, energy facilities, utility routes and facilities, 

sand and gravel extraction, subsistence, and transportation routes and facilities. Under the resources 

and habitats category, the policies relevant to Chukchi Sea natural gas development and production 

are habitats; air, land, and water quality; and historic, prehistoric, and archaeological resources. 

The State’s coastal zone within the NSB includes all State-owned submerged lands in the Chukchi 

Sea. Because Federal land is excluded from the coastal zone, the State’s inland coastal zone on the 

Chukchi Sea coast is limited to the Point Hope/Point Lay coastal sector, which is west of NPR-A. 

The coastal zone boundary extends inland roughly 25 miles from the coast and along the full length of 

all major river corridors to include all anadromous fish spawning and overwintering habitats. In 

2004, the State of Alaska amended the Alaska Coastal Management Program and adopted regulations 

under 11 AAC 110, 112, and 114. Under the amended program, coastal districts were required to 

revise their local plans to comply with the new guidelines and submit them to the State for approval. 

The State of Alaska has not approved the NSB’s revised coastal management program. If the NSB 

submits a revised plan and obtains State approval, future development activities will need to comply 

with its local enforceable policies. 

I.D.4. Notices and Information Provided to Lessees 

To encourage lessees’ knowledge and appreciation of environmental resources, to inform lessees on 

how to avoid adverse impacts to these resources, and to provide guidance to lessees on how to fulfill 

the requirements of the OCS operating regulations, BOEMRE develops and distributes the following 

administrative documents. Additional information on these topics is available in Section II.B.3(c)(2) 

and II.B.3(c)(3) of the Sale 193 FEIS. 

Notice to Lessees 

Notices to Lessees (NTL) inform lease owners/operators that they must meet the provisions of the 

regulations and how they are to operate under applicable OCS operating regulations. NTLs are either 

applicable nationally to the OCS program or are issued by and applicable to specific regions of the 

OCS. The National NTLs are posted to BOEMRE’s website at http://www.boemre.gov/ntls/. The 

Alaska Region NTLs are posted to the Alaska Region’s website at http://alaska.boemre.gov/regs/ 

NTLS.htm. New NTLs issued subsequent to the Deepwater Horizon (DWH) event are discussed in 

Section IV.D.1 of this Revised Draft SEIS and are also available on BOEMRE's website. 

Information to Lessees 

The Information to Lessee and Operators (ITL) provides lessees with additional information on how 

to mitigate potential adverse impacts from future oil and gas activities. Some ITLs provide 

information about issues and concerns related to particular environmental or sociocultural resources. 

Others provide information on how lessees might plan their activities to meet BOEMRE requirements 

or reduce potential impacts. Still other ITLs provide information about the requirements or mitigation 

required by other Federal and State agencies. To the extent that the ITL clauses alert and inform 

lessees and their contractors about mitigative measures, they are effective in lowering potential 

impacts. The ITLs listed below apply to all OCS activities in the Chukchi Sea and are considered part 

of the Proposed Action and each action alternative. Section II.B.3.c(3) of the Sale 193 FEIS provides 

the full text and discussion of each ITL listed below. 

 No. 1 –Community Participation in Operations Planning 

 No. 2 –Bird and Marine Mammal Protection 

 No. 3 –River Deltas 
BOEMRE Sale 193 Revised Draft SEIS 

8 CHAPTER I. The Proposed Action 

 No. 4 –Endangered Whales and MMS Monitoring Program 

 No. 5 –Availability of Bowhead Whales for Subsistence-Hunting Activities 

 No. 6 –High-Resolution Geological and Geophysical Survey Activity 

 No. 7 –Spectacled Eider and Steller’s Eider 

 No. 8 –Sensitive Areas to be Considered in Oil-Spill-Response Plans 

 No. 9 –Coastal Zone Management 

 No. 10 –Navigational Safety 

 No. 11 –Offshore Pipelines 

 No. 12 –Discharge of Produced Waters 

 No. 13 –Use of Existing Pads and Islands 

 No. 14 –Planning for Protection of Polar Bears 

 No. 15 – Possible listing of Polar Bear under ESA 

 No. 16 – Archaeological and Geological Hazards Reports and Surveys 

 No. 17 – Response Plans for Facilities Located Seaward of the Coast Line 

 No. 18 – Oil Spill Financial Responsibility for Offshore Facilities 

 No. 19 – Good Neighbor Policy 

 No. 20 – Rentals/Minimum Royalties and Royalty Suspension Provisions 

 No. 21 – MMS Inspection and Enforcement of Certain Coast Guard Regulations 

 No. 22 – Statement Regarding Certain Geophysical Data 

 No. 23 – Affirmative Action Requirements 

 No. 24 – Bonding Requirements 

Since the publication of the Sale 193 FEIS, there have been a couple of changes to the ITLs for the 

lessees. Notably, the polar bear has been listed as threatened under the Endangered Species Act in 

May 2008 as contemplated by ITL No. 15. Following the listing, BOEMRE reinitiated consultation 

with FWS. As stated in the ITL, BOEMRE has undergone consultation with FWS. For more 

information see Section VI. 

The Final Notice of Sale included ITL No. 25, Review of Development and Production Plans. This 

ITL was added to fully inform lessees that MMS will be conducting additional National 

Environmental Policy Act reviews on any proposed sale-related development. Among other things, 

the ITL will inform lessees that any future development plan and environmental impact analyses must 

include information demonstrating that the structures and associated infrastructure proposed are 

necessary and that no other reasonable alternative sizing, placement, or grouping of this infrastructure 

would result in a smaller environmental footprint or cause less interference with other significant uses 

of the OCS and the adjacent coastal area. 

Also, ITL 25 contains several lessee advisories requested by the State of Alaska. We are now 

advising lessees of certain information that the State of Alaska may require from them for OCS 

related operations that extend into state waters or that affect coastal resources and uses when the State 

reviews the DPP's for consistency with the Alaska Coastal Management Plan. This may include 

biological surveys to identify environmentally sensitive areas; a plan to protect environmentally 

sensitive areas to comply with the State's oil discharge prevention and contingency plan regulations: 

additional lessee training on Alaska's oil spill prevention standards: adherence to the oil pollution 

prevention regulations of the State of Alaska; and pre-booming requirements for transfers of fuel, 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER I. The Proposed Action 9

crude oil, persistent product, and oily ballast for all vessels operating in Alaska State waters. The ITL 

is provided to lessees for their planning purposes. The text of ITL No. 25 is provided below: 

No. 25 –Review of Development and Production Plans. Lessees are advised that MMS intends to 

prepare an environmental impact statement (EIS) on any Development and Production Plan submitted 

for a lease issued from Chukchi Sea Sale 193 and pursuant to regulations at 30 CFR 250. Per the 

Department of Interior Manual (516 DM 15.4), approval of an offshore oil and gas development and 

production plan in any area or region of the offshore, other than the central or western Gulf of 

Mexico, normally requires preparation of an EIS. Preparation of such an EIS typically takes 2-3 

years. 

Per 30 CFR 250.247 and 250.261, environmental information and an environmental impact analysis 

(EIA) must accompany the DPP. Information in the EIA must be as specific as necessary to assist 

MMS in complying with NEPA and other relevant Federal laws. The DPP and EIA must include the 

information necessary for evaluation of potential direct and indirect impacts of the proposed 

activities, including any proposed coastal facilities and the lessee’s plans for complying with relevant 

State of Alaska and North Slope Borough regulations for coastal facility construction and use. 

The MMS has a long established goal to ensure that exploration, development, and production 

operations are conducted in a manner that promotes the multiple use of the Outer Continental Shelf 

(OCS). To achieve this goal, MMS will take action within its authority to limit structures and 

associated infrastructure for drilling, development, production, and transportation of production to the 

minimum necessary for proper and safe operations. In support of this policy, any future DPP and EIA 

must include information demonstrating that the structures and associated infrastructure proposed in 

the DPP are necessary and that no other reasonable alternative sizing, placement, or grouping of this 

infrastructure would result in a smaller environmental footprint or cause less interference with other 

significant uses of the OCS and the adjacent coastal area (30 CFR 250 Subpart B). 

The MMS has a long established goal to ensure that exploration, development, and production 

operations are conducted in a manner that promotes the multiple use of the Outer Continental Shelf 

(OCS). To achieve this goal, MMS will take action within its authority to limit structures and 

associated infrastructure for drilling, development, production, and transportation of production to the 

minimum necessary for proper and safe operations. In support of this policy, any future DPP and EIA 

must include information demonstrating that the structures and associated infrastructure proposed in 

the DPP are necessary and that no other reasonable alternative sizing, placement, or grouping of this 

infrastructure would result in a smaller environmental footprint or cause less interference with other 

significant uses of the OCS and the adjacent coastal area (30 CFR 250 Subpart B). 

In support of the cumulative analysis in the EIS, MMS can require lessees and operations in the 

vicinity of the proposed development activity to submit information about preliminary plans for their 

leases or units (30 CFR 250.269(b)). 

Per Outer Continental Shelf Lands Act (OCSLA) implementing regulations at 30 CFR 

250.270(a)(1)(ii), the Regional Supervisor will act on the deemed submitted DPP within 60 calendar 

days after the final EIS is released or adopted. 

Lessees also need to be aware of certain information that the State of Alaska may seek from the lessee 

for OCS-related operations that extend into state waters or that affect coastal resources and uses when 

the State reviews the DPP for consistency with the Alaska Coastal Management Plan. The lessee 

should be aware of the following: 

A. The State may require lessees to complete biological surveys prior to the start of 

operations, in conjunction with local/native knowledge, to identify environmentally sensitive areas. A 

plan for protecting environmentally sensitive areas may be required by the State under its oil 

discharge prevention and contingency plan regulations (18 AAC 75, Article 4). 
BOEMRE Sale 193 Revised Draft SEIS 

10 CHAPTER I. The Proposed Action 

B. The State may require lessees to provide additional training on Alaska oil spill prevention 

standards (18 AAC 75, Article 1). 

C. The lessee may be required to adhere to the oil pollution prevention regulations of the 

State of Alaska, including financial responsibility requirements (18 AAC 75, Article 2), oil spill 

response requirements(18 AAC 75, Article 3), and oil discharge prevention and contingency plan (cplan) requirements (18 AAC 75, Article 4). 

D. The lessee may need to comply with pre-booming requirements (18 AAC 75, Article 1) 

for transfers of fuel, crude oil, persistent product, and oily ballast to all vessels operating in Alaska 

state waters. 

I.E. Prelease Processes and Activities 

A full history and description of the prelease process for Sale 193 is provided in Section I.D. of the 

Sale 193 FEIS. Moreover, provisions specific to leasing are in 30 CFR 256, 30 CFR 259, and 30 

CFR 260. Regulations concerning the Federal leasing of mineral resources are in relevant portions of 

30 CFR 200 through 699. Provisions specific to offshore leasing programs are in Subchapter B of 

that title, i.e. 30 CFR 250–282. 

I.F. Postlease Processes and Activities 

The BOEMRE is responsible for regulating and monitoring the oil and gas operations on the Federal 

OCS. Its authority extends over all operations conducted under the lease, right of use and easement, 

or USDOI pipeline right-of-way. BOEMRE’s duties also include promoting orderly exploration, 

development, and production of mineral resources, while preventing harm or damage to, or waste of, 

any natural resource, any life or property, or the marine, coastal, or human environment. Regulations 

applicable to oil, gas, and sulfur lease operations on the OCS are specified in 30 CFR 250. 

Regulations for geological and geophysical (G&G) exploration operations on the OCS (on unleased 

lands or lands under lease to a third party) are specified in 30 CFR 251. Oil-spill prevention and 

response rules are specified in 30 CFR 254. Additional rulemaking initiated subsequent to the DWH 

event are discussed in Section IV.D.1 of this Revised Draft SEIS. Note that additional regulations 

administered and enforced by agencies other than BOEMRE also apply to OCS activities. A 

pertinent example includes U.S. Environmental Protection Agency (USEPA) regulations (40 CFR 

125) regarding discharge and pollution, as well as the myriad regulatory regimes identified in Section 

I.D. of this Revised Draft SEIS. 

The following subsections briefly describe several means through which BOEMRE regulates OCS 

post-lease activities. For a full discussion of post-lease processes please refer to Sale 193 FEIS, 

Section I.E. (incorporated by reference). 

I.F.1. Ancillary Activities 

The BOEMRE regulations at 30 CFR 250.207 define the “ancillary activities” allowed to proceed on 

the OCS without the requirement of a separate permit. Information from ancillary activities is 

required to support review and mitigation measures for OCS exploration and development plans, and 

applications for pipeline rights-of-way. Shallow-hazards and site-clearance surveys are used to 

identify and characterize potentially hazardous conditions at or below the seafloor. They also identify 

potential benthic biological communities (or habitats) and archaeological resources. Geotechnical 

activities obtain physical and chemical data on surface and subsurface sediments. 

Parties seeking to conduct ancillary activities must notify the BOEMRE. Proposed ancillary activities 

are reviewed for compliance with the performance standards listed in 30 CFR 250.202(a), (b), (d), 

and (e). 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER I. The Proposed Action 11

I.F.2. Exploration Plans, and Development and Production Plans 

BOEMRE approval is required prior to any exploration, development, or production activities within 

a lease block. Lessees seeking to engage in such actions must submit for BOEMRE review an 

exploration plan or a development and production plan, as appropriate. Proposed plans must include 

supporting information such as environmental information, an archaeological report, a biological 

report in accordance with 30 CFR 250 (monitoring and/or live-bottom survey), and other 

environmental data determined necessary. This information includes an analysis of both offshore and 

onshore impacts that may occur as a result of the activities. The BOEMRE reviews supporting 

information for the occurrence of geo-hazards, man-made hazards, archaeological resources, or 

benthic communities at the proposed activity site, and evaluates potential effects on the environment. 

To this end, the Alaska Region of BOEMRE prepares an Environmental Assessment (EA) and/or and 

Environmental Impact Statement (EIS) based on available information, which may include the 

geophysical report, archaeological report, and air-emissions data. As part of the review process, the 

plan and supporting environmental information are sent to the affected State(s) for consistency review 

and determination with respect to that state’s approved Coastal Zone Management Plan (CZMP). 

Proposed plans are evaluated for compliance with applicable regulations, lease stipulations, and other 

requirements, including the adequacy of the related oil-spill response plan. 

Prior to conducting drilling operations, the operator is required to submit and obtain approval for an 

Application for Permit to Drill (APD). The APD must include detailed information on the seafloor 

and shallow seafloor conditions of the drill site and detailed information about the drilling program 

for BOEMRE’s evaluation of operational safety and pollution-prevention measures. The lessee must 

specify the best available and safest technology that will be used to minimize the potential for 

uncontrolled well flow. 

As further discussed in Section IV.D.1 of this Revised Draft SEIS, new rulemaking initiated 

subsequent to the DWH event, as well as new NTLs issued in recent months, augment prior 

regulatory requirements for Exploration Plans, Development and Production Plans and permitting on 

the OCS. 

I.F.3. Pipeline Regulations 

Regulatory authority over pipelines on the OCS and in coastal areas is shared by several Federal 

agencies, including USDOI (which includes BOEMRE), the U.S. Department of Transportation, the 

U.S. Army Corps of Engineers, the Federal Energy Regulatory Commission, and the U.S. Coast 

Guard. The U.S. Fish and Wildlife Service (FWS) also reviews applications for pipelines that are 

near certain sensitive biological communities. 

The BOEMRE regulations pertaining to pipelines are at 30 CFR 250.1000–250.1019. Pipeline permit 

applications to BOEMRE include the pipeline location drawing, profile drawing, safety schematic 

drawing, pipe-design data to scale, a shallow-hazard-survey report, and an archaeological report. The 

BOEMRE evaluates the design and fabrication of the pipeline and prepares and analysis of potential 

environmental impacts in accordance with applicable policies and guidelines. The Alaska Region of 

BOEMRE prepares an EA and/or an EIS on all pipeline rights-of-way that go ashore. The operators 

are required to periodically inspect their routes by methods prescribed by the BOEMRE Regional 

Supervisor for any indication of pipeline leakage. Some examples of pipeline monitoring techniques 

include visual monitoring, comparing the volume of product entering and exiting the pipeline, in-line 

inspection tools (smart pigs), external hydrocarbon-vapor detection (leak-detection system), and 

pressure analysis. Monthly overflights are also conducted to inspect pipeline routes for leakage. 

Pipelines may be abandoned in place if they do not constitute a hazard to navigation and commercial 

fishing, or unduly interfere with other uses of the OCS. An abandoned pipeline would have to be 

flushed and cleaned to assure no residual hydrocarbon posed a risk to the environment. 
BOEMRE Sale 193 Revised Draft SEIS 

12 CHAPTER I. The Proposed Action 

I.F.4. Best Available and Safest Technology Requirements 

To ensure that all oil and gas exploration, development, and production activities on the OCS are 

conducted in a safe and pollution-free manner, the OCS Lands Act requires that all OCS technologies 

and operations use the best available and safest technology that the Secretary determines to be 

economically feasible. These include requirements for state-of-the-art drilling technology, 

production-safety systems, well control, completion of oil and gas wells, Oil Spill Response Plans 

(OSRPs), pollution-control equipment, and specifications for platform/structure designs. 

I.F.5. BOEMRE Technical and Safety Review 

The lessee must design, fabricate, install, use, inspect, and maintain all platforms and structures on 

the OCS to ensure their structural integrity for the safe conduct of operations at specific locations. 

Applications for platform design and installation are filed with BOEMRE for review and approval. 

Production-safety equipment used on the OCS must be designed, installed, used, maintained, and 

tested in a manner that ensures the safety and protection of the human, marine, and coastal 

environments. All tubing installations open to hydrocarbon-bearing zones below the surface must be 

equipped with safety devices that will shut off the flow from the well in the event of an emergency, 

unless the well is incapable of flowing. “Incapable of flowing” means that in order to produce 

hydrocarbons from the well, artificial means would be required using mechanical pumps. All surface 

production facilities must be designed, installed, and maintained in a manner that provides for 

efficiency, safety of operations, and protection of the environment. 

I.F.6. Pollution Prevention and Oil-Spill Response 

Safety and prevention of pollution, including accidental oil spills, are the primary focus of BOEMRE 

OCS operating regulations. Pollution-prevention regulatory requirements for oil, gas, and sulphur 

operations in the OCS are in 30 CFR 250, Subpart C – Pollution Prevention and Control. These 

regulations require operators that engage in activities such as exploration, development, production, 

and transportation of oil and gas to prevent unauthorized discharge of pollutants into offshore waters. 

Operators shall not create conditions that will pose unreasonable risks to public health, life, property, 

aquatic life, wildlife, recreation, navigation, commercial fishing, or other uses of the ocean. These 

regulations further mandate that the operator conduct daily inspections of drilling and production 

facilities to determine if pollution is occurring. If problems are detected, maintenance or repairs must 

be made immediately. 

In compliance with 30 CFR 254, all owners and operators of oil-handling, -storage, or -transportation 

facilities located seaward of the coastline must submit an OSRP to BOEMRE for approval. Owners 

or operators of offshore pipelines are required to submit a plan for any pipeline that carries oil, 

condensate that has been injected into the pipeline, or gas with naturally occurring condensate. 

Pipelines carrying essentially dry gas do not require a plan. A response plan must be submitted 

before an owner/operator can use a facility. To continue operations, the facility must be operated in 

compliance with the approved plan. As a general rule, OSRPs must be updated and re-submitted for 

BOEMRE approval every two years. Revisions to a response plan must be submitted to BOEMRE 

within 15 days whenever (1) a change occurs that significantly reduces an owner/operator’s response 

capabilities; (2) a significant change occurs in the worst-case-discharge scenario or in the type of oil 

being handled, stored, or transported at the facility; (3) there is a change in the name or capabilities of 

the oil-spill-removal organizations cited in the plan; or (4) there is a significant change in the 

appropriate Area Contingency Plans. 

For more detailed discussion on pollution prevention, oil spill response plans, and oil spill response, 

the reader is referred to Section 4.3.3 of the Arctic Multi-Sale Draft EIS (USDOI, MMS, 2008a). 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER I. The Proposed Action 13

I.F.7. BOEMRE Inspection Program 

Under the direction of the OCS Regional Office in Anchorage, Alaska, BOEMRE inspection program 

for Alaska provides review and inspection of oil and gas operations. The BOEMRE conducts on-site 

inspections to ensure compliance with lease terms, Notices to Lessees, and approved plans, and to 

ensure that safety and pollution-prevention requirements of regulations are met. These inspections 

involve items of safety and environmental concern. Further information on the baseline for the 

inspection of lessee operations and facilities can be found in the National Office Potential Incident of 

Noncompliance List (USDOI, MMS, 2005). 

The purpose of the inspection program is to ensure that an oil and gas facility complies with the 

regulations and that the lessee is conducting operations in accordance with the regulations and 

approved permit. The BOEMRE expects to maintain a near continuous inspection presence during 

exploratory drilling activities. This is due to heightened public interest in the activity and the logistics 

for rotating inspection personnel to remote exploratory drilling locations. In the event of a discovery 

and subsequent development, BOEMRE will develop an inspection strategy commensurate with the 

scope and nature of such activities—the Alaska Region conducts inspections of existing development 

and production facilities 3–4 times a year. Regardless whether the activity is exploration or 

development, BOEMRE will also conduct on-site inspections of all critical operations, including 

testing of blowout preventer (BOP) equipment, running and cementing casing, and well testing. The 

Alaska Region has the authority and will issue an incident of non-compliance (INC; a documented 

and recordable action) when a violation is found and can shut-in (deactivate a piece of equipment or 

shut-down the offshore facility) any activity that is not in compliance with regulations or the 

approved permit. An activity that has been issued an INC or shut-in may not restart until the Alaska 

Region has inspected and confirmed that the non-compliance or the shut-in has been properly 

corrected. 

The BOEMRE has taken steps to further strengthen its inspection program in light of the DWH event. 

The BOEMRE is hiring additional inspectors. Also, the bureau is creating for the first time a 

National Offshore Training Center led by a training director. In the past, BOEMRE inspectors 

learned how to do their jobs through a combination of on-the-job training and industry-sponsored 

courses aimed at teaching how certain types of equipment functioned. Inspectors also received 

training from academia and third-party vendors. The bureau has never had a training center dedicated 

to training inspectors on how to do their jobs. The Director of the National Offshore Training Center 

will develop national training strategies and programs to maintain and improve the technical 

capabilities of offshore inspections and compliance personnel throughout the bureau. 

I.F.8. Structure Removal and Site Clearance 

Lessees/operators have one year from the time a lease is terminated to remove all wells and structures 

from a leased area (30 CFR 250.1700–250.1754). The BOEMRE requires lessees to submit a 

procedural plan for site-clearance verification. Lessees must ensure all objects related to their 

activities are removed following termination of their lease. 

I.F.9. Training Requirements for Offshore Personnel 

Proper training is important for ensuring that offshore oil and gas operations are carried out in a 

manner that emphasizes operational safety and minimizes the risk of environmental damage. Industry 

offshore personnel are required to have well control and production safety training (30 CFR 

250.1500-1510). 
BOEMRE Sale 193 Revised Draft SEIS 

14 CHAPTER I. The Proposed Action 

I.G. New Information and Analysis Provided by this SEIS 

Chukchi Sea Lease Sale 193 was held in February 2008, with BOEMRE accepting high bids of 

approximately $2.6 billion and issuing 487 leases for approximately 2.8 million acres. As a result of 

a lawsuit challenging the sale, the U.S. District Court for the District of Alaska remanded Sale 193 for 

further NEPA analysis of three concerns. 

First, the District Court found that BOEMRE’s NEPA process lacked sufficient analysis on the 

“environmental impacts of natural gas developments, despite industry interest and specific lease 

incentives for such development.” In accordance with the District Court remand, this SEIS provides 

within Section IV.B and IV.C an in-depth analysis of the most viable natural gas development and 

production scenario for Chukchi Sea leases. 

The second and third concerns both stem from the District Court’s finding of procedural deficiencies 

in BOEMRE’s treatment of missing or incomplete information within the Sale 193 FEIS. The 

District Court held that in order to comply with 40 CFR 1502.22, BOEMRE must determine whether 

missing information is relevant or essential, and whether the cost of obtaining the missing information 

is exorbitant, or the means of doing so is unclear. Appendix A catalogues all statements within the 

Sale 193 FEIS that identified incomplete, missing, or unavailable information, and performs the 

evaluation required by 40 CFR 1502.22. 

In conducting this extensive evaluation effort, BOEMRE analysts determined that while many items 

of incomplete, missing, or unavailable information were broadly relevant to the important issues at 

hand, none were essential for a reasoned choice among alternatives. There were several reasons why 

the missing information cited was not deemed essential. Those reasons were inherent in the 

information collection and evaluation process and, therefore, were often common to many instances 

where missing information was noted. These reasons are listed below and explained in detail in 

Appendix A. 

Recurring reasons why missing information is not essential to a reasoned choice among alternatives 

under 40 CFR 1502.22 include: 

 The availability of sufficient information to support sound scientific judgments and reasoned 

managerial decisions, even without the identified incomplete, missing, or unavailable 

information. 

 The presumption that adverse effects would certainly occur under the specific circumstance 

to which the incomplete information applies. 

 The commonality of potential impacts and their severity among all action alternatives, which 

substantially reduced the utility of incomplete information to the decision-maker. 

 The existence of other environmental laws and regulations that would preclude significant 

adverse effects on particular resources. 

 The understanding that certain items of presently missing or incomplete information will be 

known (and utilized to avoid or minimize adverse impacts) at a later stage of OCSLA 

environmental review, when the information could potentially become essential (Village of 

False Pass v. Clark, 733 F.2d 605 [9th Cir. 1984]). 

This Revised Draft SEIS also supplements the Sale 193 FEIS by analyzing a low probability, high 

impact event—a hypothetical VLOS occurring during exploration activities in the Chukchi Sea 

Planning Area. Section IV.D provides up-to-date information on all pertinent issues, including the 

affected environment, resource areas, well control incident data, and the regulation of OCS activities. 

This Section also describes a hypothetical VLOS scenario to provide a basis for the VLOS 

environmental effects analysis in Section IV.E. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 15

CHAPTER II. Alternatives, Mitigation, and Issues 

II.A. Sale 193 

The Secretary’s Final OCS Leasing Program for 2007–2012 identifies certain areas of the Chukchi 

Sea Planning Area as suitable for lease for the development of offshore oil and gas resources. In 

February of 2008, BOEMRE held Chukchi Sea Lease Sale 193, and leased approximately 2.8 million 

acres in the Chukchi Sea Planning Area. 

II.B. Alternatives 

After comprehensive scoping, Draft EIS, and public and agency commenting processes, BOEMRE in 

June 2007 released the “Final Environmental Impact Statement for Oil and Gas Lease 193 and 

Seismic-Surveying Activities in the Chukchi Sea” (Sale 193 FEIS) (USDOI, MMS, 2007a). Because 

BOEMRE did not identify any additional alternatives for the scenarios discussed in this SEIS, the 

alternatives analyzed in the Sale 193 FEIS are carried forward for consideration here. Lease Sale 193 

was held consistent with Alternative IV (as modified by the 25 statute mile coastal deferral area 

incorporated into the 2007-2012 Five-Year Program), but the impacts under each alternative are 

nonetheless considered for consistency of this analysis with the analysis in the Sale 193 FEIS. The 

analysis did not disclose any additional impacts that would have warranted consideration of additional 

alternatives. 

II.B.1. Alternatives Carried Forward in the SEIS 

Alternative I (Proposed Action) 

The Proposed Action offers for lease 6,156 whole or partial blocks within the Chukchi Sea. This area 

covers approximately 34 million acres. Specifically excluded from the Proposed Action is the 25 

Statute Mile Buffer implemented by the Secretary in the Final OCS Leasing Program for 2007–2012. 

By selecting Alternative I, the Secretary would elect to offer for lease all 34 million acres of the 

Chukchi Sea made available by the Final OCS Leasing Program for 2007–2012. In as much as the 

sale has already been held, offering only parcels identified in Alternative IV, full implementation of 

this Alternative is no longer feasible. 

Alternative II (No Lease Sale) 

This “no action” alternative is equivalent to not affirming Chukchi Sea Lease Sale 193. The 

opportunity to develop oil and gas resources that could have resulted from the Proposed Action would 

be precluded or postponed, as would any potential environmental impacts associated with the other 

alternatives. Its implementation would require cancellation of all leases awarded following the 

February 2008 sale. 

Alternative III (Corridor I Deferral) 

This alternative is the Proposed Action minus a corridor extending 60 mi offshore along the 

coastward edge of the proposed sale area to protect important bowhead whale habitat used for 

migration, feeding, nursing calves, and breeding. Alternative III would offer approximately 1,765 

whole or partial blocks comprising 9.1 million acres (3.7 million hectares). The deferral of “Corridor 

I” would result in a reduction of 36% of the commercial resources opportunity index from the 

Proposed Action (see Table IV.A-3 in the Sale 193 FEIS). Should the Secretary select Alternative III, 

portions of Chukchi Sale 193 could be affirmed, but leases issued on tracts within Corridor I would 

be cancelled. 
BOEMRE Sale 193 Revised Draft SEIS 

16 CHAPTER II. Alternatives, Mitigation, and Issues 

Alternative IV (Corridor II Deferral) (Agency Preferred Alternative) 

This alternative is the Proposed Action minus approximately 795 whole or partial blocks along the 

coastward edge of the sale area. The “Corridor II” deferral area is a subset of the Corridor I deferral 

area analyzed under Alternative III. This alternative was identified as the Agency’s Preferred 

Alternative in the Sale 193 FEIS, and was offered for lease as Sale 193 (February 2008). Selection of 

Alternative IV would affirm the issuance of the leases pursuant to Sale 193 as held and be 

implemented by removing the suspension of operations imposed on the leases. 

II.B.2. Alternatives Considered But Not Analyzed 

A full discussion of alternatives considered within the overall EIS process but not carried forward for 

detailed analysis is available in Section II.B.2 of the Sale 193 FEIS. BOEMRE has not identified any 

additional alternatives as a result of the addition of a natural gas development and production scenario 

in this SEIS, beyond those already considered in the Sale 193 FEIS. 

II.C. Mitigation Measures and Issues 

II.C.1. Mitigation Measures 

Activities under each alternative would be subject to a variety of mitigation measures. More detailed 

discussion of applicable mitigation measures is available in Section II.B of the Sale 193 FEIS. 

BOEMRE has not identified any additional mitigation measures specific to the natural gas 

development and production evaluated in this SEIS. Most pertinent to the analysis of mitigation 

measures are the binding and enforceable measures known as lease stipulations, described below. 

Lease Stipulations 

This SEIS analyzes seven standard lease stipulations under each action alternative. Section 

II.B.3.c(1) of the Sale 193 FEIS provides the full text of these stipulations and an analysis of the 

expected effectiveness of each stipulation at mitigating adverse effects. All seven of the stipulations 

(listed below) were selected by the Secretary and incorporated into the leases resulting from Sale 193 

(February 2008). 

 Protection of biological resources 

 Orientation program 

 Transportation of hydrocarbons 

 Industry site-specific monitoring for marine mammal subsistence resources 

 Conflict avoidance mechanisms to protect subsistence whaling and other subsistence-harvest 

activities 

 Pre-booming requirements for fuel transfers 

 Measures to minimize effects on spectacled and Steller’s eiders from exploration drilling 

II.C.2. Issues 

The major issue framing the environmental analysis within this SEIS are those addressed in the 

District Court’s remand of Sale 193 and evaluation of a hypothetical VLOS scenario. Issues related 

to OCS activities have been identified through many years of scoping for Alaska OCS lease sale 

evaluations, the 193 EIS process, and additional review conducted for this SEIS. A brief summary of 

identified issues related to the analysis of natural gas production and a VLOS is provided below. A 

comprehensive discussion of issues related to Sale 193 is available in Section II.B.5 of the Sale 193 

FEIS. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 17

Western Arctic Herd 

There is potential for onshore pipelines and other infrastructure associated with offshore Chukchi Sea 

development to impact the Western Arctic (caribou) Herd and subsistence use of the herd. 

Bowhead Whale 

Commenters expressed concerns over the impacts that OCS activities may have on the bowhead 

whale and their migration patterns. 

Marine Mammals 

Commenters noted the potential for exploration and development activities to impact areas known to 

be critical to the subsistence harvest of marine mammals. 

Water Quality Degradation 

Issues related to water quality degradation included operational discharges, domestic wastes, 

sediment disturbance, and discharges from service vessels. 

Structure and Pipeline Placement 

Some of the concerns expressed related to structure and pipeline emplacement, lighting issues with 

platforms, bottom area disturbances from bottom-founded structures or anchoring, and construction of 

onshore infrastructure. 

OCS-Related Support Services, Activities, and Infrastructure 

Concerns were expressed over activities related to support of OCS operations, including vessel and 

helicopter traffic and emissions. 

Sociocultural and Socioeconomic 

Concerns include employment impacts, cultural impacts, and population fluctuations. 

Environmental Resources 

Resources analyzed in the Sale 193 FEIS are carried forward for analysis within this SEIS. No 

additional resources were identified for the analysis of gas development and production. The 

following resources are analyzed in this SEIS: 

 Water Quality 

 Air Quality 

 Lower Trophic Level Organisms 

 Fish Resources 

 Essential Fish Habitat 

 Threatened and Endangered Species 

 Marine and Coastal Birds 

 Marine Mammals 

 Terrestrial Mammals 

 Vegetation and Wetlands 

 Economy 

 Subsistence-Harvest Patterns 

 Sociocultural Systems 
BOEMRE Sale 193 Revised Draft SEIS 

18 CHAPTER II. Alternatives, Mitigation, and Issues 

 Archaeological Resources 

The BOEMRE also reviewed the comments received on the Sale 193 Draft EIS as well as those on 

the Arctic Multi-Sale Draft EIS (USDOI, MMS, 2008a) to identify issues relevant to the analysis of 

natural gas production for the Chukchi Sea OCS. Through this process, BOEMRE identified two 

additional issues which are addressed in the SEIS: the potential for releasing hydrogen sulfide (H2S) 

and related effects, and the potential effects of a gas release accident 

II.C.3. Issues Considered But Not Analyzed 

The Sale 193 FEIS provides a discussion of issues considered but not carried forward for further 

analysis (Section II.B.5.b of the Sale 193 FEIS). All comments received in response to the Call for 

Information and Notice of Intent to Prepare an EIS, as well as those received during public scoping 

meetings, are part of the record of information used in developing the 193 EIS, and were summarized 

and made available to the decision-makers during the deliberation process. Several issues raised 

during scoping for the 193 EIS were not considered for detailed study in the EIS, because they were 

out of the scope of the EIS and did not affect the environmental analyses. These issues include 

administrative, policy, or process issues. No additional public scoping was conducted for this SEIS. 

The BOEMRE has considered and “scoped out” the issues below from detailed analysis in this SEIS. 

Tanker transport of produced natural gas (tankering of liquefied natural gas or LNG). The 

remand ordered by the U.S. District Court for the District of Alaska requires BOEMRE to analyze the 

environmental impact of natural gas development in the Chukchi Sea. To determine the appropriate 

gas devolvement and production scenario in this SEIS, BOEMRE Alaska OCS Region Office of 

Resource Evaluation evaluated three possible gas export strategies for the Chukchi OCS based on 

current understanding of the geologic, engineering, economic, and political issues. 

The first strategy consisted of transport via pipeline. Although different ways to transport gas from 

the North Slope have been discussed (ICF, Inc., 1982; Booz, Allen and Hamilton, 1983; GAO, 1983; 

Thomas et al., 1996; Sherwood and Craig, 2001), the most common conceptual plans involve a largediameter, overland gas pipeline running south from the Prudhoe Bay area. Pipelines are the most 

cost-effective way to transport large volumes of oil or gas to market if overland routes are feasible. 

At present, work on several gas pipeline projects is progressing, but none of the projects have been 

approved or funded. Ongoing work by several competing gas pipeline projects increases the options 

for a gas project but also increases the uncertainties regarding timing of completion, route location, 

and capacity of the final project(s). Gas development in the Chukchi OCS would require a long 

(approximately 300 miles) overland pipeline across the NPR-A to connect to the new gas pipeline. 

The pipeline might be built in sections as gas development expands westward across NPR-A. Gas 

development in the Chukchi OCS could reverse this situation, where a large gas field in the Chukchi 

supports a large overland gas pipeline to Prudhoe Bay. This way, the remote gas resources from the 

Chukchi could promote the development of marginal gas pools stranded in NPR-A. In either case, 

gas development in NPR-A and the Chukchi would be important to a future North Slope gas pipeline 

where the huge investment (>$ 30 billion) is based on a long-term (> 25 year) project. 

LNG is a second possible means to export gas from the Chukchi OCS, but is a less likely alternative. 

LNG operations will face difficult economic, technical, and regulatory challenges because they are a 

new concept to the region. LNG operations require expensive infrastructure, including pipelines, a 

large processing facility, a marine loading terminal, a fleet of LNG tankers, and receiving terminals at 

market destinations. Numerous feasibility and environmental issues will be present for each of these 

components in the LNG delivery chain. Marine transportation in the Arctic is restricted by sea-ice 

conditions that could inhibit tanker loadings and transits for 6 months of the year. No LNG ships 

have been built to handle severe ice conditions common in the Chukchi. Nearshore areas are 

relatively shallow and water depth could limit the size of LNG ships (loaded draft of 40 ft [12 m]). 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 19

A third strategy for gas development involves offshore processing, storage and loading to marine 

tankers for export. Bottom-founded production platforms in the Chukchi Sea will be very large to 

resist ice forces in waters greater than 100 ft. Because of their large size, platforms could be designed 

with internal storage compartments to hold oil or gas. Offshore loading and tanker traffic will be 

affected by rough seas in the open-water season (July-November) and severe sea ice conditions 

during the rest of the year. This strategy would face numerous economic, engineering, and regulatory 

challenges. 

Overall, this analysis suggests that a pipeline export system is the most likely scenario for 

transportation of natural gas development in the OCS areas off northern Alaska. Should other 

transportation methods be determined reasonably foreseeable in the future, the staged OCS process 

and parallel NEPA compliance would require full consideration of the consequences of such 

transportation at the time of a decision that could foreseeably result in use of that method of transport. 

Accordingly, tanker transport of produced natural gas is not analyzed in this SEIS. 

The community of Wainwright wants natural gas produced from the Chukchi Sea OCS to be 

made available to the community for power generation. This issue is beyond the scope of the 

current analysis. A contract between two parties (the gas producer and Wainwright) cannot be 

required or enforced by the Federal Government. 

Greenhouse gas emissions from consumption of produced natural gas. Environmental and 

economic impacts of greenhouse gas emissions from oil and gas consumption are not effects of Sale 

193 as defined by the Council on Environmental Quality, and thus are not required to be analyzed 

under NEPA. Greenhouse gas emissions from consumption of Sale 193 oil and gas are not direct 

effects under NEPA because they do not occur at the same time and place as the action. They are also 

not indirect effects because Sale 193 would not be a proximate cause of greenhouse gas emissions 

resulting from consumption. Also, because the impacts of consumption are not direct or indirect 

effects of the proposed action, a cumulative impact analysis would not reveal an incremental or 

cumulative effect attributable to the decision to affirm, modify, or cancel the lease sale. 

There is no reliable methodology to assess the relation between leasing in the Chukchi Sea and 

changes in nationwide or worldwide oil and gas consumption levels. Consumption of oil and gas is 

driven by a variety of complex interacting factors including energy costs, energy efficiency, 

availability of other energy sources, economics, demography, and weather or climate. While on a 

national basis lower levels of domestic oil and gas production could occur and may trigger some 

modest conservation measures having some benefits in terms of reduced greenhouse gas emissions, 

no single leasing decision would be expected to result in any discernable responsive conservation 

measures. This is particularly true with regard to Sale 193 where the actual productive capacity is 

currently an unknown. Furthermore, it is not known whether or to what extent Sale 193 oil and gas 

would be refined into plastics or other products that will not be burned, what mix of vehicles or power 

plants might utilize the product, or what mitigation measures would offset any such consumption. 

Moreover, BOEMRE does not regulate fuel consumption or carbon emissions at any level; nor does 

BOEMRE dictate the destination of the oil and gas produced from a federal lease or the products to 

be refined from it, which would determine the emissions produced. While the Energy Information 

Administration has reported emissions from a variety of petroleum products (e.g., aviation gasoline, 

motor gasoline, etc.), natural gas and other gaseous fuels (e.g., methane, landfill gas, etc.), electricity, 

coal, and renewable sources, an attempt to translate this information into emissions from the ultimate 

consumption of the oil and gas produced under Sale 193 would be an unreasonably speculative 

exercise. 
BOEMRE Sale 193 Revised Draft SEIS 

20 CHAPTER II. Alternatives, Mitigation, and Issues 

II.D. Summary of Environmental Impacts 

This section briefly summarizes the detailed impact analyses of both the Sale 193 FEIS and this SEIS. 

Conclusions from each document are presented by alternative, and for each resource area potentially 

affected under that alternative. For each resource subsection, the potential impacts associated with oil 

exploration, and development and production (including potential effects from a large accidental oil 

spill) are discussed first. This information is summarized from the Sale 193 FEIS. 

Each resource subsection also includes a summary of the potential impacts of natural gas 

development. These conclusions are derived from Chapters IV and V of this SEIS. As will be 

explained in more detail within Chapter IV, the impact analysis herein is predicated on the most 

viable natural gas development and production scenario that could result from Sale 193. This 

scenario assumes that any natural gas development and production would utilize an existing (due to 

oil development and production) platform located near the center of the Sale 193 area. This is the 

same platform location as was assumed and analyzed in the Sale 193 FEIS. The gas development and 

production scenario would also utilize the existing shorebase, and run new offshore and onshore gas 

pipelines along the same corridor as the existing oil pipelines. A more detailed explanation of how 

BOEMRE developed this natural gas development and production scenario is provided in Section 

IV.B. Since this scenario entails similar infrastructure (including the production platform, wells, both 

offshore pipelines, shore base, and both onshore pipelines) and activities for each action alternative, 

potential impacts are also similar under each action alternative. Due to these similarities, and for the 

sake of brevity, discussion of the potential impacts under each action alternative area area often 

grouped together. 

However, the potential natural gas development and production impacts under each action alternative 

analyzed are not necessarily identical. Alternatives III and IV each include deferral areas that would 

exclude from the lease sale notable portions of the coastward edge of the Chukchi Planning Area. If 

the decision-maker were to select Alternative III or IV, no wells or platforms could be constructed 

within the applicable deferral area. Deferring certain areas from consideration could in this sense 

affect the type and severity of potential environmental impacts. Coastal areas can be particularly 

sensitive to potential impacts to marine mammals, marine and coastal birds, subsistence, and other 

valued environmental resources. Increasing the minimum distance between certain potential 

development and production activities and the Chukchi coastline could potentially benefit several 

resources in a general way. As was the case with the oil scenario analyzed in the Sale 193 FEIS, any 

differences in the potential environmental impacts associated with gas development and production 

under each action alternative analyzed are directly traceable to the size and location of proposed 

deferrals. 

Finally, each resource subsection includes a summary of the potential impacts of a VLOS scenario. 

These discussions follow much the same approach for natural gas development and production, 

explained above. 

Significance thresholds are defined in Section IV.A.1. References are provided in the the sections 

being summarized. For Oil Exploration, Development, and Production, see Chapter IV and V of the 

Sale 193 FEIS. For Natural Gas Development and Production, see Sections IV.C and V.B of the 

SEIS. For VLOS, see section IV.E of the SEIS. 

II.D.1. Summary of Impacts: Alternative I – Proposed Action 

Water Quality 

Oil Exploration, Development, and Production 

The effect of the Proposed Action on water quality as a result of exploration, development, and 

production is expected to be moderate locally and low regionally. Discharges into the marine 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 21

environment would be regulated by EPA through NPDES permitting and inspection requirements. 

The risk of an accidental large oil spill would be reduced due to mitigation measures (see Sale 193 

FEIS, p. IV-38). ). If a large oil spill (analyzed in the Sale 193 FEIS as 1,500 bbl of oil for a platform 

spill, or 4,600 bbls of oil for a pipeline spill) were to occur, water quality would be affected at both 

the regional and local scales at low to moderate levels. For additional information, see Section 

IV.C.1.a of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

Natural gas development and production is not expected to cause significant adverse impacts to water 

quality. Temporary and localized adverse effects are likely to result from installation of a new 

offshore natural gas pipeline, infrequent deck drainage discharges and effects on stream water quality 

at pipeline or support road crossings. The effect of these activities on regional water quality would 

remain low. 

VLOS 

In the event of a VLOS (a spill of more than 150,000 barrels of oil), sustained degradation of water 

quality would occur through hydrocarbon (oil and natural gas) contamination. State and Federal 

criteria would be exceeded, causing significant impacts. Adverse impacts from the oil spill itself 

could be exacerbated during spill response and cleanup activities such as vessel discharge, in-situ 

burning, dispersants, drilling a relief well, and shoreline cleanup. 

Air Quality 

Oil Exploration, Development, and Production 

Proposed actions would comply with Federal and State of Alaska air quality and emissions 

requirements. As a result, the effect of the Proposed Action on air quality is expected to be low and 

air quality to remain well within National Ambient Air Quality Standards and Prevention of 

Significant Deterioration incremental limits. For additional information, see Section IV.C.1.b of the 

Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

Minor adverse impacts to air quality would occur from the emissions of reciprocating diesel engines, 

gas turbines, and generators generally associated with development and production activities. 

However, any increase in concentrations of criteria pollutants from these activities would be small 

and localized. Overall effects would be low and would not exceed any Clean Air Act standards. 

Natural gas development and production would result in a negligible contribution to U.S. and global 

greenhouse gas emissions. 

VLOS 

In the event of a VLOS, large amounts of regulated, potentially harmful pollutants could be emitted 

into the atmosphere. An initial explosion of gas and oil would result in a large plume of smoke 

containing several types of pollutants. Significant impacts to air quality could occur from the 

evaporative emissions of a large quantity of offshore oil. Certain spill response and cleanup activities 

such as in-situ burning would cause their own adverse impacts. The duration of these impacts 

depends on regional weather and the size and duration of the spill. 

Lower Trophic Level Organisms 

Oil Exploration, Development, and Production 

The level of effect on lower trophic level organisms with standard mitigation would be minor, with 

moderate impacts near drilling locations and from trenching for pipeline installation. A large oil spill 

contacting the coast could persist in tidal and sub-tidal sediments for tens of years with moderate 
BOEMRE Sale 193 Revised Draft SEIS 

22 CHAPTER II. Alternatives, Mitigation, and Issues 

effects on local lower trophic communities. For additional information, see Section IV.C.1.c of the 

Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

Several components of the natural gas development scenario, such as installing an offshore gas 

pipeline and anchoring vessels, have the potential to impact lower trophic level organisms. However, 

these impacts would be localized and temporary, given the expectation of eventual recolonization. As 

a result, no adverse impacts to lower trophic level organisms are expected to result from natural gas 

production. Overall, no significant adverse effects on this resource would occur. 

VLOS 

In the event of a VLOS, negative direct and indirect effects would occur with respect to many lower 

trophic level organisms and their communities. Recovery time is dependent upon the duration and 

timing of the spill, life cycle developmental stages, and physical factors (i.e. weather and currents) 

influencing the movement of oil and organisms through the described environment. Effects are 

generally anticipated to be less than one year for phytoplankton populations and one or more years for 

invertebrate populations within the pelagic, benthic, epontic, and onshore communities. Negative 

effects on local foodwebs would result. 

Fish Resources 

Oil Exploration, Development, and Production 

Construction activities are anticipated to result in temporary and/or localized adverse impacts to fish 

and fish habitats, with recovery expected to occur in fewer than three generations. A large oil spill 

contacting intertidal or estuarine habitats used by fishes could result in significant adverse impacts to 

some local breeding populations. Recovery to former status by immigration from nearby population 

segments would require more than three generations. For additional information, see section IV.C.1.d 

of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

Several types of direct and indirect impacts would occur as a result of the natural gas development 

and production scenario. Direct impacts, however, would be minimized by mitigation measures. 

Some pelagic adult species of fish would be able to avoid or reduce noise effects by swimming away 

from the sound source. Impacts would occur to seafloor habitat from pipeline installation and 

anchoring and to freshwater and riparian habitat from onshore pipeline installation. These effects 

cannot be avoided, but would be localized, and minor 

VLOS 

In the event of a VLOS, large quantities of oil (offshore and nearshore) and natural gas (offshore) 

could cause significant impacts to several species of fish. The effects on fish and their populations 

would depend on a variety of factors including life stage, season of the reproductive cycle, species’ 

distribution and abundance, locations of the species in the water column or benthos, the extent and 

location of spawning areas in riverine systems, and migratory patterns. Particularly vulnerable are 

various life stages of the following species: pink and chum salmon, Arctic cod, sand lance, capelin, 

nearshore sculpin species, nearshore flounders and plaice, saffron cod, migratory least cisco, 

migratory Dolly Varden, migratory Arctic char, rainbow smelt, stickleback, and migratory whitefish. 

Essential Fish Habitat 

Oil Exploration, Development, and Production 

Seismic surveys conducted in association with the proposed lease sale would have minor impacts on 

Essential Fish Habitat (EFH). Construction-related disturbance is also expected to result in minor 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 23

negative impacts to freshwater and marine salmon EFH, Arctic cod EFH, and saffron cod EFH. A 

large oil spill or chronic small oil spills could negatively impact the EFH of Arctic cod and saffron 

cod. A large oil spill or chronic small-volume oil spills impacting intertidal or estuarine habitats used 

by early life-history stages of Pacific salmon would be likely to result in significant effects on local 

populations. These would require three or more generations to recover to their former status. For 

additional information, see Section IV.C.1.e of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

Construction of an onshore gas pipeline would cause minor effects on salmon freshwater EFH. In the 

event of a large-scale natural gas release, the chemical and physical water column environment of 

Arctic cod, Pacific salmon and in areas, saffron cod Essential Fish Habitat would be affected 

temporarily or in the short-term, and at a negligible to minor level. 

VLOS 

Essential Fish Habitat for Arctic cod, saffron cod, and all five species of Pacific salmon would be 

significantly impacted in the event of a VLOS. 

Threatened and Endangered Marine Mammals 

In addition to the species discussed in this section, several marine mammals have been recently 

proposed for listing under the ESA, a group that includes Pacific walrus, bearded seal, and ringed 

seal. The potential impacts of the Proposed Action on these species are discussed within the Other 

Marine Mammals section (below). For additional information, see Section IV.C.1.f(2) of the Sale 

193 FEIS (USDOI, MMS, 2007a). 

Oil Exploration, Development, and Production 

Overall, bowhead whales and polar bears exposed to noise-producing activities such as vessel and 

aircraft traffic, drilling operations, seismic surveys, and construction activities would be likely to 

experience temporary, non-lethal effects. It is unlikely that fin and humpback whales would be 

adversely affected by noise-causing oil and gas activities in the Proposed Action area. Prolonged 

exposure to freshly spilled oil could cause adult whale mortalities, but, based on available 

information, the number would be small if the spill contacted bowheads in open water. If a large 

amount of fresh oil contacted a significant portion of a large aggregation of bowheads, especially with 

a high percentage of calves, effects could be greater than under more typical circumstances, 

potentially rising to a population-level adverse effect. Significant impacts to polar bears could occur 

during a large oil spill, depending on the location of the spill. For additional information, see Section 

IV.C.1.f(1) of the Sale 193 FEIS (USDOI, MMS, 2007a). 

The Proposed Action’s potential impacts on those marine mammals recently proposed for listing 

under the ESA (a group that includes Pacific walrus, bearded seals and ringed seals) are considered 

within the Other Marine Mammals portion of this subsection. 

Natural Gas Development and Production 

Potential impacts to listed whales from natural gas development and production would be similar to 

those from oil development and production, as described in the paragraph above. No additional 

exploration or drilling activities would take place during the natural gas scenario, and the potential for 

a large oil spill would no longer exist. Natural gas development and production could result in 

increased noise and disturbance to bowhead as well as fin and humpback whales. Bowhead, fin and 

humpback whales exposed to noise-producing activities such as vessel and aircraft traffic, 

construction activities, and production activities most likely would experience temporary, non-lethal 

effects. There is variability in whale response to certain noise sources; this variability appears to be 
BOEMRE Sale 193 Revised Draft SEIS 

24 CHAPTER II. Alternatives, Mitigation, and Issues 

context specific (e.g., feeding versus migrating whales) and also may be related to reproductive status 

and/or sex or age. Overall impacts are expected to be minor.

Various aspects of the natural gas development and production scenario have the potential to disturb 

polar bears, but most impacts would be temporary and non-lethal, and would not rise to the level of 

significance. Additional ESA Section 7 consultation would be required before BOEMRE approves 

any development and production plan that could follow from a lease sale. The current regulatory 

framework provides for an authorization to incidentally take ESA-listed marine mammals by 

harassment, provided the taking is also authorized under the MMPA. That process would identify and 

require any additional, site-specific mitigation deemed necessary by FWS to further avoid impacts to 

polar bears or to avoid adverse modification of critical habitat. 

VLOS 

In the event of a VLOS, significant effects on endangered cetacean species (including bowhead, fin, 

and humpback whales) and polar bears could occur through several mechanisms, specifically 

inhalation of toxic fumes from freshly spilled oil, loss of seasonal habitat, reduction in prey, and 

contamination of prey. Spill response and cleanup activities can also displace each species from 

important habitat areas. Contact with oil would result in lethal effects for polar bears. Contact with 

oil could also result in lethal effects to cetaceans under certain circumstances. High levels of 

ingestion or exposure to toxic fumes could lead to death of individuals. Spill response and cleanup 

efforts can lead to additional exposure as well as disturbance and displacement of polar bears. 

Other Marine Mammals 

Other marine mammals found in the Chukchi Sea include gray whale, minke whale, beluga whale, 

killer whale, harbor porpoise, Pacific walrus and ice seals. 

Oil Exploration, Development, and Production 

Effects of full-scale industrial development of the waters of the Chukchi Sea likely would accumulate 

through displacement of marine mammals from their preferred habitats, increased mortality, and 

decreased reproductive success. Significant impacts could occur to belugas and/or walrus through the 

loss of large numbers of individuals in the event of a large oil spill. For additional information, see 

Section IV.C.1.h of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

While the complexity of how marine mammal species react to underwater and above water sound 

renders an exact determination of potential adverse impacts difficult, abundant regulatory review and 

careful design of project and activitiy-specific mitigation measures are expected to preclude instances 

of level A (“harm”) take of marine mammals and to reduce the potential for level B (“harassment”) 

take as regulated under the MMPA. No population-level impacts are anticipated to result from 

natural gas development and/or production. 

VLOS 

Non-listed cetaceans (including gray, minke whales, beluga whales, killer whales, and harbor 

porpoise) could experience significant impacts in the same manner as the listed cetaceans discussed 

above. Those cetaceans with a greater tendency towards seasonal aggregation, namely the beluga 

whale, would be at higher risk of population-level impacts. Gray whales could be particularly 

affected if benthic invertebrate prey are lost or contaminated. The greatest potential for significant 

impacts to pinnipeds (including bearded, ringed, ribbon, spotted seals and walrus) in the Chukchi Sea 

is from long-term exposure to contaminants as well as from decreased availability of prey species – 

fish and invertebrates. If hydrocarbons from a VLOS become sequestered in marine sediments, then 

the walrus diet of benthic organisms makes it particularly vulnerable to long-term chronic ingestion 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 25

of hydrocarbons as well as reductions in prey availability in important habitat areas or near haulout 

locations. Walrus are also sensitive to disturbance when congregated on ice or at coastal haulouts. 

Threatened and Endangered Marine and Coastal Birds 

The yellow-billed loon was recently classified as a candidate species. The potential impacts of the 

Proposed Action on this species are considered within the Other Marine and Coastal Birds section, 

below. 

Oil Exploration, Development, and Production 

Disturbance, collision hazards, and oil/toxic pollution could result in the taking of threatened Steller’s 

and spectacled eiders. Without comprehensive mitigation measures to avoid or minimize potential 

impacts, these activities are likely to adversely affect Steller’s and spectacled eiders. Similarly, 

disturbance and oil/toxic pollution could result in the taking of Kittlitz’s murrelet, a candidate species. 

Without comprehensive mitigation measures to avoid or minimize potential impacts, these activities 

may affect the Kittlitz’s murrelet. OCS activities in the Ledyard Bay Critical Habitat Unit (LBCHU) 

could result in physical modification of seafloor habitats and decreased use of the LBCHU by molting 

spectacled eiders. Without comprehensive mitigation measures to avoid or minimize potential 

impacts, physical modification of the LBCHU seafloor would adversely modify the LBCHU. For 

additional information, see Section IV.C.1.f(2) of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

The natural gas development and production scenario analyzed in this SEIS comprises activities that 

are very similar or even identical to those analyzed in the preceding Sale 193 FEIS, and does not 

include some of the higher-risk activities (i.e. seismic surveying and exploration, platform 

construction, and oil production). In this sense, one can expect natural gas-related impacts to be a 

continuation of the potential adverse environmental impacts associated with the oil development and 

production activities analyzed in the Sale 193 FEIS. The Sale 193 FEIS as well as each Biological 

Opinion found notable potential for adverse impacts to Threatened and Endangered marine and 

coastal birds, but also explained that many of these potential impacts could be avoided or mitigated. 

It is reasonable to presume that through development of additional, site-specific mitigation measures 

during later environmental review processes, the new activities associated with the gas scenario 

(namely installing and operating an offshore gas pipeline, expanding an onshore facility, and 

installing and operating an onshore gas pipeline though NPR-A) would produce only minor impacts 

on Threatened and Endangered marine and coastal birds. No significant impacts are expected from 

any potential releases of natural gas. Significant adverse effects could occur from extending the life 

of the platform and other facilities, should high numbers of Threatened or Endangered birds from 

declining populations suffer mortality from collisions. Additional discussion on the types of impacts 

that could affect marine and coastal birds generally is provided in the section below. 

VLOS 

In the event of a VLOS, significant impacts could occur to Steller’s and spectacled eiders if spilled oil 

reaches LBCHU. Kittlitz’s murrelts could experience significant impacts if oil contacted a large 

enough portion of Alaska’s Chukchi Sea coast. 

Other Marine and Coastal Birds 

Oil Exploration, Development, and Production 

Marine and coastal birds could be adversely affected by OCS activities through disturbances, 

collisions, habitat loss, petroleum exposure, and exposure to toxic contamination. Several areas in the 

Chukchi OCS are historically documented to be important to marine and coastal birds, and several 

species or species-groups have a high probability of experiencing substantial negative impacts. The 
BOEMRE Sale 193 Revised Draft SEIS 

26 CHAPTER II. Alternatives, Mitigation, and Issues 

risk that several regional bird populations could experience significant adverse impacts is also high. 

Spilled oil has the greatest potential for affecting large numbers of birds. Most notably, a large spill 

could impact common and thick-billed murres in late summer and early fall, when juveniles have not 

yet developed the ability to fly and attendant males are flightless for several weeks while molting. 

This inability to move quickly out of the area, coupled with the potential for affecting large numbers 

of birds, could lead to a sharp decrease in murre abundance at the Cape Thompson and Cape Lisburne 

colonies. For additional information, see Section IV.C.1.g of the Sale 193 FEIS (USDOI, MMS, 

2007a). 

Natural Gas Development and Production 

As marine and coastal bird presence is quite variable by season and location, an accurate assessment 

of impacts at this early stage is difficult. Additional NEPA and other environmental review processes 

occurring at later stages of the OCS Lands Act program (i.e. exploration, development and 

production) will have site-specific plans to focus an analysis. Significant adverse impacts to marine 

and coastal birds would be avoided and mitigated through restriction and measures implemented 

during those later review processes. 

VLOS 

If marine and coastal birds came into contact with oil from a VLOS, they could experience exposure 

from wetting and loss of thermoregulatory ability, loss of buoyancy, or from matted plumage, 

inability to fly or forage, ingestion of oil, and inhalation of vapors. The greatest potential for 

significant impacts is if spilled oil reached important habitat areas. Non-listed marine and coastal 

birds that are particularly vulnerable to population-level impacts are murres, puffins, short-tailed 

shearwaters and auklets, black guillemot, long-tailed ducks, common eider, king eider, black-legged 

kittiwake, Pacific brant, phalaropes, lesser snow geese, and other waterfowl and shorebirds. 

Terrestrial Mammals 

Oil Exploration, Development, and Production 

Among the terrestrial-mammal populations that could be affected by oil exploration and development 

in the Sale 193 area are caribou (Central Arctic, Western Arctic, and Teshekpuk Lake herds), 

muskoxen, grizzly bears, and Arctic foxes. The primary potential effects of OCS exploration and 

development activities on terrestrial mammals would come from disturbance associated with ice-road 

and air-support traffic along pipeline corridors and near other onshore-support facilities. Habitat 

alteration associated with gravel extraction (mining) to support the construction of gravel pads for 

onshore facilities is possible. Effects could also come from potential oil spills contacting coastal 

areas used by caribou for insect relief, and for scavenging by grizzly bears and Arctic foxes. The 

effects of Chukchi Sea oil exploration and development on caribou, muskoxen, and grizzly bears 

would likely include local displacement within about 4 km of onshore pipelines and roads (Joly et al., 

2006; Cameron et al., 2005; Haskell et al., 2006). If a large oil spill occurred in the Chukchi Sea, it 

likely would result in the loss of a small number of caribou, muskoxen, grizzly bears, and Arctic 

foxes. However, significant impacts to local grizzly bear populations could occur if a large oil spill 

affected one of the salmon-spawning rivers in the project area. For additional information, see 

Section IV.C.1.i of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

It is likely that several species of terrestrial mammals would be temporarily disturbed by natural gas 

development, and to a lesser extent, natural gas production activities. Negative impacts of this type 

can be difficult to quantify. However, existing data and anecdotal evidence strongly suggest that no 

species of terrestrial mammal would suffer significant adverse impacts. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 27

VLOS 

With the exception of caribou, terrestrial mammals do not aggregate in coastal areas in numbers 

sufficient to permit population level effects from oiling. Even if a large group of caribou happened to 

be directly affected, it is most likely that full recovery of population numbers would occur within two 

years. Terrestrial mammals such as bears, wolves, wolverines, and fox could also be affected through 

consumption of contaminated prey or carcasses, but effects are not anticipated to be significant. 

Vegetation and Wetlands 

Oil Exploration, Development, and Production 

Seismic surveys and exploration activities would be concentrated offshore, with no impacts on 

onshore and inland vegetation and wetlands. Adverse effects on wetlands and terrestrial vegetation 

communities resulting from oil development and production would likely be localized. These 

impacts would be moderate to significant at a local scale, especially if a large spill occurred, but 

would have a small effect on the ecological functions, species abundance, and composition of 

wetlands and plant communities of the North Slope at a regional scale. For additional information, 

see Section IV.C.1.j of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

Given the unique sensitivity of the tundra ecosystem in the region analyzed, some potential impacts to 

vegetation associated with natural gas development and production may be long lasting (e.g. 

disruption of slow-recovering vegetation communities) or even permanent (e.g. thermokarst). These 

impacts would, however, be highly localized and insignificant on a regional scale. 

VLOS 

If oil were to contact vegetation and wetlands resources, it could persist for 10 years or more, and also 

cause erosion. However, very little of the Arctic shoreline includes habitats that are sensitive to oil 

impacts. Tundra and marsh areas would only be affected if the presence of spilled oil coincided with 

a storm surge event. 

Economy 

Oil Exploration, Development, and Production 

Sale 193 would generate increases in North Slope Borough (NSB) property taxes that would average 

about 25% above the level of Borough revenues (without the sales) in the peak years and taper off to 

<15% in the latter years. In the early years of production, each sale would generate increases in 

revenues to the State of Alaska of <0.3%. The increases would taper off to an even smaller percent in 

the latter years of production. The change in total employment and personal income is <2% over the 

2003 baseline for the NSB and <0.5% over the 2005 baseline for the rest of Alaska for each of the 

three major phases of OCS activity: exploration, development, and production. The employment and 

personal income increase includes workers to clean up a large oil spill of 1,500 bbl or 4,600 bbl. 

Sale193 would contribute to extending the lifespan of the Trans-Alaska Pipeline System (TAPS). For 

additional information, see Section IV.C.1.k of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

Natural gas development and production under the Proposed Action would result in a variety of 

beneficial economic impacts, namely employment, personal income, and revenues. 
BOEMRE Sale 193 Revised Draft SEIS 

28 CHAPTER II. Alternatives, Mitigation, and Issues 

VLOS 

A VLOS would generate several thousand direct, indirect, and induced jobs, and millions of dollars in 

personal income associated with oil spill response and cleanup in the short run. A VLOS could also 

have negative long-term impacts to potential activities in the future. 

Subsistence-Harvest Patterns 

Oil Exploration, Development, and Production 

Effects on subsistence-harvest patterns could occur as a result of oil spills, seismic survey activity, 

and construction-related activities. Oil spills could cause multiyear suspensions or curtailments of 

subsistence activities for some marine mammal resources. Construction-related activities—pipeline 

placement, traffic noise, heavy-equipment movement, etc.—could hinder the harvest of subsistence 

resources. Because of the concentration of construction-related activities and the potential for this 

region to be affected by any oil-spill incident that might occur over the life of the field, the 

communities that use this area heavily for their subsistence resources would be those most affected by 

oil exploration, development, and production activities. Conversely, the communities that lie at some 

distance from the concentrated areas of construction would be those that experience less sale-related 

effects on subsistence-related activities. 

For the communities of Barrow, Wainwright, Point Lay, and Point Hope, and Kivalina, noise and 

disturbances could periodically affect subsistence resources. Effects on bowhead whales, beluga 

whales, other marine mammals, terrestrial mammals, freshwater fish, marine fish, most birds, and 

polar bears are expected to range from negligible to local and short-term (generally <1 year) and have 

no regional population effects. No resource or harvest area would become unavailable or undesirable 

for use, and no species would experience overall population reductions. In the case of a large oil 

spill, areas directly oiled, areas to some extent surrounding them, areas used for staging, and 

transportation corridors for spill response would not be used by subsistence hunters for some time 

following a spill. The duration of avoidance by subsistence users would vary depending on the 

volume of the spill, the persistence of oil in the environment, the degree of impact on resources, the 

time necessary for recovery, and the confidence in assurances that resources were safe to eat. Oilspill cleanup would increase these effects. Cleanup disturbances could displace subsistence species, 

alter or reduce subsistence-hunter access to these species, and alter or extend the normal subsistence 

hunt. Such oil-spill effects would be considered significant. For additional information, see Section 

IC.C.1.l of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

While natural gas development and production is not expected to appreciably reduce any populations 

of subsistence species, it is possible that disturbance caused by these activities could alter the local 

availability of these resources to harvesters. These impacts would be considered short-term and 

localized, and would not rise to the level of significant adverse effects. 

VLOS 

A VLOS in the Chukchi Sea could significantly affect subsistence-harvest patterns in several ways. 

Subsistence resources could be diminished, displaced and more difficult to access, and/or 

contaminated. Concerns about contamination could persist many years, long after actual harvest 

disruption. In light of sharing networks, a spill originating in the Chukchi Sea region could produce 

indirect impacts felt by communities remote from the sale area and far removed from the spill. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 29

Sociocultural Systems 

Oil Exploration, Development, and Production 

In characterizing the potential adverse effects from OCS activities, we look at the magnitude and 

duration of disruption, with “significant” effects equated to conditions described as a chronic 

disruption of social organization, cultural values, and institutional organization for a period two to 

five years with a tendency toward displacement of existing social patterns. 

The effects of the 3D/2D seismic activities that are projected to occur are likely to be minimal. 

Effects on social well-being (social systems) would be noticeable because of concern over deflection 

of the bowhead whale due to seismic survey activities and the attendant effects on subsistence 

harvest. Routine activities from exploration, development and production, and decommissioning, 

could cause noticeable disruption to social organization, cultural practices, and institutional 

organizations, especially during development, a period that will last more than five years. However, 

the combination of effects would not be sufficient to displace existing social patterns at the Regional 

level. On the local level, Wainwright may experience significant effects with noticeable disruption, 

most likely from the placement of onshore infrastructure (that is, the shore base in the scenario). The 

most prominent effect would be the change in land use from the introduction of industrialization. 

Wainwright could experience effects on social organization, cultural values, and institutional 

organization for a period exceeding five years. Displacement of social patterns could occur as a result 

of social system adaptation to chronic disruptions. In addition, social patterns could be affected by a 

growing cash economy sector from offshore exploration support activities as it impacts existing 

subsistence practices in Chukchi Sea coastal villages. 

For a large oil spill, noticeable disruption in excess of two years could occur from the oil spill and 

cleanup activities. The effects of this disruption would last beyond the period of clean up and would 

represent a chronic disruption of social organization, cultural values, and institutional organization. 

The effects would have a tendency to displace existing social patterns. 

Activities associated with 3D/2D seismic surveys, exploration, development, production and 

decommissioning will cause some disruption to some elements of social organization, cultural 

practices, and institutional organization for a period of at least two years. This disruption is not 

expected to have a tendency to remarkably change (displace) existing social patterns at the regional 

(NSB) level. Effects could be significant but manageable on a local level (at Wainwright in the 

scenario because of supply base activity). Effects from a large oil spill could represent a chronic 

disruption of social organization, cultural values, and institutional organization and have a tendency 

to displace existing social patterns. For additional information, see Section IV.C.1.m of the Sale 193 

FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

The following conclusions may be drawn from the analyses: 

 At the regional level (NSB), effects from Sale 193 natural gas development and production 

should not exceed the significance threshold. 

 At the local level (Wainwright in the scenario), effects from Sale 193 natural gas 

development and production should not exceed the significance threshold. 

 Mitigation measures should prove effective in ameliorating many of the effects of Sale 193 

natural gas development and production. Social systems are expected to successfully respond 

and adapt to the change brought about by the continuation of production activities. This 

accommodation response represents circumstances that should not exceed the significance 

threshold. 
BOEMRE Sale 193 Revised Draft SEIS 

30 CHAPTER II. Alternatives, Mitigation, and Issues 

VLOS 

A VLOS could cause chronic disruption to sociocultural systems for at least two years and likely 

longer. Longer term disruptions to subsistence resources and practices would compound these 

effects. 

Archaeological Resources 

Oil Exploration, Development, and Production 

Archaeological surveys and analyses are required in areas where potential archaeological resources 

are at risk from offshore operations. These requirements are specified in the regulations (30 CFR 

250.194; 30 CFR 250.203; 30 CFR 250.204; 30 CFR 250.1007[a][5]; and 30 CFR 250.1010[c]); and 

in law through the National Historic Preservation Act. Any archaeological resources, either onshore 

or offshore, are expected to be identified through required site-specific surveys before any activities 

are permitted, and potential effects will be avoided or mitigated. For additional information, see 

Section IV.C.1.n of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Natural Gas Development and Production 

There is a small potential that certain natural gas development activities could cause irreversible 

adverse impacts to currently unknown archaeological resources. Such impacts could be significant. 

However, the potential for significant adverse impacts will be further reduced through adherence with 

standard pipeline construction protocols and measures identified during the NHPA Section 106 

consultation process. 

VLOS 

An irreversible adverse impact to an archaeological resource is significant. The aspect of a VLOS 

scenario with the highest potential to cause such impacts is onshore spill response and cleanup 

activities that can alter site dynamics and increase resource degradation. 

Environmental Justice 

Oil Exploration, Development, and Production 

Alaskan Inupiat Natives are the predominant residents of the North Slope communities. As such, 

they could be disproportionately affected by disturbance impacts from seismic activity, vessel, 

aircraft, construction noise, and oil spills because of their reliance on subsistence foods. “Significant” 

effects on Environmental Justice are defined as: disproportionately high adverse impacts to lowincome and minority populations. Potentially significant impacts to subsistence resources and 

harvests, and consequent impacts to sociocultural systems, could result in adverse Environmental 

Justice impacts. With required mitigation and conflict avoidance measures in place, significant 

impacts to subsistence resources and hunts from seismic activity, noise, and disturbance would not be 

expected to occur. As a result, significant impacts on sociocultural systems and disproportionately 

high adverse impacts on low-income and minority populations in the region would be avoided. 

Disproportionately high and adverse impacts to this group could occur in the unlikely event of a large 

oil spill, however. For additional information, see Section IV.C.1.p of the Sale 193 FEIS (USDOI, 

MMS, 2007a). 

Natural Gas Development and Production 

No major adverse impacts are expected for Alaska Inupiat Natives, the only significant minority 

group within the action area. However, one can expect several forms of minor impacts related to 

potential effects on subsistence resources and practices, human health, and perhaps sociocultural 

systems. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 31

VLOS 

A VLOS in the Chukchi Sea has the potential to cause disproportionate high adverse environmental 

and health impacts to defined minority populations in the Chukchi Sea Region, specifically Alaska 

Inupiat Natives. 

II.D.2. Summary of Impacts: Alternative II – No Lease Sale 

Under the No Action alternative (Alternative II), the Secretary would decline to affirm Sale 193, and 

would instead cancel the leases. No offshore development or production would occur under Sale 193, 

although such activities could occur within the Chukchi Sea under a future lease sale. Potential 

environmental impacts to the marine, coastal, and human environment from offshore development 

and production would not occur or would be delayed. Economic benefits to local communities, the 

North Slope Borough, the State of Alaska, and the Federal Government would not be realized at this 

time, due to delay and/or missed opportunities. The selection of this alternative would also postpone 

potential contributions to national energy supplies and security. A variety of adverse and beneficial 

impacts generally associated with petroleum production could be displaced to other localities, both 

domestic and foreign. 

II.D.3. Summary of Impacts: Alternative III – Corridor I Deferral 

The major difference between Alternative III (Corridor I deferral) and Alternative I (the Proposed 

Action) is that the blocks within the deferral area would not be offered for lease under Alternative III. 

Exploration seismic surveying, ancillary activities along potential pipeline routes, and installation of a 

pipeline to shore could still occur within the deferral corridor. No exploration or development 

drilling or platform construction would occur within the deferred area. 

This deferral corridor would increase the minimum distance from shore in terms of the following: 

 Length of gas pipelines from a platform to shore 

 Travel distances for vessels and aircraft supporting exploration and development drilling 

activities and platform construction and operations 

 Discharges, emissions, and noise associated with drilling and platform installation and 

operation 

 The source of a VLOS 

The deferral area (Corridor I) under Alternative III is wider (i.e., defers more blocks) than the deferral 

area (Corridor II) under Alternative IV. The minimum distance from shore for activities listed above 

is longer under Alternative III as compared with Alternative IV. 

Summaries of potential impacts under Alternative III are presented first for the oil exploration, 

development, and production scenario analyzed in the Sale 193 FEIS (USDOI, MMS, 2007a), then 

for the natural gas development and production scenario analyzed in Sections IV.B and IV.C, and 

lastly for the VLOS scenario analyzed in Sections IV.D and IV.E. 

Oil Exploration, Development, and Production 

Water Quality 

The level of potential activities remains the same for Alternative I, III, or IV; therefore, the actions 

and sources of water quality degradation do not change. The deferral areas may avoid localized 

discharges to marine waters; however, the removal of the deferred lease blocks would not 

significantly change the effects on marine water quality either negatively or beneficially. Permitted 

discharges that are compliant with granted permits would not pose a significant degree of risk to 

water quality at the various proposed development and production sites. 
BOEMRE Sale 193 Revised Draft SEIS 

32 CHAPTER II. Alternatives, Mitigation, and Issues 

Air Quality 

Potential air quality impacts to adjacent onshore areas would be lower under Alternative III than 

Alternative I because of the greater distance from shore of the nearest tract available for leasing. The 

difference in potential impacts, however, is small. 

Lower Trophic Level Organisms 

The effects on lower trophic level organisms would be due partly to possible discharges in nearshore 

areas and to oil spills that could contact the coastline next to the Spring Lead System. The deferral of 

1,765 whole or partial blocks near the coast would decrease the level of potential effects. Therefore, 

total effects from Alternative III would be lower than total effects summarized for Alternative I 

(above), but the relative level of effects from each alternative would be similar. 

Fish Resources 

The primary benefit of Alternative III is that it would move sources of potential effects farther away 

from important coastal and anadromous fish habitats. The increased distance between offshore 

development and coastal fish habitats could also conceivably decrease the chance of spilled oil 

contacting the coastline, increase the weathering of spilled oil prior to contact, and increase the 

available spill response time. 

Essential Fish Habitat 

This deferral alternative would provide more protection for coastal and marine fish habitat by moving 

drilling and construction noise disturbances and water quality impacts (exploration and production 

platform discharges, and turbidity) farther away from the Chukchi Sea coastline. 

If a large oil spill occurred, the increased distance to the shoreline conceivably reduces the percent 

chance of one or more spills ≥1,000 bbl contacting sensitive coastal resources. Also, the increased 

time required for oil to travel this greater distance would conceivably allow for more effective 

response from spill response depots. 

Deferrals could increase the length of pipeline necessary to lay on the seafloor. Increased pipeline 

distances could result in greater pipeline construction impacts and a greater chance for pipeline 

rupture and subsequent spill. The potential effect categories remain the same as the proposed action, 

but the anticipated impacts would be lower due to the operations setback from the Chukchi coastline. 

Overall, the greatest net ecological benefits to nearshore EFH would occur from this alternative 

because it contains the largest deferral area. 

Threatened and Endangered Marine Mammals 

Several marine mammals have been recently proposed for listing under the ESA, a group that 

includes Pacific walrus, bearded seal, and ringed seal. The potential impacts of the Proposed Action 

on these species remain within the Other Marine Mammals section (below). 

This alternative would reduce potential conflicts between migrating bowhead whale populations, 

bowhead whale subsistence hunters, and offshore oil and gas operations. However, exploration 

seismic surveys would be allowed to continue in the corridor. 

Differences in noise and oil-spill effects on bowhead whales from this deferral compared to 

Alternative I (Proposed Action) and Alternative IV (Corridor II Deferral) are difficult to quantify, but 

can be described qualitatively. While the selection of this alternative decreases the opportunity of 

discovering a commercial field, the resources in and adjacent to this area still could be adversely 

affected by a large oil spill originating from a production site and/or pipeline located elsewhere in the 

sale area. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 33

This alternative would move sources of industrial noise and sources of crude oil farther offshore and 

away from the spring lead system, thus reducing the likelihood of spring bowhead whale encounters 

with industrial noise. It would not, however, substantially reduce the chance of crude oil contacting 

the spring-migratory route because: (1) pipelines, constructed through the spring-migratory route in 

order to transport oil to shore-based processing facilities, could leak; and, (2) oil-spill-trajectory 

models indicate that depending on the volume of oil spilled and oceanographic and weather 

conditions, oil spilled outside Corridor I could be transported into the spring-migratory route. 

However, because this alternative reduces the number of potential oil-spill launch sites and their 

locations are farther away from the spring-migratory route, any spill that would occur would 

conceivably take longer to reach and enter the spring-migratory route, thus allowing more time to 

respond to the spill. Observations by Clarke, et al. (2011) and satellite tracking by Quakenbush, et al. 

(2010) have confirmed use of the deferred area by migrating bowhead whales in the fall. Therefore, 

bowhead whales could encounter oil and gas-related industrial noise and oil spills in the deferred 

area. Deferral of this area under Alternative III could make such encounters somewhat less frequent, 

but bowhead whales would still encounter some attenuated levels of noise from adjacent areas. 

Ancillary activities such as pipeline associated surveys and construction, support vessel and aircraft 

traffic to and from shore, and accidental spills would remain the same as described for Alterative I 

(Proposed Action). 

Implementing existing mitigation measures and conservation recommendations in the NMFS Arctic 

Region Biological Opinion (dated July 17, 2008) would provide the necessary protection to prevent 

and/or minimize adverse environmental impacts on the bowhead whale from routine activities. 

Selecting this alternative would decrease the potential for impacts to polar bears at important denning 

habitat and barrier islands. The increased distance between offshore development and terrestrial 

critical habitats could decrease the percent chance that oil could contact polar bears in the event of a 

spill, increase weathering of spilled oil prior to contact with coastal habitats, and increase available 

spill-response time. 

Other Marine Mammals 

The primary benefit of the corridor provided by this alternative is that it would move sources of 

potential adverse effects farther away from important coastal habitats. The increased distance between 

offshore development and coastal habitats could do the following: decrease the percent chance of 

spilled oil contacting those marine mammals, like spotted seals and walrus, which tend to use coastal 

habitats; increase weathering of spilled oil prior to contact with coastal habitats; and increase 

available spill-response time. 

While polar bears and walrus prefer offshore sea ice habitat, they are increasingly forced ashore by a 

lack of sea ice in late summer and fall in the Chukchi Sea. The increased use of the coastline for 

these species, particularly for the large aggregations of walrus using coastal haulouts, puts them at 

increased risk from oil spills and disturbance events onshore. Increasing the size of the coastal 

deferral slightly decreases the risks from disturbance and the potential for oil spills reaching shore for 

these species. While this may be less true for bearded, ringed and spotted seals, spotted seals 

aggregate at certain key areas along the Chukchi and Beaufort Sea coasts during the open water 

season. Additional protection of the nearshore spring lead systems, parts of which would be deferred 

by the wider coastal corridor, would be beneficial to ringed and bearded seals and to polar bears 

which prey upon them within the spring lead system. The FWS has identified barrier islands along the 

U.S. coast of the Chukchi Sea as Critical Habitat for the polar bear. 
BOEMRE Sale 193 Revised Draft SEIS 

34 CHAPTER II. Alternatives, Mitigation, and Issues 

Threatened and Endangered Birds 

The yellow-billed loon was recently classified as a candidate species. The potential impacts of the 

Proposed Action on this species are considered within the Other Marine and Coastal Birds section, 

below. 

Despite a deferral, this alternative could present new sources of disturbance, collision hazards, and 

oil/toxic pollution that could result in the taking of threatened Steller’s and spectacled eiders. These 

activities remain likely to adversely affect Steller’s and spectacled eiders. Similarly, this alternative 

could present new sources of disturbance and oil/toxic pollution that could result in the taking of 

Kittlitz’s murrelet, a candidate species. 

This alternative could also present new activities that could result in the physical modification of 

seafloor habitats and decrease use of the LBCHU by molting spectacled eiders. Under this 

alternative, these activities are less likely to adversely modify the LBCHU compared to Alternative I. 

Other Marine and Coastal Birds 

This deferral area would be in the form of a corridor on the shoreward margin of the proposed lease 

sale area. The primary benefit of this corridor is that it would move sources of potential adverse 

effects farther away from important bird habitats. The increased distance between offshore 

development and coastal bird habitats could also decrease the percent chance of spilled oil contacting 

bird habitat, increase weathering of spilled oil prior to contact, and increase available spill-response 

time. 

Terrestrial Mammals 

The primary benefit of this corridor is that it would move sources of potential adverse effects farther 

away from important coastal habitats. The increased distance between offshore development and 

coastal habitats would conceivably decrease the percent chance of spilled oil contacting coastal 

habitats, increase weathering of spilled oil prior to contact coastal habitats, and increase available 

spill-response time. 

Vegetation and Wetlands 

The effects of Alternative III would be the same as Alternative I (Proposed Action). 

Economy 

The effects of Alternative III would be the same as Alternative I (Proposed Action). 

Subsistence-Harvest Patterns 

This alternative would potentially reduce sources for chronic noise and disturbance impacts on 

subsistence resources, subsistence whaling, and other marine mammal hunting. Because potential 

launch points for oil spills would move seaward, time for spilled oil to weather and time to mount an 

oil-spill response would be increased. Consequently, the effects on subsistence-harvest patterns 

would be expected to be reduced. 

Sociocultural Systems 

There would be a reduction in the effects on the components of sociocultural systems in comparison 

to Alternative I (Proposed Action). However, this would not substantially alter the overall effects on 

sociocultural systems. 

Archaeological Resources 

The effects of Alternative III would be the same as Alternative I (Proposed Action). 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 35

Environmental Justice 

Sale-specific Environmental Justice effects would derive from potential noise, disturbance, and oil 

spill effects on subsistence resources, subsistence-harvest patterns, and sociocultural systems. Noise, 

disturbance, and oil spill effects under Alternative III are expected to be reduced relative to those 

described for Alternative I (Proposed Action). The only substantial source of potential 

Environmental Justice-related effects on coastal subsistence-oriented communities on the Alaskan 

Chukchi Sea coastline would occur in the event of a large oil spill, which could affect subsistence 

resources. Such effects would represent disproportionately high and adverse effects on Alaskan 

Natives in Chukchi Sea coastal communities—and would be considered significant Environmental 

Justice impacts. Potential adverse effects are expected to be mitigated substantially, though not 

eliminated. 

Natural Gas Development and Production 

The activities associated with natural gas development and production with the most potential to 

impact the environment (i.e. continued operation of an offshore platform, installation of an offshore 

and an onshore gas pipeline in the same corridor as existing oil pipelines) are very similar to activities 

analyzed in the oil exploration, development and production scenario. In general, the deferral 

corridor proposed in Alternative III would affect potential impacts associated with the natural gas 

development and production scenario in the same manner as described above, for the oil exploration, 

development and production scenario. By increasing the minimum distance of the platform to shore, 

Alternative III could decrease adverse impacts to air quality in coastal areas, nearshore lower trophic 

level organisms, marine mammals and birds that use the spring lead system and other nearshore areas, 

subsistence users, and community health. A longer offshore gas pipeline could cause additional 

impacts to water quality, certain offshore species, etc, but these impacts would be minor. The 

deferral corridor included in Alternative III would not alter potential impacts associated with other 

components of the natural gas development and production scenario such as constructing an onshore 

facility and onshore pipeline. 

Impacts of VLOS 

In general, environmental impacts from a VLOS occurring under Alternative III are very similar to 

those from a VLOS occurring under Alternative I. 

There are two principal manners in which potential impacts may differ as between Alternative III and 

Alternative I. First, by implementing 60-mile deferral corridor, selecting Alternative III would reduce 

the area of the Chukchi Sea made available for oil and gas activities under Sale 193. To the extent 

that spilled oil from VLOS occurring in this area is more likely (as compared to a VLOS occurring in 

other portions of the lease sale area) to contact important resource areas, a deferral could reduce the 

potential for adverse impacts to resources in nearshore and coastal areas. Benefits could accrue to 

nearshore and coastal water quality, certain species of fish, beluga whales, polar bears, many species 

of birds, certain species of seals, walrus, terrestrial mammals, and communities that depend on 

subsistence. Second, deferring additional area along the coastward edge of the sale area increases the 

minimum potential distance between a VLOS and shore, which could allow more time and space for 

spill response and cleanup activities in the event of a VLOS. This could reduce the extent of 

nearshore and onshore contact by spilled oil. 

II.D.4. Summary of Impacts: Alternative IV – Corridor II Deferral 

The major difference between Alternative IV (Corridor II deferral) and Alternative I (the Proposed 

Action) is that the blocks within the deferral area would not be offered for lease under Alternate IV. 

Exploration seismic surveying, ancillary activities along potential pipeline routes, and installation of a 

pipeline to shore could still occur within the deferral corridor. No exploration or development 

drilling or platform construction would occur within the deferred area. 
BOEMRE Sale 193 Revised Draft SEIS 

36 CHAPTER II. Alternatives, Mitigation, and Issues 

This deferral corridor would increase the minimum distance from shore in terms of the following: 

 Length of oil and gas pipelines from a platform to shore 

 Travel distances for vessels and aircraft supporting exploration and development drilling 

activities and platform construction and operations 

 Discharges, emissions, and noise associated with drilling and platform installation and 

operation could occur 

 The source of a VLOS 

The deferral area (Corridor II) under Alternative IV is narrower (i.e., defers fewer blocks) than the 

deferral area (Corridor I) under Alternative III. The minimum distance from shore for activities listed 

above is longer under Alternative III (60 miles) as compared with Alternative IV (30 miles). 

Summaries of potential impacts under Alternative IV are presented first for the oil exploration, 

development, and production scenario analyzed in the Sale 193 FEIS (USDOI, MMS, 2007a), then 

for the natural gas development and production scenario analyzed in sections IV.B and IV.C, and 

lastly for the VLOS scenario analyzed in sections IV.D and IV.E. 

Oil Exploration, Development, and Production 

Water Quality 

The level of potential activities remains the same for Alternative I, III, or IV; therefore, the actions 

and sources of water quality degradation do not change. The deferral areas may avoid localized 

discharges to marine waters; however, the removal of the deferred lease blocks would not 

significantly change the effects on marine water quality either negatively or beneficially. Permitted 

discharges that are compliant with granted permits would not pose a significant degree of risk to 

water quality,at the various proposed development and production sites. 

Air Quality 

Alternative IV would lower potential air quality impacts to the adjacent onshore area more than 

Alternative I but not as much as under Alternative III. Tracts available for leasing are nearer the 

shore than under Alternative III, but not as close as under Alternative I. The difference in potential 

air quality impacts, however, is small. 

Lower Trophic Level Organisms 

The effects of Alternative IV would be the same as Alternative I (Proposed Action). 

Fish Resources 

The primary benefit of Alternative IV is that it would move sources of potential effects farther away 

from important coastal and anadromous fish habitats. The increased distance between offshore 

development and coastal fish habitats could also conceivably decrease the chance of spilled oil 

contacting the coastline, increase the weathering of spilled oil prior to contact, and increase the 

available spill response time. This alternative would provide the same types of net resource benefits 

as Alternative III, but at a reduced level. 

Essential Fish Habitat 

As explained under the analysis for Alternative III, a deferral would provide more protection for 

coastal and marine fish habitat by moving drilling and construction noise disturbances and water 

quality impacts (exploration and production platform discharges, and turbidity) farther away from the 

Chukchi Sea coastline. The primary benefit of the deferral of Corridor II under Alternative IV is that 

it would move sources of potential noise and contaminant effects farther away from important coastal 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 37

and anadromous fish habitats. The increased distance between offshore development and coastal fish 

habitats could also decrease the percent chance of spilled oil contacting nearshore fish habitats, 

increase the weathering of spilled oil prior to contact, and increase the spill-response time. 

Threatened and Endangered Marine Mammals 

Several marine mammals have been recently proposed for listing under the ESA, a group that 

includes Pacific walrus, bearded seal, and ringed seal. The potential impacts of the Proposed Action 

on these species remain within the Other Marine Mammals section (below). 

The assessment of this alternative is essentially identical to the assessment for Alternative III 

(Corridor I Deferral). This alternative also would preclude the development, production, and 

abandonment of oil and gas activities in the lease blocks within Corridor II, thereby reducing (but not 

a much as Alternative III) potential conflicts between migrating bowhead whale populations, 

bowhead whale subsistence hunters, and offshore oil and gas operations. Exploration seismic surveys 

would be allowed to continue within the corridor. 

Differences in noise and oil-spill effects on bowhead whales from this deferral compared to 

Alternative I (Proposed Action) and Alternative III (Corridor I Deferral) are difficult to quantify. 

While the selection of this alternative decreases the opportunity of discovering a commercial field and 

the number of oil-spill launch sites, the resources in and adjacent to this area still could be adversely 

affected by a large oil spill originating from a production site and/or pipeline located elsewhere in the 

sale area. Therefore, the impacts of oil spills and industrial noise on threatened and endangered 

marine mammals, as described and for Alternative I (Proposed Action), apply. 

The deletion of this area from the lease sale would move sources of industrial noise and sources of 

crude oil farther offshore and away from the spring lead system, thus somewhat reducing the 

likelihood of spring bowhead whale encounters with industrial noise. It would not, however, 

substantially reduce the chance of crude oil contacting the spring-migratory route because: (1) 

pipelines constructed through the spring-migratory route to transport oil to shore-based processing 

facilities could leak; and (2) oil-spill-trajectory models indicate that depending on the volume of oil 

spilled and oceanographic and weather conditions, oil spilled outside Corridor II could be transported 

into the spring-migratory route. However, because this alternative reduces the number of potential 

oil-spill launch sites and their locations are farther away from the spring-migratory route, any spill 

that would occur would conceivably take longer to reach and enter the spring-migratory route, thus 

allowing more time to respond to the spill (but not as much response time afforded by Alternative III, 

Corridor I Deferral). Observations by Clarke, et al. (2011) and satellite tracking by Quakenbush, et 

al. (2010) have confirmed use of the deferred area by migrating bowhead whales in the fall. 

Therefore, bowhead whales could encounter oil and gas-related industrial noise and oil spills in the 

deferred area. Deferral of this area under Alternative IV could make such encounters somewhat less 

frequent, but bowhead whales would still encounter some attenuated levels of noise from adjacent 

areas. Ancillary activities such as pipeline associated surveys and construction, support vessel and 

aircraft traffic to and from shore, and accidental spills would remain the same as described for 

Alterative I (Proposed Action). 

Selecting Alternative IV would also decrease the potential for impacts to polar bears at important 

denning habitat and barrier islands, though to a lesser extent than Alternative III. As in Alternative 

III, Alternative IV could increase the distance between offshore development and terrestrial critical 

habitats which could decrease the percent chance that oil would contact polar bears in the event of a 

spill, increase weathering of spilled oil prior to contact with coastal habitats, and increase available 

spill-response time. 
BOEMRE Sale 193 Revised Draft SEIS 

38 CHAPTER II. Alternatives, Mitigation, and Issues 

Other Marine Mammals 

Alternative IV would provide a deferral area smaller than Alternative III and provide greater net 

resource benefits to marine mammals than Alternative I. This deferral area would be in the form of a 

corridor on the shoreward margin of the proposed sale area. The primary benefit of this corridor is 

that it would move sources of potential adverse effects farther away from important coastal habitats. 

The increased distance between offshore development and coastal habitats could do the following: 

slightly decrease the percent chance of spilled oil contacting those marine mammals, like spotted 

seals, which tend to use coastal habitats; increase weathering of spilled oil prior to contact with 

coastal habitats; and increase available spill-response time. 

Threatened and Endangered Birds 

The yellow-billed loon was recently classified as a candidate species. The potential impacts of the 

Proposed Action on this species are considered within the Other Marine and Coastal Birds section, 

below. 

Despite a deferral, this alternative could present new (but potentially fewer than Alternative I) sources 

of disturbance, collision hazards, and oil/toxic pollution that could result in the taking of threatened 

Steller’s and spectacled eiders. These activities remain likely to adversely affect Steller’s and 

spectacled eiders. Similarly, this alternative could present new, but potentially fewer, sources of 

disturbance and oil/toxic pollution that could result in the taking of Kittlitz’s murrelet, a candidate 

species. 

This alternative could also present new activities that could result in the physical modification of 

seafloor habitats and decrease use of the LBCHU by molting spectacled eiders. Under this 

alternative, these activities are less likely to adversely modify the LBCHU compared to Alternative I. 

Other Marine and Coastal Birds 

This alternative has a smaller deferral area than Alternative III. The primary benefit of this deferral is 

that it would move sources of potential adverse effects farther away from important bird habitats. 

The increased distance between offshore development and coastal bird habitats could also decrease 

the percent chance of spilled oil contacting bird habitats, increase weathering of spilled oil prior to 

contact, and increase available spill-response time. This alternative would provide the same types of 

net resource benefits as Alternative III, but at a reduced level. 

Terrestrial Mammals 

This alternative would provide a deferral area smaller than Alternative III and would be in the form of 

a corridor on the shoreward margin of the proposed sale area. The primary benefit of this corridor is 

that it would move sources of potential adverse effects farther away from important coastal habitats. 

The increased distance between offshore development and coastal habitats would slightly decrease 

the percent chance of spilled oil occurring and contacting terrestrial mammals and associated habitat, 

increase weathering of spilled oil prior to contacting terrestrial mammals and associated habitat, and 

increase available spill-response time. 

Vegetation and Wetlands 

The effects of Alternative IV would be the same as Alternative I (Proposed Action). 

Economy 

The effects of Alternative IV would be the same as Alternative I (Proposed Action). 

Subsistence-Harvest Patterns 

This alternative would potentially reduce sources for chronic noise and disturbance impacts on 

subsistence resources, subsistence whaling, and other marine mammal hunting. Because potential 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER II. Alternatives, Mitigation, and Issues 39

launch points for oil spills would move seaward, time for spilled oil to weather and time to mount an 

oil-spill response would be increased. Consequently, reduced effects on subsistence-harvest patterns 

would be expected. Reductions in noise, disturbance, and oil-spill effects from this deferral would 

provide the same types of resource benefits as described in Alternative III but at a reduced level, 

because the area deferred is smaller. 

Sociocultural Systems 

There would be a reduction in effects on the components of sociocultural systems in comparison to 

Alternative I (Proposed Action). However, this would not substantially alter the overall effects on 

sociocultural systems. 

Archaeological Resources 

The effects of Alternative IV would be the same as Alternative I (Proposed Action). 

Environmental Justice 

Sale-specific Environmental Justice effects would derive from potential noise, disturbance, and oilspill effects on subsistence resources, subsistence-harvest patterns, and sociocultural systems. Noise, 

disturbance, and oil-spill effects under Alternative IV (Corridor II Deferral) are expected to be 

reduced from those described for Alternative I (Proposed Action). Effects reductions from this 

deferral would provide the same types of resource benefits as described in Alternative III but at a 

reduced level, because the area deferred is smaller. The only substantial source of potential 

Environmental Justice-related effects on coastal subsistence oriented communities on the Alaskan 

coastline would occur in the event of a large oil spill, which could affect subsistence resources. Such 

effects would represent disproportionately high and adverse effects on Alaskan Natives in Chukchi 

Sea coastal communities and would be considered significant Environmental Justice impacts. 

Potential adverse effects are expected to be mitigated substantially, though not eliminated. 

Natural Gas Development and Production 

The activities associated with natural gas development and production with the most potential to 

impact the environment (i.e. continued operation of an offshore platform, installation of an offshore 

and an onshore gas pipeline in the same corridor as existing oil pipelines) are very similar to activities 

analyzed in the oil exploration, development and production scenario. In general, the deferral 

corridor proposed in Alternative IV would affect potential impacts associated with the natural gas 

development and production scenario in the same manner as described above, for the oil exploration, 

development and production scenario. By increasing the minimum distance of the platform to shore, 

Alternative IV could decrease adverse impacts to air quality in coastal areas, nearshore lower trophic 

level organisms, marine mammals and birds that use the spring lead system and other nearshore areas, 

subsistence users, and community health. A longer offshore gas pipeline could cause additional 

impacts to water quality, certain offshore species, etc, but these impacts would be minor. The 

deferral corridor included in Alternative IV would not alter potential impacts associated with other 

components of the natural gas development and production scenario such as constructing an onshore 

facility and onshore pipeline. 

Impacts of VLOS 

In general, environmental impacts from a VLOS occurring under Alternative IV are very similar to 

those from a VLOS occurring under Alternative I. 

There are two principal manners in which potential impacts may differ as between Alternative IV and 

Alternative I. First, by implementing a deferral corridor, selecting Alternative IV would reduce the 

area of the Chukchi Sea made available for oil and gas activities under Sale 193. To the extent that 

spilled oil from VLOS occurring in this area is more likely (as compared to a VLOS occurring in 
BOEMRE Sale 193 Revised Draft SEIS 

40 CHAPTER II. Alternatives, Mitigation, and Issues 

other portions of the lease sale area) to contact important resource areas, a deferral could reduce the 

potential for adverse impacts to resources in nearshore and coastal areas. Benefits could accrue to 

nearshore and coastal water quality, certain species of fish, beluga whales, polar bears, many species 

of birds, certain species of seals, walrus, terrestrial mammals, and communities that depend on 

subsistence. Second, deferring additional area along the coastward edge of the sale area increases the 

minimum potential distance between a VLOS and shore, which could allow more time and space for 

spill response and cleanup activities in the event of a VLOS. This could reduce the extent of 

nearshore and onshore contact by spilled oil. 

Because Alternative IV defers a relatively small area over what is already deferred via the 25 Statute 

Mile Buffer implemented in the Final OCS Leasing Program for 2007-2012 and incorporated into 

Alternative I, its potential to reduce impacts from a VLOS event above the potential reductions from 

Alternative I is small. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER III. Description of the Environment 41

CHAPTER III. Description of the Environment 

The following sections summarize the description of the physical, biological, and socioeconomic 

conditions and resources from the Sale 193 FEIS. The organization of this chapter is consistent with 

Chapter III of the Sale 193 FEIS. Most numbered headings have been retained as designated in the 

Sale 193 FEIS for ease of reference. 

This section also provides additional information about the affected environment where it is relevant 

to understanding potential effects from natural gas development and production and/or a VLOS (very 

large oil spill). Most of this additional information is new information which became available 

subsequent to the publication of the Sale 193 FEIS in 2007. Many of the additional studies 

referenced in this chapter were identified by BOEMRE analysts during their ongoing review of 

current scientific literature. Others were suggested for incorporation by stakeholders, government 

agencies, and public commenters. Discussion of additional data, studies, regulatory changes, etc. is 

provided within subsections titled “New Information for SEIS Analysis.” Where no important new 

information was identified for a particular environmental condition or resource, a statement to that 

effect is provided. Of all the additional information reviewed for this SEIS, none was found to alter 

the analysis or conclusions regarding oil exploration, development and production in the Sale 193 

FEIS. 

Changes in the regulatory status of certain species under the ESA are acknowledged within the 

Threatened and Endangered species sections. For the sake of consistency with the Sale 193 FEIS, 

background description for newly-proposed (but not yet “listed”) species is retained within the Other 

Marine Mammals and Other Marine and Coastal Birds subsections of this Chapter. 

For a more detailed discussion of the environmental conditions and resources in the Sale 193 area, 

including maps, readers are directed to the Sale 193 FEIS (USDOI, MMS, 2007a, incorporated by 

reference). 

III.A. Physical Environment 

III.A.1. Physiography 

The Chukchi Sea is located in the Arctic Ocean northwest of the Alaska Arctic coast. The Chukchi 

Sea Planning Area overlies a broad, low-relief continental shelf that is gently inclined to the north. 

Approximately 98% of the Sale 193 area covers this relatively shallow continental shelf adjacent to 

the Arctic Ocean. Approximately 80% of the continental shelf lies between the 95 and 200 ft (30 and 

60 m) isobaths (Grantz et al., 1982). Nearshore areas (shallower than 40 m) exhibit complex 

bathymetry characterized by ridges and troughs. Hanna Shoal within the Sale 193 area and Herald 

Shoal to the west side rise above the surrounding seafloor to approximately 20 m below sea level. 

There are also two major sea valleys in the Chukchi Sea: Herald Canyon and Barrow Canyon. 

The shoreline west of Barrow is characterized by nearly continuous sea cliffs up to 12 m high and cut 

into perennially frozen ice-rich sediments. Near Icy Cape and Point Franklin offshore barrier islands 

along the coast enclose shallow lagoons. Elsewhere the cliffs are abutted by narrow beaches. The 

Arctic Coastal Plain (ACP) is flat near the coast, and gradually increases in relief to the south towards 

the foothills of the Brooks Range. 

New information for SEIS analysis 

No new information regarding physiography has been introduced in this supplement. 
BOEMRE Sale 193 Revised Draft SEIS 

42 CHAPTER III. Description of the Environment 

III.A.2. Climate and Meteorology 

The Chukchi Sea is an Arctic climate characterized by moderate winds, cold temperatures during the 

winter, cool temperatures in the summer, and little annual precipitation. The region is dominated by 

subfreezing temperatures for most of the year, and the Chukchi Sea is almost totally ice covered from 

early December to mid-May. During the winter, winds can be strong and prolonged, leading to 

extreme ice pressures and dangerous wind-chill conditions. A brief warm and snow-free season 

follows in June, July, and August. 

New information for SEIS analysis 

The Arctic has seen very large cyclical variations over the past 2 million years. The changes have not 

been uniform over the area. Large changes also have taken place abruptly, spanning just a few 

decades. The driving factors are complex but involve changes in solar radiation, atmospheric 

circulations, ocean circulations, and the cryosphere. The Arctic Mulitple-Sale Draft EIS (USDOI, 

MMS, 2008a) provides a summary discussion of 20th century climate trends, variability, and projected 

changes to climate in the Arctic. The assessments of climate change and effects in the Arctic given in 

the Arctic Multi-Sale Draft EIS are based on the 2007 publication by the Intergovernmental Panel on 

Climate Change (IPCC, 2007) and the Arctic Research Center’s Arctic Climate Impact Assessment 

(2005). These two reports are considered to include the most thorough scientific evaluation of 

climate change (Karcher, 2010). 

The Arctic climate is undergoing changes as a result of global climate change as well as natural 

cyclical variations. The Arctic Climate Impact Assessment (ACIA, 2005) summarized spatial and 

temporal temperature trends in the Arctic based on observations from the Global Historical 

Climatology Network database (Peterson and Vose, 1997) and the Climate Research Unit database 

(Jones and Moberg, 2003). The greater amount of warming in the Arctic compared to that for the 

globe as a whole is consistent with climate model projections (IPCC, 2007). In general, temperatures 

increased from 1900 to the mid-1940s, decreased until about the mid-1960s, and then increased again 

up to the present. From 1966-2003, the average rate of temperature change for the Arctic was 0.40 

°C (0.7 °F) per decade (ACIA, 2005). When temperature trends are broken down by season, the 

largest changes occurred in winter and spring. 

An analysis by Rigor, Colony, and Martin (2000) for the entire Arctic Ocean for the period 1979-

1997, indicates an increase in surface air temperature of about 1.0 °C (1.8 °F) per decade in the 

eastern Arctic, whereas the western Arctic shows no trend, or even a slight cooling, in the Canadian 

Beaufort Sea. During fall, the trends show cooling of about 1.0 °C (1.8 °F) per decade over the 

Beaufort Sea and Alaska (Rigor, Colony, and Martin, 2000). During spring, a significant warming 

trend of 2 °C (3.6 °F) per decade can be seen over most of the Arctic. Summer shows no significant 

trend. 

A trend analysis for first-order observing stations in Alaska for the period of 1949-2007 shows an 

average temperature change of 1.9 °C (3.4 °F). The largest increase was seen in winter and spring, 

with the smallest change in autumn. The trend has been far from linear. There was a decrease in 

temperature in the period from 1949-1976 followed by an abrupt increase in temperature in the period 

from 1973-1979. Since 1979, only a little additional warming has occurred in Alaska with the 

exception of Barrow and a few other locations (Rigor, Colony, & Martin, 2000). 

Precipitation in the Arctic exhibits an upward trend, consistent with what is observed in mid-latitudes. 

Mean annual precipitation in the Arctic has increased at the rate of 1.4% per decade in the period 

from 1900-2003 and at a rate of 2.2% per decade in the period from 1966-2003 (ACIA, 2005). A few 

studies also indicate that an increasingly larger portion of precipitation falls in the form of rain 

(ACIA, 2005). 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER III. Description of the Environment 43

Climate change in the Arctic is projected to be larger than in other areas of the globe (ACIA, 2005). 

However, Arctic climate has a larger natural variability and is highly complex and, therefore, climate 

projections may have greater uncertainty. Of all the parameters, sea level rise has the largest 

uncertainty. 

III.A.3. Physical Oceanography 

The physical oceanography in the Chukchi Sea Planning Area is influenced by: (1) flow of water 

through the Bering Strait and the Siberian Coastal Current; (2) atmospheric-pressure systems; (3) 

surface-water runoff; (4) density differences between watermasses; and (5) seasonal and perennial sea 

ice. 

Flow in the Chukchi Sea generally is northward from the Bering Strait and, in general, is 

topographically steered. The mean transport can be interrupted by wind-forced currents, and the 

variations can be large (Weingartner et al., 1998; Woodgate, Aagaard, and Weingartner, 2005). 

The general cycle of the watermasses is cooling in the fall, increasing salinity in winter, and warming 

and freshening starting in spring and continuing into summer. Large changes in temperature and 

salinity occur throughout the year, with the largest variability along the Alaskan Chukchi coast. 

Tides are small in the Chukchi Sea, generally <0.3 m. Tidal currents are largest on the western side 

of the Chukchi and near Wrangel Island, ranging up to 5 cm/s (USDOI, MMS, 2007a; Woodgate, 

Aagaard, and Weingartner, 2005). Storm surges are both positive and negative. 

New information for SEIS analysis 

Recent tide gauge observations at Barrow show coastal water levels are driven primarily by wind 

stress and barometric pressure changes from the passage of storm centers and frontal passages 

(NOAA, 2011b; J. Inslee per comm., 2011). Storm surge on the coast and coastal water level 

withdrawl can be significant (about 1.0 m amplitude; J. Inslee per comm., 2011). Highest monthly sea 

levels are are generally in August and lowest monthly mean sea levels are in March. Winds from the 

west are associated with positive surges, and winds from the east are associated with negative surges. 

In late fall, the lack of sea ice increases the open-water area enhancing water transport and increasing 

wave height (Lynch and Brunner, 2007). 

III.A.4. Sea Ice 

There are three general forms of sea ice in the Sale 193 area: (1) landfast ice, which is attached to the 

shore, is relatively immobile and extends to variable distances offshore; (2) stamukhi ice, which is 

grounded and ridged ice; and (3) pack ice, which includes first-year and multiyear ice, and moves 

under the influence of winds and currents. These general ice types vary spatially and temporally in 

the Chukchi Sea Planning Area and are strongly influenced by the bathymetry and location of 

offshore shoals as well as atmospheric-pressure fields. 

In the Sale 193 area, sea-ice extent has a large seasonal cycle, generally reaching a maximum extent 

in March and a minimum in September. There is a large amount of interannual variability in the 

formation and breakup patterns of sea ice. 

Sea ice generally begins forming in late September or early October, covering most of the sale area 

by mid-November or the beginning of December (Brower et al., 1988; Belchansky, Douglas, and 

Platonov, 2004). The summer melt pattern primarily is influenced by the influx of warmer water 

from the Bering Sea. Melt-onset begins in early May in the southern portion of the Sale 193 area and 

early to mid June in the northern portion. By about mid-May, the nearshore ice and thin ice begin to 

melt; by July, the pack ice begins retreating northward. At the height of summer (mid-September in 

the Arctic), the Chukchi is normally 80% free of ice (Mulherin, Sodhi, and Smallidge, 1994). Freeze 
BOEMRE Sale 193 Revised Draft SEIS 

44 CHAPTER III. Description of the Environment 

onset begins in mid- to late October in the southern portion and late September to late October in the 

northern portion (Belchansky, Douglas, and Platonov, 2004). 

The Arctic sea ice is undergoing changes in extent, thickness, distribution, age, and melt duration 

(Stroeve et al., 2005; NASA, 2005; Comiso, 2006). The analysis of long-term data sets indicates 

substantial reductions in both the extent (area of ocean covered by ice) and thickness of the Arctic 

sea-ice cover during the past 20–40 years. 

Landfast Zone 

The mean annual cycle of landfast ice begins in October and grows slowly through February. First 

ice appears anywhere from late October to late December. Stable landfast ice appears from midJanuary to mid-March. In the shallow (2 m and less), inner part of the landfast zone, the ice freezes to 

the seafloor; in the outer part, the ice floats. Thawing begins about late May, and breakup occurs 

from about late May to mid-June. Overall there is a gradual formation of landfast ice and a rapid 

retreat. 

Stamukhi Zone 

The ice zone that lies seaward of the landfast ice has been referred to as the stamukhi (shear or flaw) 

zone. This zone is a region of dynamic interaction between the relatively stable ice of the landfast 

zone and the mobile ice of the pack-ice zone that results in the formation of ridges, leads, and 

polynyas (large areas of open water). 

Pack-Ice Zone 

The pack-ice zone lies seaward of the stamukhi zone and includes: (1) first-year ice; (2) multiyear 

floes, ridges, and floebergs; and (3) ice islands. 

During the winter, the pack ice in the northern part of the Chukchi Sea Planning Area generally 

moves in a westerly direction. Pack ice in the southern part of the Planning Area is usually 

transported to the north or northwest. 

Sea ice thicker than 5 m is common in the Arctic Ocean pack ice. 

Chukchi Sea Open-Water System 

A large polynya (or a series of polynyas) develops between the landfast- and pack-ice zones 

extending the length of the Chukchi coast from Point Hope to Barrow during the winter and spring 

(Stringer and Groves, 1991). Polynyas preferentially occur along coasts with offshore winds, as is 

frequently the case in the eastern Chukchi Sea between Point Hope and Barrow during winter. 

During May and June, the average width of the open-water system is about 4 km at the northern end 

(toward Barrow) but widens to about 100 km at the southern end (toward Point Hope). September is 

the period of maximum open water; the freezeback process begins in October. General locations for 

polynyas in this region are illustrated in the Sale 193 FEIS (Figure III.A-14). 

Ice Gouging 

At depths shallower than 60 m, linear depressions have been gouged into the seafloor by the keels of 

drifting ice masses. Between Point Barrow and Icy Cape, the maximum observed gouge-incision 

depth generally increases slightly from 2.4 m at 12 m of water depth to 2.8 m at 24 m of water depth. 

Below 28–30 m, the gouge-incision depth decreases with increasing depth, possibly a reflection of the 

thin sediment cover. Contemporary ice gouging may be occurring in water at least 43 m deep. In the 

central part of the Sale 193 area, ice gouges were observed cutting across sand-ripple fields that may 

be active under present-day current regimes. 

The BOEMRE has collated available ice-gouge and strudel-scour data from site-specific exploration 

and development surveys in the Beaufort Sea and is just beginning this effort in the Chukchi Sea. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER III. Description of the Environment 45

Required site-specific surveys in support of proposed drilling or production activities in the Chukchi 

Sea will provide information on ice gouging in the local area before decisions are made on specific 

proposed activities, and will be added to the collated data base. 

New information for SEIS analysis 

Satellite data have shown that Arctic March sea-ice extent has decreased by about 2.7% per decade 

during the period 1979 through 2010 (Perovich et al., 2010). This decreasing trend is observed in all 

seasons, but the greatest decrease is found in September with a trend of -11.5% per decade (NSIDC, 

2010a). The 2010 minimum was the third lowest year for ice extent following 2008 and 2007 

(NSIDC, 2010b). In September 2007, Arctic sea-ice extent reached its lowest value since satellite 

measurements began in 1979, and was 23% lower than the previous record established in 2005 

(NSIDC, 2007). The causes of the decline in sea ice are thought to be attributed to many variables, 

including a rise in air temperatures, changes in radiative fluxes from increases in greenhouse gases, 

and changes in atomospheric circulation and warming ocean temperatures (Overland and Wang, 

2010; Woodgate, Weingartner, and Lindsay, 2010). 

Sea-ice extent predictions, using several climate models and taking the mean of all the models, 

estimate that the Arctic will be ice free during summer in the later part of the 21st century (IPCC, 

2007). There is considerable uncertainty in the estimates of summer sea ice in these climate models, 

with some predicting 40–60% summer ice loss by the middle of the 21st century (Holland, 2006). 

Using a suite of models, a 40% loss is estimated for the Beaufort and Chukchi seas (Overland and 

Wang, 2007). Some investigators, citing the current rate of decline of the summer sea ice extent, 

believe it may be sooner than predicted by the models and may be as soon as 2013 (Stroeve et al., 

2008). Other investigators suggest that variability at the local and regional level is very important for 

making estimates of future changes. Generally, it is thought that the Arctic will become ice free in 

the summer, but at this time there is considerable uncertainty about when that will happen (Stroeve et 

al., 2011, Tietsche et al., 2011, Zhang, Steele and Schwiger 2010, Overland and Wang, 2010). 

The BOEMRE sponsored a workshop held in McLean, VA from March 29-31, 2011 titled Evaluation 

of the Use of Hindcast Model Data for Oil Spill Risk Analysis (OSRA) in a Period of Rapidly 

Changing Conditions. The BOEMRE convened climate and ocean modelers and a scientific review 

board tasked with providing BOEMRE with recommendations on this topic. Once the report is 

finalized these recommendations will be considered and evaluated for use in BOEMRE science and 

policy in future NEPA documents. 

III.A.5. Water Quality 

Water quality describes the chemical, physical, and biological characteristics of water, usually in 

respect to its suitability for a particular purpose. Important water column properties include 

temperature, salinity, and density. 

Due to very limited development in its watersheds, the U.S. Chukchi Sea experiences little nonpoint 

source pollution runoff. Industrial impacts are minimal and potential degradation of the Arctic OCS 

water quality is confined almost exclusively to external inputs, such as nearshore discharges of treated 

wastewaters into coastal communities and the long-range transport of various global contaminants. 

Marine water quality conforms to the U.S. Environmental Protection Agency (USEPA) criteria for the 

protection of marine life. Water quality in the nearshore Arctic Ocean (landward of the 40-m waterdepth line) may be slightly affected locally by both anthropogenic and natural sources. Most 

detectable pollutants occur at very low levels in Arctic waters and/or sediments and do not pose an 

ecological risk to marine organisms (USDOI, MMS, 2003b). 

Local water quality is largely related to seasonal biological activity and naturally occurring processes, 

such as water-column stratification due to temperature differentials, seasonal plankton blooms 

(primarily in spring and fall), naturally occurring oil/hydrocarbon seeps, seasonal changes in water 
BOEMRE Sale 193 Revised Draft SEIS 

46 CHAPTER III. Description of the Environment 

turbidity due to terrestrial runoff, formation of surface water ice, and natural erosion of organic 

material along the shorelines. The main rivers that flow into the Arctic marine environment remain 

relatively unpolluted by human activities. 

New information for SEIS analysis 

No new information regarding water quality has been introduced in this supplement. 

III.A.6. Air Quality 

The USEPA uses six “criteria pollutants” as indicators of air quality and has established for each of 

them a maximum concentration above which adverse effects on human health may occur. These 

threshold concentrations are called National Ambient Air Quality Standards (NAAQS). 

The air quality of the Chukchi Sea area is well within the NAAQS and State of Alaska ambient air 

quality standards (18 AAC 50). The area is relatively pristine; there are few nearby industrial 

emission sources and no substantial population centers. Because concentrations of criteria pollutants 

are far less than federal and state standards, the Chukchi area is classified as an attainment area under 

the Clean Air Act. 

New information for SEIS analysis 

No new information regarding air quality has been introduced in this supplement. 

III.A.7. Acoustic Environment 

Ambient sound levels in the Chukchi Sea can vary dramatically between and within seasons as a 

result of the following: (1) variability in components of environmental conditions such as sea ice, 

temperature, wind, and snow; (2) the presence of marine life; (3) the presence of industrial shipping, 

research activities, and subsistence activities; and (4) other miscellaneous factors. Ambient sound 

levels can affect whether a specific sound is detectable by a receiver, including a living receiver. 

Burgess and Greene (1999) measured ambient sound in the Beaufort Sea in September to be 

approximately 63 to 133 dB re 1 μPa. 

In the Chukchi Sea, natural sources of marine sound include wind stirring the surface of the ocean, 

lightning strikes, animal vocalizations and noises (including whale calls, echolocation clicks, and 

snapping shrimp), subsea earthquakes, and ice movements. At least seasonally, animals can also 

contribute significantly to the background sound in the acoustic environment of the Chukchi Sea. 

Human sources of sound in the marine environment include vessels (motor boats used for subsistence 

and local transportation, commercial shipping, research vessels, etc.); navigation and scientific 

research equipment; airplanes and helicopters; human settlements; military activities; and marine 

development. 

New information for SEIS analysis 

No new information regarding the acoustic environment has been introduced in this supplement. 

III.B. Biological Environment 

III.B.1. Lower Trophic Level Organisms 

The Chukchi Sea is generally thought of as having the highest benthic faunal mass of all the Arctic 

shelves (Grebmeier and Dunton, 2000; Dunton et al., 2005). This biomass is relatively high in the 

northeastern Chukchi Sea when compared to the central and western Chukchi Sea (Grebmeier and 

Dunton, 2000). Grebmeier and Dunton (2000) explain this richness is due in part to nutrient 

availability from large amounts of organic matter sinking to the seafloor in these areas. A review 

paper by Grebmeier, et al. (2006), synthesizing some 20 years of data from interdisciplinary 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER III. Description of the Environment 47

oceanographic cruises, found there are areas of high benthic biomass and abundance in the south 

central and northeastern Chukchi Sea. Primary productivity in the Chukchi Sea is higher near the 

Bering Strait, along the Russian Chukotka coast, around Point Hope and Cape Lisburne, and along 

the Alaskan coast, including Ledyard Bay. Primary productivity is probably high within the Sale 193 

area during the early summer retreat of the ice edge. During midsummer, primary productivity 

generally is low and relatively uniform within the Sale 193 area. Several kelp communities present in 

the Chukchi Sea are located only inshore of the Sale 193 area; their spatial extent is probably limited 

by the presence of rock and other hard substrate. 

New information for SEIS analysis 

The Sale 193 FEIS explains why the oil exploration, development and production scenario could only 

cause localized and insignificant impacts to lower trophic level organisms. Section IV.B.3 of the 

present document concludes that any impacts to these resources from the natural gas development and 

production scenario would likewise be localized and temporary. In contrast, a VLOS could impact 

lower trophic communities and organisms on a much broader scale. To better understanding the 

potential impacts to lower trophic level organisms from a VLOS, it is useful to elaborate on the 

existing background discussion of the Sale 193 FEIS. Additional detail regarding lower trophic level 

organisms in the Chukchi Sea is therefore provided here. 

The term lower trophic organism refers to numerous species, and includes those animals, plants, 

algae, and bacteria that constitute the primary and sometimes secondary trophic levels of the 

ecological communities found within the affected environments described in this SEIS. Communities 

may have one or more trophic levels, with each level consisting of one or more species existing by 

consuming a species or group of species in the trophic level beneath it (Levinton, 1982). The 

exception to this rule is the primary production or primary trophic level, consisting of organisms that 

fix carbon through photosynthesis or chemosynthesis. There are three separate communities, or 

groups of organisms, that coexist in similar niches within the described environments that are of 

special concern to this analysis: pelagic communities, benthic communities, and epontic 

communities. The pelagic community comprises two loosely defined groups that make up the 

organisms living in the open water, those living at or near the surface (sometimes referred to as the 

neuston), and those living within the pelagic realms of the water column. The benthic community 

consists of both the epifauna (those living just above but still strongly associated with the benthos) 

and the infauna (those living within the sedimentary layers of the benthic surface). The epontic 

community consists of lower trophic those organisms living on and in the sea ice. 

Pelagic Communities 

The neuston make up the planktonic assemblages, consisting primarily (by numbers of individuals) of 

phytoplankton, with the remainder consisting mostly of metazoan animals living within the 

planktonic mass and collectively known as the zooplankton (Levinton, 1982). Each spring and 

summer, the Chukchi Sea typically experiences a short but intense phytoplankton bloom that is 

temporally controlled by sea ice cover, nutrient availability, and river runoff. Phytoplankton 

populations making up those blooms in the Chukchi Sea are representative of a complex ecosystem 

where distinct water masses of Pacific Ocean origin come together. These contributions consist of 

north Pacific current waters pushing northeastward and influencing Alaska coastal, Bering shelf, and 

Anadyr waters, each with their own unique assemblages of phytoplankton and nutrients, that are 

moved into the Chukchi Sea by the processes of advection (Hopcroft, Kosobokova, and Pinchuk, 

2010, as stated in Hopcroft, Questel, and Clarke-Hopcroft, 2010). Collectively these waters contribute 

an estimated 1.8 million metric tons of phytoplankton that are forced across the Bering Sea and into 

the Chukchi Sea annually (Springer, McCroy, and Turco, 1989). The Chukchi zooplankton fauna is 

also primarily of Pacific origin, particularly during the ice-free months (Hopcroft, Questel, and 

Clarke-Hopcroft, 2010). The diversity and abundance of species, families, and phyla found within the 
BOEMRE Sale 193 Revised Draft SEIS 

48 CHAPTER III. Description of the Environment 

zooplankton of the Chukchi Sea are reflective of the productivity and diversity of the phytoplankton 

and their waters of origin (Dunton, et al., 2005, Grebmeier, et al., 2006). Ichthyoplankton (fish larvae 

living and feeding temporarily within the planktonic mass), such as Arctic cod (Boreogadus saida), 

are commonly found in plankton samples (Norcross, et al., 2010). Meroplankton (animals that spend 

only part of their life cycles within the planktonic masses, typically the larvae of benthic or open 

pelagic animals) are represented by larval stages of diverse organisms including polychaetes, 

cnidarians, and most arthropods known in Arctic waters including opilio crabs, barnacles, copepods, 

mysids, and euphasiids (Brusca and Brusca, 2003). Nauplii larvae of resident copepods (known as 

holoplankton, and living their entire developmental cycle within the planktonic masses) are diverse 

and abundant. Copepods are well represented in planktonic masses of Arctic waters including 

numerous calanoid copepod genera, including the Oithona, Oncaea, Calanus, Microcalanus, and 

Pseudocalanus. Copepods are essential to the food webs of the Arctic, being important prey of 

organisms as diverse as Arctic cod and bowhead whales (Bluhm and Gradinger, 2008). Further down 

in the water column, pelagic communities consist of organisms that are found throughout the 

relatively shallow waters of the region (Hopcroft, Bluhm, and Gradinger, 2008). Within the Chukchi 

Sea and adjoining basin there is considerable diversity of both small and large squid, jelly fish, 

hydromedusae and ctenophores. Abundant populations of larvaceans (free-living urochordates, or 

tunicates), particularly the large (approximately 7 mm) Arctic species Oikopleura vanhoeffeni are 

found throughout the Chukchi Sea (Lane et al. 2008). The biomass of larvaceans may rival that of the 

copepods, particularly at ice-edge collection stations where some of the highest recorded densities for 

Oikopleura vanhoeffeni have been observed. Pteropods, or pelagic molluscs, are often abundant and 

represent an important component of biomass in the region (Hopcroft, Questel, and Clarke-Hopcroft, 

2010). 

Benthic Communities 

Chukchi sea benthic communities are among the most abundant and diverse in Arctic regions due to 

the primary productivity created by phytoplankton populations (Grebmeier, 2006). As the spring and 

summer plankton blooms recede and the release of carbon from ice melt and subsequent release of 

material from epontic communities occur, the passive downward drift of nutrients fuels the benthic 

communities (Dunton, et al., 2006; Quijon, Kelly, and Snelgrove, 2008). The south-central Chukchi 

Sea has the highest algal and faunal biomass on the combined Bering Sea shelf and southern Chukchi 

Sea (Grebmeier 1993; Feder et al., 2007). Kelp beds (communities dominated by the large kelp 

Laminaria solidungula) occur in at least two areas along the coast. One first described by Mohr, 

Wilimovsky, and Dawson (1957) and confirmed by Phillips et al. (1982) is located about 20 km 

northeast of Peard Bay near Skull Cliff. Another was reported by Phillips and Reiss (1985) 

approximately 25 km southwest of Wainwright. The known kelp beds are located relatively close to 

the coast in Alaska state waters. These unique biological communities consist of bottom substrates 

dominated by cobblestone or rock that exhibit highly diverse epifaunal communities of isopod, 

copepod, amphipod, shrimp, and molluscs. The Ledyard Bay Critical Habitat Area is south of these 

areas (see Figure 1 and the marine and coastal bird section of this document for a description of this 

habitat). A benthic ecology study by Blanchard, Nichols, and Parris (2010) involved the sampling of 

benthic communities at the Burger and Klondike drill sites. Benthic fauna in both exploration sites 

were abundant and diverse, and unique in their respective compositions. They found the two sites 

exhibited differences in substrate composition, water depth, and both infaunal and epifaunal 

community compositions. Starting at the southeast corner of Klondike and moving into the northwest 

corner of Burger, abundance and diversity of benthic communities, percentage of mud in the 

substrate, and water depth all increase. Infaunal biota were more diverse and abundant than epifaunal 

communities. Representatives from 383 taxonomic categories of infauna and 19 genera of epifauna 

were identified. Polychaetes and burrowing or tube-dwelling amphipods dominated the infaunal 

communities: 48% were polychaete worms, 30% were crustaceans (mostly amphipods and 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER III. Description of the Environment 49

cumaceans), and 19% were molluscs (clams and snails). Epifaunal communities were dominated by 

brittle and sea stars, and also included sea cucumbers, snails, tunicates, barnacles, and crabs. 

Epontic Communities 

Sea ice is an essential driver of the ecosystems in the Chukchi Sea (Gradinger, 2008). Epontic 

communities inhabit a three-dimensional network of brine channels between the ice crystals in fast 

and pack ice, or the undersurface, hard bottom substrate of the ice-water interface (Horner 1985). The 

spatial and temporal variability of biological sea ice parameters occurs on various scales which are 

directly linked to environmental variables, in particular light availability and nutrient supply, which in 

turn is influenced by snow cover, ice morphology and microstructure, and sediment incorporation 

(Junge et al., 2004, Gradinger 2008). Lee, et al. (2003) found ice algae contributed 74% of under-ice 

pelagic productivity during winter months of no photosynthetically active radiation, performing a 

sustaining capacity in the environment enabling survival of pelagic and benthic communities. Epontic 

communities are often highly diverse and consist of numerous crustaceans (dominated by amphipods 

and euphasiids), larval polychaetes, and nematodes. Gammaridean amphipods may exist at numbers 

of >1000/m2. They are the dominant macrofaunal taxon in the Arctic under-ice habitat and the best 

studied consumers of ice algal production in the Arctic (Gradinger and Bluhm, 2004). The organic 

matter produced within the sea ice serves as the base for the ice-associated food web including 

protozoans and metazoans, which are represented by ciliates, rotifers, copepods, copepod nauplii, 

nematodes, turbellarians, and, in the case of offshore fast ice, larvae of benthic polychaetes and 

gastropods (Horner 1985). Meiofauna abundances decrease as one moves from the nearshore ice (up 

to 350,000 animals/m2) to the deep-sea basin by about three orders of magnitude (Gradinger and 

Bluhm, 2005; Gradinger et al., 2005). Although a variety of ice meiofauna and metazoan larvae 

consume ice algae, only a fraction (>10%) of the ice algal production is consumed by them 

(Gradinger et al., 2005). The remainder provides nutrients to the under ice environment in the form of 

sinking carbon. 

III.B.2. Fish Resources 

The Alaskan Chukchi and western Beaufort seas support at least 98 fish species representing 23 

families (Mecklenburg, Mecklenburg, and Thorsteinson, 2002; Fautin, et al., 2010). The primary 

assemblages of Arctic fishes are defined as (1) freshwater fishes, (2) marine fishes, and (3) 

diadromous fishes. These assemblages can be further defined at a secondary assemblage level: (a) the 

neritic-demersal assemblage, (b) the neritic-pelagic assemblage, (c) the cryopelagic fish assemblage, 

(d) the oceanic-pelagic assemblage, (e) the oceanic-demersal assemblage, and (f) the diadromous 

assemblage. 

Neritic-demersal Assemblage 

The neritic-demersal assemblage is comprised of marine fishes living at or near the seafloor of the 

continental shelf and capable of active swimming. Species of this assemblage that are attributed as 

being widespread or abundant include the fourhorn sculpin, twohorn sculpin, polar eelpout, and 

Arctic flounder. 

Neritic-pelagic Assemblage 

The neritic-pelagic assemblage is comprised of fishes inhabiting the water column over the 

continental shelf. Species of this assemblage regarded as widespread or abundant include the Pacific 

herring, Arctic cod, capelin, and Pacific sand lance. 

Cryopelagic Assemblage 

The cryopelagic fish assemblage describes fishes actively swimming in neritic or oceanic waters but, 

during their life cycle, are associated with drifting or fast ice. The Arctic cod is abundant in the 

region and their enormous autumn-winter pre-spawning swarms are well known. The species is also 
BOEMRE Sale 193 Revised Draft SEIS 

50 CHAPTER III. Description of the Environment 

widely distributed and they make distant migrations, not only along the shelf areas in the Arctic Basin 

but also in higher latitudes. In addition to the Arctic cod, other cryopelagic fishes of the Alaskan 

Arctic region include polar cod, toothed cod, and Pacific sand lance. 

Oceanic-pelagic Assemblage 

The oceanic-pelagic assemblage of fishes inhabits the water column of oceanic waters seaward of the 

200-m isobath; most species exhibit some preference for bathymetric stratification. Those species 

chiefly occurring within the upper 200 m of the water column are regarded as epipelagic fishes. 

Several of the epipelagic species include the Pacific herring, Arctic cod, polar cod, and Pacific sand 

lance. 

Oceanic-demersal Assemblage 

The oceanic-demersal assemblage includes fishes living on or close to ocean-bottom substrates. The 

ogac, ribbed sculpin, spatulate sculpin, shorthorn sculpin, spinyhook sculpin, archer eelpout, pale 

eelpout, and daubed shanny are included in this assemblage. 

Diadromous Assemblage 

The diadromous assemblage fishes move between fresh, brackish, and/or marine waters. The term 

diadromous incorporates all migration types between marine and fresh waters, including single 

lifetime events, repetitive multiyear events, spawning migrations, feeding migrations, and seasonal 

movements between environments. 

Nearshore waters are the prime feeding area for North Slope diadromous fishes (Gallaway and 

Fechhelm, 2000). Diadromous and marine fishes are believed to compete for the same prey resources 

in nearshore waters (Craig, 1984; Fechhelm, Buck, and Link, 2006). 

Of the five species of Pacific salmon (anadromous fishes) present in Alaska, three are present with 

some regularity within the action area: pink, chum, and chinook. The occurrence of pink and chum 

salmon in Arctic waters probably is due to their relative tolerance of cold water temperatures and 

their predominantly marine life cycle (Craig and Halderson, 1986, citing Salonius, 1973). Pink 

salmon are the most abundant salmon species in the Chukchi Sea. There are indications of small runs 

of chinook salmon in the Kugrua River, through Elson Lagoon (George, pers. comm. cited in 

Fechhelm and Griffiths, 2001), and strays have been captured in the Kuk River, near Wainwright 

(Craig and Halderson, 1986). 

New information for SEIS analysis 

Norcross, et al. (2010) established baseline information on demersal fish species and ichthyoplankton 

in the Chukchi Sea in the U.S. and Russian waters during the summer of 2004. Thirty species within 

10 families were collected. Sculpins were the most commonly caught fish. Demersel fish habitat was 

found to be characterized by sediment type, bottom salinity, and bottom temperature. Twenty-five 

species of ichthyoplankton were collected in the study. Ichthyoplankton habitat was characterized by 

water column temperature and salinity. Four fish assemblages were identified based on water mass 

and habitat characteristics: Coastal Fishes, South Central Chukchi Sea Fishes, Western Chukchi Sea 

Fishes, and North Central Chukchi Sea fishes. 

III.B.3. Essential Fish Habitat 

Salmon EFH 

Freshwater Essential Fish Habitat (EFH) for salmon includes all streams, lakes, ponds, wetlands, and 

other water bodies currently or historically accessible to salmon. Marine EFH for the salmon 

includes all estuarine and marine areas used by Pacific salmon of Alaska origin, extending from the 

influence of tidewater and tidally submerged habitats to the limits of the U.S. Exclusive Economic 
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CHAPTER III. Description of the Environment 51

Zone (EEZ). In the deeper waters of the continental slope and ocean basin, salmon occupy the upper 

water column. 

New information for SEIS analysis 

The Northern Pacific Fishery Management Council (NPFMC) Arctic Fishery Management Plan 

(2009) identifies three commercial target species in the U.S. Arctic: Arctic cod, saffron cod, and 

snow crab (opilio crab). The EFH for these three species was designated as Level 1 EFH (least 

available information of 4 levels), where distribution data are available for some or all portions of the 

geographic range of the species. The EFH for the three commercial target species are described as 

follows (NPFMC, 2009): 

Arctic Cod EFH, Adult and Late Juvenile 

The general distribution areas for this life stage are located in pelagic and epipelagic waters from 

nearshore to offshore areas along the entire shelf (0–200 m) and upper slope (200–500 m) throughout 

Arctic waters, and often associated with ice floes which may occur in deeper waters. The NPFMC 

has not determined EFH for eggs, larvae, and early juveniles (NPFMC, 2009). 

Saffron Cod EFH, Adult and Late Juvenile 

The general distribution area for this life stage is located in pelagic and epipelagic waters along the 

coastline, within nearshore bays, under ice along the inner (0–50 m) shelf throughout Arctic waters, 

and wherever there are substrates consisting of sand and gravel. The NPFMC has not determined 

EFH for eggs, larvae, and early juveniles (NPFMC, 2009). 

Opilio Crab EFH, Adult and Late Juvenile 

The general distribution area for this life stage is located in bottom habitats along the inner (0–50 m) 

and middle (50–100 m) shelf in Arctic waters south of Cape Lisburne, wherever there are substrates 

consisting mainly of mud. Essential Fish Habitat for snow crab eggs is inferred from the general 

distribution of egg-bearing female crabs. The NPFMC has not determined EFH for larvae and early 

juveniles (NPFMC, 2009). 

Ecosystem Component Species 

The AFMP describes and maps eight ecosystem component species that “are thought to be, should 

conditions allow, commercially viable.” These ecosystem component species are yellowfin sole, 

Alaska plaice, flathead sole, Bering flounder, starry flounder, capelin, rainbow smelt, and blue king 

crab. Habitat descriptions for these ecosystem component species can be found in the AFMP 

(NPFMC, 2009). 

The Magnuson-Stevens Act (as amended) provides for an ecosystem-based approach to the 

management and protection of fish and fish habitat. Ecosystem component species are a category of 

non-target species that a Fishery Management Council may consider designating in a Fishery 

Management Plan. The intent of designating ecosystem component species is to understand the 

habitat of ecosystem component species, promote ecosystem-based management and provide sound 

conservation and sustainability of fish and fisheries. The policy of designating ecosystem component 

species recognizes the “complex interactions among ecosystem components, and seeks to protect 

important species utilized by other ecosystem component species, potential target species, other 

organisms such as marine mammals and birds, and local residents and communities” (NPFMC, 

2009). 

III.B.4. Threatened and Endangered Species 

This section provides information on species currently listed as Threatened or Endangered under the 

Endangered Species Act (ESA) that may be present in the action area. This group includes several 
BOEMRE Sale 193 Revised Draft SEIS 

52 CHAPTER III. Description of the Environment 

marine mammals, specifically bowhead whale, fin whale, humpback whale, and polar bear. Also 

listed are two species of birds, the spectacled eider and Steller’s eider. Kittlitz’s murrelet, classified 

as a candidate species under the ESA, is also considered here. 

Marine Mammals (Threatened and Endangered) 

Cetaceans 

Three species of cetaceans listed as endangered under the ESA occur within or near the Chukchi Sea 

Planning Area. These species are the bowhead whale, fin whale, and humpback whale. The bowhead 

whale is the most common ESA-listed whale in the Chukchi Sea. No critical habitat for any of these 

species has been designated within the Chukchi Sea. 

The Western Arctic stock of bowheads is the most robust of the bowhead populations; this stock of 

bowheads is increasing, resilient to current levels of mortality and other adverse effects, and may 

have reached the lower limit of the estimate of the population size that existed prior to intensive 

commercial whaling (e.g., Shelden et al., 2001; IWC, 2004a,b; Angliss and Outlaw, 2005; IWC, 

2005a,b).The abundance of the Western Arctic stock in 2001 was estimated by George et al. (2004) to 

be 10,470 and by Zeh and Punt (2004, cited in Angliss and Outlaw, 2005) as 10,545. Bowheads are 

potentially more vulnerable to pollution and experience multiple pollution events in their lifetime 

because they are extremely long lived, slow to mature, slow growing, have low reproductive rates and 

have high survivorship. 

Bowhead whales travel mostly parallel and within 40 miles of the Alaskan coast during spring 

migration (Quakenbush, 2010b). The Chukchi Sea Planning Area is an integral part of the total range 

of BCB seas bowhead whales, and portions of this planning area are primary calving grounds during 

the spring for these whales. 

Quakenbush, et al. (2010a), notes a sample size of 19 satellite tagged whales, with acknowledged sex, 

size class, capture site and time of year bias clearly not representing an ideal representation of the 

population, that all nineteen likely traveled through some portion of the Lease Sale 193 Area. Of 

these, fourteen transmitted sufficient locations to determine how they passed through the lease area 

and five with locations transmitted from within leased blocks. Generally, the probability that 

bowhead whales would use the the lease area during the months examined was low (range from 1% to 

31%) with the highest probability of use in September. The temporal pattern was similar for the 

leased blocks, although the probability of use within those blocks (1% or less) was much lower than 

that for the lease area as a whole. Movements and behavior from this study indicate the greatest 

potential for disturbance from industrial activities is near Pt. Barrow in September and October and in 

the lease area in September. 

Polar Bear 

There are two polar bear stocks recognized in Alaska: the southern Beaufort Sea stock (SBS) and the 

Chukchi/Bering Seas stock (CBS). The SBS ranges from the Baillie Islands, Canada west to Point 

Hope. The CBS ranges from Point Barrow west to the Eastern Siberian Sea. These two populations 

overlap in the western Beaufort Sea and in the eastern Chukchi Sea from Point Hope to Point Barrow, 

centered near Point Lay (Amstrup, 1995; Amstrup et al., 2005). 

The polar bear’s preferred habitat is the annual ice over the continental shelf and inter-island 

archipelagos that encircle the polar basin (Derocher, Lunn, and Stirling, 2004). The coast, barrier 

islands, and shorefast ice edge provide an important corridor for polar bears traveling and feeding 

during fall, winter, and spring months. Late winter and spring leads that form offshore from the 

Chukchi Sea coast provide important feeding habitat for polar bears. Polar bears usually forage in 

areas where there are high concentrations of ringed seals, as these are their primary prey (Stirling and 

McEwan, 1975; Larsen, 1985), although bearded seals, walrus, and beluga whales are also taken 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER III. Description of the Environment 53

(Amstrup and DeMaster, 1988). Polar bears will feed opportunistically on a variety of foods 

including carrion, bird eggs, and vegetation (Smith, 1985; Smith and Hill, 1996; Derocher, Wiig, and 

Bangjord, 2000). 

In northern Alaska, pregnant females enter maternity dens by late November and emerge as late as 

early April. Maternal dens typically are located in snow drifts in coastal areas, stable parts of the 

offshore pack ice, or on landfast ice (Amstrup and Garner, 1994). Most dens of the CBS are thought 

to occur on Wrangel Island. Along the U.S. Chukchi Sea coast, polar bear denning occurs at Cape 

Lisburne; Cape Beaufort; the barrier islands between Point Lay and Peard Bay; the Kukpowruk, Kuk, 

and Sinaruruk rivers; Nokotlek Point; Point Belcher; Skull Cliff; and Wainwright Inlet. 

Polar bears are excellent swimmers and swim while actively hunting, while moving between hunting 

areas, and while moving between sea ice and terrestrial habitats. Swimming is believed to be more 

energetically costly than walking, which helps explain why bears will often abandon the melting sea 

ice in favor of land when ice concentrations drop below 50% (Derocher, Lunn, and Stirling, 2004). 

Polar bear use of coastal areas during the fall open-water period has increased in recent years and is 

projected to continue to increase (Kochnev et al., 2003; Schliebe et al., 2005). 

Marine and Coastal Birds (Threatened and Endangered) 

Threatened and endangered species in the Chukchi Sea Planning Area include the spectacled eider 

(threatened) and Steller’s eider (threatened). These species are known to seasonally occur in the 

Chukchi Sea OCS. The Kittlitz’s murrelet is a candidate species for listing under the ESA. 

Full descriptions of each species are provided in the 2006 BE (USDOI, MMS, 2006a), which is 

hereby incorporated by reference. Summary descriptions are provided below. Full descriptions of 

each species is also provided in the 2009 BE (USDOI, MMS, 2009b) and BO (USDOI, FWS, 2009). 

The documents are on the BOEMRE website http://alaska.boemre.gov/ref/Biological_opinions_ 

evaluations.htm. 

Spectacled Eider 

Spectacled eider was listed as a threatened species under the ESA in May 1993 (58 FR 27474). The 

breeding population on the North Slope currently is the largest breeding population of spectacled 

eiders in North America. The North Slope population in the fall (October) is estimated to be 33,587 

birds (Stehn et al., 2006). Spectacled eider density varies across the Alaskan Arctic Coastal Plain 

(ACP) (Larned, Stehn, and Platte, 2006). 

Spectacled eiders make use of the spring lead system when they migrate from the wintering area. The 

spring lead system includes the Ledyard Bay Critical Habitat Unit and typically has represented the 

only open-water area along their path. 

Spectacled eiders on the North Slope breed across the ACP, east to approximately the Canadian 

border. Once tundra nesting habitats are sufficiently melted to allow nesting (historically around June 

10), most breeding pairs of spectacled eiders leave nearshore coastal areas to begin nesting on the 

ACP—as many as a few thousand pairs might nest on the North Slope. Spectacled eider nesting 

density on the ACP is variable, ranging from 0 to 0.95 nests per square kilometer (Larned, Stehn, and 

Platte, 2006). 

Male spectacled eiders leave the nesting area at the onset of incubation and seek open waters of the 

Chukchi and Beaufort Seas until they move to molting areas in the Chukchi Sea or Russia. Many 

postbreeding male spectacled eiders slowly begin to converge in offshore aggregations in Ledyard 

Bay starting in July and begin an extended molt. While molting they are flightless for several weeks. 

Males that breed on the ACP (but return to molting areas in Russia) still make limited use of Ledyard 

Bay and other coastal areas of the Beaufort or Chukchi seas on their westward migration. 
BOEMRE Sale 193 Revised Draft SEIS 

54 CHAPTER III. Description of the Environment 

Female spectacled eiders begin to move to coastal areas at the end of their nesting effort. Females 

whose nests fail early on go to the coast and may linger in nearshore areas. Female spectacled eiders 

also use Ledyard Bay for flightless molt and are flightless for a period of a few weeks. Spectacled 

eider females with broods are the last to arrive at Ledyard Bay around the end of the first week of 

September. 

The Ledyard Bay area was designated critical habitat for the spectacled eider in 2001 (66 FR 9145). 

The critical habitat area includes the waters of Ledyard Bay within about 74 km (40 nmi) from shore, 

excluding waters <1.85 km (~1 nmi) from shore. Ledyard Bay Critical Habitat Unit (LBCHU) is an 

important molting area for North Slope-breeding spectacled eiders in the summer (males) and fall 

(breeding females). The molt is an energetically demanding period, and eiders are believed to use 

LBCHU for molting because of a combination of environmental conditions, abundance and 

accessibility of prey organisms, and level of disturbance and predation. Using satellite telemetry, 

Petersen, Larned, and Douglas (1999) determined that most spectacled eiders molting at LBCHU 

were between 30 and 40 km (10–21 nmi) offshore. Overall, many spectacled eiders remain in 

LBCHU until forced out by sea ice (typically late October through mid-November). Following the 

molt, spectacled eiders move to their wintering area south of St. Lawrence Island in the Bering Sea. 

Steller’s Eider 

The Alaska breeding population of Steller’s eiders is listed as a threatened species under the ESA. It 

is the least-abundant eider in Alaska, with a discontinuous historic breeding range along the coast 

from the Alaska Peninsula northward to the Beaufort Sea (Cooke, 1906; Rothe and Arthur, 1994; 

USDOI, FWS, 2002c). 

Although Steller’s eiders may occur at greater densities outside Kasegaluk Lagoon, the total numbers 

probably are low given the small numbers that breed on the North Slope. Less than 5% of the 

breeding population nests in Arctic Alaska (Rothe and Arthur, 1994). Over 95% of the Alaskan 

breeding Steller’s eiders occur on the ACP near Barrow (USDOI, FWS 1999, 2002b; Quakenbush et 

al., 2004). The FWS believes the ACP nesting population numbers to be in the hundreds or low 

thousands. Steller’s eiders are paired within flocks when they arrive on the ACP, typically from early 

to mid-June (Quakenbush et al. 2004). They often nest on coastal wetland tundra, but some nest near 

shallow ponds or lakes well inland (Bent 1987, Quakenbush et al. 1995, Solovieva 1997); the greatest 

breeding densities were found near Barrow (Quakenbush et al., 2002), although they do not breed 

every year when present (Suydam, 1997). The calculated average nesting density across the North 

Slope during 2002–2006 was 0.0045 birds/km2

 (USDOI, FWS, 2007). 

Paired male Steller’s eiders depart the North Slope after the nest is initiated in mid- to late June. 

Female eiders and their young-of-the-year typically depart the North Slope from late September to 

early October (Johnson and Herter, 1989). Unlike spectacled eiders, Steller’s eiders do not molt in 

the Chukchi Sea. During molt migration, Alaskan breeding Steller’s eiders stop and rest in areas of 

the Alaska Chukchi Sea, often in nearshore waters (within 2 km or 1 nmi of shore) near Ledyard Bay 

and Icy Cape. There is less use at more northerly locations near Wainwright and Peard Bay. More 

males than females migrate from Alaska to areas along the coast of Chukotka, while males that do not 

go to Chukotka spend more time on the Alaska Chukchi Sea coast. 

Kittlitz’s Murrelet 

Kittlitz’s Murrelet is listed as a candidate species (Listing Priority Number 2) throughout Alaska 

under the ESA. This species may nest as far north as Cape Beaufort (100 km northeast of Cape 

Lisburne) in the Amatusuk Hills. Observations of breeding Kittlitz’s murrelets are sparse along the 

Alaskan Chukchi coast. Thompson, Hines, and Williamson (1966) observed a nest several miles 

inland on the Lisburne Peninsula northeast of Cape Thompson near Angmakrok Mountain. Breeding 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER III. Description of the Environment 55

farther north is unlikely due to lack of suitable habitat (Day, Kuletz, and Nigro, 1999). These birds 

are solitary nesters and extensive survey efforts are required to determine local abundance. 

Murrelet foraging areas may occur in or near the Chukchi Sea Planning Area. Kittlitz’s murrelets 

have been observed on a regular basis in the Chukchi Sea as far north and east as Point Barrow 

(Bailey, 1948) and could occur in the Beaufort Sea (USDOI, FWS, 2006a). Regular observations of 

Kittlitz’s murrelets at sea were noted in late summer and early fall by Divoky (1987), but they have 

not been subsequently observed by others on similar cruises in the Chukchi Sea. This suggests that 

there is a great deal of annual variation in their occurrence in the Chukchi Sea. 

New information for SEIS analysis 

Changes in status under the ESA for the yellow-billed loon, Pacific walrus, four subspecies of ringed 

seals, and two distinct population segments of bearded seals are addressed under the “New 

Information for SEIS Analysis” headings of Section III.B.5 Marine and Coastal Birds and Section 

III.B.6 Other Marine Mammals. 

Analysts’ review identified no new information regarding threatened and endangered marine and 

coastal birds that would change the analysis or alter the conclusions discussed under environmental 

consequences in Chapter IV. 

The following new information regarding threatened and endangered species is incorporated. 

Bowhead Whale 

In recent years, several notable studies on bowhead whales, their abundance, and their use of the 

Chukchi Sea have become available. The size of the Western Arctic, or Bering-Chukchi-Beaufort 

(BCB), population appears to remain robust. Koski et al. (2008) provide a preliminary estimate of 

11,836 (CV+0.29 and at 95% Confidence Interval 6,795-20,618) for the 2002-2003 population using 

photo-identification data. Koski et al. (2010) investigated several models using aerial photoidentification data, but the most precise estimate was the result of a simple model with no covariates. 

Abundance of the BCB bowhead population in 2004 (excluding calves) was estimated to be 12,631 

(CV+0.2442), 95% bootstrap confidence interval (7,900: 19,700) and 5% lower limit of 8,400. All 

abundance estimates computed from photographic data were consistent with expectations based on 

independent abundance and trend estimates from the ice-based surveys from 1978 to 2001. There is 

also more confidence that bowheads utilizing the action area are of one stock. Collective results of 

three decades of research have established that while the BCB population is out of genetic 

equilibrium, there is no compelling evidence of a multi-stock condition within its range, nor any 

compelling evidence of conservation risk under the current single-stock management regime (George 

et al., 2007, Taylor et al., 2007, and IWC, 2008. Rugh, et al. (2008) further indicate through spring 

migration re-identification of individual whales a wide mixing and near-random distribution of resighting dates throughout the spring migration that is indicative of a single stock of whales that have a 

somewhat plastic schedule. 

A study analyzing the eastern portion of the Chukchi Sea and the western Beaufort Sea northeast of 

Barrow (Ashjian et al. 2010) identified climate and oceanographic mechanisms, supported by 

traditional knowledge, that form recurrent aggregations of zooplankton and subsequently fall 

bowhead whale feeding concentrations. Similar studies have been proposed for the Chukchi Sea. 

Moore, et al. (2010), and Moore, Stafford and Munger (2010) note studies that further support late 

summer and fall feeding concentrations of bowhead whales in that area as per acoustic surveys and 

visual surveys. Okkenon et al. (2009) provides additional acoustic Doppler current profiler data that 

infer upwelling and zooplankton aggregation in the western Beaufort shelf in this same area. 

Meanwhile, recent passive acoustic surveys (Delarue et al. 2009) and satellite telemetry studies 

(Quakenbush et al. 2010a, Quakenbush et al. 2010b) provide additional data defining spring and late 

fall-early winter migration routes. Quakenbush (2010a) and ADFG et al. (July, 2010) indicate that all 
BOEMRE Sale 193 Revised Draft SEIS 

56 CHAPTER III. Description of the Environment 

the satellite tagged whales travelled through the Lease Seal 193 area, most taking less than one week 

to transit through. These studies generally confirm BOEMRE’s understanding about bowhead whale 

migratory habits—that bowhead whales transit through the Lease Sale 193 area during their migration 

from Barrow to the Bering Sea, but that corridors are poorly defined and highly subject to interannual variability. The population of bowhead whales that seasonally occupies the Chukchi Sea is 

the subject of a regulated subsistence harvest by Alaska and Russian Natives. A harvest report is 

submitted to the International Whaling Commission annually (Suydam, et al. 2006, Suydam et al., 

2007, 2008, and 2009). 

During mid-March to approximately mid-June, bowheads migrate through leads on their way to their 

primary summer feeding grounds in the Canadian Beaufort Sea, although Quakenbush (2010b) has 

noted the following: 

...even though the Beaufort Sea has virtually 100% ice cover when bowheads migrate through in the 

spring, ice does not seem to limit the movement of tagged whales between Barrow and Amundsen 

Gulf. There must be enough openings and thin ice to allow whales to travel straight from Barrow to 

Amundsen Gulf without lingering and waiting for leads to open. Likewise, sea ice within the Bering 

Sea does not seem to limit movements of tagged whales. 

Quakenbush (2010b) goes on, however, to suggest that land-fast ice does seem to limit the 

distribution of bowhead whales, and provides the following example: 

“...in the spring of 2009, six bowheads migrated to Amundsen Gulf, which was filled with land-fast 

ice. The whales remained at the ice edge of the gulf cleared of land-fast ice...” 

In many years, large numbers of bowheads have been observed feeding in the western Beaufort Sea 

(Quakenbush, 2010a). In some years, the northeastern Chukchi Sea is a foraging area for bowheads. 

Clark and Ferguson (2010) note in 2009, a light ice year, bowhead whales were observed feeding 

from 30 June to 11 July near Pt. Franklin, and at least one easily identified whale was present during 

this thirteen day period. Ice cover at this time ranged from 5% to 80%. A group of at least 12 

bowheads was also observed feeding southwest of Pt. Barrow on 19 September 2009 when no ice was 

present. 

Bowhead whales travel mostly parallel and within 40 miles of the Alaskan coast during spring 

migration (Quakenbush, 2010b). The Chukchi Sea Planning Area is an integral part of the total range 

of BCB seas bowhead whales, and portions of this planning area are primary calving grounds during 

the spring for these whales. 

Quakenbush, et al. (2010a), notes a sample size of 19 satellite tagged whales, with acknowledged sex, 

size class, capture site and time of year bias clearly not representing an ideal representation of the 

population, that all nineteen likely traveled through some portion of the Lease Sale 193 Area. Of 

these, fourteen transmitted sufficient locations to determine how they passed through the lease area 

and five with locations transmitted from within leased blocks. Generally, the probability that 

bowhead whales would use the the lease area during the months examined was low (range from 1% to 

31%) with the highest probability of use in September. The temporal pattern was similar for the 

leased blocks, although the probability of use within those blocks (1% or less) was much lower than 

that for the lease area as a whole. Movements and behavior from this study indicate the greatest 

potential for disturbance from industrial activities is near Pt. Barrow in September and October and in 

the lease area in September. Bowhead whales travel mostly parallel and within 40 miles of the 

Alaskan coast during spring migration (Quakenbush, 2010b). The Chukchi Sea Planning Area is an 

integral part of the total range of BCB seas bowhead whales, and portions of this planning area are 

primary calving grounds during the spring for these whales. 
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CHAPTER III. Description of the Environment 57

Fin and Humpback Whales 

During 2006–2009 open-water seasons, marine mammal observer (MMO)-monitoring associated 

with seismic surveys, barging, and marine research in the Chukchi Sea documented sightings of fin 

whales and humpback whales. 

In the 2008 BO (NMFS, 2008), NMFS found that “there is no indication that fin whales typically 

occur within the Chukchi Sea or Beaufort Sea Planning Areas or in areas directly adjacent. Fin whales 

are uncommon to the eastern Chukchi Sea and the Chukchi OCS Planning Area in which lease sales 

are held.” 

The 2008 BO by NMFS states that for the purpose of analysis, humpbacks are assumed to occur 

seasonally just south of the Bering Straight, and that these whales are the source of those observed in 

the U.S. Beaufort and Chukchi Seas in 2006-2009. The 2006-2009 sightings confirmed humpback 

use of the western Beaufort Sea and Chukchi Sea Planning Areas, and adjacent areas in the southeast 

Chukchi Sea. The humpback whales recently sighted in the Chukchi Sea and Beaufort Sea most 

likely belong to the Western North Pacific Stock. The humpback whale’s known summer feeding 

habitats include the southern portion, especially the southwestern portion, of the Chukchi Sea. 

This new information resulted in reinitiation of ESA consultation with NMFS for OCS activities in 

the Chukchi Sea and Beaufort Sea Planning Areas. The 2008 Biological Evaluation (USDOI, MMS, 

2008b) and the 2008 Biological Opinion (NMFS, 2008) provide additional information on these 

sightings. These documents are on the BOEMRE website http://alaska.boemre.gov/ref/ 

Biological_opinions_evaluations.htm. 

Polar Bear 

On May 15, 2008, FWS listed the polar bear as threatened throughout its range (73 FR 28212). The 

FWS concurrently published an Interim Final 4(d) Rule, which provides guidance on the 

implementation of the ESA. This special rule adopts the existing conservation regulatory 

requirements in place under the Marine Mammal Protection Act of 1972 as amended (MMPA) and 

the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) as 

the appropriate regulatory provisions for this threatened species. 

The most recent estimate of the Chukchi / Bering Seas (CBS) population of polar bears suggests a 

minimum of 2000 bears (74 FR 69139 [July 1, 2009]). However this figure is based on older den 

survey data from Wrangel Island, rather than range-wide mark/ recapture or other population survey 

methods. The most recent estimate for the Southern Beaufort Sea population of polar bears is a 

minimum of 1397 bears (74 FR 69139 [July 1, 2009]). The polar bear was listed as a threatened 

throughout its range largely due to the continuing loss of sea ice habitat caused by climate change (73 

FR 28212 [May 15, 2008]). With a small population of a species that has low reproductive rates, any 

loss of large numbers of polar bears (especially adult females) or prey species would exacerbate that 

decline. The USGS has predicted that without changes in the rate of sea ice loss, the polar bear will be 

extirpated from Alaska (Durner et al, 2007). Recovery of the CBS and SBS stocks in Alaska would 

not occur unless the population begins to rebound from other factors limiting population productivity 

and growth. 

The BOEMRE reinitiated ESA Section 7 consultation with FWS in 2009. This consultation 

addressed the new information on listing the polar bear as threatened, and updated information on 

ESA listed species, potential effects, and the Arctic environment. In July 2009, BOEMRE provided 

an updated Biological Evaluation to FWS for consultation on the polar bear (in addition to Steller’s 

eider, spectacled eider, Kittlitz’s murrelet, yellow-billed loon). The FWS provided their Biological 

Opinion to BOEMRE on September 3, 2009 (USDOI, FWS, 2009). 
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58 CHAPTER III. Description of the Environment 

On October 29, 2009, FWS published a proposed rule in the Federal Register identifying proposed 

Critical Habitat for the Polar Bear (74 FR 56058). On December 7, 2010, FWS published the final 

rule designating Critical Habitat in the Federal Register (75 FR 76086). The final rule identifies 

geographic areas containing features considered essential for the conservation of the polar bear. The 

FWS has identified three areas or units as Critical Habitat that require special management or 

protection: barrier island habitat, sea ice habitat and terrestrial denning habitat. In the Chukchi Sea, 

Critical Habitat for the polar bear includes all barrier islands along the coast and sea ice out to the 

300m (984 ft) depth extending to the outer limits of the U.S. Exclusive Economic Zone (75 FR

76121). 

Potential impacts to polar bears and their Critical Habitat are analyzed in the “Threatened and 

Endangered Marine Mammals” section of Chapter IV. 

III.B.5. Marine and Coastal Birds 

Most birds occurring in the Chukchi Sea area are present on a seasonal basis. During spring 

migration, arrival times at coastal breeding areas usually coincide with the formation of leads. Many 

seabirds (such as murres) and sea ducks (such as common eiders and long-tailed ducks) will closely 

follow leads that typically form along the edge of the landfast ice. Migration times vary between 

species, but spring migration for most species takes place between late March and late May. Many 

birds that breed on the North Slope must migrate through the Sale 193 area twice each year. 

Departure times from the Beaufort and Chukchi seas during postbreeding or fall migration vary 

between species and often by sex within the same species, but most marine birds will have moved out 

of the Chukchi Sea by late fall before the formation of sea ice. The following sections summarize 

movement patterns, locations, and life history characteristics for several key avian groups. 

Cliff-Nesting Seabirds 

Common murres and thick-billed murres 

Common murres and thick-billed murres breed as far north as Cape Lisburne and farther south at 

Cape Thompson. If the colony is reduced in size below a certain threshold, the colony is abandoned 

and can remain so for decades. Murres are primarily piscivorous and rely on dispersed schools of 

offshore fish. Based on limited data, murre foraging areas overlap with the area considered in the 

proposed sale (Sale 193 FEIS, Fig. III.B-7). Also, as a result of molting and foraging in late summer 

and fall, flightless males and young are vulnerable to disturbances and spills. Flightless individuals 

are not capable of undertaking large scale movements to other areas. 

Horned puffin and tufted puffin 

The horned puffin and the tufted puffin are found in the Chukchi Sea area, where they breed in 

colonies. Sowls, Hatch, and Lensink (1978) reported the horned puffin was the most abundant puffin 

species in the Chukchi Sea with breeding colonies at Cape Lisburne and Cape Thompson. They can 

breed on suitable beach habitat on islands nearshore by digging burrows or hiding under large pieces 

of driftwood or debris. Horned puffins are primarily piscivorous and rely on dispersed schools of 

offshore fish. In other areas of Alaska, breeding colonies of horned puffins have been reported to 

forage in excess of 100 km offshore (Hatch et al., 2000). 

Black-legged kittiwake 

Breeding colonies of the black-legged kittiwake in the Chukchi Sea (Cape Thompson and Cape 

Lisburne) are at the northern limit of their breeding range in Alaska. Data collected between 1960 

and 1978 reported approximately 48,000 black-legged kittiwakes bred along the Chukchi Sea coast 

between Cape Thompson and vicinity to Cape Lisburne (USDOI, FWS, 2005a). Divoky (1987) 

reported black-legged kittiwakes were abundant from mid-July until late September in the Chukchi 

Sea north of Cape Thompson, where they range far offshore through most of the area considered for 
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CHAPTER III. Description of the Environment 59

the lease sale. Divoky (1987) estimated over 400,000 black-legged kittiwakes in the pelagic Chukchi 

Sea. The portion of this population in the proposed lease sale area is substantial late in the openwater season. 

Bering Sea Breeders and Summer Residents 

Northern fulmar 

The northern fulmar does not breed along the Chukchi Sea coast, and those observed in this area 

during the spring and summer are nonbreeders or failed breeders from southern areas. Divoky (1987) 

estimated 45,000 northern fulmars in pelagic waters of the Chukchi Sea (typically south of Cape 

Lisburne) during late August to mid-September. 

Short-tailed shearwater 

The short-tailed shearwater in the Chukchi Sea are most common in the southern portion, and are 

routinely found in the proposed sale area from late August to late September. At northern latitudes, 

short-tailed shearwaters likely forage on dense patches of euphausiids and amphipods. 

Auklets 

Three species of auklets, (parakeet, least, and crested) breed as far north as the Bering Strait (Sowls, 

Hatch, and Lensink, 1978), but move into the Chukchi Sea, including much of the proposed lease sale 

area, from late August into early October. 

High Arctic-Associated Seabirds 

Black guillemot 

Black guillemot breeding individuals in the Chukchi Sea range from Cape Thompson northward 

(Roseneau and Herter, 1984). Despite the relatively small breeding population in Alaska (the Chukchi 

and Beaufort seas have a combined total of fewer than 2,000 birds), the pelagic population in the 

Chukchi Sea is estimated to be around 70,000 (Divoky, 1987). Black guillemots remain closely 

associated with sea ice throughout their lifetime, where they feed extensively on Arctic cod (Divoky, 

1987). 

Ross’ gull 

Ross’ gulls may be encountered near Point Barrow. Many migrate south through the Chukchi Sea 

and pass through the Bering Strait to winter in the Bering Sea. 

Ivory gull 

The ivory gull is uncommon to rare in pelagic waters of the Chukchi Sea during summer, and small 

numbers migrate through in fall to wintering areas in the northern Bering Sea. Divoky (1987) 

reported that ivory gulls are closely associated with the ice edge throughout their lifecycle. 

Arctic tern 

The Arctic terns are rare in the pelagic waters of the Chukchi Sea (Divoky, 1983). Dau and Larned 

(2005) observed more than 600 Arctic terns between Omalik Lagoon and Point Barrow, with the 

majority located in Kasegaluk Lagoon near the village of Point Lay. 

Tundra-Breeding Migrants 

Jaegers 

The three species of jaegers (pomarine, parasitic, and long-tailed) are common in the Chukchi Sea in 

summer until late September, when they move south to the Bering Sea (Divoky 1987). Jaegers are 

dispersed throughout pelagic areas of the Chukchi Sea, with no obvious high concentration areas. 
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60 CHAPTER III. Description of the Environment 

Glaucous gull 

Glaucous gulls typically occur in low densities in the Chukchi Sea, but commonly congregate at food 

sources (Divoky, 1987). They are most common in the Chukchi Sea from late July to late September 

within 70 km of shore between Icy Cape and Barrow. Most glaucous gulls in the Chukchi Sea area 

breed inland near freshwater, but some breed at coastal seabird colonies (Divoky, 1987; Sowls, 

Hatch, and Lensink, 1978). 

Waterfowl 

Loons 

Pacific loons are the most common loon species migrating along the Chukchi Sea coast, although redthroated and yellow-billed loons are present in fewer numbers. Yellow-billed loons typically nest 

near large, deep, tundra lakes where they nest on low islands or near the edges of lakes to avoid 

terrestrial predators (Johnson and Herter, 1989). Red-throated loons nest on smaller ponds than 

yellow-billed or Pacific loons. In spring, loons typically migrate along coastal routes, although some 

may migrate using inland routes (Johnson and Herter, 1989). Most loons stay very close to shore 

during fall migration until they reach the Lisburne Peninsula, where they head farther out to sea 

towards the Bering Strait (Divoky 1987). Most of the postbreeding loon migration takes place in 

September. Low numbers, patchy distributions, and specific habitat requirement may make yellowbilled loons more susceptible to environmental perturbations such as disturbance, habitat alterations, 

and oil spills than species that are more abundant, widely distributed, and able to exploit a greater 

diversity of habitats (Hunter, 1996). 

Long-tailed duck 

The long-tailed duck is a common species in the Chukchi Sea after the first week of September until 

late October. Typical migration distances offshore for long-tailed ducks, as well as other species, are 

along the 20-m isobath. Many long-tailed ducks molt in Kasegaluk Lagoon and Peard Bay on the 

Chukchi Sea coast (Johnson, Frost, and Lowry, 1992; Kinney, 1985). Molting long-tailed ducks tend 

to stay in or near the lagoons, especially near passes between the lagoon and the sea (Johnson, 

Wiggins, and Wainwright, 1992). Brackney and Platte (1986) observed long-tailed ducks feeding 

heavily in passes between barrier islands (Lysne, Mallek, and Dau, 2004). 

Common eider 

The common eider typically migrates during spring along the Chukchi Sea coast using offshore openwater leads. Common eiders nest on barrier islands or spits along the Chukchi Sea coast (Johnson 

and Herter, 1989). Most common eiders nest on barrier islands or spits along the Chukchi Sea coast 

(Johnson and Herter, 1989). During a 2005 aerial survey conducted in late June to coincide with the 

common eider egg laying and early incubation period, 742 eiders were observed between Omalik 

Lagoon and Point Barrow. Most common eiders were observed in Kasegaluk Lagoon and Peard Bay 

(Dau and Larned, 2005). Beginning in late June, postbreeding male common eiders begin moving 

towards molting areas in the Chukchi Sea; by July and August, most common eiders in the Chukchi 

Sea are molting males. Most breeding female common eiders and their young begin to migrate to 

molt locations in late August and September. Common molt areas in Alaskan waters in the Chukchi 

Sea are near Point Lay, Icy Cape, and Cape Lisburne (Johnson and Herter, 1989). The Peard Bay 

area was particularly important to molting eiders (Kinney, 1985). After the molt is completed, some 

common eiders move offshore into pelagic waters, but most eiders remain close to shore (Divoky, 

1987). 

King eider 

Most king eiders begin to migrate through the Chukchi Sea during spring and arrive in the Beaufort 

Sea by the middle of May (Barry, 1968). The location and timing of offshore leads along the Chukchi 
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CHAPTER III. Description of the Environment 61

Sea is a major factor determining routes and timing of king eider migration (Barry, 1968). Powell et 

al. (2005) reported that Ledyard Bay may be a critical stopover area for foraging and resting during 

spring migration. Many male king eiders move to staging areas along the Chukchi Sea, including 

Ledyard Bay, in mid- to late July (Dickson, Suydam, and Balogh, 2000; Dickson, Balogh, and 

Hanlan, 2001). The Peard Bay area is also particularly important to molting eiders (Kinney, 1985), 

and the typical staging time in Ledyard Bay was reported at 17–24 days (range 1–48 days). Most 

king eiders nest on the North Slope between Icy Cape and the western boundary of the Arctic 

National Wildlife Refuge. 

Brant 

Many brant migrate along the west coast of Alaska en route to breeding areas on the North Slope or 

the Canadian High Arctic. Brant typically nest on offshore spits, barrier islands, or on islands formed 

in large river deltas. In June, black brant have been observed along the Chukchi Sea coast in 

Kasegaluk Lagoon and Peard Bay (Dau and Larned, 2005). Kasegaluk Lagoon also is an important 

stopover location during postbreeding migration. 

Greater white-fronted goose 

The greater white-fronted goose breeds along the coasts of the Bering, Chukchi, and Beaufort seas. 

In northern portions of Alaska, these geese typically breed within 30 km of the coast (King, 1970 

cited in Johnson and Herter, 1989). Most greater white-fronted geese reach Alaska via the Central 

and Pacific Flyways and reach North Slope breeding grounds using overland routes (Johnson and 

Herter, 1989). In 1989–91, Johnson, Wiggins, and Wainwright (1992) observed as many as 4,205 

white-fronted geese during one aerial survey of Kasegaluk Lagoon; the peaks of migration out of 

Kasegaluk lagoon appeared to be in the first week of June and the last week of August. 

Kasegaluk Lagoon supports one of two consistently used nesting colonies for lesser snow geese in the 

United States. 

Tundra swans 

Tundra swans have been observed in Kasegaluk Lagoon with flightless young-of-the-year birds 

indicating that tundra swans breed in Kasegaluk Lagoon (Johnson, Wiggins, and Wainwright, 1992). 

Shorebirds 

Although many shorebirds breed on tundra, they also rely on coastal areas such as beaches, barrier 

islands, lagoons, and mudflats for some portion of their lifecycle. These coastal areas are especially 

important habitats where shorebirds replenish energy reserves after breeding and prior to southward 

migration. The most common shorebird species breeding on the Arctic Coastal Plain include dunlin, 

semipalmated sandpiper, pectoral sandpiper, and red phalarope (Alaska Shorebird Working Group, 

2004). Many shorebirds leaving the Beaufort Sea move west along the Chukchi Sea coast. It appears 

reasonable to assume that large numbers of shorebirds move west along the Chukchi Sea coast, 

stopping at high-productivity sites to replenish energy reserves and rest. 

Phalaropes 

Both red and red-necked phalaropes are present in the Chukchi Sea during the open-water periods. 

Phalaropes are common in pelagic waters as well as within a few meters of shore, where their 

distribution typically is tied to zooplankton abundance. Due to their reliance on zooplankton, their 

distribution is patchy and variable; however, because they are tied to a moving prey source they may 

be encountered throughout the Chukchi Sea in varying concentrations. During aerial surveys 

conducted in Kasegaluk Lagoon from 1989–91, phalaropes were the most numerous shorebirds 

present. Based on ground observations, red phalaropes are considered more common than red-necked 

phalaropes in Peard bay and Kasegaluk Lagoon. Phalaropes are one of the key species groups of 
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62 CHAPTER III. Description of the Environment 

shorebirds that use Kasegaluk Lagoon and Peard Bay, where they stage or stop over in nearshore 

marine and lacustrine waters (Alaska Shorebird Working Group, 2004). 

Dunlin 

Two subspecies of Dunlin breed in Alaska. Dunlins are one of the key species of shorebirds that use 

Kasegaluk Lagoon, where they stage or stop over in silt tidal flats and salt-grass meadows (Alaska 

Shorebird Working Group, 2004). 

Raptors and Ravens 

A variety of raptors and corvids may be present in the coastal zone along the Chukchi Sea coast 

adjacent to the proposed lease sale area. On the North Slope, raptors typically are more common 

within 20 km of the Brooks Range foothills (Johnson and Herter, 1989) and population densities are 

lower near the coast, especially during the breeding season. Snowy owls are the raptor most 

commonly encountered near Kasegaluk Lagoon. 

New information for SEIS analysis 

On March 25, 2009, the yellow-billed loon was recognized as a candidate species (Listing Priority 

Number 8) throughout its range under the ESA (74 FR 12932). 

The BOEMRE reinitiated ESA Section 7 consultation with FWS in 2009. This consultation 

addressed the new information on recognizing the yellow-billed loon as a candidate species and 

updated information on ESA listed species, potential effects, and the Arctic environment. In July 

2009, BOEMRE provided an updated Biological Evaluation to FWS for consultation on Steller’s 

eider, spectacled eider, Kittlitz’s murrelet, yellow-billed loon, and polar bear. The FWS provided 

their Biological Opinion to BOEMRE on September 3, 2009 (USDOI, FWS, 2009). 

III.B.6. Other Marine Mammals 

Eleven species of marine mammals occur in the Chukchi Sea and are not currently listed as 

endangered or threatened under the ESA. 

Pinnipeds 

Five species of pinnipeds are associated with sea ice in Alaskan waters: Pacific walrus and four 

species of phocid seals or ice seals (ringed, spotted, ribbon, bearded). All five species haul out on sea 

ice to rest, give birth, and molt, and they all exhibit seasonal migrations in conjunction with the 

seasonal advance and retreat of ice (Fay, 1974). Ribbon and spotted seals are thought to prefer the 

loose ice of the “ice front,” whereas ringed seals, bearded seals, and walrus are thought to prefer more 

interior pack ice (Fay, 1974; Burns, Shapiro, and Fay, 1981; Simpkins et al., 2003). 

Pacific walrus 

Pacific walrus range throughout the shallow continental shelf waters of the Bering and Chukchi seas, 

where their distribution is closely linked with the seasonal distribution of the pack ice. Walrus are 

migratory, moving south with the advancing ice in autumn, and north as the ice recedes in spring 

(Fay, 1981). During the summer months, the majority of the subadults, females, and calves move into 

the Chukchi Sea, where they tend to concentrate in areas of unconsolidated pack ice within 100 km of 

the leading edge of the pack ice. In contrast, adult males generally abandon the sea ice in spring for 

coastal haulouts in Bristol Bay and the Gulf of Anadyr (Jay and Hills, 2005). By July, large groups of 

up to several thousand walrus can be found along the edge of the pack ice between Icy Cape and 

Point Barrow. Walrus rely on sea ice as a substrate for resting and giving birth (Angliss and Outlaw, 

2005) and generally require ice thicknesses of 50 cm or more to support their weight (Fay, 1982). 

When suitable pack ice is not available, walrus will haul out to rest on land, preferring sites sheltered 

from wind and surf. Traditional haulout sites in the eastern Chukchi Sea include Cape Thompson, 
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CHAPTER III. Description of the Environment 63

Cape Lisburne, Icy Cape, and the barrier islands off of Kasegaluk Lagoon. In low ice years, when the 

pack ice retreats northward of the continental shelf, walrus come ashore to rest and remain near 

foraging areas. For example, in 2010, as many as 10,000-20,000 walrus were hauled out along the 

barrier island northwest of Point Lay (USDOI, FWS, 2010). As the pack ice advances at the end of 

the summer open-water season, large herds begin moving back down to the Bering Sea. 

Walrus generally are found in waters <200 m deep along the pack ice margin where ice 

concentrations are <80% (Fay 1982; Fay and Burns, 1988). The juxtaposition of broken ice over 

relatively shallow continental shelf waters is important to them for resting between feeding bouts, 

particularly for females with dependent young which may not be capable of deep diving or long term 

exposure to the frigid water. The shallow Chukchi Sea and eastern Siberian Sea serve as the main 

feeding grounds for the bulk of the Pacific walrus population in the summer and autumn (Kochnev, 

2004). Walrus specialize in feeding on benthic macroinvertebrates (e.g., clams, snails, shrimp, crabs, 

worms) and prefer to forage in areas <80 m deep (Fay, 1982). 

Ringed Seal 

Ringed seals are year-round residents in the Chukchi and Beaufort seas, and are the most common 

and widespread seal species in the area. In winter and spring, the highest densities of ringed seals are 

found on stable, shorefast ice. Ringed seals seem to prefer icefloes >48 m in diameter and often are 

found in the interior pack ice, where sea-ice concentrations exceed 90% (Simpkins et al. 2003). In 

early summer, the highest densities of ringed seals in the Chukchi Sea are found in nearshore fast and 

pack ice (Bengston et al., 2005). During summer, ringed seals are found dispersed throughout openwater areas, although in some regions they move into coastal areas (Smith, 1987; Harwood and 

Stirling, 1992). In the late summer and early fall, ringed seals often aggregate in open-water areas 

where primary productivity is thought to be high (Harwood and Stirling, 1992). Few, if any, seals 

inhabit ice-covered waters shallower than 3 m due to water freezing to the bottom and/or poor prey 

availability caused by the limited amount of ice-free water (71 FR 9785). In Alaskan waters, the 

primary prey of ringed seals is Arctic cod, saffron cod, shrimp, amphipods, and euphausiids (Kelly, 

1988; Reeves, Stewart, and Leatherwood, 1992). 

Spotted Seal 

Spotted seals are common in the coastal Alaskan waters in ice-free seasons, and they often aggregate 

in onshore coastal haulouts. They migrate south from the Chukchi Sea and into the Bering Sea in 

October-November (Lowry et al., 1998). Adult spotted seal principal foods are schooling fishes, 

although the total array of foods is quite varied. In the Arctic, their diet is similar to that of ringed 

seals, including a variety of fishes such as Arctic and saffron cod, and also shrimp, and euphausiids 

(Kato, 1982; Quakenbush, 1988; Reeves, Stewart, and Leatherwood, 1992). Within their geographic 

range they are known to eat sand lance, sculpins, flatfishes, and cephalopods (mainly octopus). The 

juvenile diet is primarily crustaceans (shrimp). 

Ribbon Seal 

In Alaska, ribbon seals range northward from Bristol Bay in the Bering Sea and into the Chukchi and 

western Beaufort seas. They are found in the open sea, on pack ice, and rarely on shorefast ice (Kelly, 

1988). As the ice recedes in May to mid-July, they move farther north in the Bering Sea, hauling out 

on the receding ice edge and remnant ice (Burns, Shapiro, and Fay, 1981). Recent information 

suggests that many ribbon seals migrate into the Chukchi Sea for the summer months (Kelly, 1988). 

Ribbon seals dive as deep as 200 m in search of food. They eat a variety of different foods, but their 

main prey is fish such as eelpouts, capelin, pricklebacks, Arctic cod, saffron cod, herring, and sand 

lance. Foods other than fishes include cephalopods (primarily squid), shrimp, mysids, and crabs. 
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64 CHAPTER III. Description of the Environment 

Bearded Seal 

In Alaskan waters, bearded seals occur over the continental shelves of the Bering, Chukchi, and 

Beaufort seas (Burns, 1981). Seasonal movements of bearded seals are directly related to the advance 

and retreat of sea ice and to water depth (Kelly, 1988). During winter, most bearded seals in Alaskan 

waters are found in the Bering Sea. During summer, the most favorable bearded seal habitat is found 

in the central and northern Chukchi Sea, where they are found near the widely fragmented margin of 

the pack ice; they also are found in nearshore areas of the central and western Beaufort Sea during 

summer. Bearded seals predominantly are benthic feeders (Burns, 1981), feeding on a variety of 

invertebrates (crabs, shrimp, clams, and snails) and other food organisms, including Arctic and 

saffron cod, flounders, sculpins, and octopuses (Kelly, 1988; Reeves, Stewart, and Leatherwood, 

1992). Bearded seals also feed on ice-associated organisms when they are present, allowing them to 

live in areas with water depths considerably deeper than 200 m. During the open-water period, 

bearded seals occur mainly in relatively shallow areas, preferring areas no deeper than 200 m 

(Harwood et al., 2005; Monnett and Treacy, 2005). 

Cetaceans 

Beluga Whale 

Beluga whales of the Beaufort Sea and eastern Chukchi Sea stocks winter in the Bering Sea and 

summer in the Beaufort and Chukchi Seas, migrating around western and northern Alaska along the 

spring lead system in April and May (Richard, Martin, and Orr, 2001; Angliss and Outlaw, 2005). 

During June, July, and part of August it is likely that the ranges of the two stocks do not overlap 

much (Suydam, Lowry, and Frost, 2005). Most belugas move into shallow coastal or estuarine 

waters during at least a portion of the summer (Caron and Smith, 1990; Frost and Lowry, 1990). 

Eastern Chukchi belugas move into coastal areas along Kotzebue Sound and Kasegaluk Lagoon in 

late June and remain there until mid to late July (Suydam et al., 2001; Suydam, Lowry, and Frost, 

2005). Stomach content analysis of belugas suggests feeding is not the major reason for their 

presence near Kasegaluk Lagoon during this time (Suydam, Lowry, and Frost, 2005). Some of the 

largest gravel beds in the Chukchi Sea occur in Kasegaluk Lagoon and research suggests these areas 

are likely used for molting (Frost, Lowry, and Carroll, 1993). The low saline content and warmer 

water exiting the lagoons may facilitate the molting process (Suydam, Lowry, and Frost, 2005). 

After leaving coastal areas, it is believed the animals move northeastward and spend the remainder of 

the summer in the northern Chukchi and western Beaufort seas. During the late summer and autumn, 

most belugas migrate far offshore near the pack-ice front (Frost et al., 1988; Hazard, 1988; Clarke, 

Moore, and Johnson, 1993; Miller, Elliott, and Richardson, 1998) and deeper slope waters. 

The main fall-migration corridor of beluga whales is ~100+ km north of the coast. Movements of 

tagged belugas indicate that the western Chukchi Sea is an autumn migratory destination, with many 

whales moving into Russian waters near Wrangel Island between mid-September and early October. 

They remain near Wrangel Island for weeks before moving south into the Bering Sea (Richard, 

Martin, and Orr, 2001). It is likely members from both stocks occur in similar places and at similar 

times during the fall migration (Suydam, Lowry, and Frost, 2005). 

Most feeding is done over the continental shelf and in nearshore estuaries and river mouths. Principal 

species eaten include Arctic and saffron cods, herring, capelin, smelt, salmon, flatfishes, char, 

whitefish, and sculpins (Frost and Lowry, 1990; Richard, Martin, and Orr, 2001). Octopus, squid, 

shrimp, crabs, and clams are eaten occasionally. Belugas generally are associated with ice and 

relatively deep water throughout the summer and autumn, which may reflect their preference for 

feeding on ice-associated Arctic cod (Moore et al., 2000). 
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CHAPTER III. Description of the Environment 65

Killer Whale 

Killer whales occur along the entire Alaskan coast (Braham and Dahlheim, 1982), including the 

Chukchi Sea. Killer whales travel through the Bering Strait in the spring as the pack ice retreats and 

can be found in the Beaufort and Chukchi seas until fall, when the ice advances. 

Killer whales are observed rarely in the Alaska Arctic. A discussion of these whales is in the Sale 

193 FEIS. New information indicates a crude estimate of 56 killer whales off the Chukotka coast 

(Melinkov, 2007). 

Harbor Porpoise 

In Alaska, three separate stocks have been recommended; the Bering Sea stock is the only stock 

expected to be present in the action area. Sixteen Native accounts of harbor porpoise near Point 

Barrow and along the northern coast of Alaska between 1930 and 1991 are noted in Suydam and 

George (1992). Harbor porpoises occur mainly in shelf areas (Read, 1999), diving to depths of at 

least 220 m and staying submerged for more than five minutes (Harwood and Wilson, 2001). Harbor 

porpoises typically occur in small groups of only a few individuals (Read, 1999); however, they can 

be observed in larger aggregations during feeding or migration. Harbor porpoises feed on a variety of 

small, schooling fish and cephalopods (Read, 1999). 

Harbor porpoise are discussed in the Sale 193 FEIS. New information has been found regarding 16 

Native accounts of harbor porpoise near Point Barrow between 1930 and 1991 (Suydam and George, 

1992). 

Gray Whale 

During the summer months, eastern north Pacific gray whales and their calves feed in the northern 

Bering and Chukchi seas (Tomilin, 1957; Rice and Wolman, 1971; Braham, 1984; Nerini, 1984). 

Gray whales prefer areas of little or no ice cover (<5%) (Moore and DeMaster, 1997). They are a 

coastal species, spending most of their time in waters <60 m deep. In mid-October, the whales begin 

their migration to the west coast of Baja California and the east coast of the Gulf of California to 

breed and calve (Swartz and Jones, 1981; Jones and Swartz, 1984). The northbound migration starts 

in mid-February and continues through May (Rice et al., 1984). 

Gray whales are bottom feeders, sucking sediment from the seafloor. Their primary prey is 

amphipods, although other food items (including polychaete worms, crab larvae, small fish and 

benthic invertebrates) are also ingested. Although gray whales probably feed opportunistically 

throughout their range, they return annually to primary feeding areas in the northern Bering Sea and 

Chukchi Sea (Moore and Clarke, 2002). The northeastern-most recurring gray whale feeding area is 

in the Chukchi Sea southwest of Barrow (Clarke, et al., 1989) and they were known to feed in the 

offshore shoals at least as far north as Hanna Shoal (located near the northern boundary of the 

Chukchi Sea Planning area). In the time period between 1982 and 1991 gray whales were frequently 

seen on Hanna Shoal (Moore and Clarke, 1992). Recent aerial surveys (Clarke, et al., 2011) have 

found an apparent shift in distribution, with no gray whales seen in the offshore shoals in 2008, 2009, 

or 2010. The relative lack of gray whale sightings (and mudplumes that indicate the presence of 

feeding gray whales offshore) was markedly different from observations made during 1982-1991 

surveys. Industry marine mammal observers have observed some whales in the general area 

immediately southeast of Hanna Shoal each year since 2007. The observation by industry observers 

of gray whales in the vicinity of leases and Hanna Shoal may indicate some use remains; however, 

these observations do not indicate feeding, specifically. 

Minke Whale 

Aerial surveys suggest that minke whales are associated with the 100-m contour in upper slope waters 

(Moore et al., 2000). They are either solitary or found in small groups, but they can occur in large 
BOEMRE Sale 193 Revised Draft SEIS 

66 CHAPTER III. Description of the Environment 

aggregations associated with concentrations of prey in the higher latitudes. Minke whales feed on 

fish (e.g., herring, sand lance) as well as on invertebrates (e.g., euphasiids, copepods). 

New information for SEIS analysis 

On December 6, 2010 NMFS released status reviews for bearded and ringed seals (Cameron et al., 

2010; Kelly et al., 2010) in response to petitions to list ringed, bearded, and spotted seals as 

threatened under the ESA (Center for Biological Diversity, 2008). On December 10, 2010 proposed 

rules to list ringed and bearded seals were published in the Federal Register (75 FR 77496; 75 FR 

77496). The BOEMRE has reviewed the status reviews and Federal Register notices and would 

initiate consultation if NMFS officially listed either species. In light of the above actions, additional 

information is provided regarding ice seals populations in the Chukchi Sea and adjacent regions. 

Surveys by Brueggeman et al. (2009), Blees et al. (2010), and Funk et al. (2010), provide additional 

ocular observation data concerning tendencies in the distributions of pinniped species, though the data 

focuses on very specific locations at very specific times during three open water seasons. 

Kelly et al. (2010) estimates that over 1,000,000 ringed seals inhabit the Beaufort, Chukchi and 

Bering Seas based on information from existing surveys and studies. Ringed seal numbers are 

believed to be considerably higher in the Bering and Chukchi seas, particularly during winter and 

early spring (71 FR 9783). Recent work by Bengston et al. (2005) reported an abundance estimate of 

252,488 ringed seals in the eastern Chukchi Sea, while Frost and Lowry (1981) estimated 80,000 

ringed seals in the Beaufort Sea during summer and 40,000 during winter. Some authors (Armstrup 

1995) believe the Beaufort Sea population is four times these numbers. Kelly et al. (2010) placed 

their maximum density estimate of ringed seals at Prudhoe Bay and along the coast south of Kivalina 

at 1.62 seals/km2

. 

Early estimates of the Bering-Chukchi seas bearded seal population ranged from 250,000-300,000 

(Burns 1981; Popov 1976). Cameron et al. (2010) developed a crude estimate of 3,150 resident 

bearded seals in the Beaufort Sea that was uncorrected for submersed seals or seasonal migrants, and 

around 27,000 residents in the Chukchi Sea. Cameron et al. (2010) estimated the maximum density 

of bearded seals from Prudhoe Bay to the coast south of Kivalina to be about 0.14 seals/km2

. No 

evidence suggests a population decline has occurred and stocks are considered healthy. 

There have been recent efforts to improve abundance estimates for spotted seals in the Bering Sea 

(Boveng et al. 2009; Allen and Angliss 2010). Studies to determine a correction factor for the 

number of spotted seals at sea missed during surveys have been initiated, but only preminary results 

are currently available. The Alaska Department of Fish and Game placed satellite transmitters on 

four spotted seals in Kasegaluk Lagoon and estimated the ratio of time hauled out versus time at sea. 

Preliminary results indicate the proportion of spotted seals hauled out are on average about 6.8% (CV 

= 0.85) (Lowry et al. 1994). Using this correction factor, with the maximum count of 4,145 from 

1992, results in an estimate of 59,214 spotted seals in Alaskan waters (Allen and Angliss 2010). 

Unstratified density estimates of spotted seals in the southeastern Bering Sea were calculated to be 

0.37 spotted seals per square nautical mile (nmi2

). Abundance estimates for that region were reported 

as 10,876 (stratified) and 13,125 (unstratified); however, only seals on the ice were counted and no 

adjustment was made for seals in the water (Allen and Angliss 2010). 

There have also been efforts to improve abundance estimates for the Alaska stock of ribbon seals. 

Burns (1981) estimated the Bering Sea ribbon seal population at 90,000-100,000, and aerial surveys 

have been conducted in parts of the eastern Berin Sea in 2003 (Simpkins et al. 2003), 2007 (Cameron 

and Boveng 2007, Moreland et al. 2008), and 2008 (Peter Boveng, NMML, unpubl. data). Data from 

the aerial surveys are currently being analyzed to construct estimates of abundance for the eastern 

Bering Sea from frequencies of sightings, ice distribution, and the timing of seal haulout behavior. In 

the interim, NMML researchers have developed a provisional estimate of 49,000 ribbons seals in the 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER III. Description of the Environment 67

eastern and central Bering Sea during the surveys (Allen and Angliss). Ribbon seal observations 

remain rare in the Beaufort Sea, but are more common in the Chukchi Sea. In more recent industryrelated surveys (Funk et al., 2011; Brueggeman et al., 2009; Blees et al., 2010), very small numbers 

of ribbon seals were occasionally observed by marine mammals observers. Existing data indicates 

ribbon seals mostly occur in the northern Bering and southwestern Chukchi seas, with a small 

scattering of individuals in the eastern and northern Chukchi Sea. 

On February 10, 2011, the U.S. Fish and Wildlife Service released its 12-month Finding on a Petition 

to List the Pacific Walrus as Endangered or Threatened. The USFWS found that listing the Pacific 

walrus as threatened throughout its range is warranted due to diminishing sea ice, but precluded by 

higher priority actions to amend the Lists of Endangered and Threatened Wildlife and Plants (76 FR 

7634). The most recent estimate for the Pacific walrus population is 129,000 based on a 2006 survey 

(Speckman, et al., 2010). 

Funk, et al. (2011) notes Marine Mammal Observer observations of killer whales in the Lease Sale 

Area in 2006, 2007, and 2008 during open water season oil and gas related operations. 

III.B.7. Terrestrial Mammals 

Caribou, muskoxen, grizzly bear, and Arctic fox are the terrestrial mammal species most likely to be 

affected by development and production of natural gas from the Chukchi Sea OCS. Other species, 

such as moose, are too sparse in the area to be affected by Chukchi Sea development. 

Caribou 

Three caribou herds use habitats of Alaska’s Arctic plain in the project area: the Western Arctic Herd 

(WAH), the Central Arctic Herd (CAH), and the Teshekpuk Lake Herd (TLH). 

Caribou from the CAH and WAH migrate seasonally to take advantage of seasonally available forage 

resources, however TLH are more sedentary, remaining on their herd range throughout the year. For 

the CAH and WAH the spring migration of parturient female caribou from the overwintering areas to 

the calving grounds starts in late March (Hemming, 1971), with bulls and nonparturient females 

generally migrate later. 

Synchronized calving takes place in the spring, generally from late May to late June (Hemming, 

1971). Traditional calving grounds consistently provide high nutritional forage to lactating females 

during calving and nursing periods, which is critical for the growth and survival of newborn calves. 

The WAH calving area is inland on the NPR-A, west of the Proposed Action area. The TLH’s central 

calving area generally is located on the east side of Teshekpuk Lake and near Cape Halkett adjacent 

to Harrison Bay. The CAH generally calves within 30 km of the Beaufort coast between the Itkillik 

and Canning rivers. 

During the postcalving period in July through August, caribou generally attain their highest degree of 

aggregation with continuous masses of animals in herds, sometimes in excess of tens of thousands. 

Cow/calf groups are most sensitive to human disturbance during this period. 

Insect-relief areas also become important during late June to mid-August during the insect season 

(Lawhead, 1997). For insect relief, caribou use various coastal and upland habitats such as ridges, 

snowfields, mountain foothills, sand dunes, sand bars, spits, river deltas, and barrier islands where 

strong breezes prevent swarms of biting mosquitos and oestrid flies from plaguing caribou. 

Muskoxen 

There are muskoxen west of Prudhoe Bay as far as Fish Creek in northern NPR-A and in the Itkillik 

Hills south of Kuparuk all the way to the Colville River. Distribution of muskoxen during the calving 

season, summer, and winter are similar (Reynolds, 1992). Family groups may frequently be seen 

along the Beaufort Coast between Prudhoe Bay and the Colville River. The most important habitats 
BOEMRE Sale 193 Revised Draft SEIS 

68 CHAPTER III. Description of the Environment 

for muskoxen appear to be riparian shrub areas, upland shrub areas and moist sedge-shrub meadows 

(Johnson et al., 1996). 

Grizzly Bear 

On the North Slope, grizzly dens occur in pingos, banks of rivers and lakes, sand dunes, and steep 

gullies in uplands (Harding, 1976; Shideler and Hechtel 2000). Grizzly bears in the western Brooks 

Range use a variety of food sources seasonally, including the WAH, beach-cast marine mammal 

carcasses and, to a small degree, fish runs that occur in major Chukchi coast drainages. 

Arctic Fox 

The availability of winter food sources directly affects fox abundance and productivity (Angerbjorn et 

al., 1991). Development at the Prudhoe Bay oil fields probably has led to increases in Arctic fox 

abundance and productivity (Burgess, 2000) as foxes readily use development sites for feeding, 

resting, and denning, and their densities are greater in the oil fields than in surrounding undeveloped 

areas (Eberhardt et al., 1982; Burgess et al., 1993). 

New information for SEIS analysis 

No new information regarding terrestrial mammals has been introduced in this supplement. 

III.B.8. Vegetation and Wetlands 

Vegetation 

The following paragraphs describe the most common vegetation types found up to 50 km inland from 

the Chukchi Sea shoreline. The description of vegetation in the study area is based on studies 

conducted by the Circumpolar Arctic Vegetation Mapping Team (2003). 

Sedge, Moss, Dwarf-Shrub Wetlands 

These wetlands are the most abundant vegetation type within the 50-km belt and cover about 41% of 

the area. 

Tussock Sedge, Dwarf Shrub, Moss Tundra 

This plant community, classified as moist tussock tundra, is the second most abundant within the 50-

km belt and covers about 24% of the area. 

Sedge/Grass Moss Wetland 

This vegetation type covers about 9% of the area within the 50-km belt. 

Erect Dwarf-Shrub Tundra 

This tundra community covers about 8% of the area within the 50-km belt. 

Nontussock Sedge, Dwarf-Shrub, Moss Tundra 

This moist tundra plant community covers about 6% of the area evaluated within 50-km belt. 

Noncarbonate Mountain Complex 

This vegetation type covers about 6% of the area within the 50-km belt, and is found on mountains 

and plateaus with noncarbonate bedrock. 

Carbonate Mountain Complex 

This vegetation type covers about 4% of the area within the 50-km belt, and is found on mountains 

and plateaus with limestone and dolomite bedrock. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER III. Description of the Environment 69

Sedge, Moss, Low-Shrub Wetland 

This vegetation type covers about 1% of the area within the 50-km belt. 

Low-Shrub Tundra 

This vegetation type covers about 1% of the area within the 50-km belt. 

Wetlands 

Estuarine wetland systems are found along the Chukchi Sea shoreline in enclosed and protected bays, 

which are partly obstructed, or with sporadic access to the open ocean (Cowardin et al., 1979). Large 

estuarine wetland complexes are found in Omalik Lagoon, Kasegaluk Lagoon, Icy Cape, Peard Bay, 

and Wainwright Inlet. These wetlands typically range from sandy/silt flatlands to emergent persistent 

wetlands dominated by several sedge species adapted to brackish-water conditions. Most of the 

intertidal biota of the Arctic is impoverished due to the effect of annual ice and the minimal tidal 

amplitude, so there is almost no littoral biota and few marine wetlands. Genera that are normally 

intertidal elsewhere in the world are found in the Arctic in subtidal ecosystems. 

New information for SEIS analysis 

No new information regarding vegetation and wetlands has been introduced in this supplement. 

III.C. Social Systems 

III.C.1. Economy 

Economic activity is measured in the form of revenues, employment, and personal income. Alaska 

OCS activities contribute to economic activity in the North Slope Borough (NSB), State of Alaska, 

and Federal government. 

The tax base in the NSB consists mainly of high-value property owned or leased by the oil industry in 

the Prudhoe Bay area. NSB oil and gas property tax revenues have exceeded $180 million annually. 

In 2005, revenues from oil and gas property taxes were $197 million, and total general fund revenues 

were $220 million. The State of Alaska’s tax base is comprised mostly of revenues from oil and gas 

production. Federal revenues are generated primarily from income and payroll taxes. 

The NSB is the largest employer of permanent residents in the NSB. However, very few North Slope 

residents have been employed by the oil and gas industry or supporting industries in and near Prudhoe 

Bay since production started in the 1970’s. Local residents represent only about one percent of those 

hired for North Slope oil industry related jobs, with most North Slope oil-industry workers residing 

outside the NSB. Unemployment in the NSB has ranged from 3.5% to 10.1% between 1975 and 

2007. Aggregate personal income for the NSB in 2006 was $0.3 billion. 

New information for SEIS analysis 

In 2008, NSB revenues from oil and gas property taxes were $235 million, and total general fund 

revenues were $281 million. These figures do not represent a significant change from recent past 

years’ totals, as NSB’s revenues from these sources have remained rather steady. 

Unemployment in the NSB has ranged from 3.5% to 5.3% between 1975 and 2010. Aggregate 

personal income for the NSB in 2008 was $448 million, and per capita personal income was $66,664. 

Again, this figure is generally consistent with aggregate personal income figures over recent past 

years. 
BOEMRE Sale 193 Revised Draft SEIS 

70 CHAPTER III. Description of the Environment 

III.C.2. Subsistence-Harvest Patterns 

Generally, subsistence is considered hunting, fishing, and gathering for the primary purpose of 

acquiring traditional food. The Alaska National Interest Land Conservation Act (ANILCA) defines 

subsistence as follows: 

the customary and traditional uses by rural Alaska residents of wild, renewable resources for direct 

personal or family consumption as food, shelter, fuel, clothing, tools, or transportation; for the making 

and selling of handicraft articles out of nonedible byproducts of fish and wildlife resources taken for 

personal or family consumption; for barter or sharing for personal or family consumption; and for 

customary trade. (16 U.S.C. 3113). 

Subsistence activities are assigned the highest cultural values by the Inupiat and provide a sense of 

identity in addition to being an important economic pursuit. The sharing, trading, and bartering of 

subsistence foods structure relationships among communities, and the sharing of these foods helps 

maintain ties with family members elsewhere in Alaska. 

Many studies have examined the relationship between subsistence and wage economies and how 

subsistence and wage activities are integrated into rural Alaskan socioeconomic systems. Within the 

NSB, both subsistence activities and wage economic opportunities are highly developed, and highly 

dependent on each other (Kruse, Kleinfeld, and Travis, 1981; Kruse, 1982, 1991; Harcharek, 1995; 

Shepro and Maas, 1999). Those individuals most active in subsistence activities tend to be those who 

are also very involved in the wage economy (e.g., to purchase a boat, fuel, guns, and ammunition). 

Full-time employment, however, limits the time a subsistence hunter can spend hunting to after-work 

hours. 

Community Subsistence-Harvest Patterns 

The communities adjacent to the Chukchi Sea Planning Area live within a diverse resource base that 

includes both marine and terrestrial animals. Generally, communities harvest the resources most 

available to them. Coastal/marine food resources include whales, seals, walrus, waterfowl, and fish. 

Terrestrial/aquatic resources include caribou, freshwater fishes, moose, Dall sheep, edible roots and 

berries, and furbearing animals. The aggregate community subsistence-harvest areas are extensive 

for the primary subsistence resources, including marine mammals (whales, seals, walrus, polar bears), 

caribou, fish, birds (and eggs), furbearers (for hunting and trapping), moose, Dall sheep, grizzly bears, 

small mammals, invertebrates, berries, edible roots, and fuel and structural material. Large portions 

of the marine subsistence-harvest areas of the Alaskan Chukchi subsistence communities are included 

in the Chukchi Sea Planning Area. 

While subsistence-resource harvests differ from community to community, the resource combination 

of caribou, bowhead whales, and fish has been identified as the primary grouping of resources 

harvested. Caribou is the most important overall subsistence resource in terms of hunting effort, 

quantity of meat harvested, and quantity of meat consumed. The bowhead whale is the preferred 

meat and the subsistence resource of primary importance because it provides a unique and powerful 

cultural basis for sharing and community cooperation (Stoker, 1984 cited in Alaska Consultants, Inc., 

Courtnage, and Braund, 1984). Depending on the community, fish is the second or third most 

important resource after caribou and bowhead whales. Bearded seals and various types of birds are 

also considered primary subsistence species. Waterfowl are particularly important during the spring, 

when they provide variety to the subsistence diet. Seal oil from hair seals and bearded seals is an 

important staple and a necessary complement to other subsistence foods. 

The subsistence pursuit of bowhead whales is of major importance to the Chukchi Sea coastal 

communities most likely to be affected by Lease Sale 193: Barrow, Wainwright, Point Hope, and 

Point Lay (see Figure 1). Barrow’s location at the demarcation point between the Chukchi and 

Beaufort seas is unique and Barrow is the only community adjacent to the Planning Area that harvests 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER III. Description of the Environment 71

whales in the spring and fall. Wainwright, Point Hope, and Point Lay whale only during the spring 

season (North Slope Borough, 1998). Wainwright’s marine subsistence activities focus on the coastal 

waters from Icy Cape in the south to Point Franklin and Peard Bay in the north. The Kuk River 

lagoon system is an important marine and wildlife habitat used by local Wainwright hunters. Point 

Hope’s strategic location close to the pack-ice lead makes it uniquely situated for hunting the 

bowhead. Point Lay, about 90 mi southwest of Wainwright, sits on the edge of Kasegaluk Lagoon 

near the confluence of the Kokolik River with Kasegaluk Lagoon. Beluga whale is the village’s 

preferred and pivotal marine mammal resource (Huntington and Mymrin, 1996; Huntington, 1999). 

Point Lay hunters have recently pursued and obtained a bowhead whale quota for the community. 

Point Lay took one bowhead whale in the spring 2009 hunt. 

The Sale 193 FEIS provides information on annual harvests of subsistence resources for the Chukchi 

communities (see Sale 193 FEIS: Tables III.C-4, III.C-5, III.C-6, III.C-7, III.C-8, and III.C-9). 

Summaries of the Chukchi Sea coastal communities and maps of each community’s subsistenceharvest areas are included in the Sale 126 Final EIS (USDOI, MMS, 1990b). Maps of the 

subsistence-harvest areas are included also in the Northwest NPR-A Final EIS (USDOI, BLM and 

MMS, 2003). 

New information for SEIS analysis 

Annual bowhead whale subsistence harvest assessments by Suydam et al. (2006), Suydam et al. 

(2007), Suydam et al. (2008), Suydam et al. (2009), and Suydam et al. (2010) provided new harvest 

data in relation to the annual subsistence bowhead whale hunts in Chukchi Sea coastal communities, 

although these reports do not show any changes to traditional harvest trends. Huntington (1999) and 

the Communities of Buckland, Elim, Koyuk, Point Law, and Shaktoolik employs TEK to broaden the 

information record concerning beluga whale migration and behavior in the region. 

III.C.3. Sociocultural Systems 

“Sociocultural systems” encompasses three organizing concepts: social organization, cultural values, 

and institutional organizations of communities. These concepts are interrelated. 

Social organization 

“Social organization” means how people are divided into social groups and networks. Social 

organization encompasses households and families, but also wider networks of kinship and friends, 

which, in turn, are embedded in groups that are responsible for acquiring, distributing, and consuming 

subsistence resources. The fundamental Inupiat social organization is kin-related groups engaged in 

subsistence activities. 

Cultural values 

“Cultural values” means concepts regarding what is desirable that are widely and explicitly or 

implicitly shared by members of a social group. The Inupiat culture on the North Slope has strong 

ties to the natural environment. Cultural values, many of which are rooted in, maintained, and 

reinforced by the interrelatedness of social organization, include a close relationship with natural 

resources and an emphasis on kinship, maintenance of the community, cooperation, and sharing. 

Subsistence is a central activity that embodies these values, with bowhead whale hunting being the 

paramount subsistence activity. Family and kinship relationships are strong influences on 

contemporary life, shaping social interactions that include cooperative activities and sharing. Cultural 

values of the Inupiat include characteristics such as respect for Elders, cooperation, sharing, family 

and kinship, knowledge of language, hunting traditions, and respect for nature. Borough residents 

express concerns regarding effects of oil and gas activities on archaeological, historic, and traditional 

land use and the incorporation of traditional and contemporary local knowledge into development 

projects (URS Corporation, 2005). 
BOEMRE Sale 193 Revised Draft SEIS 

72 CHAPTER III. Description of the Environment 

Residents of the Chukchi Sea coastal communities have been remarkably consistent in their primary 

concerns during the more than 20 years of public hearings and meetings on State and Federal oil 

development on the North Slope. Cultural concerns mentioned include: 

 A general fear of cultural change, especially in terms of the loss of a subsistence lifestyle, 

which may lead to social disruptions or social problems in local communities (including 

youth becoming less interested in traditional ways). 

 Concern that an influx of population and outside influences will disrupt and degrade Inupiat 

community life. 

 Concern that oil and gas development will impose additional demands upon Inupiat 

communities and individuals such as numerous hearings and review of numerous documents. 

Institutional organization 

“Institutional organization” refers to the government and nongovernment entities that provide services 

to the community. Institutional arrangements focus primarily on the structure of borough, village, 

and tribal governments, and the Native regional and various village for-profit and not-for-profit 

corporations. But this could include extended institutional arrangements or voluntary organizations 

such as Search and Rescue. The government and nongovernmental organizations that make up the 

institutional organization of the area include the NSB, city governments, Tribal governments, Alaska 

Native Regional Corporations, village corporations, nonprofit corporations, and nongovernmental 

organizations, such as the Alaska Eskimo Whaling Commission (AEWC). 

Each of the Chukchi Sea coastal communities, with the exception of Point Lay, has a city 

government. While certain municipal powers were turned over to the Borough, community 

governments play an important role in the administration of Borough programs and representing 

community interests. Federally recognized tribal governments in most Chukchi Sea Native villages 

are active in community government and in providing services. The NSB provides all utilities to 

Chukchi Sea coastal communities and subsidizes fuel costs. No roads connect these communities, 

and problems remain concerning high fuel costs, uncertain transportation, erosion, storm-surge 

flooding, unemployment, and the need for better utilities (Fuller and George, 1997; U.S. Army Corps 

of Engineers, 2005). 

Point Hope, Point Lay, Wainwright, and Barrow have either a traditional village or Indian 

Reorganization Act Tribal council form of tribal government. The Inupiat Community of the Arctic 

Slope, the regional tribal government, has recently taken a more active and visible role in regional 

governance and in providing some services. 

The Arctic Slope Regional Corporation (ASRC) runs several subsidiary corporations, and along with 

village profit and not-for-profit corporations, has provided employment and other services in the 

Borough’s communities. An in-depth profile of the ASRC and Alaska Native village corporations for 

Atqasuk (Atqasuk Corporation), Point Lay (Cully Corporation), Wainwright (Olgoonik Corporation), 

Point Hope (Tikigaq), and Barrow (UIkpaegvik Inupiat Corporation) is in Northern Economics, Inc. 

(2006) and URS Corporation (2005). Generally, much of the surface estate in and around the 

communities is owned by the village corporations, except in Barrow where land ownership is a 

mixture of public and private lands. 

Nongovernment organizations, such as the AEWC and whaling captain’s associations, play an 

important role in the management of resources vital to the subsistence and cultural needs of the 

communities. 

New information for SEIS analysis 

No new information regarding sociocultural systems has been introduced in this supplement. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER III. Description of the Environment 73

III.C.4. Archaeological Resources 

There are two major locations for archaeological resources/historic properties in the Sale 193 area: 

offshore and onshore. Within these locations, archaeological resources/historic properties are 

identified and discussed as either prehistoric or historic. 

Offshore Archaeological Resources 

It is generally accepted that prehistoric human populations may have entered North America at 

around 12,000 years B.P. (see for example Hopkins, 1967; Bonatto and Salzano, 1997; Wang, et al., 

2007; and Goebel, et al., 2008). The BOEMRE uses a conservative date of 13,000 B.P. as the earliest 

possible human migration and occupation of Alaska in the analysis of prehistoric archaeology 

potential. Based on core data from the Beaufort and Chukchi seas, sea level low-stands corresponding 

to this age are probably around -55 m (see for example Hopkins, 1967; Elias, et al., 1992; and Darigo, 

et al. 2007). The BOEMRE has adopted a slightly deeper water depth of -60 m as representing the 

possible sea level still-stand corresponding to approximately 13,000 years B.P. Along this portion of 

the now submerged shelf, relict terrestrial landforms provide indicators of areas where there is a 

higher potential for archaeological sites to occur. 

Any shipwrecks in the Sale 193 area beyond the areas of intensive ice gouging are more likely to be 

preserved than shipwrecks in State waters because wave action and ice are less likely to contribute to 

the breakup of ships in deeper waters. Two potential shipwreck locations have been identified in the 

Sale 193 area (see Map 7 of the Sale 193 FEIS). 

Onshore Archaeological Resources 

Information for some of the approximately 83 known archaeological sites onshore in the Chukchi Sea 

coastal area is in the Alaska Heritage Resources Survey File (State of Alaska, DNR, 2006). Twentyone sites along the shore in the Wainwright Quadrant, 52 sites in the Point Lay Quadrant, and 10 sites 

in the Point Hope Quadrant illustrate the archaeological-resource potential of the shore area along the 

Chukchi Sea coast. The Chukchi Sea coast is eroding at an average of about 0.3 m per year, 

periodically exposing new archaeological sites. 

New information for SEIS analysis 

No new information regarding archaeological resources has been introduced in this supplement. 

III.C.5. Environmental Justice 

Alaska Inupiat Natives are residents of the communities of the North Slope, a recognized U.S. 

minority group, and the predominant residents of the NSB. The ethnic compositions of Barrow, 

Atqasuk, Wainwright, Point Lay, and Point Hope are shown in Table III.C-15 in the Sale 193 FEIS 

(USDOI, MMS, 2007a). The table shows that these communities are classed as minority 

communities on the basis of their proportional American Indian and Alaska Native membership. Low 

income commonly correlates with Native subsistence-based communities in coastal Alaska; however, 

subsistence-based communities in the region qualify for Environmental Justice analysis based on their 

racial/ethnic minority definitions alone (USDOC, Bureau of the Census, 2000, 2002). The Inupiat are 

the only minority population allowed to conduct subsistence hunts for marine mammals in the U.S. 

Chukchi Sea region. There are not substantial numbers of “other minorities” in potentially affected 

Inupiat communities. Negative effects to members of these communities could occur because OCS 

activities may negatively affect the subsistence resources, subsistence harvest practices, and 

sociocultural systems that members of North Slope communities rely upon. 

New information for SEIS analysis 

No new information regarding Environmental Justice has been introduced in this supplement. 
BOEMRE Sale 193 Revised Draft SEIS 

74 CHAPTER IV. Environmental Consequences 

CHAPTER IV. Environmental Consequences 

IV.A. Basic Assumptions for Effects Assessment 

IV.A.1. Significance Thresholds 

The Council on Environmental Quality (CEQ) National Environmental Policy Act (NEPA) 

regulations (40 CFR 1508.27) define the term “significantly” in terms of both context and intensity. 

“Context” considers the setting of the Proposed Action, what the affected resource might be, and 

whether the effect on this resource would be local or more regional in extent. “Intensity” considers 

the severity of the impact, taking into account such factors as whether the impact is beneficial or 

adverse; the uniqueness of the resource (for example, threatened or endangered species); the 

cumulative aspects of the impact; and whether Federal, State, or local laws may be violated. Impacts 

may be beneficial or adverse. Impacts are described in terms of frequency, duration, general scope, 

and/or size and intensity. The significance thresholds used in the Sale 193 FEIS and this SEIS use 

terminology that is consistent with that definition. 

The impact analyses address the significance of impacts on resources, with consideration of such 

factors as the nature of the impact (for example, habitat disturbance or mortality), the spatial extent 

(local and regional), recovery times (years, generations), and the effects of mitigation (e.g., 

implementation of the oil-spill-response plan). Adverse impacts that are reduced by required 

mitigation to below the “significance thresholds” are considered “not significant.” 

This SEIS adopts the significance thresholds used in the Sale 193 FEIS. The following are 

descriptions of significance thresholds from the Sale 193 FEIS for the resources considered. 

Water Quality 

A significant effect on water quality is determined by any of the following: A regulated contaminant 

is discharged into the water column, and the resulting concentration outside a specified mixing zone 

is above the acute (toxic) State standard or Environmental Protection Agency (USEPA) criterion 

more than once in a 1-year period and averages more than the chronic State Standard or USEPA 

criterion over 25 square kilometers (km2

) for a month. The spillage of crude or refined oil in which 

the total aqueous hydrocarbons in the water column exceeds 1.5 ppm (parts per million), the assumed 

acute (toxic) criterion, for more than 3 days over at least 10 km2

 and 15 parts per billion (ppb), the 

assumed chronic criteria, and the State of Alaska ambient-water-quality standard, for more than a 

month over 25 km2

. An increase in anthropogenic contaminants in regional sediments to levels that 

have resulted in adverse biological effects in 10% of tested organisms (Effects Range-Low; Long et 

al., 1995; Long, Field, and Macdonald, 1998). Violations would be caused by exceeding an effluent 

limit or creating an oil sheen. The accidental discharge of a small volume of crude or refined oil also 

might cause an adverse impact. However, an action of violation or accidental discharge of a small 

volume of crude or refined oil would not necessarily constitute a significant environmental impact as 

defined in 40 CFR 1508.27. 

Air Quality 

A significant effect on air quality is determined by the following: Emissions cause an increase in 

pollutants over an area of at least a few tens of square kilometers that (1) exceeds half the increase 

permitted under the Prevention of Significant Deterioration (PSD) criteria or the National Ambient 

Air Quality Standards (NAAQS) for nitrogen dioxide, sulfur dioxide, or particulate matter <10 

micrometers in diameter; or (2) exceeds half the increase permitted under the NAAQS for carbon 

monoxide or ozone. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 75

Biological Resources 

A significant effect on biological resources is determined as follows: an adverse impact that results in 

a decline in abundance and/or change in distribution requiring three or more generations for the 

indicated population to recover to its former status. Biological resources include whales, seals, 

walrus, marine and coastal birds, terrestrial mammals, lower trophic level organisms, and fishes. 

Threatened and Endangered Species 

A significant effect on threatened or endangered species is determined by an adverse impact that 

results in a decline in abundance and/or change in distribution requiring one or more generations for 

the indicated population to recover to its former status. For declining populations, any take identified 

during the Section 7, ESA consultation process would constitute a significant impact. 

Economy 

A significant effect on the economy is determined as follows: economic effects that would cause 

important and sweeping changes in the economic well-being of the residents or the area or the region. 

Local employment is increased by 20% or more for at least 5 years. 

Subsistence-Harvest Patterns 

A significant effect on subsistence-harvest patterns occurs when one or more important subsistence 

resources becomes unavailable, undesirable for use, or available only in greatly reduced numbers for 

a period of 1-2 years. 

Sociocultural Systems 

A significant effect on sociocultural systems is defined by a chronic disruption of sociocultural 

systems that occurs for a period of 2-5 years, with a tendency toward the displacement of existing 

social patterns. 

Environmental Justice 

Significant effects in this category include impacts on human health or environment that cause 

disproportionate, high adverse effects on minority or low-income populations. This threshold would 

be reached if one or more important subsistence resources becomes unavailable, undesirable for use, 

or available only in greatly reduced numbers for a period of 1 to 2 years; or chronic disruption of 

sociocultural systems occurs for a period of 2 to 5 years, with a tendency toward the displacement of 

existing social patterns. Tainting of subsistence foods from oil spills and contamination of 

subsistence foods from pollutants would contribute to potential adverse human health effects. 

Archaeological Resources/Historic Properties 

Significant effects on archaeological resources or historic properties are indicated when an interaction 

between an archaeological site and an effect-producing factor occurs and results in the loss of unique, 

archaeological information. 

IV.B. Natural Gas Development and Production Scenario 

IV.B.1. Summary 

The natural gas development and production scenario below (see also Figure 2) provides the 

framework for BOEMRE’s analysis in response to the July 2010 remand from the U.S. District Court 

for the District of Alaska (Native Village of Point Hope v. Salazar, No. 1:08-cv-00004-RRB [D. 

Alaska]). The scenario is based on our review of the exploration, development, and production 

scenario in the Sale 193 FEIS, options for natural gas production and transportation, information on 

current and planned North Slope infrastructure, and the professional judgment of BOEMRE staff. 
BOEMRE Sale 193 Revised Draft SEIS 

76 CHAPTER IV. Environmental Consequences 

Recovery Recovery Consumed Injected Consumed

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020 172 13.5 49.1 62.6

2021 81.2 222 17.5 63.7

2022 95.1 261 20.5 74.6

2023 95.1 261 20.5 74.6

2024 95.1 261 20.5 74.6

2025 95.1 261 20.5 74.6

2026 83.7 229 18.0 65.7

2027 73.7 202 15.9 57.8

2028 64.8 178 14.0 50.9

2029 57.0 156 12.3 44.7

2030 138 10.8 39.4 50.2

2031 44.2 121 9.5 34.7

2032 38.9 107 8.4 30.5

2033 34.2 94 7.4 26.8

2034 30.1 82 6.5 23.6

2035 26.5 73 5.7 20.8 50 137.0 5.0 45.0 123.3 10

2036 23.3 64 5.0 18.3 75 205.5 7.5 67.5 184.9 15

2037 20.5 56 4.4 16.1 100 274.0 10.0 90.0 246.6 20

2038 18.1 49 3.9 14.2 125 342.5 12.5 112.5 308.2 25

2039 15.9 44 3.4 12.5 150 411.0 15.0 135.0 369.9 30

2040 38 3.0 11.0 150 411.0 15.0 135.0 369.9 30 14.0

2041 12.3 34 2.7 9.7 150 411.0 15.0 135.0 369.9 30

2042 10.8 30 2.3 8.5 150 411.0 15.0 135.0 369.9 30

2043 9.5 26 2.1 7.5 150 411.0 15.0 135.0 369.9 30

2044 8.4 23 1.8 6.6 150 411.0 15.0 135.0 369.9 30

2045 150 411.0 15.0 135.0 369.9 30

2046 150 411.0 15.0 135.0 369.9 30

2047 150 411.0 15.0 135.0 369.9 30

2048 150 411.0 15.0 135.0 369.9 30

2049 150 411.0 15.0 135.0 369.9 30

2050 150 411.0 15.0 135.0 369.9 30

2051 120 328.8 12.0 108.0 295.9 24

2052 100 274.0 10.0 90.0 246.6 20

2053 80 219.2 8.0 72.0 197.3 16

2054 50 137.0 5.0 45.0 123.3 10

2055

TOTAL 1160 250 910 2500 250 2250

Gas 

(Bcf/yr)

Dissolved 

gas 

(Bcf/yr)

Gas 

Production 

wells

Year

Gas Cap recovery

Gas 

(MMcf/d)

Gas rate 

(Bcf/yr

Gas Sales 

(Bcf/yr)

Gas Sales 

(MMcf/yr)

Dissolved 

gas 

(MMcf/day)

Gas 

(Bcf/yr)

Gas 

(Bcf/yr)

Chukchi Oil and Gas

0.0

20.0

40.0

60.0

80.0

100.0

120.0

140.0

160.0

2010 2020 2030 2040 2050 2060

Year

Annual Oil in MMBO and

Annual Gas Bcfg

oil production

gas production

gas consumption

Figure 2. Scenario for gas production in the Chukchi OCS begins as oil production decreases (illustrated 

below in Figure 3 and by the squares in the graph above). 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 77

The Sale 193 FEIS scenario presumes that oil, solution gas, and condensate would be recovered, but 

only oil and condensate would be transported off-lease for the first 15 years (from 2020 to 2035). 

Further, the scenario presumes that the TAPS oil pipeline system will continue to operate through at 

least 2044. The Sale 193 FEIS scenario did not include production of natural gas. Natural gas in 

northern Alaska is described as “stranded” until a gas-transportation system to outside markets is 

constructed. At the time of preparation of the Sale 193 FEIS, a large-diameter gas pipeline was 

considered the most likely transportation system; however, there were no specific proposals being 

considered at that time. The BOEMRE considered it unrealistic to assume that natural gas would be 

economical to produce from the Chukchi Sea Planning Area until construction and operation of a gastransportation system seemed likely. 

Since completion of the Sale 193 FEIS, the Alaska Gasline Inducement Act (AGIA) was passed by 

the State of Alaska to encourage construction of a gas pipeline from the North Slope to market. In 

addition, in 2007, BP and ConocoPhillips proposed the Denali pipeline project. Given these events, 

BOEMRE considered the construction and operation of a gas-transportation system more likely and 

included production of natural gas from the Chukchi Sea Planning Area in the Arctic Multi-Sale Draft 

EIS (USDOI, MMS, 2008a). Appendix E of the Arctic Multi-Sale Draft EIS provides a discussion of 

past and current gas pipeline proposals. 

For this SEIS, BOEMRE estimates that approximately 500 million cubic feet of gas will be consumed 

as fuel by offshore and onshore facilities, leaving a gas sales volume of 2.25 trillion cubic feet (see 

Figure 2). Gas production would be phased-in around 2035, and peak gas production would start in 

2039. All gas reserves would be depleted in 2054 (see Figure 2). During a 10-year transition period 

(2035 to 2044), both oil and gas would be produced from the offshore platform. Infrastructure 

required to support these activities includes a platform with topside facility, numerous wells, an 

offshore oil pipeline, an onshore processing facility, and an onshore pipeline through the NPR-A 

region. 

IV.B.2. Background 

Scenarios are conceptual views of the future and represent possible sets of activities. To develop 

scenarios, we consider the petroleum-resource potential of an area, the technology to develop and 

produce oil and gas from the offshore area, and industry trends in northern Alaska. While scenarios 

provide a reasonable basis for analyzing the effects of future activities, the presence and location of 

commercial oil or gas accumulation is purely hypothetical until proven by drilling. The primary 

purpose of a scenario is to provide a common basis for the analysis of potential environmental 

impacts, should future activities occur. 

The BOEMRE technical experts have reviewed the scenario laid out in the Sale 193 FEIS (see Sale 

193 FEIS, Section IV.A.) and determined that it remains valid. The Proposed Action was presumed 

to result in leasing and exploration of the Chukchi Sale area, as well as the discovery, development 

and production of one large oil field. Recoverable oil resources from this field were presumed to be 

one billion barrels—lower oil volumes are not likely to be economically viable in this remote, highcost location. At such a volume, an oil discovery could also be associated with a large volume of 

natural gas (in solution with oil and as a separate gas cap). Total potential of the initial reserve could 

be 2.75 trillion cubic feet. 

Oil is a more valuable commodity than gas; this is not expected to change in the foreseeable future. 

Consequently, oil would be produced first. In a typical reservoir management strategy, solution gas 

recovered as a secondary product with oil is used as fuel for facilities, and the excess gas is injected 

into the reservoir to facilitate oil recovery. Later in the field life, as oil production rates decline 

towards depletion, gas can be produced for sale. The estimated timeframe for oil development 

activities is given in Figure 3. Overall, the timeframe from leasing to abandonment is projected to be 

50 years. 
BOEMRE Sale 193 Revised Draft SEIS 

78 CHAPTER IV. Environmental Consequences 

IV.B.3. Infrastructure 

Production would occur from a single platform; water depth and sea conditions are the two main 

factors in selecting a platform type. Because the continental shelf is relatively deep in the Chukchi 

(mostly deeper than 100 ft) and affected by ice movements most of the year (which precludes a 

floating production system), a large bottom-founded platform is likely to be used as a central facility. 

The platform would support 1-2 drilling rigs, production and service (injection) wells, processing 

equipment, fuel and production storage capacity, and quarters for personnel. The processing 

equipment installed on the platform would be initially designed for the peak oil and associated gas 

2005

2006 4

2007 4

2008 4

2009 3 1 1

2010 31 1

2011 2 2 1

2012 1 2 1

2013 1 2 1

2014 1 1 1

2015 1 1 1 1

2016 1

2017 30

2018 30

2019 8 2 5 30

2020 1 6 8 3 3 5 54.0 147,945

2021 18 8 5 4 5 70.0 191,781

2022 18 8 5 4 5 82.0 224,658

2023 18 8 5 4 5 82.0 224,658

2024 10 8 6 3 5 82.0 224,658

2025 10 4 82.0 224,658

2026 72.2 197,699

2027 63.5 173,975

2028 55.9 153,098

2029 49.2 134,726

2030 1 43.3 118,559

2031 38.1 104,332

2032 30 33.5 91,812

2033 30 29.5 80,795

2034 30 26.0 71,099

2035 22.8 62,567

2036 20.1 55,059

2037 17.7 48,452

2038 15.6 42,638

2039 13.7 37,521

2040 12.1 33,019

2041 10.6 29,057

2042 9.3 25,570

2043 8.2 22,501

2044 7.2 19,801

2045

2046

2047

TOTAL 25 4 6 7 1 80 48 28 20 30 180 1000

On-Platform 

Wells

Subsea 

Wells

Service 

Wells

Seismic 

Surveys

Exploration 

Wells 

Delineation 

W ells

Exploration 

Drilling Rigs

Annual Oil 

Production 

(MMbbl)

Daily Oil 

Production 

(bopd

Year Production 

Drilling Rigs

New 

Shorebases

In-Field 

Flowlines 

(miles)

Offshore 

Pipelines 

(miles) 

Production 

Platforms 

Chukchi Oil Production

0

10

20

30

40

50

60

70

80

90

2005 2010 2015 2020 2025 2030 2035 2040 2045 2050

Year

MMbbl/yr

Sale

Discovery

Development

Activities

Production

Figure 3. Sale 193 FEIS scenario for oil production, with the addition of offshore pipelines for gas now 

indicated in years 2032–2034. It is acknowledged that oil and gas activities in the Chukchi Sea 

have not come to pass as projected in the scenario for the Sale 193 FEIS. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 79

rates (approximately 225,000 barrels/day and 260 million cubic feet/day; see Figure 3, above). In 

addition to the platform, oil production would require supporting infrastructure, including a 

shorebase, offshore oil pipelines, and an onshore oil pipeline across NPR-A to TAPS. To develop the 

oil reservoir, the platform would be installed near the center of the field area surrounded by subsea 

wells. Wells would be drilled from the platform and as subsea wells. On-platform wells would 

include both oil production and injection wells. Subsea wells (approximately half of the total number 

of production wells) may be up to 15 mi from the platform. Production from the subsea wells would 

be gathered to the central platform by small diameter, multi-phase in-field flowlines. The main part 

of the gas reservoir (“gas cap”) is typically located near the center and (structurally) the highest part 

of the field because gas is a lighter substance than oil and water. 

Raw production from the wells consists of a mixture of oil, gas and water that needs to be separated 

before transport through pipelines. After separation by processing equipment on the platform, 

formation water will be treated and injected into the subsurface. After separation and treatment, 

solution gas would be used as fuel for the facility or injected into the gas cap to maintain reservoir 

pressure so that more oil can be recovered. We assume that half of the estimated service wells 

(28 wells, see Figure 3) will inject water and half will inject gas into the gas cap. We also assume 

that 2 of the 28 service wells will be shallow disposal wells to handle waste water and treated well 

cuttings from drilling on-platform wells. Offshore facilities, the shorebase, and any necessary 

facilities along the onshore pipeline route will consume approximately 500 Bcf of gas during 34 years 

of operations (2020 to 2054) and the remaining gas reserves of 2.25 Tcf will be transported to market 

(see Figure 2). 

IV.B.4. Development, Production, and Transportation of Natural Gas 

Five underlying considerations are important to the discussion of a gas development scenario and are 

bulleted below. These factors suggest that the first commercial gas production will only occur when 

it can utilize existing oil production facilities because the higher value substance (oil) is needed to 

support the cost of the new infrastructure. It is, therefore, presumed that natural gas development and 

production is predicated upon, and would only follow, the oil exploration, development, and 

production activities analyzed in the Sale 193 FEIS. 

Important considerations for gas development: 

 There is no transportation system at the present time to deliver natural gas from Arctic 

Alaska to market. The abundant gas resources (proven and undiscovered) in this region will 

continue to be stranded until a large capacity gas transportation system is operational. 

 A large-diameter, overland gas-sales pipeline system is the most feasible and 

economically viable project to move large quantities of gas from Arctic Alaska to 

outside markets. An important assumption of our gas production scenario is that a future 

North Slope gas-sales pipeline is built. Several gas-sales pipeline projects have been 

proposed by industry and strongly supported by federal and state governments, although none 

have been constructed. At the present time, a new North Slope gas-sales pipeline is not 

expected to be operational until 2020. At least 10 to 15 years of available gas supplies have 

been identified close to this future gas-sales pipeline and will likely be produced and fill the 

gas-sales pipeline before remote gas fields can come online. We do not expect full-scale gas 

production from the Chukchi OCS or available capacity in the gas-sales pipeline until at least 

2030. 

 Other gas transportation strategies (e.g. tankering of liquefied natural gas) have more 

difficult technical, regulatory, and economic challenges than an overland gas pipeline 

project. These strategies were considered, but we found that they are much less likely to 

occur. 
BOEMRE Sale 193 Revised Draft SEIS 

80 CHAPTER IV. Environmental Consequences 

 The economics of gas development are much less attractive than oil development. The 

main disadvantage results from a price discount for gas compared to oil. A steep discount on 

an energy basis is expected to persist into the future. Despite the low market price for gas, 

the development costs for new gas fields (platforms, wells, and pipelines) are very similar to 

oil. This unfavorable cost-price relationship burdens all gas projects. 

 Royalty Suspension Volumes are on a lease basis and are intended to encourage the 

development of both oil and gas resources. On leases containing both oil and gas resources 

the RSVs will likely be depleted by the earlier oil production. On leases containing only gas 

resources (leases over the gas cap) the RSVs would be available when gas is produced for 

sale. 

Other characteristics of the gas production scenario are: 

 Gas production is expected to be delayed until most of the recoverable oil is produced. 

 Gas production would briefly overlap declining oil production and last for another 20 years 

(see Figure 2). Overall, the timeframe for all activities (leasing to abandonment) could span 

50 years. 

 Gas production would utilize the same oil production platform described in the Sale 193 FEIS 

scenario. 

 No additional exploration seismic surveys would be needed for gas development and 

production. 

 No additional exploration drilling would be conducted for gas production. 

 No new development drilling would be needed for gas development and production. Existing 

oil wells and gas injection wells would be used as gas production wells. 

 No in-field flowlines would be needed or constructed. 

 Natural gas liquid (condensate) would be separated from the gas stream and transported 

through the oil pipeline to market. Consequently, the gas pipeline would carry only dry gas 

(no water or condensates). 

 No produced water discharges would occur. Any produced water would be treated and 

injected into the subsurface through existing disposal wells. 

 A gas pipeline from the platform to the shore facilities would be needed. The new pipeline 

would be constructed during open-water season along same corridor as oil pipeline. Shore 

facilities are assumed to be near Wainwright. 

 The oil production shore facilities would be expanded to accommodate gas processing. 

Administrative, maintenance, staff, buildings, and capabilities would continue to be used. 

 A gas pipeline from the shore facility across NPR-A to the main transportation hub near 

Prudhoe Bay would be needed. The pipeline across NPR-A would be constructed on risers 

(vertical support members) during winter along the same corridor as the oil pipeline to 

TAPS. 

 No hydrogen sulfide (H2S) was recorded in any of the five historic wells drilled in open-hole 

conditions during 1989-1991: OCS-Y 1482 Klondike #1, OCS-Y 1275 #1 (Popcorn), OCS-Y 

1413 #1 (Burger), OCS-Y 1320 #1 (Crackerjack), and Chevron OCS-Y 0996 #1 (Diamond) 

(Shell Gulf of Mexico Inc., 2009). Based on the absence of H2S in any previously drilled 

exploration well in the Chukchi Sea, the Beaufort Sea, or the Canadian Beaufort Sea, H2S is 

not expected in any natural gas produced from the Chukchi Sea Planning Area (Shell Gulf of 

Mexico Inc., 2009). 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 81

Aspects of gas development and production that may affect the human environmental include: the 

presence of infrastructure (offshore platform, offshore and onshore pipelines, and shore base); noise 

and other disturbance from development activities; vessel, air, and ground transportation; emissions 

and discharges; and accidental events. 

A timeframe for development and production is given in Figure 3. The platform would hold one or 

two drilling rigs, processing equipment, fuel- and production-storage capacity, and quarters for 

personnel. After the offshore platform is constructed for oil production and later modified for natural 

gas production, operations would largely involve resupply of materials and personnel, inspection of 

various systems, and maintenance and repair. Platform operations would transition from oil 

production to gas production during the last 10 years of oil production. Construction of a new gas 

pipeline to shore, expansion of the shorebase, and construction of a gas pipeline across NPR-A would 

occur during this transition period (2030 to 2035). The existing shorebase would be expanded and 

modified to support gas production. All necessary transportation (marine dock, airport, roads) and 

support (fuel storage, warehouses, crew quarters, and communication systems) infrastructure would 

have been constructed previously. 

As many as 30 gas production wells are expected to be needed; however, all of these wells can be 

converted from existing wells from the oil production operations. The injection wells drilled into the 

gas cap of the reservoir (approximately 14 wells) would be converted to gas production wells. Many 

of the previously drilled oil wells are expected to produce higher and higher proportions of associated 

gas. Consequently, no additional well drilling is anticipated for full-scale gas production. 

Installation of a subsea gas pipeline from the offshore platform to landfall would occur during 

summer open-water season. High-resolution seismic surveys and geotechnical studies to locate 

shallow hazards, obtain engineering data for placement of the pipeline, and to detect archaeological 

resources and certain types of benthic communities will be conducted along several potential routes. 

The offshore pipeline would be trenched into the seafloor as a protective measure against damage by 

floating ice masses. The gas pipeline is expected to be laid along the same corridor as the oil 

pipeline. The pipelines will be inspected and cleaned regularly by internal devices (“pigs”). 

An overland gas pipeline across NPR-A along the same corridor as the oil pipeline would transport 

gas to the main transportation hub near Prudhoe Bay where a gas-sales pipeline is expected to be 

located. Installation of the overland pipeline would likely occur during the winter months when 

tundra travel is feasible. Like the oil pipeline, the gas pipeline would be elevated. Several 

compression stations for the gas pipeline would be constructed along the pipeline. These facilities are 

likely to be co-located with onshore oil and gas fields along the pipeline route. 

Offshore development activities would be supported by helicopters and supply vessels. Expansion of 

the onshore facility and construction of the overland pipeline would be supported by barges, aircraft, 

and perhaps winter ice roads. Transportation activities would be frequent during these development 

activities. The level of transportation in and out of the shorebase would drop significantly after 

development activities are completed. During production operations, there would be 1 to 3 helicopter 

flights offshore per day, and one vessel trip every 1 to 2 weeks to the production platform. Marine 

traffic would occur during the open-water season and possibly during periods of broken ice with icereinforced vessels. 

To avoid potential disturbance effects on birds and marine mammals, BOEMRE, NMFS, and FWS 

recommend that aircraft maintain minimum flight altitudes—human safety will take precedence at all 

times over this recommendation. Information to Lessees No. 2 in the Sale 193 FEIS recommends a 

minimum flight altitude of 1,500 ft above seal level (ASL) and above ground level (AGL). The 2007 

FWS BO specifies that aircraft remain above 1,500 ft over Ledyard Bay Critical Habitat Unit (Figure 

1). The FWS’ MMPA Incidental Take Regulations require a minimum altitude of 1,500 ft and a 

horizontal distance of 800 m (1/2 mi) from walrus hauled out on land or ice. 
BOEMRE Sale 193 Revised Draft SEIS 

82 CHAPTER IV. Environmental Consequences 

After the gas reserves are depleted, the abandonment phase would begin. Wells would be 

permanently plugged (with cement) and wellhead equipment removed. Processing modules would be 

moved off the platform. Pipelines would be decommissioned, which involves cleaning the pipelines, 

plugging both ends, and leaving them in place (buried in the seabed). The overland oil and gas 

pipelines are likely to be used to develop oil and gas fields in the NPR-A, so they would remain in 

operation. Finally, the platform will be disassembled and removed and the seafloor site would be 

restored to a practicable, predevelopment condition. Surveys would be required to confirm that no 

debris remains and that the drill site and pipelines were abandoned properly. The abandonment 

process could take several years. 

IV.B.5. Potential for Natural Gas Releases 

This analysis evaluates the potential for a large gas release during natural gas development and 

production, as well as the potential impacts of such releases on the environment. This analysis 

identifies three general types of potential releases: from loss of well control at production platforms, 

from ruptured pipelines, and from onshore facilities. The following subsections discuss possible 

ways in which natural gas may be released into the environment, assign probabilities to notable 

events, and present release scenarios for further environmental resource-specific analysis. 

Loss of Well Control 

It is possible that a loss of well control during natural gas production could cause a release of natural 

gas into the environment. The Sale 193 FEIS, Appendix A, discusses the rates for loss of well control 

during drilling, which includes workovers—estimated at 5.9 x 10-3 blowouts per well drilled by 

Holland (1997). The production well control incident rate for production of both oil and gas is 5.0 x 

10-5 blowouts per well year (Holland, 1997). Appendix B of this EIS discusses updated rates for loss 

of well control from drilling. The well control incident rate during production is lower than the during 

the development drilling phase. It should be noted that the natural gas development and production 

scenario analyzed in this SEIS does not entail the drilling of any new wells, but could include 

workovers. 

During sales-gas production, which would commence in 2035, it is estimated that one well control 

incident of a single well on the facility could occur, releasing 10 million cubic feet of natural gas for 1 

day. This is based on the average well production for one day from one well and estimated rates of 

blowout duration for production wells. 

Ruptured Pipeline 

Although unlikely, there exists some potential for a gas pipeline to rupture. The estimated rate of 

offshore gas pipeline ruptures in the Gulf of Mexico is 2.4 x 10-5 per mile-year (USDOI, MMS, 

2009). For a 90 mile pipeline, over a 20 year production life, the estimated number of incidents is 

0.04 offshore pipeline ruptures over the life of the project. The estimated rate for generic DOT 

onshore gas transmission lines from 1990-2009 is 1.5 x 10-4 per pipeline mile-year. For a 300 mile 

onshore pipeline, over a 20 year production life, the estimated number of significant incidents using 

DOT’s estimated rate is 0.9 pipeline rupture over the life of the project. Under DOT regulation, 

significant incidents are incidents that involve property damage of more than $50,000, injury, death, 

release of gas, or that are otherwise considered significant by the operator. 

A major release of natural gas would cause a sudden decrease in gas pressure, which in turn would 

automatically initiate procedures to close the valves on both ends of the ruptured segment of pipeline. 

Closure of the valves would effectively isolate the rupture and limit the amount of natural gas 

released into the environment. Given the daily flow rate and the estimated total number of valves, it 

is estimated that approximately 20 million cubic feet could be released within one pipe section 

between two valves. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 83

Onshore, from an elevated pipeline, or from an offshore platform, the gas would disperse into the 

atmosphere. Offshore, from a subsea pipeline release, the gas would bubble to the surface and 

continue into the atmosphere, where it would dissipate at water temperatures greater than -2 °C. In 

temperatures lower than -2 °C, sea ice forms and gas could rupture the ice, be released through flaws, 

leads, fractures or polynyas or be trapped and then encapsulated into the growing ice sheet within 18-

72 hours (Dickins and Buist, 1981; Fingas and Hollebone, 2003). Recent work (Semiletov et al., 

2004) has demonstrated the usual assumption that the sea-ice cover is a barrier to gas exchange 

between the upper ocean and the atmosphere might need to be reconsidered for ice temperatures 

greater than -10 °C based on the original work of Gosink et al. (1976). This would mean gas could be 

released at temperatures lower than -2 °C. For purposes of analysis, it is estimated that pockets of 

natural gas under ice could persist from 1 to 3 days under large continuous ice sheets and could be 

distributed over 2 square kilometers, assuming a 30 cm depth as the ice pack moved. 

Onshore Facility 

Although unlikely, due to the enclosed space, there exists some potential for a gas leak and explosion 

at the onshore facility. The greatest hazard as a result of a natural gas leak is a fire or explosion. 

Methane has an auto-ignition temperature of 1,000 degrees Fahrenheit and is flammable at 

concentrations between 5 to 15 percent in air. Unconfined mixtures of methane in air are not 

explosive. However, a flammable concentration within an enclosed space in the presence of an 

ignition source can result in a potential explosion hazard. 

Gas Release Fate 

Natural gas is primarily made of up methane CH4 and ethane C2H6 which make up 85-90% of the 

volume of the mixture. Propane, butane, and heavier hydrocarbons can be extracted from the gas 

system and liquefied for transportation and storage. These are commonly known as liquid petroleum 

gas or LPG. Pentane through decane are the intermediate-weight hydrocarbons and are volatile 

liquids at atmospheric temperature and pressure. The common names for these are pentanes-plus, 

condensate, natural gasoline, and natural gas liquids. Accidental condensate spills were analyzed in 

Sale 193 FEIS (USDOI, MMS, 2007a). Produced gas is expected to be dry gas (no water or 

condensates). 

The primary component of natural gas is methane, a colorless, odorless, and tasteless gas. It is not 

toxic in the atmosphere, but is classified as a simple asphyxiate, possessing an inhalation hazard. As 

with all gases, if inhaled in high enough concentration, oxygen deficiency could occur and result in 

suffocation. The specific gravity of methane is 0.58. Being lighter than ambient air, it has the 

tendency to rise and dissipate into the atmosphere. 

Environmental Impacts 

The potential environmental impacts of natural gas releases are discussed, as applicable, within 

resource-specific portions Chapter IV. 

IV.C. Effects of Natural Gas Development and Production 

The natural gas development and production scenario applies to each of the three action alternatives 

(Alternative I - Proposed Action, Alternative III-Corridor I Deferral, and Alternative IV-Corridor II 

Deferral). The scenario assumes that the production platform would be constructed near the center of 

the Sale 193 area, outside of the deferral areas presented in Alternatives III and IV. This location 

would be available for leasing under each alternative. The hypothetical location of the shore base and 

the routes of both offshore and onshore pipelines remain constant under the three action alternatives 

in the scenario. Differences in potential environmental impacts associated with each action 

alternative are directly traceable to the size and location of deferrals or absence thereof. For example, 
BOEMRE Sale 193 Revised Draft SEIS 

84 CHAPTER IV. Environmental Consequences 

deferral corridors can influence the distance from shore of platform-related activities, support vessel 

and aircraft routes, and the length of an offshore natural gas pipeline. Under Alternatives I, III, and 

IV, the production platform would be located a minimum distance of approximately 29, 65, and 35 

miles from shore, respectively. If the shore base changed location to achieve the shortest possible 

distance from shore for the platform under each alternative, then the distances would be 12, 60, and 

20 miles respectively. 

The development and production of natural gas from existing infrastructure would not require any 

additional exploration activities. The potential effects from exploration activities, including various 

types of seismic surveying, are fully analyzed in the Sale 193 FEIS. Relevant conclusions of that 

analysis are also summarized in Chapter II of this SEIS. Because no additional exploration activities 

would occur as a result the natural gas development and production scenario, there is no need to 

duplicate a full impacts analysis of exploration activities in this SEIS. Further, no additional 

mitigation measures, beyond those analyzed in the Sale 193 FEIS, have been identified in regard to 

natural gas development and production activities. Standard mitigation measures and regulations are 

discussed, as appropriate. A full list of references for the data and major assumptions behind this 

analysis are available in the Sale 193 FEIS. Many of these references are retained in this SEIS in 

order to contextualize the present discussion. All new information used to support this natural gas 

analysis is cited accordingly. 

Under the No Action alternative (Alternative II), the Secretary would decline to affirm Sale 193. No 

offshore development or production would occur under Sale 193, although such activities could occur 

within the Chukchi Sea under a future lease sale. Therefore, potential environmental impacts to 

marine, coastal, and human environment from offshore development and production would not occur 

or would be delayed. Economic benefits to local communities, the North Slope Borough, the State of 

Alaska, and the Federal Government would not be realized at this time, due to delay and/or missed 

opportunities. This alternative would also postpone potential contributions to national energy 

supplies and security. A variety of adverse and beneficial impacts generally associated with 

petroleum production could be displaced to other localities, both domestic and foreign. No additional 

mitigation measures have been identified in this SEIS for the No Action alternative. 

Subsequent to the publication of the Sale 193 FEIS, BOEMRE prepared a Draft EIS for the proposed 

Arctic lease sales remaining in the 2007-2012, Five-Year Program (Sales 209 and 217 in the Beaufort 

Sea and Sales 212 and 221 in the Chukchi Sea) (USDOI, MMS, 2008a). This Draft Arctic Multi-Sale 

EIS was published in November 2008. The Draft Arctic Multi-Sale EIS used the most recent and best 

available information to update description of the OCS environment and analyzed resources. The 

Arctic Multi-Sale Draft EIS evaluated the potential environmental effects for leasing, exploration, and 

development and production of both oil and gas resources. The reader is referred to the Arctic MultiSale Draft EIS for a comprehensive update for the Arctic OCS. 

Also subsequent to the publication of the Sale 193 FEIS, BOEMRE reinitiated ESA Section 7 

consultation with both the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife 

Service (FWS). These consultations addressed new information on the occurrence of fin and 

humpback whales in the Chukchi Sea Planning Area, the newly listed polar bear, the yellow-billed 

loon as a candidate species, and updated information on ESA listed species, potential effects, and the 

Arctic environment. In May 2008, BOEMRE provided an updated Biological Evaluation to NMFS 

for consultation on bowhead, fin, and humpback whales (USDOI, MMS, 2008b). The NMFS 

provided their Biological Opinion to BOEMRE on July 17, 2008 (NMFS, 2008). In July 2009, 

BOEMRE provided an updated Biological Evaluation to FWS for consultation on Steller’s eider, 

spectacled eider, Kittlitz’s murrelet, yellow-billed loon, and polar bear. The FWS provided their 

Biological Opinion to BOEMRE on September 3, 2009 (USDOI, FWS, 2009). 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 85

Analysis of potential impacts uses the same organization as the Sale 193 FEIS, without regard to 

recent changes in a status of certain species under the ESA. Potential impacts to Pacific walrus, 

bearded seals, and ringed seals are considered within Section IV.C.10, Other Marine Mammals. 

Potential impacts to the yellow-billed loon are considered within Section IV.C.9, Marine and Coastal 

Birds. 

IV.C.1. Water Quality 

Consistent with regulations (40 CFR 125.122) implementing the Clean Water Act, determining 

impacts to water quality resulting from marine discharges is made based on consideration of the 

following ten criteria: 

 The quantities, composition, and potential for bioaccumulation or persistence of the 

pollutants to be discharged. 

 The potential transport of such pollutants by biological, physical, or chemical processes. 

 The composition and vulnerability of the biological communities that may be exposed to such 

pollutants, including the presence of unique species or communities of species, the presence 

of species identified as endangered or threatened pursuant to the Endangered Species Act, or 

the presence of those species critical to the structure or function of the ecosystem, such as 

those important for the food chain. 

 The importance of the receiving water area to the surrounding biological community, 

including the presence of spawning sites, nursery/forage areas, migratory pathways, or areas 

necessary for other functions or critical stages in the lifecycle of an organism. 

 The existence of special aquatic sites including, but not limited to, marine sanctuaries and 

refuges, parks, national and historic monuments, national seashores, wilderness areas, and 

coral reefs. 

 The potential impacts on human health through direct and indirect pathways. 

 Existing or potential recreational and commercial fishing, including finfishing and 

shellfishing. 

 Applicable requirements of an approved Coastal Zone Management Plan. 

 Marine water quality criteria developed pursuant to Section 304(a)(1). 

 Such other factors relating to the effects of the discharge as may be appropriate. 

Effects from Natural Gas Development 

Relatively little additional development would be needed for natural gas development to proceed 

from the existing oil production platform. No additional drilling would occur, precluding additional 

disturbance and greatly reducing the potential for most discharges. Natural gas development activities 

that may affect water quality in the area include construction of a gas pipeline from the platform to 

the onshore facility, expansion of the onshore facility, and construction of a gas pipeline from the 

onshore facility across the NPR-A. 

Degradation of marine water quality could result from installation of the gas pipeline from the 

platform activities. Sediment resuspension and bottom disturbances are likely to occur as a result of 

installing and burying the subsea pipeline. The area, duration, and amount of turbidity depend on the 

grain-size composition of the discharge, the rate and duration of the discharge, the turbulence in the 

water column, and the current regime. The extent of the area affected could potentially vary under 

each of the action alternatives in that an increase in the areas deferred from leasing could result in an 

increase in the length of the platform-to-coast offshore gas pipeline. In the Chukchi Sea Planning 

Area, the sea bottom within 80 km of shore is mostly sand; farther from shore, the bottom is mostly 

mud (Lewbel, 1984). Turbidity typically would extend 3 km from trenching operations. Turbidity 
BOEMRE Sale 193 Revised Draft SEIS 

86 CHAPTER IV. Environmental Consequences 

would increase over a few square kilometers in the immediate vicinity of dredging operations only 

during actual dredging. Conditions typically return to ambient conditions within hours to days, 

depending on the amount, composition, and frequency of the disposed material. Discharges of 

pollutants and dredge and fill material are regulated under State and Federal permitting processes 

which require project-specific environmental assessment and documentation. 

Effects on water quality from construction activities, including dredging and pipeline installation, 

would be local and short-term. Effects on local water quality are expected to be low, while the effect 

on regional water quality is expected to be very low. 

Effects from Natural Gas Production 

Natural gas production under Sale 193 would cause little to no adverse impacts to marine water 

quality. 

Dry gas is expected to be produced during the gas production phase of the platform. Remaining 

produced water in the gas stream would be separated, treated, and injected into the subsurface through 

a disposal well. This would remove produced water as a potential source of water quality 

degradation. 

Three waste-stream discharges during gas production could degrade water quality: deck drainage, 

sanitary waste, and domestic waste. Deck drainage refers to any waste resulting from platform 

washing; deck washing; spillage; rainwater; and runoff from curbs, gutters, and drains, including drip 

pans and wash areas. Pollutants, such as detergents used in platform and equipment washing, oil, 

grease, workovers fluids, and various other chemicals used during normal operations may be present 

in deck drainages. Chemicals may include ethylene glycol, lubricants, fuels, biocides, surfactants, 

corrosion inhibitors, cleaners, solvents, paint cleaners, bleach, dispersants, coagulants, and any other 

chemical used in the daily operations of the facility. Deck-drainage discharges are not continuous 

discharges and vary significantly in volume. Low Arctic temperatures prevent high volumes of deck 

drainage during the long winter months, and precipitation drainage is expected to occur only during 

the open-water (summer) months. Small quantities (<300 gallons per day) of deck drainage are 

expected during the gas-production phase of the platform. Higher quantities may occur during 

periods of high precipitation. Because of the remoteness of the platform and storage limitations, 

sanitary and domestic wastes are expected to be treated and discharged into marine waters. These 

discharges would be subject to NPDES permitting and associated water quality-based limitations, as 

well as associated monitoring requirements. Unreasonable degradation of water quality would be 

avoided in this manner. 

The effect on water quality would be local and would continue for the life of the discharge. The 

effect on local water quality from gas production is expected to be moderate, while the effect on 

regional water quality is expected to be very low. Sustained degradation of local and area wide water 

quality to levels above State and Federal criteria from natural gas is unlikely. 

In the event of a natural gas release, methane would be released into the water and proceed to rise 

through the water column as a function of pressure and temperature. When released in a blowout or 

rupture at depth, quality of the water would be altered temporarily and in deeper, colder waters, some 

of the natural gas would enter the water as a water-soluble fraction. Upon reaching the surface the 

gaseous methane would react with air, forming carbon dioxide (CO2) and water which would then 

disperse into the atmosphere. The near-surface water quality would have higher concentrations of 

CO2 than is natural and could, therefore, affect processes and reactions at the water-air interface. 

Depending on the size of the event, the effects on water quality would be temporary to short-term and 

would be negligible to minor in quality. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 87

Conclusions 

Neither natural gas development nor production is expected to cause significant adverse impacts on 

water quality. Temporary and localized adverse effects are likely to result from installation of a new 

offshore natural gas pipeline and from small scale and infrequent deck drainage discharges. The 

effect of these activities on regional water quality would remain very low under each action 

alternative. 

IV.C.2. Air Quality 

The type and relative amounts of air pollutants generated by offshore operations vary according to the 

phase of activity. There are three principal phases of OCS operations: exploration, development, and 

production. No exploration activities associated with the gas production are expected. Impacts to air 

quality would result from the discharge of air pollutants from industrial equipment associated with 

natural gas support, development, and production activities. 

Effects from Natural Gas Development 

Emissions from development would result from the construction of an offshore pipeline, expansion of 

onshore support facilities, and construction of up to 300 mi of onshore pipeline across NPR-A. The 

main sources of emissions would include: 

 heavy construction equipment used to install the platform-to-shore pipeline; 

 construction and support equipment, including cranes, generators, compressors, welders, 

heaters, and safety flares; and 

 tugboats (needed to move equipment and supply barges), support vessels, and helicopters. 

The main emissions would be nitrogen oxides (NOx) and carbon monoxide (CO), with lesser amounts 

of sulfur dioxide (SO2), volatile organic compounds (VOC), and particulate matter (PM). The best 

available control technology (BACT) is expected to be used and would be required if emissions for 

the project where determined to exceed PSD Class II limits under USEPA or ADEC air quality 

regulations. 

Effects from Natural Gas Production 

The types of emissions sources and their emission rates would not be significantly different from 

those associated with oil production alone. The main sources of emissions during gas production 

would include: 

 production equipment, including generators, turbines, pumps, gas compression equipment, 

boilers, heaters, and storage tanks; 

 gas processing at the onshore facility; and 

 support activities, including vessel and aircraft traffic. 

The main source of offshore emissions during the production phase would be from turbines used for 

power generation, gas compression, oil pumping, and water injection. Other sources of emissions 

would be evaporative losses of VOCs from tanks, pumps, compressor seals, and valves. Reductions 

in VOC emissions are expected as a result of equipping tanks and valves with seals designed to 

prevent VOC leakage. VOCs would also be emitted if there were an accidental release of gas emitted 

during flaring and venting. Operators would be required to have a safety flare to safely burn any 

unexpected releases of natural gas. Flaring gas would be done for safety purposes; but it also would 

eliminate most of the VOCs, although some emissions of NOx, carbon dioxide, SO2, and PM would 

be released. 
BOEMRE Sale 193 Revised Draft SEIS 

88 CHAPTER IV. Environmental Consequences 

A significant increase in O3 concentrations onshore is not likely to result from offshore development 

or production. Photochemical pollutants such as ozone are not emitted directly; they form in the air 

from the interaction of other pollutants in the presence of sunshine and heat. Although sunshine is 

present in the Chukchi Sea Planning Area most of each day during summer, temperatures remain 

relatively low (Brower et al., 1988). The World Meteorological Organization maintains a monitoring 

station in Barrow, Alaska that provides continuous measurement of ozone concentrations. The 

station’s recorded data from 1973 to 2010 is available on the Internet (WMO, 2010). The highest 

recorded ozone concentration of 0.0396 ppm occurred in 1996 with a maximum 2010 level of 0.0349 

ppm. Throughout the data history, the highest ozone levels occurred during the fall and winter 

seasons, the period from October through February. Levels are slightly lower in the summer and drop 

to the lowest levels in March and April when concentrations range from 0.007 ppm to 0.013 ppm. 

These measurements are well within the National and State of Alaska 8-hour average O3 standard of 

0.075 ppm. Because the O3 precursor emissions from development and production of a single gas 

field in the Chukchi Sea are expected to be considerably lower than the existing emissions from the 

Prudhoe Bay/Kuparuk/Endicott complex, the gas development and production should not cause any 

O3 concentrations to exceed the 8-hour Federal standard. 

In the 2008 Arctic Multi-Sale Draft EIS for the Beaufort Sea and Chukchi Sea Planning Areas Oil and 

Gas Lease Sales 209, 212, 217, and 221 (USDOI, MMS, 2008a), estimates were made of the total 

emissions of carbon dioxide (CO2) and methane (CH4) from projected oil and gas activities associated 

with the proposed Chukchi Sea lease sales (Sales 212 and 221) (USDOI, MMS, 2008a). Table 1 lists 

the total calculated emissions of CO2 and CH4 for the peak period of activity associated with a 

Chukchi Sea lease sale, as analyzed in the Arctic Multi-Sale Draft EIS, and compares them with the 

total U.S. greenhouse gas emissions for the year 2005. Emissions factors for the various activities 

were largely based on a comprehensive inventory of air emissions from OCS activities in the Gulf of 

Mexico for the year 2000 (Wilson, Fanjoy, and Billings, 2004). 

The global CO2 emissions rate from combustion of fossil fuels for 2005 was estimated to be 28,193 

Tg (USEPA, 2008). The U.S. contribution to this total is about 20% (EPA, 2008c). The estimated 

CO2 emissions from both oil and gas activities resulting from a Chukchi Sea Lease sale are 0.006-

0.008% of 2005 CO2 emissions in the U.S. The estimated CH4 emissions from a Chukchi Sea lease 

sale are 0.0001-0.0004% of 2005 CH4 emissions in the U.S. Natural gas development and production 

from Sale 193 would represent less than half (< 50%) of the estimated CO2 and CH4 emissions 

associated with a Chukchi Sea lease sale. 

Table 1. Projected greenhouse gas emissions from the production activities associated with the Proposed 

Action. 

Greenhouse 

Gas 

Million Metric Tons C02

Equivalent 

Total 2005 U.S. 

Emissions, Million 

Metric Tons C02

Equivalent 

Emission from Chukchi 

Sale as Percentage of 

Total U.S. Emissions 

CO2 0.341 - 0.482 6,089 0.006 - 0.008 

CH4 0.0006 - 0.0020 539 0.0001 - 0.0004 

CO2 + CH4 0.342 - 0.484 6,628 0.005 - 0.007 

The amount of black carbon associated with natural gas production would be relatively small on the 

appropriate global scale; the consumptions of diesel, natural gas, and other fuels produces less black 

carbon as compared to oil and coal; and Clean Air Act regulations would require appropriate 

technological controls of these activities. 

Visibility may be defined in terms of visual range and the contrast between plume and background, 

which determines perceptibility of the plume. For their proposed Liberty Project, BPXA ran the 

VISCREEN model, which calculates the potential impact of a plume of specified emissions for 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 89

specific transport and dispersion conditions. It found noticeable effects on a limited number of 

days—those that had the most restrictive meteorological conditions in terms of visibility—but no 

effects at all during average meteorological conditions. We expect that those results would be 

representative of gas development in the Chukchi Sea Planning Area. 

The effects of emissions from production activities are expected to cause small, local, and temporary 

increases in the concentrations of criteria pollutants. Consequently, we consider the effect of gas 

production on air quality to be low. 

Conclusions 

Minor adverse impacts to air quality would occur from the emissions of diesel reciprocating engines, 

gas turbines, and generators generally associated with development and production activities. 

However, any increase in concentrations of criteria pollutants from these activities would be small, 

local, and temporary. Overall effects would be low and would not exceed any Clean Air Act 

standards. Natural gas development and production would result in a negligible contribution to U.S. 

and global greenhouse gas emissions. The location of such impact could potentially vary under each 

action alternative. The deferral areas incorporated into Alternatives III and IV would remove certain 

air quality impacts (such as emissions from the platform) farther from the coastline and human 

populations. It is also possible that support vessels and aircraft would be forced to travel greater 

distance, leading to greater emissions overall. 

IV.C.3. Lower Trophic Level Organisms 

Several aspects of the new natural gas production scenario could potentially impact lower trophic 

level organisms, specifically installation of a new platform-to-shore pipeline and extended operation 

of the platform and associated infrastructure. Localized and temporary adverse impacts can be 

expected from these activities. Minimal impacts to lower trophic level organisms are expected from 

the expansion of the onshore facility, installation of a gas pipeline across the NPR-A, or other 

components of the natural gas development and production scenario. 

Effects from Natural Gas Development 

Natural gas development and production would be predicated on the existence of oil development and 

production infrastructure. The oil scenario analyzed in the FEIS envisions a single production 

platform with a footprint of several acres. Relatively little additional development would be needed 

for natural gas production to proceed. Most of these new activities, such as recompletion of wells, 

expansion of the topside facility, associated vessel and aircraft traffic, expansion of the shore base, 

and installation of a onshore pipeline across NPR-A would have minimal long-term population level 

impacts on lower trophic level organisms. 

The installation of an offshore pipeline to connect the platform with the onshore facility, however, 

would adversely impact lower trophic level resources. This new offshore gas pipeline would be 

buried about 12 feet deep – deep enough to minimize the potential for disruption from ice keels. The 

pipeline corridor, approximately 70 feet wide, would run parallel to the existing offshore oil pipeline 

over an estimated distance of 30-150 miles, disturbing roughly 1,000-2,000 acres of typical benthic 

organisms. Some of this area will have already been disturbed during installation of the offshore oil 

pipeline. The extent of the area affected could vary under each of the action alternatives in that an 

increase in the areas deferred from leasing could result in an increase in the length of the platform-tocoast offshore gas pipeline. 

This action would disturb a seafloor that is currently inhabited by mollusks (clams) and other fauna 

that are particularly abundant in the northern and northeastern parts of the proposed lease area (Feder 

et al., 1994: Fig. 4b). Recovery times for benthic communities were studied by Conlan and Kvitek 

(2005) as a response to ice gouges in relatively shallow water (12–28 m) in the Canadian high Arctic. 
BOEMRE Sale 193 Revised Draft SEIS 

90 CHAPTER IV. Environmental Consequences 

They found that new scours were recolonized quickly by some animals (such as polychaetes and 

amphipods) but predicted recolonization of the original community would require many years. Two 

ice scours studied for 8 or 9 years achieved only 65–84% recolonization of the original community 

within that time. The fastest recolonization rate (65% in 8 years) might be appropriate for the slightly 

deeper but warmer northeastern Chukchi Sea. The large clams on which walrus usually feed are 

probably some of the last organisms to recolonize disturbed areas. Previous studies had shown that 

when kelp was removed experimentally from boulders in the Beaufort Sea, only 50% of the denuded 

area was recolonized within 3 years. The study concluded that grazing by invertebrates might be a 

reason for the limited recolonization. Recently, recolonization rates were measured for kelp within 

cages that excluded invertebrates (Konar, 2007). However, even within the cages, there was no 

recruitment within 2 years, demonstrating again that kelp recovers very slowly from disturbance. 

Based on these studies, the scenario assumes that the recovery time would require slightly more than 

a decade. The disruption of 1,000 to 2,000 acres of benthic organisms, requiring approximately 10 

years to recover, could cause lethal impacts for those individuals in the affected area, but would not 

cause population-level impacts on a regional scale. Any overlap between the new offshore gas 

pipeline corridor and the existing offshore oil pipeline corridor would minimize the distribution of 

adverse impacts. 

The anchoring of vessels supporting various gas development activities will cause some continuing 

bottom disturbance on a small scale. These adverse impacts are expected to be temporary and minor. 

Effects from Natural Gas Production 

Natural gas production under Chukchi Sea Lease Sale 193 would cause little to no adverse impacts to 

lower trophic level organisms. No additional drilling at the production platform would occur, 

precluding additional disturbance and greatly reducing the potential for most discharges. It is 

expected that any gas produced under Sale 193 would be dry gas. If present, any produced water will 

be of minimal quantity. Any remaining produced water in the gas stream would be separated, treated, 

and injected into the subsurface through a disposal well. This would remove produced water as a 

potential source of water quality degradation. 

In the event of a large release of natural gas, primary concerns to benthic environments are the 

pressure of the outflow, makeup of the gas concentrates (and percentages of gas solids), mud or 

sediment components, and physical factors causing dispersal of ejected materials in the immediate 

affected environments (Solheim and Elverhoi, 1993). Pressure of gas deposit will determine both the 

amount of methane escaping from the site and the force at which it will be ejected from the subbenthic surface. In turn, the amount of force combined with percentage of mud, silt, or sand will 

directly affect the plume ejected from the blowout site and the capacity of the resulting discharge to 

be deposited in the areas adjacent to the blowout site (Rye, Brandvic, and Strom, 1997). Plumes with 

higher density, or higher sand content, will be deposited at shorter distances from the blowout site 

relative to high percentages of silt or mud, which would be suspended in the water column and 

deposited farther from the well site (Johansen, 2000). Physical factors, such as current direction and 

speed, wind speed and direction, and presence or absence of ice cover, will influence the deposition 

on nearby benthic environments (Birtwell and McAllister, 2002). Deposition of ejected substrate 

material onto nearby benthic resources could severely affect the capacity of localized resources to 

support benthic and epibenthic invertebrate and vertebrate populations, including Essential Fish 

Habitat, for one or more years. However, recovery would occur in less than three generations, and 

overall impacts would be considered minimal and not significant. 

Conclusions 

Several components of the natural gas development scenario, such as installing an offshore gas 

pipeline and anchoring vessels, have the potential to impact lower trophic level organisms. However, 

these impacts would be localized and temporary, given the strong expectation of recolonization. As a 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 91

result, no adverse long-term population level impacts to lower trophic level organisms are expected to 

result from natural gas production. Therefore, no significant adverse effects on this resource would 

occur. 

IV.C.4. Fish Resources 

Activities which directly impact habitat or produce high levels of noise or pollution can measurably 

affect fish populations. Relevant impacts can include short- and long-term displacement from work 

areas due to emitted underwater sounds and sediment plumes, short-term losses of seafloor habitats, 

and multiyear injury/mortality in a “zone-of-influence” near sources of pollution. Some fish, 

particularly sedentary or bottom-obligate fish, could be harmed or killed under the above conditions. 

Pelagic swimming fish are more able and likely to avoid these activities. 

The following activities associated with the natural gas development and production scenario have the 

potential to affect fish: trenching seafloor to place a gas pipeline from platform to shore; regulated or 

unregulated discharges from platform; vessel noise; platform operating noise; and pipeline 

construction across NPR-A. These activities would overlap marine and freshwater salmon EFH 

(adult, juvenile, eggs) and Arctic cod marine EFH (adult, juvenile) in some areas. The potential 

effects would include: physical disturbance of fish habitat; alterations in quality of water in which fish 

occur; disturbance, startle or displacement from noise; exposure of sedentary fish to discharges and 

repetitive noise. Some of these negative effects would be temporary and negligible; other negative 

effects (such as benthic habitat trenching and disturbance to spawning behavior or habitat) would 

have longer-term effects. 

Effects from Natural Gas Development 

Relatively little additional development would be required to transition from oil production activities 

to natural gas production activities. There are some components of the natural gas development 

scenario, however, that could affect fish resources by disturbing portions of the Chukchi seafloor or 

by producing relatively high levels of noise. 

Seafloor Disturbance 

One activity that would cause direct disturbance of the seafloor is vessel anchoring, which may be 

necessary to support the development (and production) of natural gas. Anchoring could cause both 

direct and indirect impacts to fish resources. Direct impacts could occur if fish are crushed or injured 

during anchoring or weighing anchor. Indirect impacts to fish resources may occur should an anchor 

damage sessile organisms (e.g., kelp) or their habitats (e.g., boulders). Such damage is possible under 

certain conditions when anchors fail to hold fast and drag across the seafloor. Anchoring in fragile 

areas (e.g., kelp beds) likely would yield more damage to fish resources and habitat than anchoring 

offshore in sand or mud. There are a few kelp beds in the Chukchi Sea, but they are located nearshore 

or in coastal lagoons, unlikely sites for a vessel to anchor unless necessary for safety. The magnitude 

of any damage to the seafloor would depend chiefly on exactly where anchors were placed, whether 

an anchor drags, and what an anchor might drag across. Direct impacts to benthic fish habitats would 

be restricted to the anchoring site, and these limited areas would be very small compared to the total 

area of benthic habitat available. These negative impacts are considered negligible. 

The installation of new gas pipelines could also cause direct and indirect impacts to fish resources. 

The offshore gas pipeline would extend shoreward from the production platform for a distance of 

between 30-150 miles. Trenching would be necessary to protect against damage by ice in all water 

depths under 165 ft (50 m). Both trenching and actual pipelaying would take place during the short 

open-water season or during mid- to late winter, when landfast ice has stabilized. In addition to 

disturbing a long corridor of seafloor, trenching would temporarily increase turbidity around the 

project footprint. Depending on the nature of the substrate, this turbidity could either remain for short 

amounts of time or be moved offsite into other areas. At a coastal landfall, the pipeline likely would 
BOEMRE Sale 193 Revised Draft SEIS 

92 CHAPTER IV. Environmental Consequences 

be elevated on an existing, short gravel causeway (assuming one is constructed during the oil 

development phase) to protect it against shoreline erosion. Overall, installation of the new offshore 

gas pipeline would cause direct and indirect impacts similar to vessel anchoring, but would do so on a 

much larger scale. Though adverse impacts would be expected, they would remain temporary and 

localized. The extent of the area affected could potentially vary under each of the action alternatives 

in that an increase in the areas deferred from leasing could result in an increase in the length of the 

platform-to-coast offshore gas pipeline. 

The potential for adverse impacts would be minimized through the applicable regulatory processes 

implemented by BOEMRE and other Federal agencies. Pipeline permit applications to BOEMRE 

include the pipeline location drawing, profile drawing, and other relevant information. The BOEMRE 

evaluates the design and fabrication of the pipeline and prepares an additional NEPA analysis. All 

pipeline rights-of-way that go ashore require an EA if not an EIS. The NMFS and FWS also review 

and provide comments on applications for pipelines that are near certain sensitive biological 

communities. The BOEMRE will not approve a proposed pipeline route if any bottom disturbing 

activities (from the pipeline itself or from the anchors of lay barges and support vessels) encroach on 

any biologically sensitive areas. 

The onshore gas pipeline across NPR-A also has the potential to adversely impact fish resources. 

However, there exist many more opportunities to proactively avoid or at least minimize potential 

adverse impacts. Installation of the long overland gas pipeline across NPR-A would likely occur in 

the winter months when tundra travel is feasible. The pipeline itself would be elevated on vertical 

supports and utilize the same corridor as the overland oil pipeline, which would already be in place. 

Appropriate avoidance and mitigation measures would be expected to result from the regulatory 

processes that apply to such projects. Post-landfall pipeline and associated maintenance-road 

alignment would depend on a number of factors, including cost and distance and avoidance of 

wetlands and other sensitive habitats as dictated by Federal policy and law. These policies would 

guide reductions in direct construction impacts on fish-bearing streams and lakes through mitigation 

efforts such as clear-span crossings, setbacks, and sediment- and erosion-control measures. Future 

facility locations would be evaluated on a site-specific basis to avoid or minimize adverse 

construction-related impacts to fish habitats that could be affected by the proposed sale. These 

construction activities are anticipated to result in temporary and/or localized adverse impacts to fish 

and fish habitats, but recovery would be expected to occur in fewer than three generations. 

Noise 

Marine organisms have evolved a plethora of ways to sense their environment and use these senses to 

provide information that allows them to communicate and to find their way. Most relevant to this 

discussion, fish can detect sounds (Popper et al., 2003) and changes in water-current (Coombs and 

Braun, 2003). Loud noises or intense changes in water pressure can elicit a startle response and 

disrupt fish behavior on individual and group levels. Although no additional seismic activities or well 

drilling would occur, two components of the natural gas development and production scenario would 

produce enough noise to potentially affect fish: vessel traffic and pipeline installation. 

Engine-powered vessels may radiate considerable levels of noise underwater. Diesel engines, 

generators, and propulsion motors contribute significantly to the low frequency spectrum. Much of 

the necessary machinery to drive and operate a ship produces vibration, within the frequency range of 

10 Hz-1.5 kiloHertz, with the consequence of radiation in the form of pressure waves from the hull 

(Mitson and Knudsen, 2003). In addition to broadband propeller noise, there is a phenomenon known 

as “singing,” where a discrete tone is produced by the propeller, usually due to physical excitation of 

the trailing edges of the blades. This can result in very high tone levels within the frequency range of 

fish hearing. The overall noise of a vessel may emanate from many machinery sources. Pumps in 

particular often are significant producers of noise from vibration and, at higher frequencies, from 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 93

turbulent flow. Sharp angles and high flow rates in pipework can also cause cavitation, and even 

small items of machinery might produce quite high levels of noise. Some, but not all relevant studies 

have noted avoidance behavior by fish subjected to loud noises from a vessel. Data also suggests that 

abnormal fish activity may continue for some time as the vessel travels away. However, vessel noise 

is inherently transient, rendering adverse impacts temporary. Fishes in the immediate vicinity of 

vessels may also exercise avoidance. In light of the above, vessel noise is likely to be of negligible 

impact to fish resources. 

Noise-related disturbance effects on fish and direct loss or degradation of fish habitats are likely to 

occur during construction in the marine environment. The new offshore gas pipeline is no exception 

to this general rule. Potential pipeline locations would be evaluated on a site-specific basis to avoid 

or minimize adverse construction-related impacts to fish habitats. The installation of the new pipeline 

would be anticipated to result in temporary and/or localized adverse impacts to fish and fish habitats. 

The minimum potential length of both the offshore gas pipeline as well as support vessel travel routes 

could vary under each action alternative given the fact that two alternatives include deferral areas of 

varying size. 

Effects from Natural Gas Production 

Noise 

The production platform would require continued servicing from vessels which, as discussed above, 

produce noise when in transit. Vessel activity would be less frequent and be generally restricted to an 

area between the drill site and a land-based support site. Additional noise may occur through other 

aspects of gas production. All of these noise impacts, however, would have a negligible effect on fish 

resources. 

Pollution 

Although salmon and other fish species have exhibited sensitivity to polycyclic aromatic 

hydrocarbons (PAH) and pollutants associated with industrial activities, applicable regulations place 

strict standards on all production activities, and nothing within the natural gas production scenario 

analyzed here exhibits real potential to measurably impact fish resources through pollution. 

Release of Natural Gas 

Although most natural gas eventually rises to the surface of the water, some enters the water as a 

water-soluble fraction. This can include hydrocarbon mixtures that trigger behavioral and 

physiologic responses in adult and juvenile fish and present toxicity exposure to adult and juvenile 

fish, eggs and larvae. Depending on the size of the event, the toxicity effects on fish populations in 

the region would be negligible to minor. Fish life stages would also be exposed to physical aspects of 

a gas blowout or rupture at depth through sound produced by the explosion and release; pressure 

waves caused by the release; and bubble release, travel, and collapse. Behavioral, physiological or 

physical effects could occur as a result of adults, juveniles, larvae, and eggs being exposed to these 

physical effects of a natural gas blowout or rupture. Depending on the size of the event, the physical 

effects would be negligible to minor on fish populations in the region. 

Conclusions 

Several types of direct and indirect impacts would occur as a result of the natural gas development 

and production scenario. Direct impacts, however, would be minimized by the ability of many fish to 

avoid disturbance and flee from areas of high noise. Indirect impacts would occur to seafloor habitat 

from pipeline installation and anchoring. These effects cannot be avoided, but would likewise remain 

localized, temporary, and minor. Consequently, no significant adverse effects would occur. 
BOEMRE Sale 193 Revised Draft SEIS 

94 CHAPTER IV. Environmental Consequences 

IV.C.5. Essential Fish Habitat 

The following activities associated with the natural gas production and development scenario were 

analyzed for their potential to impact Essential Fish Habitat: trenching seafloor to place a gas pipeline 

from platform to shore; regulated or unregulated discharges from platforms; vessel noise; platform 

operating noise; and pipeline construction across NPR-A. These activities would overlap with marine 

and freshwater salmon EFH (adult, juvenile, eggs) and Arctic cod marine EFH (adult, juvenile) in 

some areas. It is also possible that certain activities could impact opilio crab EFH and saffron cod 

EFH, both of which are located in relatively close proximity to the lease sale area. The potential 

impacts would include: physical disturbance of fish habitat; alterations in quality of water in which 

fish occur; disturbance, startle, or displacement from noise; and exposure of sedentary fish to 

discharges and repetitive noise. Some of these impacts would be temporary and negligible; others 

(such as benthic habitat trenching and disturbance to freshwater spawning areas) would have longerterm impacts on habitat. 

A separate EFH consultation document is being developed and will be transmitted to NOAA 

Fisheries this summer. That document will contain BOEMRE’s formal EFH determination. Any 

resulting conservation recommendations from NOAA Fisheries can be incorporated into the Final 

SEIS. 

Effects from Natural Gas Development 

With respect to natural gas development, trenching and the installation of new gas pipelines is the 

only component likely to impact Essential Fish Habitat. Two separate pipelines would be built under 

this scenario. An offshore gas pipeline would extend shoreward from the production platform for a 

distance of 30-150 mi. Trenching would be necessary to protect against damage by ice in all water 

depths less than 165 ft (50 m). Both trenching and actual pipelaying would take place during the 

short open-water season or during mid- to late winter, when landfast ice has stabilized. In addition to 

disturbing a long corridor of seafloor, trenching would temporarily increase turbidity around the 

project footprint. Depending on the nature of the substrate, this turbidity could either remain for 

short-amounts of time or be moved offsite into other areas. At a coastal landfall, the pipeline likely 

would be elevated on a short gravel causeway to protect it against shoreline erosion. Overall, 

installation of the new offshore gas pipeline would cause direct and indirect impacts similar to vessel 

anchoring, but would do so on a much larger scale. Though negative impacts to marine salmon as 

well as Arctic and saffron cod would be expected, they would remain temporary and localized. 

The potential for negative impacts would be minimized through the applicable regulatory processes 

implemented by BOEMRE and other Federal agencies. Pipeline permit applications include the 

pipeline location drawing, profile drawing, and other relevant information. The BOEMRE evaluates 

the design and fabrication of the pipeline and prepares an additional NEPA analysis. All pipeline 

right-of ways that go ashore require an EA if not an EIS. The FWS also reviews and provides 

comments on applications for pipelines that are near certain sensitive biological communities. Lease 

Stipulation No 1—Protection of Biological Resources—which requires lessees to survey for, as well 

make every reasonable effort to preserve and avoid areas of biological significance—would further 

mitigate potential a negative impacts to EFH. 

An onshore gas pipeline across NPR-A would also be necessary, and it too would have the potential 

to negatively impact Essential Fish Habitat. The onshore pipeline has comparatively less potential to 

impact these resources, given the greater opportunities to avoid or at least minimize potential adverse 

impacts when working onshore. Installation of the long overland gas pipeline across NPR-A would 

likely be in the winter months when tundra travel is feasible. The pipeline itself would be elevated on 

vertical supports and utilize the same corridor as the overland oil pipeline, which would already be in 

place. Appropriate avoidance and mitigation measures would be expected to result from the 

regulatory processes that apply to such projects. Post-landfall pipeline and associated maintenance-
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 95

road alignment would depend on a number of factors, including cost and distance and avoidance of 

wetlands and other sensitive bird and wildlife habitats as dictated by Federal policy and law. These 

policies would guide mitigation efforts to reduce direct construction impacts to fish-bearing streams 

and lakes such as clear-span crossings, setbacks, and sediment- and erosion-control measures. Future 

facility locations would be evaluated on a site-specific basis to avoid or minimize adverse 

construction-related impacts to fish habitats that could be impacted by the proposed sale. These 

construction activities are anticipated to result in temporary and/or localized adverse impacts to fish 

and fish habitats, but recovery would be expected to occur in fewer than three generations. 

Effects from Natural Gas Production 

Little additional impact to Essential Fish Habitat is expected to result from continued production 

activities. Minor and temporary noise impacts from vessel traffic could impact each species’ EFH, 

including the opilio crab. In the event of a large-scale natural gas release, the chemical and physical 

water column environment of Arctic cod Essential Fish Habitat would be impacted temporarily or on 

a short-term basis, and at a negligible to minor level. Noise and a potential natural gas release could 

also negatively impact habitat that, while not officially designated at present, is most likely used by 

saffron cod and opilio crab during their larval stages. 

Conclusions 

Installation of natural gas pipelines is the only development activity associated with the natural gas 

development and production scenario likely to cause more than negligible impacts to EFH. The 

onshore pipeline is expected to avoid any serious negative impacts (such as obstructing streams or 

disturbing spawning areas) by virtue of its raised design and later site-specific review (including EFH 

consultation, if BOEMRE determines that the action may adversely affect EFH). The offshore 

pipeline would cause notable, but very localized impacts within a relatively narrow corridor. The size 

of the area affected by the pipeline would increase with the size of the coastal deferral selected. Both 

the onshore and offshore pipelines would be subject to rigorous additional regulatory review. In 

terms of natural gas production activities, negative impacts to Essential Fish Habitat would only be 

anticipated in the event of a large-scale natural gas release or other accident (such as an unpermitted 

discharge). Overall, negative impacts to EFH from natural gas development and production would be 

temporary and localized, and would not rise to the level of significance. 

IV.C.6. Whales – Threatened and Endangered 

The aspect of natural gas development and production posing the greatest risk of impacts to whales is 

noise. Generally speaking, noise impacts on cetaceans can range from behavioral change (avoidance 

response, altered travel routes, etc.) to physical harm such as hearing loss, the latter of which can 

result (in serious cases) in an inability to communicate, detect, and/or echolocate. Sometimes even 

relatively low levels of noise not directly harmful to a whale itself can “mask” naturally-occurring 

noises upon which whales rely in order to perform basic functions such as communication, 

echolocation, and feeding. Noise impacts to cetaceans are largely dependent on the specifics of a 

given situation: i.e. the species affected; the age, sex and reproductive status; the accumulated hearing 

damage of an individual; and/or the size of the group of whales affected. Visual assessment of 

impacts can be problematic, as negatively impacted whales may continue certain behavior (e.g. 

feeding or migration) out of necessity. 

The primary concern here is whether natural gas development and production activities could produce 

noise and disturbance sufficient to cause bowhead, fin, or humpback whales to avoid high value 

areas, thereby risking biological consequences. The analysis below focuses on the potential effects 

on bowhead whales from natural gas development and production in the Chukchi Sea OCS. Fin and 

humpback whales are expected to react to natural gas development and production activities similarly 

to bowhead whales in terms of avoidance behavior, migration route alteration, or displacement from 
BOEMRE Sale 193 Revised Draft SEIS 

96 CHAPTER IV. Environmental Consequences 

feeding areas; however, species specific thresholds for response may be different in some cases. 

Further, effects on fin and humpback whales would be limited to a few individuals because of the low 

numbers of these species that occur in the Chukchi Sea Planning Area. Impacts to each of these 

species could vary under each action alternative, given the different respective minimum distance 

from shore at which the platform could be constructed. 

Effects from Natural Gas Development 

Activities associated with the development of natural gas that could cause adverse impacts to 

Threatened and Endangered whales are the transit of marine vessels and aircraft, installation of an 

offshore gas pipeline, and to a lesser extent, recompletion of existing wells and expansion of the 

topside facility and shore base. 

Potential Effects from Vessel Traffic 

Gas development activities would lead to a temporary increase in vessel traffic to service the existing 

platform and support the installation of a new offshore gas pipeline. Some marine vessels including 

sealift and other barges and boats (but not including icebreakers) would be used in natural gas 

development activities. It is conceivable that cetaceans could be disturbed or struck by these vessels. 

As noted in discussion of the affected environment, baseline information indicates that current rates 

of vessel strikes of bowheads are low. At present, available data do not suggest that strikes of 

bowheads by oil and gas-related vessels will become an important source of injury or mortality. 

The greater issue is noise. Bowheads react to the approach of vessels at greater distances than they 

react to most other industrial activities. According to Richardson and Malme (1993), most bowheads 

begin to swim rapidly away when vessels approach rapidly and directly. This avoidance may be 

related to the historic commercial and continuing subsistence hunting. Avoidance usually begins 

when a rapidly approaching vessel is 1-4 km (0.62-2.5 mi) away. A few whales may react at 

distances from 5-7 km (3-4 mi), and a few whales may not react until the vessel is <1 km (<0.62 mi) 

away. Received noise levels as low as 84 dB re 1 μPa (decibels relative to one micropascal) or 6 dB 

above ambient may result in strong avoidance of an approaching vessel at a distance of 4 km (2.5 mi) 

(Richardson and Malme, 1993). Vessel disturbance has been known to disrupt activities and social 

groups. Fleeing from a vessel generally stopped within minutes after the vessel passed, but scattering 

may persist for a longer period. Parks et al. (2011) note for North Atlantic right whales (a species 

similar to bowhead whales) and Holt and Noren (2008) note for killer whales that individuals 

modified calls in response to increased background and vessel noise, respectively, by increasing the 

amplitude of their calls. McDonald, Hildebrand, and Mesnick, however, noted the decline in blue 

whale song tonal frequencies was not fully explained by the hypothesis of increasing ocean noise. But 

these authors put forth a testable hypothesis that post whaling population increase is altering sexually 

selected trade-offs for singing males between song intensity (ability to be heard at a greater distance) 

and song frequency (ability to produce songs of lower pitch). 

Where vessels approach slowly or indirectly, bowheads are much more tolerant, and reactions are 

generally less dramatic. The encounter rate of bowhead, humpback, and fin whales with vessels 

associated with natural gas development would depend on the location of the platform in relation to 

both shipping routes and areas of heavy use. During their spring migration (April through June), 

bowheads likely would encounter few, if any, vessels along their migration route, because ice at this 

time of year typically would be too thick for supply vessels to operate in. Bowheads, humpback, and 

fin whales probably would adjust their individual swimming paths to avoid approaching within 

several kilometers of vessels attending the production platform, and would also move away from 

vessels that approached them within a few kilometers (Richardson, et al., 1995, pp. 262-272). 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 97

Potential Effects from Aircraft Traffic 

Gas development activities involve small and temporary increases in air traffic within the action area. 

Fixed wing aircraft may serve as whale spotters during pipeline route surveys or pipeline installation 

activities in the nearshore areas. The use of spotter aircraft could be an important mitigation 

technique that would reduce the overall potential for gas development to cause adverse impacts to 

whales. Helicopters are likely to be used to transport crews and supplies in support of modification of 

the production platform for gas development. Aircraft noise may elicit a response, such as a turn or 

hasty dive, from a whale or group of whales. But given the altitude at which these aircraft are 

expected to fly, the potential for adverse reactions is small. Any impacts that did occur would be 

temporary and minor. Under Alternatives III and IV, the minimum travel route to a platform would 

be longer. 

Potential Effects from Construction Activities 

Natural gas development would entail a variety of construction-type activities, to include expansion 

and maintenance of the topside facility and the onshore base, and most notably, installation of an 

offshore gas pipeline. These activities can impact Threatened and Endangered marine mammals in 

that they are relatively noisy. Both expansion projects would produce noise from stationary locations, 

and could thus be largely avoided by baleen whales. Despite the long, linear nature of pipelines, their 

construction is a slow-moving, relatively stationary operation. Thus, pipeline construction represents 

a similarly temporary and avoidable source of disturbance. To avoid or minimize adverse impacts, 

relevant organizations (i.e., project proponents, BOEMRE, NMFS) will need to develop timing 

guidelines and operational protocols to govern the specifics of this project. This review would take 

place at a later stage of review, when more site-specific information would be known. 

Potential Effects from Abandonment 

Some adverse impacts to whales may also occur during abandonment of natural gas production wells 

and the offshore gas pipeline. Abandonment operations include plugging and abandoning wells, 

decommissioning subsea pipelines, and removal of production equipment and platforms. Established 

procedures and regulations govern all these operations. Pipelines are flushed/cleaned and then 

usually left in place buried below the seafloor surface. Production equipment would be partly 

disassembled and then moved off the platform during the summer open-water season. These 

activities are not expected to cause impacts to whales, apart from the possibility of vessel noise 

impacts as analyzed above. 

Abandonment of wells, meanwhile, involves a very slight potential for more serious adverse impacts. 

During abandonment, wells usually are permanently plugged with cement after the wellhead 

equipment is removed. The casings for delineation wells usually are cut mechanically or with small 

explosive charges. The use of explosives could result in injury or even death to threatened and 

endangered marine mammals in the area at the time of the explosions. Extensive monitoring (e.g. 

aerial surveys and passive acoustic monitoring) and implementation of mitigation to prevent 

harassment or injury would reduce the potential for adverse impacts. Overall, impacts from 

abandonment are expected to be low. 

Studies of gray, bowhead, and humpback whales have shown that received levels of impulses in the 

160-170 dB re 1 μPa range appear to cause avoidance behavior in a significant portion of the animals 

exposed. Any activity causing noise reaching these levels would risk level B “harassment” take of 

whales, and require a take authorization under the MMPA. Additional mitigation measures required 

to avoid significant adverse impacts would be required by later BOEMRE and NMFS review 

processes. Detailed analysis of potential Exploration Plans and Development & Production Plans, 

along with mitigation measures incorporated into any necessary Incidental Take Authorizations 

(ITA), would further reduce the potential for any significant adverse impacts 
BOEMRE Sale 193 Revised Draft SEIS 

98 CHAPTER IV. Environmental Consequences 

Effects from Natural Gas Production 

Potential Effects from Disturbance 

During natural gas production, operation and maintenance of the platform and related infrastructure 

could potentially affect ESA-protected cetaceans by introducing additional noise into local waters. 

Given the relatively low noise levels associated with normal production activities, and the fact that 

whales appear to exhibit less avoidance behavior with stationary sources of relatively constant noise 

than with moving sound sources, any such impacts would be temporary, avoidable, and minor. 

Air support for crew rotations and supply deliveries would continue for gas production activities on 

the platform. This air support would consist of turbine helicopters flying along straight lines, making 

roughly one to three trips per day. Most bowheads are unlikely to react significantly to occasional 

single passes by low-flying helicopters ferrying personnel and equipment to offshore operations. In 

fact, most bowhead whales exposed to helicopter overflights were observed to exhibit no obvious 

response to helicopter overflights at altitudes above 150 m (500 ft). Other studies confirm that peak 

sound levels received underwater diminished with increasing aircraft altitude. At altitudes below 150 

m (500 ft), some bowheads probably would dive quickly in response to the aircraft noise (Richardson 

and Malme, 1993). However, bowhead reactions to a single helicopter flying overhead probably are 

temporary (Richardson et al., 1995a). This noise generally is audible for only a brief time (tens of 

seconds) if the aircraft remains on a direct course, and the whales are likely to resume their normal 

activities within minutes. Mitigation measures (whether implemented via BOEMRE policy, NMFS 

Incidental Take Rules, Section 7-ESA consultations, or other sources) which prescribe minimal 

altitudes for aircraft transiting through the action area will serve to further reduce potential impacts. 

Potential Effects from a Natural Gas Release 

The scenario for gas production entails the conversion of existing oil wells on production platforms to 

gas/gas condensate wells after oil recovery has been ongoing. There would be a period of years where 

oil and gas production would overlap. Accidental spills of condensates and oil were analyzed in 

USDOI, MMS (2007). Released gas would be expected to be dry gas with no condensates or water. 

There would be no effects on cetaceans from an onshore gas facility, including pipelines. 

Effects from atmospheric release of natural gas from production platform facilities would have no 

effect on cetaceans unless explosion or fire results. Rapid dissipation of the lighter than air 

components of gas into the atmosphere and the localized short term nature of a release minimize the 

time of exposure and potential inhalation of fumes by cetaceans, and effects would be minor to 

negligible. In such cases the visible presence of fire and smoke plumes, emergency activities to 

control the event and the noise from an explosion would have potential temporary effects. Cetaceans, 

including bowhead, fin and humpback whales normally avoid noise and human activity similar to 

those occurring during control activities and operational noise from platforms. Noise from an 

explosion would be a single instant event and non-lethal to cetaceans. 

Effects are possible in the event that a gas release occurs. An accident involving an ocean-bottom 

well-control device failure or undersea gas transport pipeline release could result from corrosion, 

breaks or other factors, and lead to a gas release. Undersea pipeline releases would be short term (up 

to one day) and limited to the volume of gas/condensate present between pressure-sensitive control 

valves—up to 10 million cubic feet of gas—that close when pressure is lost. Volume of 

gas/condensate is also dependent on pipe diameter and distance between control valves. Releases 

would be local and in the immediate area of the release. Methane and ethane natural gas components 

would likely bubble to the surface and dissipate in the atmosphere, given the shallow depths of the 

Chukchi Sea. Toxic effects upon baleen whale prey items would be negligible considering the low 

volume, short duration, rapid dissipation, and localized nature of a release. During the spring 

migration of bowhead whales and beluga whales through the spring polynya system or spring lead 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 99

system (SLS), a temporary disruption of migration is possible if release/explosion/control activities 

occurred during the migration period, or when migrating animals are present and migrating through a 

release area. Short-term, non lethal avoidance of activity or startle behavior in response to an 

explosion or short-term release would be expected. Also, there is the potential for a short-term delay 

in migration or a detour movement avoiding the localized area of release. This would be considered a 

minor effect with no mortality or injury expected. Cavitation noise from the gas bubbles would be of 

short duration and dependent on the rate of gas release, but is not anticipated to reach levels that 

would injure or cause temporary hearing loss by cetaceans. It could, however, reach levels that may 

induce a startle or local avoidance response. 

There are a number of considerations regarding effects of a major natural gas release under icecovered conditions. First are the relationships among temperature (at the ice/water interface), 

condition of the ice (relative to motion), stress cracks, flaw zones, and leads. Second is the presence 

of beluga, bowhead, ice seals and other pagophillic species. Bowheads and belugas would be present 

in the Lease Sale 193 area (associated with the spring lead and polynya system) in the months of 

March through June of the ice cover period. During this period the mean sea-ice interface 

temperature is greater than -2.2 °C which is the threshold temperature whereby brine channels 

provide a pathway for encapsulated or trapped methane to the atmosphere. At temperatures below -2 

°C gas ice continues to form downward, encapsulating gases within the ice. Estimates range from 18 

to 72 hours for released and subsequently trapped gas beneath the ice to be encapsulated (when ice is 

forming beneath the ice sheet) depending on the time of year. Whales and sea mammals associated 

with the moving ice and broken ice found in leads and polynyas, flaw zones, stress cracks, and open 

water areas would rarely have large pockets of trapped methane available at the ice-seawater 

interface, because the diffuse fractures and open water areas would rapidly move methane gas 

through the ice and into the atmosphere. A large release of methane could also rupture the ice sheet 

and thus provide rapid movement of methane to the atmosphere. The possibility for methane trapped 

in large pockets is further reduced by movement and dispersal of methane bubbles through the water 

column. Moreover, currents and entrapment in small volumes will disperse bubbles of gas over a 

wide area due to the micro roughness of the bottom surface of the ice. 

Breathing holes visited by ice seals and polar bears provide for a rapid venting of methane to the 

atmosphere and pose little risk to these species. Conceptually, some ringed seal dens could 

temporarily concentrate escaping methane as it slowly vents through the snow roof of such dens. 

The deferral areas incorporated into Alternatives III and IV could increase the distance of a potential 

release from the platform to areas receiving more bowhead use. However, the probability and 

severity of any impacts associated with a release from the onshore facility would remain the same, 

and the risks associated with a release from the offshore pipeline, although remaining quite small, 

could increase with a lengthier pipeline. 

Conclusions 

Natural gas development and production could result in increased noise and disturbance to bowhead, 

fin, and humpback whales. Bowhead, fin, and humpback whales exposed to noise-producing 

activities such as vessel and aircraft traffic, construction activities, and production activities most 

likely would experience temporary, non-lethal effects. There is variability in whale response to 

certain noise sources; this variability appears to be context specific (e.g., feeding versus migrating 

whales) and also may be related to reproductive status and/or sex or age. Overall impacts to bowhead 

whales are expected to be temporary, non-lethal, and minor; effects on fin and humpback whales are 

expected to be temporary, non-lethal, and negligible. 
BOEMRE Sale 193 Revised Draft SEIS 

100 CHAPTER IV. Environmental Consequences 

IV.C.7. Polar Bears – Threatened and Endangered 

To date, documented impacts to polar bears in Alaska by oil and gas development activities are few. 

The potential for adverse impacts is largely associated with increases in industrial activity or 

expansion of industrial footprints, as well as related increases in human/polar bear interactions. 

Because the development and production of natural gas stemming from Sale 193 would be predicated 

on existing oil production infrastructure, increases to the industrial footprint would be quite small 

when viewed on a regional scale. Minimal impacts could result from the potential increase in 

human/polar bear interactions associated with expanding the onshore facility, installing the offshore 

and onshore pipelines, and extending the production timeframe within the action area. The FWS and 

USGS have predicted that polar bears may be extirpated throughout much of their range within the 

next 40 to 75 years if current trends in sea ice reduction continue (73 FR 28212 [15 May 2008]). 

Nonetheless, impacts to bears as a direct result of oil and gas development activities appear to be 

minimal. 

Effects from Natural Gas Development 

The construction of new infrastructure in polar bear habitat has the potential to adversely impact these 

animals through disturbance and displacement. The offshore gas pipeline would require a relatively 

narrow corridor through designated polar bear Critical Habitat. Once buried, the pipeline would be 

under sea ice habitat for most of the year. The offshore pipeline would be installed during the open 

water season, and would be buried in the seafloor. Vessel traffic associated with natural gas 

development activity is not expected to cause impacts to polar bears, because they show little reaction 

to vessels and generally do not linger in open water where vessels are more likely to travel. As 

explained in the BO (USDOI, FWS, 2009), “During the open-water season, most polar bears remain 

offshore on the pack ice. Barges and vessels transporting materials for construction and on-going 

operations of facilities usually travel in open-water and avoid large ice floes. Therefore, there is some 

spatial separation between vessels and polar bears.” If there is an encounter between a vessel and a 

bear, it would most likely result in short-term behavioral disturbance only. Polar bear responses to 

vessels are brief, and generally include walking toward, stopping and watching, and 

walking/swimming away from the vessel. 

Extensive or repeated overflights by helicopters travelling to and from offshore facilities could disturb 

polar bears. Polar bears have been known to run from other sources of noise and the sight of aircraft, 

especially helicopters. According to the BO (USDOI, FWS, 2009), “Behavioral reactions of polar 

bears would likely be limited to short-term changes in behavior and have no long-term impact on 

individuals. In addition, [BOEMRE] requires these types of flights to operate at an altitude of >1,500 

ft above ground level where possible, which would significantly reduce disturbance.” It is expected 

that flight altitude requirements will minimize disturbances, and that adverse impacts from this 

activity will be temporary and minimal. 

Pipeline construction could cross barrier island and nearshore coastal habitats. Polar bears may be 

temporarily displaced, or their behavior modified (e.g., by changing direction or speed of travel), by 

construction activities. As explained in the BO (USDOI, FWS, 2009), “Disturbance from stationary 

activities could elicit several different responses in polar bears. Noise may act as a deterrent to bears 

entering the area, or conversely, it could attract bears. Bears attracted to development facilities may 

result in human–bear encounters, leading to unintentional harassment, or intentional hazing of the 

bear.” Mitigation measures (such as implementation of a human-bear conflict management plan) 

generally required under MMPA Incidental Take Authorizations (typically a Letter of Authorization) 

would reduce the potential for these impacts. Any adverse impacts would be localized and negligible. 

Under the Final Rule designating Critical Habitat for polar bears, terrestrial denning habitat (Critical 

Habitat Unit 2) was not designated along the U.S. Chukchi Sea coastline (75 FR 76086 [Dec. 7, 

2010]). In the Bering and Chukchi seas, the majority of dens that have been documented occur on 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 101

Wrangel and Herald islands, and on the Chukotka Peninsula in Russia. In recent years, sea ice 

formation along the coastline is occurring later in winter, which may preclude access to coastal 

denning areas along the U. S. Chukchi Sea coastline. While the FWS has determined that the 

coastlines of the Chukchi and Bering seas are not critical habitat, some dens may occur along the 

coast. Disturbance at den sites from construction or other human activities could result in a female 

with cubs abandoning the den site, resulting in death from hypothermia or predation to the cubs. 

Should construction activities be proposed near an active den, mitigation measures (such as den 

detection and avoidance) generally required under the Letter of Authorization would reduce the 

potential for these impacts. The raised onshore pipeline would not pose a physical barrier to polar 

bear movement and once away from the coast would not be in polar bear habitats. 

Impacts from overland vehicles such as snowmachines would not result in more than temporary 

disturbance and energy expenditures for bears. 

Effects from Natural Gas Production 

Natural gas production activities would also risk disturbing polar bears. Potential sources of 

disturbance may be grouped as stationary sources (in this case including operations, maintenance, and 

repair activities) and mobile sources (e.g. vessels, aircraft, and vehicle traffic). Natural gas 

production will require the support of vessels, aircraft, and overland vehicles with similar, but less 

frequent effects, described for development activities. 

Data and experience from past and ongoing activities in other portions of northern Alaska suggest that 

polar bears will habituate to or simply avoid gas production operations. The greatest risk to the polar 

bears from ongoing operations is the likely increase in human/polar bear interactions, which could be 

dangerous to both parties. In recent years, much progress has been made in reducing and managing 

these risks. The MMPA ITR provides clear guidance to the oil and gas industry and has been very 

effective at preventing injury to both humans and polar bears. Under the MMPA, since 1991, the oil 

and gas industry in Alaska has sought and obtained incidental take authorization for the take of small 

numbers of polar bears and no polar bears have been killed due to encounters with the current 

industry activities on the North Slope of Alaska (73 FR 28212, [15 May 2008]). Documented direct 

impacts on polar bears by the oil and gas industry operations during the past 30 years are minimal. 

As previously noted, there is a small potential that a large gas release could occur from a platform, 

pipeline, or onshore facility. Impacts to polar bears would be minimal since gas quickly dissipates in 

the atmosphere. Potential impacts could result from a bear in the immediate vicinity inhaling gases; 

however, this is highly unlikely. Breathing holes visited by polar bears provide for rapid venting of 

methane to the atmosphere and pose little risk to the species. Impacts to polar bear critical habitat 

would occur only if an explosion resulted from the release, and these would be very short term. 

Conclusions 

Various aspects of the natural gas development and production scenario have the potential to disturb 

polar bears, but most impacts would be temporary and non-lethal, and would not rise to the level of 

significance. Pursuant to Section 7 of the ESA, BOEMRE has already consulted with FWS regarding 

potential impacts to polar bears from activities that would be authorized under a lease sale, as well as 

impacts from a certain degree of exploration activity. The BOEMRE has re-initiated consultation in 

light of the recent designation of polar bear Critical Habitat. Additional consultation would also be 

required before BOEMRE would approve any Development and Production Plans. The ESA and 

MMPA contain general prohibitions of the unauthorized take of polar bears. OCS operators who 

acquire and adhere to an Incidental Take Authorization (ITA) can avoid liability for incidental take 

under the MMPA. The ITA process would identify and require any additional, site-specific 

mitigation deemed necessary by FWS to preclude the take from causing more than a negligible 

impact to the polar bear population. Current regulations provide that compliance with the terms and 
BOEMRE Sale 193 Revised Draft SEIS 

102 CHAPTER IV. Environmental Consequences 

conditions of an MMPA ITA insures that the ITA holder is also in compliance with the ESA (see 

final special rule published at 73 FR 76249 [December 16, 2008]). ]). Impacts to polar bears from 

natural gas development and production are expected to be similar to those identifies in the FEIS for 

oil development and production. As discussed in the FEIS, the coastal deferrals provide increased 

protection for polar bears. Selection of either the Hanna Shoal deferral or the deepwater deferral does 

not provide additional protections for the polar bear. 

IV.C.8. Marine and Coastal Birds – Threatened and Endangered 

Potential impacts to Threatened and Endangered marine and coastal birds in the Chukchi Sea area 

have been the subject of two recent Biological Opinions, which identified habitat loss, disturbance, 

and displacement as potential causes of adverse impacts relevant to this natural gas development and 

production scenario. The results of FWS analyses are used to inform much of the discussion below. 

Effects from Natural Gas Development 

In regard to development-related issues, FWS explains that “Given the large size of the Program 

Areas, significant impacts from permanent habitat loss in the marine environment are not anticipated. 

However, if facilities are located within the LBCHU, spring leads, or other areas used by large 

numbers or a high proportion of the populations of listed and candidate species, adverse effects could 

occur” (USDOI, FWS, 2009). 

The impacts of terrestrial development, meanwhile, are highly dependent on the specific areas being 

disturbed. Particularly vulnerable to disturbance are nesting birds, which may flush, leaving eggs or 

ducklings exposed; displacement during nesting times can lead to reduced foraging efficiency and 

higher energetic costs. A pipeline for gas delivery is expected to be placed along a future oil pipeline, 

with approximately another 10 m wide fill footprint. Additional facility footprints were not 

considered necessary. The road/pipeline corridor was assumed to be 482.8 km (300 miles) long. 

Consequently, indirect nesting habitat impacts from a gas pipeline construction are estimated to affect 

4.83 km2

 (1193.8 ac). Consistent with previous calculations which used nesting densities of 1.1 

nests/km2

 for spectacled eiders and 0.06 nests/km2 for Steller’s eider, an estimated take of 5.3 

spectacled eiders and <1 Steller’s eider could occur during construction of a gas pipeline. 

It is possible that development infrastructure could attract predators such as Arctic foxes, leading to 

negative impacts to marine and coastal birds. Such impacts, however, are unlikely. Natural gas 

development is not expected to affect bird predator populations (birds and foxes) as changes in the 

shorebase to accommodate gas would be made in such a manner that it would not provide nesting or 

denning sites for these predators. Further, the addition of a gas pipeline between the shorebase and 

the TAPS would be adjacent to an existing oil pipeline/maintenance road, so other birds and foxes 

would not benefit from additional sources of human-use foods or garbage, as no new facilities with 

dumpsters or dumpsites are needed. These food sources could continue to be a problem in coastal 

villages, however. 

Effects from Natural Gas Production 

As with the small amounts of natural gas periodically flared during oil production operations, the 

release and flaring of 10 million ft3

 of natural gas during a one day loss of gas well control would 

affect few birds in the immediate vicinity. Some migrating birds may become disoriented by the 

flare, especially during periods of darkness or inclement weather and could increase their potential for 

colliding with the platform structure. As collisions with structures in the Chukchi and Beaufort seas 

are typically low, the effects on non-listed bird species would be minimal; however, any collision 

mortality of spectacled or Steller’s eiders would be considered a significant adverse effect if these 

bird losses were not recovered within a generation. No adverse effects on coastal and marine birds 

are anticipated from a sudden release of natural gas from a pipeline rupture because the gas would 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 103

typically dissipate into the atmosphere instead of lingering in a localized area where birds could be 

present. 

The one aspect of the natural gas production scenario with the potential to significantly affect 

Threatened and Endangered marine and coastal birds is the risk of collisions with vessels and 

infrastructure. The FWS 2007 BO concludes that approximately 3 adult spectacled eiders and 1 adult 

Steller’s eider could be killed per year through collision with vessels and structures associated with 

the oil development and production scenario outlined in the Sale 193 FEIS. The similarities between 

the oil development and production scenario analyzed in the Sale 193 FEIS and the natural gas 

development and production scenario analyzed here suggest that FWS’ estimated collision rate could 

be useful to the current discussion. If crude strike rates were applied to the production platform (0.4 

strikes/year for spectacled eiders and 0.02 strikes/year for Steller’s eiders), an estimated 8 spectacled 

and 1 Steller’s eider (0.4 round up) could be lost through collisions with a structure located offshore 

over the entire 20 years of gas production. 

The operation of a gas production facility and pipeline would not change the distribution or 

abundance of bird predators as no new sources of nesting/denning sites or access to artificial food 

sources would be generated. Resident fox populations would continue to be affected by winter food 

supply and disease. 

Generally speaking, deferral areas could help reduce impacts by moving activities farther from 

coastal areas that typically exhibit greater bird use. 

Conclusions 

The natural gas development and production scenario analyzed in this SEIS comprises activities that 

are very similar or even identical to those analyzed in the preceding Sale 193 FEIS, and does not 

include some of the higher-risk activities (i.e. seismic surveying and exploration, platform 

construction, oil production). Therefore, one can expect natural gas-related impacts to be a 

continuation of the potential adverse environmental impacts associated with the oil development and 

production activities analyzed in the Sale 193 FEIS. 

The Sale 193 FEIS, as well as each Biological Opinion, found notable potential for adverse impacts to 

Threatened and Endangered marine and coastal birds, but also explained that many of these potential 

impacts could be avoided or mitigated. It is reasonable to presume that through development of 

additional, site-specific mitigation measures during later environmental review processes, the new 

activities associated with the gas scenario (namely installing and operating an offshore gas pipeline, 

expanding an onshore facility, and installing and operating an onshore gas pipeline though NPR-A), 

would produce only minor impacts to Threatened and Endangered marine and coastal birds. No 

significant impacts are expected from any potential releases of natural gas. If high numbers of 

Threatened or Endangered birds from declining populations experience collisions and mortality as a 

result of extending the life of the platform and other facilities, this would constitute significant 

adverse effects. There are no differences in the level of adverse effect between the different sale 

alternatives because the location of the gas pipeline would be the same for each alternative and the 

offshore location of the gas facility would not change. Additional discussion on the types of impacts 

that could affect marine and coastal birds is provided in the section below. 

IV.C.9. Marine and Coastal Birds 

Marine and coastal birds could be exposed to a variety of potential negative effects during 

development and production of natural gas. Relevant sources of potential impacts include collision, 

habitat loss, and general disturbance. Sources of potential disturbance include heavy equipment, 

vessels, and support aircraft used during modification and operation of the production platform and 

shore facility, as well as the installation of offshore and onshore gas pipelines. As will be explained, 

the level of potential impacts depends to a great extent on the specific location and timeframe of these 
BOEMRE Sale 193 Revised Draft SEIS 

104 CHAPTER IV. Environmental Consequences 

activities. In general, species with a relatively higher potential for substantial effects include murres, 

puffins, short-tailed shearwaters and auklets, black guillemot, loons, long-tailed duck, common eider, 

king eider, black-legged kittiwake, Pacific brant, phalaropes, and lesser snow goose. 

Effects from Natural Gas Development 

Migrating birds may be directly impacted through collisions, vessel strikes, and aircraft strikes. 

Collisions with manmade structures are often associated with weather conditions that cause poor 

visibility and/or magnify the lighting system of man-made structures. Often, artificial lights can 

attract disoriented birds, which may collide with the light support structure (e.g., pole, tower, or 

vessel). Mitigation measures pertaining to the array and use of lighting systems on vessels and 

platforms should reduce the potential for such impacts, which is expected to remain minor. Marine 

and coastal birds could also be directly impacted by aircraft strikes. However, these events are 

relatively rare, and would also be further reduced by mitigation required by future environmental 

review. 

Although the natural gas development scenario entails expansion of the onshore facility and 

construction of offshore and onshore gas pipelines, it is unlikely that these activities would notably 

reduce marine and coastal bird habitat. The projected footprints of these facilities would be relatively 

small in terms of regional habitat availability. Also, it is anticipated that particularly important areas 

would be avoided through future, site-specific environmental review processes. 

The response of marine and coastal birds to disturbances can vary depending on the species, time of 

year, disturbance source, habituation, and other factors (Fox and Madsen, 1997). For some species of 

waterfowl, the distance at which disturbances will be tolerated varies depending on flock size, 

because larger flocks react at greater distances than smaller flocks (Madsen, 1985). The vessels 

which would support natural gas development activities would not create noise or other forms of 

disturbance intense enough to have a significant impact on marine and coastal birds. Though 

installation of the pipelines could entail relatively large-scale activity in a small portion of the coastal 

environment, these impacts would be reduced through future environmental review processes related 

to project siting, and would in any event be temporary in nature. The noise and presence of aircraft 

operating at low altitudes have the potential to disturb birds. Birds would flush or move away from 

the noise and approaching aircraft. There is an energetic cost to repeatedly moving away from 

aircraft disturbances as well as a cost in terms of lost foraging opportunities or displacement to an 

area of lower prey availability. Support aircraft flying over nesting areas could flush adults from 

nests with could lead to abandonment or egg/chick death from exposure to the elements or predators. 

Low-level flights over rearing broods could also result in the separation of adults and young, with 

similar consequences. Implementation of mitigation measures, such as minimum flight altitude 

requirements, would reduce the magnitude and frequency of aircraft related noise disturbances to 

coastal and marine birds. Overall, impacts from disturbance are somewhat likely, but would not be 

considered significant. 

Natural gas development would not affect bird predator populations (birds and foxes) as changes in 

the shorebase to accommodate gas would be made in such a manner that would provide nesting or 

denning sites for these predators. The addition of a gas pipeline between the shorebase and the TAPS 

would be adjacent to an existing oil pipeline/maintenance road, so other birds and foxes would not 

benefit from additional sources of human-use foods or garbage as no new facilities with dumpsters or 

dumpsites are needed. These food sources could continue to be a problem in coastal villages, 

however. 

Effects from Natural Gas Production 

Natural gas production would simply lengthen the window of time within which marine and coastal 

birds could be subjected to collisions and noise. These types of impacts are analyzed in the 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 105

Development section directly above. Of course, vessel and aircraft traffic would be less frequent 

during the production phase than during certain portions of development, further reducing adverse 

impacts. 

The operation of a gas production facility and pipeline would not change the distribution or 

abundance of bird predators as no new sources of nesting/denning sites or access to artificial food 

sources would be generated. Resident fox populations would continue to be affected by winter food 

supply and disease. 

No additional types of impacts are anticipated during natural gas production. 

Conclusions 

As marine and coastal bird presence is quite variable by season and location, an accurate assessment 

of impacts at this early stage is difficult. Additional NEPA and other environmental review processes 

occurring at later stages of the OCS Lands Act program (i.e., exploration, development, and 

production) will have site-specific plans to focus an analysis. Significant adverse impacts to marine 

and coastal birds would be avoided and mitigated through restriction and measures implemented 

during those later review processes. There are no differences in the level of adverse effect between 

the different sale alternatives because the location of the gas pipeline would be the same for each 

alternative and the offshore location of the gas facility would not change. 

IV.C.10. Other Marine Mammals 

The main area of concern regarding the effects of industrial development on marine mammals is the 

potential for disturbance caused by industrial noise in the air and water, as discussed in Section 

IV.C.6. 

Effects from Natural Gas Development 

The natural gas development scenario would entail several sources of noise that could impact marine 

mammals, including small modifications to the platform and related infrastructure, installation of a 

new offshore gas pipeline, and a temporary increase in vessel and air traffic. Potential impacts will be 

considered for each group of marine mammals that could be present within the action area. Each of 

the following species is protected under the MMPA, and additional mitigation measures may be 

applied through subsequent regulatory processes. 

Phocids (Ringed, Spotted, Ribbon, and Bearded Seals) 

The effects of air traffic on pinnipeds in the action area are expected to be localized and transient in 

nature. Some pinnipeds may be disturbed on the ice or at haulouts on land and enter the water, 

although their responses will be highly variable and brief in nature (Born, Riget, Dietz, et al., 1999; 

Boveng, Bengtson, Buckley, et al., 2008, 2009; Burns and Harbo, 1972; Cameron, Bengston, Boveng, 

et al., 2010; Kelly, Bengston, Boveng, et al., 2010). Mitigation measures prohibiting aircraft 

overflights below 1,500 ft will lessen aircraft impacts to these pinnipeds. Results from studies of an 

existing facility (specifically, the Northstar development) roughly analogous to what is contemplated 

under the present natural gas development scenario suggest that any adverse impacts to phocids 

would be minor, short-term, and localized, with no measurable consequences to the seal population as 

a whole. 

Pacific Walrus 

Walrus are particularly vulnerable to disturbance events given their tendency to aggregate in large 

groups. Reactions to disturbances when on ice are highly variable (Richardson et al., 1995a). 

Reactions at group haulouts (on land) are more consistent; walrus will flee haulout locations in 

response to disturbance from aircraft and ship traffic, though walrus in the water are thought to be 

more tolerant. Females with dependent young are considered the least tolerant of disturbances. 
BOEMRE Sale 193 Revised Draft SEIS 

106 CHAPTER IV. Environmental Consequences 

Walrus are particularly sensitive to helicopters and changes in engine noise, and are more likely to 

stampede when aircraft turn or bank overhead. Disturbances caused by vessel and air traffic may 

cause walrus groups to abandon land or ice haulouts. Severe disturbance events could result in 

trampling injuries or cow-calf separations, both of which are potentially fatal. But while adverse 

impacts can be severe, they are also to a large extent avoidable. The FWS has concluded that a 

minimum altitude of 1000 ft above sea level (ASL) is sufficient in sea ice habitats (see p. 24 of the 

FWS Chukchi Sea EA, 2008) with a 1/2 mile (800m) horizontal buffer. The BOEMRE has taken the 

more precautionary approach of a 1 mile horizontal buffer and 1500 ft above ground level (AGL) or 

ASL based in part on industry data and on unpublished ADFG and FWS haulout monitoring data (see 

NTL 2 in the original Sale 193 EIS). While BOEMRE does not regulate air space within the project 

area, direct overflights of terrestrial or sea ice walrus haulouts by industry are strongly discouraged. 

Typical mitigation measures include flight corridors, a minimum of one to two miles inland and 

directly from shore to the exploration site, while maintaining a minimum of one horizontal mile from 

groups of walrus hauled out on ice or land. 

Overall, the potential for serious adverse impacts to individuals or groups of walrus do exist, but the 

probability is minimal in light of mitigation techniques, such as minimum altitude requirements for 

aircraft. Impacts to walrus are expected to be minor as a result of natural gas development. 

Cetaceans 

Potential effects to gray whale, minke whale, beluga whale, killer whale, and harbor porpoise are 

analyzed in this subsection. From a behavioral perspective, increased anthropogenic noise that would 

result from natural gas development activities could interfere with communication among cetaceans, 

mask important natural and conspecific sounds, or alter natural behaviors (i.e., displacement from 

migration routes or feeding areas, disruption of feeding or nursing). Behavioral impacts appear to be 

affected by the animal’s sex and reproductive status, age, accumulated hearing damage, type of 

activity engaged in at the time, group size, and/or whether the animal has heard the sound previously 

(e.g., Olesiuk et al., 1995; Richardson et al., 1995a; Kraus et al., 1997; National Research Council, 

2003a, 2005a). Toothed whales can be particularly sensitive to high-frequency sounds given their use 

of high-frequency sound pulses in echolocation, and moderately high-frequency calls for 

communication. Baleen whales, a group including gray and minke whales, are similarly sensitive to 

the low frequency noise that is often characteristic of construction, machinery operation, vessel noise, 

and aircraft noise. Studies of gray, bowhead, and humpback whales have shown that received levels 

of impulses in the 160-170 dB re 1 μPa range appear to cause avoidance behavior in a significant 

portion of the animals exposed. Any activity causing noise reaching these levels would risk level B 

“harassment” take of whales, and require a take authorization under the MMPA. Additional 

mitigation measures required to avoid significant adverse impacts would be required by later 

BOEMRE and NMFS review processes. Detailed analysis of potential Exploration Plans and 

Development & Production Plans, along with mitigation measures incorporated into any necessary 

Incidental Take Authorizations (ITA), would further reduce the potential for any significant adverse 

impacts. Overall, while natural gas development activities may impact whales through masking and 

avoidance, significant impacts are not expected. 

Effects from Natural Gas Production 

The ‘noisiest’ period of offshore oil and gas operations occurs during exploration and site 

establishment (Richardson et al., 1995a). Conversely, production activities generally are quieter and 

require fewer support operations. Data from the Northstar facility indicates that underwater noise 

from vessels was detectable as far as 30 km offshore, and that noise from normal production activities 

reached background values at 2-4 km. Impacts from vessels are analyzed in greater detail above, 

within the section regarding development activities. Vessel traffic during the production phase will 

be comparatively infrequent, and therefore represents a reduced potential for adverse impacts. Non-
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 107

vessel noise associated with production would only be problematic if it deflected cetacean migration. 

Such deflection would be highly localized and affect only a portion of the whales migrating through 

the Chukchi Sea. No population-level effects are anticipated. 

The potential impacts of a large gas release could occur from a platform, pipeline, or onshore facility. 

Cetaceans are not likely to congregate in the vicinity of a platform or an onshore facility. In the event 

of a rupture in a sub-sea pipeline, impacts to marine mammals would be minimal since gas quickly 

dissipates in the atmosphere. Potential impacts could result if animals in the immediate vicinity were 

to inhale gases; however this is highly unlikely. Breathing holes visited by ice seals provide for rapid 

venting of methane to the atmosphere and pose little risk to these species. It is possible that, given a 

methane release, some ice ring natal dens immediately above a breathing hole could temporarily 

concentrate escaping methane before it could vent through the snow roof of such dens. 

Conclusions 

While the complexity of how marine mammal species react to underwater and above water sound 

make an exact determination of potential adverse impacts difficult, abundant regulatory review and 

careful design of mitigation measures are expected to preclude instances of level A, or “harm” take of 

marine mammals, and to reduce the potential for level B, or “harassment” take. No population-level 

impacts are anticipated as a result of natural gas development and/or production. By increasing the 

minimum distance of the platform from shore, the coastal deferral corridors could increase the 

distance that support vessel and aircraft routes must travel, as well as lengthen the offshore gas 

pipeline. However, pushing development further offshore would decrease the overall potential for 

natural gas development and production to impact marine mammals, particularly in spring when the 

coastal lead system is so very important. 

IV.C.11. Terrestrial Mammals 

Among the terrestrial mammal populations that could be affected by development activities for gas 

production in the Sale 193 area are caribou of the Central Arctic (CAH), Western Arctic (WAH), and 

Teshekpuk Lake (TLH) herds; muskoxen; grizzly bears; and Arctic foxes. The primary potential 

effects would come from ice-road and air-support traffic (disturbance) along pipeline corridors and 

near other onshore-support facilities and habitat alteration associated with gravel extraction (mining) 

for gravel pads for onshore facilities. These effects would be the same across all action alternatives. 

The effects of development on caribou, muskoxen, and grizzly bears would likely include local 

displacement within about 4 km of onshore pipelines and roads (Cameron et al., 2005). 

Effects from Natural Gas Development 

Caribou 

Caribou can be disturbed briefly by low-flying aircraft, fast-moving ground vehicles associated with 

onshore pipelines, and the construction of other facilities (Calef, DeBock, and Lortie, 1976; Horejsi, 

1981). The response of caribou to potential disturbance is highly variable, from no reaction to violent 

escape reactions, depending on their distance from human activity; speed of approaching disturbance 

source; frequency of disturbance; sex, age, and physiological condition of the animals; size of the 

caribou group; and season, terrain, and weather. 

Caribou have been shown to exhibit panic or violent flight reactions to aircraft flying at elevations of 

60 m (162 ft) or less and exhibit strong escape responses (animals trotting or running from aircraft) to 

aircraft flying at 150-300 m (500-1,000 ft) (Calef, DeBock, and Lortie, 1976). However, these 

documented reactions of caribou were from aircraft that circled and repeatedly flew over caribou 

groups. 
BOEMRE Sale 193 Revised Draft SEIS 

108 CHAPTER IV. Environmental Consequences 

Gravel mining would alter a small area of river habitat along rivers but is not expected to disturb 

many caribou. Most caribou migrate south of the project area during the winter months when gravel 

will be mined, but small bands may be present. 

Caribou successfully cross under pipelines that are elevated a minimum of 7 ft above the tundra, a 

requirement for onshore pipelines in the NPR-A (USDOI, BLM, 2006a). Pipelines without adjacent 

roads and vehicle traffic are not likely to affect caribou movements. 

Research has suggested that caribou in Arctic Alaska generally avoid areas within 4 km of oil-field 

roads after they are constructed (Cameron et al., 1992; Joly, Nellemann, and Vistness, 2006). 

However, avoidance is not absolute and caribou may habituate to infrastructure and human activity 

(Haskell et al., 2006). 

From the mid-1970’s through the mid-1980’s, use of calving and midsummer habitats by CAH 

caribou declined near oil-field infrastructure on Alaska’s Arctic Coastal Plain (Dau and Cameron, 

1986). In the Kuparuk Development Area, west of Prudhoe Bay, abundance of calving caribou was 

less than expected within 4 km of roads and declined exponentially with road density (Cameron et al., 

2005). 

Cow and calf groups appear to be the most sensitive to vehicle traffic, especially during the early 

summer months immediately after calving, and bulls appear to be least sensitive during that season. 

Minimizing traffic, especially within calving areas during the calving period, would reduce the 

potential for negative impacts on caribou. 

The construction of roads and gravel pads may provide caribou with additional insect-relief habitat, 

particularly when there is little or no road traffic present. Conversely, the construction of roads and 

pipelines could provide vectors by which invasive species, parasites, and new diseases could be 

introduced into the Arctic environment (Kutz et al., 2004; Urban, 2006). 

Tolerance to aircraft, ground-vehicle traffic, and other human activities has been reported in several 

studies of ungulate populations in North America, including caribou (Davis, Valkenburg, and 

Reynolds, 1980; Valkenburg and Davis, 1985; Johnson and Todd, 1977). Cronin, Whitlaw, and 

Ballard (2000) maintain that effects from onshore development and production have not resulted in 

negative population-level effects, and that the CAH has grown throughout the period of oil field 

development at a rate comparable to other herds in undeveloped areas (Lenart, 2007; State of Alaska, 

2009). 

These findings suggest that caribou are largely able to habituate and adapt to oil field infrastructure. 

No significant impacts to caribou herds on the North Slope as a result of the gas development in the 

Sale 193 area are expected. 

Muskoxen 

Potential effects of development activities include direct habitat loss from gravel mining in river 

floodplains, and indirect habitat loss through reduced access caused by physical or behavioral barriers 

created by roads, pipelines, and other facilities (Clough et al., 1987 cited in Winters and Shideler, 

1990; Garner and Reynolds, 1986). Muskoxen concentrate and feed in riparian areas, especially in 

the winter months. Muskoxen may be more exposed to development than caribou, because they tend 

to remain year-round in the same habitat area (Jingfors, 1982); therefore, muskoxen may be more 

likely to habituate because of this year-round exposure. 

Muskoxen cows and calves appear to be more sensitive (responsive) to helicopter traffic than males 

and groups without calves, and muskoxen in general are more sensitive to overflights by helicopter 

than by fixed-wing aircraft (Miller and Gunn, 1979; Reynolds, 1986). A cow disturbed during the 

calving season may abandon her calf, if the calf is a day or two old (Lent, 1970). However, 

muskoxen appear to become accustomed to helicopter flights above 500 ft (180 m), at least for a time 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 109

(Miller and Gunn, 1980). Groups of muskoxen responded less to fixed-wing flying over them during 

the summer, rutting season, and fall than during winter and calving periods (Miller and Gunn, 1980; 

Reynolds, 1986). 

No significant impacts to muskoxen on the North Slope as a result of the gas development in the Sale 

193 area are expected. 

Grizzly Bears 

Major sources of noise and disturbance include air and ground vehicle traffic and human presence 

associated with onshore operations, such as construction of ice roads, installation of onshore 

pipelines, and gravel mining. These activities may disturb grizzly bears occurring within a few miles 

of the activities. 

Responses to ground-based human activities are stronger than responses to aircraft, especially when 

encounters occur in open areas such as the Arctic Slope (McLellan and Shackleton, 1989). The 

establishment of permanent structures (oil fields, mines, etc.) usually leads to human-bear encounters 

on a regular basis and to conflict, particularly when bears learn to associate humans with food 

(Schallenberger, 1980; Harding and Nagy, 1980; Miller and Chihuly, 1987; McLellan, 1990). Some 

bears may habituate to human noise and presence, leading to an increase in encounters. However, 

individual bears vary in the degree of habituation-tolerance to human presence, and some will 

continue to avoid areas where humans are present (Olson and Gilbert, 1994). 

Most onshore construction activities such as gravel mining, ice-road construction, and ice-road traffic 

are assumed to occur during the winter months when grizzly bears are denning. Grizzly bears use 

earthen dens along riverbanks during winter months where gravel extraction for the construction of 

gravel pads and gravel islands supporting offshore oil development may occur. This activity could 

disturb and displace a few bears from den sites. Implementing the guidelines in the MMS publication 

Guidelines for Oil and Gas Operations on Polar Bear Habitats could reduce the chances of adverse 

grizzly bear-human interactions that may lead to the injury or loss of people and bears. 

Arctic Fox 

Development infrastructure can increase the availability of food and shelter for Arctic fox. Facilities 

provide additional food sources for foxes at dumpster sites near the galley and dining halls and at 

dumpsites (Eberhardt et al., 1982; Rodrigues, Pollard, and Skoog, 1994). Crawlspaces under housing, 

culverts, and pipes provide foxes with shelter for resting and, in some cases, artificial dens (Eberhardt 

et al., 1982; Burgess and Banyas, 1993). 

Oil development on the North Slope has not harmed the fox population (Eberhardt et al., 1982). 

Arctic fox numbers and productivity are higher in the Prudhoe Bay area compared to adjacent 

undeveloped areas (Burgess et al., 1993). A study of den sites and fox productivity in the area of 

Prudhoe Bay indicates that adult fox densities and pup production are higher in the oil fields than in 

surrounding undeveloped areas (Burgess et al., 1993). An increase in the fox population associated 

with development may adversely affect some fox-prey species (such as ground-nesting birds) in the 

area of infrastructure (Burgess et al., 1993). 

Also helping to reduce potential disturbance of each of the above species, BOEMRE distributes an 

Information to Lessees regarding Bird and Mammal Protection. This document recommends air- and 

vessel-traffic distances to avoid disturbance of bird ands marine mammals that generally use many of 

the same coastal habitats as these terrestrial mammals. The ITL serves to alert industry to the 

potential effects of air and vessel traffic and to recommend measures to reduce those effects. As a 

result of their habitat similarities to birds and marine mammals, the ITL also is expected to reduce 

noise and disturbance effects of air and vessel traffic on caribou, muskoxen, grizzly bears, and Arctic 

foxes. 
BOEMRE Sale 193 Revised Draft SEIS 

110 CHAPTER IV. Environmental Consequences 

Effects from Natural Gas Production 

Caribou and muskoxen would be periodically exposed to disturbances from road and air traffic 

related to maintenance of the gas pipeline across NPR-A. These effects are expected to be temporary 

and negligible at the population level. The small potential for a large natural gas release is also of 

little concern. The distance between any of the sale areas and the coast is such that it is extremely 

unlikely that natural gas released in offshore areas could contact the coast (or the terrestrial mammals 

on the coast). Also, natural gas will weather and dissipate quickly in the Beaufort or Chukchi, 

preventing widespread issues. Overall, the effects from a natural gas blowout or any other accident 

should be much lower than that which would be expected for a similar crude oil accident. 

Conclusions 

It is likely that several species of terrestrial mammals would be temporarily disturbed by natural gas 

development, and to a lesser extent, natural gas production activities. Negative impacts of this type 

can be difficult to quantify. However, existing data and anecdotal evidence strongly suggest that no 

species of terrestrial mammal would suffer significant adverse impacts under any action alternative. 

IV.C.12. Vegetation and Wetlands 

Foreseeable adverse impacts on terrestrial vegetation communities would be caused by the expansion 

of the shore-base facility, construction of the gas pipeline across NPR-A, gravel quarrying, and 

continued use of the gravel road along the pipeline corridor across NPR-A under all the action 

alternatives. Disturbances could include loss of tundra vegetation acreage, damage or destruction of 

vegetation cover, shift in plant species composition, and introduction of noxious weeds. 

Effects from Natural Gas Development 

The expansion of the shorebase facilities to support natural gas production would have minor impacts 

on some of the plant communities. These impacts would be localized and could include loss of 

tundra acreage, damage or loss of vegetation cover, shift in species composition, and introduction of 

noxious weeds. 

Impacts would result from the construction and maintenance of pump stations, pipelines, vertical 

supports, and communication lines along a 300-mi pipeline corridor stretching eastward. Impacts on 

vegetation due to gravel borrow pits, gravel pads, and gravel roads would also be expected from the 

construction of both the pipeline system and the shore-base facility. 

Tundra vegetation cover would be removed permanently in areas where gravel pits are established. 

Tundra vegetation also would be buried under gravel pads established for the construction of pump 

stations and under gravel roads and runways. Communication lines and vertical supports also would 

require the removal or burying of tundra vegetation. Buried vegetation likely would die. Permanent 

gravel roads and pads would have direct impacts on plant communities. As they would greatly differ 

from adjacent substrates, gravel pads would comprise a set of completely different plant species if 

colonized. Most changes in plant communities around gravels pads and gravel roads would occur 

within about 50 m of the structure. Changes in plant-species composition also likely would occur in 

areas affected by thermokarst. Thermokarst (irregular depressions caused by melting and heaving of 

frozen ground) likely would occur where gravel roads and gravel pads cause changes in adjacent 

areas’ moisture regime, natural drainage patterns, or snow-drift patterns (National Research Council, 

2003b). Snow drifts caused by gravel structures increase wintertime soil-surface temperature and 

increase thaw depth in soils near the structures that, in turn, produce thermokarst and alter species 

composition for plant communities. Warmed soils enhance nutrient availability leading to increases 

in annual primary production and a shift toward graminoid-dominated communities characterized by 

low plant species diversity. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 111

Roadside dust produced on gravel roads is known to cause loss of vegetation, specifically of mosses 

typically found on acidic tundra. Sphagnum moss is particularly sensitive to the toxic effects of 

calcium in the dust; a significant reduction or elimination of sphagnum moss, especially in the 0-10 m 

adjacent to the road, has been reported in acidic tundra (Walker et al., 1987). Mosses promote low 

soil temperatures and permafrost development by conducting heat under cool, moist conditions and 

by insulating soils under warm, dry conditions (Oechel and Van Cleve, 1986). Mosses are a large 

component of the vegetation of the western North Slope; among the common ones are sedge/grass, 

moss wetlands (W1), sedge/moss/dwarf shrub wetlands (W2), and tussock-sedge/dwarf shrub/moss 

tundra (G4). Another impact is the earlier meltdown of the snow drift accumulated near roads, 

because the darker dust covering snow surfaces absorb more heat. Earlier meltdown could provide 

early open areas to wildlife several days or weeks before adjacent snow-covered tundra becomes 

accessible. The use of chip-seal treatment (an application of asphalt followed with an aggregate rock 

cover) of roads could dramatically reduce the impacts of roadside dust generation (National Research 

Council, 2003b) in roads designed to be permanent. 

Plant species sensitive to disturbance and with poor potential for recovery usually are common 

wetland species and include Eriophorum vaginatum, Ledum palustre spp. decumbens, Vaccinium 

vitis-idaea, Dryas integrifolia, Betula nana, Arctostaphylos rubra, Salix phlebophylla, and S. 

reticulata among others. Some mosses, particularly Sphagnum sp. and Tomentypnum nitens, and all 

lichens are also very sensitive to disturbance with slow recovery rates. Direct physical effects on 

vegetation due to disturbances related to roads and gravel pads, as well as other impacts, can reduce 

the insulating quality of the vegetation and cause added disruption of the surface by thawing the 

underlying ice-rich permafrost (National Research Council, 2003b). 

There is the potential to introduce non-native plants and noxious weeds with heavy equipment used in 

gravel borrow pits, pipelines, and so forth. Non-native plant species, however, may lack 

physiological and morphological adaptations required to survive extreme Arctic conditions. Their 

growth and reproduction would be limited by extreme low temperatures in the soil and aboveground, 

short photoperiods, and sporadic midsummer freeezes (National Research Council, 2003b). 

Reasonably foreseeable impacts on wetlands and terrestrial vegetation communities would be 

localized and would not adversely affect the functions of wetland ecosystems at a regional scale. 

These impacts would be moderate to significant at a local scale, but would have a small effect on the 

ecological functions, species abundance, and composition of wetlands and plant communities of the 

North Slope at a regional scale. Impacts on tundra vegetation and palustrine wetlands due to small oil 

spills and small discharges (saline water, hydraulic fluids, and diesel) are likely to be minor, because 

these spills would be localized and in small quantities. 

Standard operating practices for operating on the North Slope are expected to be implemented on a 

site-specific basis. These practices, which are discussed in Section IV.B.10 of the Sale 193 FEIS, are 

expected to protect tundra vegetation and wetlands from direct impacts to the greatest extent 

practicable. Notable standard practices include extracting gravel during winter months, using ice 

roads and ice pads for transport and construction activities, and building gravel pads to a thickness 

over 1.8 meters and potentially placing polyethylene insulation under the pad itself) to protect against 

thawing of permafrost. 

Effects from Natural Gas Production 

Loss of vegetation, specifically of mosses and lichens typically found on acidic tundra, could occur 

from roadside dust related to maintenance of the gas pipeline across NPR-A. Discharges that could 

occur during production of natural gas include diesel, hydraulic fluids, and other fluids used in 

operating the shore-base facility and pump-station equipments. Vegetation recovery from diesel fuel 

spills would be slow. In experimental spills of diesel fuel, tundra plant communities on diesel fuel 
BOEMRE Sale 193 Revised Draft SEIS 

112 CHAPTER IV. Environmental Consequences 

plots showed no recovery after 1 year, with almost no recovery of mosses, lichens, and dicots (no 

graminoids). 

Conclusions 

Given the unique sensitivity of the tundra ecosystem in the region analyzed, some potential impacts to 

vegetation associated with natural gas development and production may be long lasting (e.g. 

disruption of slow-recovering vegetation communities) or even permanent (e.g. thermokarst). These 

impacts would, however, be highly localized and insignificant on a regional scale for all action 

alternatives. 

IV.C.13. Economy 

Natural gas development and production would generate economic activity manifested primarily in 

employment, personal income, and revenues to the local, state, and federal government. Economic 

effects would occur in the North Slope Borough (NSB), the rest of Alaska, and the rest of the U.S. 

The exploration and development scenario in Section IV.A is the basis for analyzing potential 

economic effects in this section. The reader should refer to that section for timing of OCS activity. 

The activities, construction, and operation of infrastructure described in the gas development and 

production scenario generate economic activity. The resulting increases in employment and personal 

income would occur in two distinct phases: development and production. In general, employment 

numbers and associated personal income peak during development, then drop to a plateau during the 

production phase as production rates decline. 

Section IV.A.1 defines the significance threshold for economics as effects “that would cause 

important and sweeping changes in the economic well-being of residents in the area or region. Local 

employment is increased by 20% or more for at least 5 years” (p. 74). The term “local employment” 

here means workers that are permanent residents of the NSB, both Inupiat and non-Inupiat, and does 

not include North Slope oil-industry workers who commute to residences within or outside of Alaska. 

Revenues accruing to local, state, and Federal government can also cause changes in economic wellbeing. 

Effects from Natural Gas Development and Production 

Natural gas development and production under Sale 193 would have a positive impact on fiscal 

components, such as employment, personal income, and revenues in the region. Under the 

significance criteria above, employment and personal income effects from natural gas activities would 

be insignificant. However, property tax revenues accruing to the NSB would be substantial. 

Employment and Personal Income 

Employment and personal income effects during the natural gas development phase are assumed to be 

similar to the effects described for oil development and production in Section IV.C.1.k. and Table 

IV.C-1 in the Sale 193 FEIS. Natural gas development would initially cause a small increase in 

employment and personal income when it commences circa 2030. Additional workers would be 

needed to modify, expand, and develop new infrastructure associated with gas production as oil 

production rates decline and operations shift toward natural gas development. This small increase 

from the additional man power required to expand and modify the existing shore base to support gas 

production would continue during the 10 year transition period of 2035-2044, where both oil and gas 

would be produced from the offshore platform, and then taper off in later years of production back to 

the levels provided in Table IV.C-1 in the Sale 193 FEIS. 

The employment and personal income associated with gas development would be slightly less than 

the employment and personal income associated with oil development, since most of the 

infrastructure necessary for gas development and production (roads, facilities, etc.) will have already 

been built for oil production prior to gas development (which is projected to begin in 2030). Just as 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 113

local employment and personal income effects would be insignificant from oil development described 

in the Sale 193 FEIS, local employment and personal income effects from gas development would 

continue to be insignificant under the significance threshold listed above. 

While a majority of the jobs directly related to the oil and gas industry may be filled by workers who 

are not residents of the NSB, most of the (indirect) infrastructure, government, and support jobs are 

expected to be taken by local residents. 

Revenues 

Natural gas development and production would generate property tax revenues for the NSB totaling 

approximately $90 million over the depreciable life of the shore based gas support facilities and 

overland pipeline. The onshore infrastructure will be completed in 2035 and be assessed coincident 

with projected declines in NSB property tax levels. The contribution from this new infrastructure to 

NSB property tax revenue could yield up to $27.75 million in year 2035, providing an increase in 

NSB property taxes of about 32% above the level of projected Borough revenues without natural gas 

development and production. 

Gas development and production would generate increases in property tax revenues to the State of 

Alaska of up to $2.25 million, with a total of up to $7.3 million accruing to the State over the 

depreciable life of the infrastructure. Given the geographical location of the parcels to be leased, no 

royalties would flow to the State from gas production. The Federal government, however, would 

receive royalties from the projected gas production totaling approximately $2.7 billion over the life of 

the production profile. 

Natural gas from Sale 193 leases will contribute to extending the useful life of a large capacity North 

Slope gas pipeline to outside markets. 

Conclusions 

Natural gas development and production under all action alternatives would result in a variety of 

beneficial economic impacts, namely employment, personal income, and revenues. Under the 

significance threshold listed above, employment and personal income effects would be insignificant. 

Natural gas development and production would generate a substantial increase in property tax 

revenues accruing to the NSB, an increase in property tax revenues for the State, an increase in 

royalties the Federal government receives from gas production, and would contribute to extending the 

useful life of a large capacity North Slope gas pipeline to outside markets. 

IV.C.14. Subsistence-Harvest Patterns 

Access to subsistence resources and subsistence hunting areas could be affected by reductions in 

subsistence resources and changes in the distribution of subsistence resources. These changes could 

occur as a result of noise and disturbance from aircraft and vessel traffic, support-base expansion; and 

pipeline construction and maintenance. 

Effects from Natural Gas Development 

The noise-producing activities are those most likely to produce disturbance effects on critical 

subsistence species that include bowhead and beluga whales, seals, fish, caribou, and birds. Noise 

disturbance would be associated with aircraft and vessel support of modifications to platform 

facilities, installation of a gas pipeline from the platform to shore, expansion of shore facilities, and 

construction of the gas pipeline across NPR-A. 

Most bowheads exhibit no obvious response to helicopter overflights at altitudes above 150 m (500 

ft). At altitudes below 150 m (500 ft), some bowheads probably would dive quickly in response to 

the aircraft noise (Richardson and Malme, 1993). Bowheads are not affected much by aircraft 

overflights at altitudes above 300 m (984 ft). Below this altitude, some changes in whale behavior 
BOEMRE Sale 193 Revised Draft SEIS 

114 CHAPTER IV. Environmental Consequences 

might occur, depending on the type of plane and the responsiveness of the whales present in the 

vicinity of the aircraft. Fixed-wing aircraft flying at low altitude often cause hasty dives. Reactions 

to circling aircraft are sometimes conspicuous if the aircraft is below 300 m (984 ft), uncommon at 

460 m (1,500 ft), and generally undetectable at 600 m (2,000 ft). The effects from such an encounter 

with either fixed-wing aircraft or helicopters generally are brief, and the whales should resume their 

normal activities within minutes (Richardson and Malme, 1993). There is variability in their response 

to certain noise sources. Some of the variability appears to be context specific (i.e., feeding versus 

migrating whales) and also may be related to reproductive status and/or sex or age. This potential 

effect could be mitigated by ensuring that flight paths avoid whale aggregations or that flights are 

high enough to avoid disturbance. Overall, bowhead whales exposed to noise-producing activities, 

such as vessel and aircraft traffic and pipeline construction activities, most likely would experience 

temporary (Richardson et al., 1995a), non-lethal effects. 

Even a brief disturbance response from aircraft and vessel noise might temporarily interrupt the 

movements of belugas or temporarily displace some animals when vessels pass through an area. 

Such events could interfere especially with beluga movements to and from the lagoon areas, 

particularly Kasegaluk Lagoon where the community of Point Lay hunts belugas; this harvest is 

concentrated during a few weeks in early July. Reducing or delaying the use of these habitats by 

belugas could affect their availability to subsistence hunters. There is evidence that belugas will 

accommodate or acclimate to a particular pattern of noise after extensive exposure, and such 

acclimation also could affect Inupiat hunter access. For example, Point Lay residents rely on the 

harvest of belugas more than any other Chukchi Sea village and, at the present time, they are very 

successful at herding these animals by boat into Kasegaluk Lagoon where they are then hunted. If 

noise from boat-traffic activity increased and the belugas acclimated to the noise, there is the 

possibility that this herding technique would be less successful and the hunt reduced. 

Aircraft traffic (particularly helicopter trips) and supply-boat traffic is assumed to be a potential 

source of disturbance to bearded, ringed, and spotted seals hauled out on the ice or beaches along the 

coast. Air-traffic disturbance would be very brief and would disturb small groups of seals hauled out 

along the coast. The effects of air traffic on pinnipeds in the action area are expected to be local and 

transient in nature. Some groups of pinnipeds may be disturbed from their haulouts and enter the 

water, although their responses will be highly variable and brief. 

Activities that occur during ice-minimum conditions in summer in the Chukchi Sea may come into 

direct contact with adult females and subadult walrus (Jay et al, 1996). If disturbances cause walrus 

to abandon preferred feeding areas or interferes with pup-rearing, resting, or other necessary life 

functions, then the walrus population could be negatively affected. Walrus will flee haulout locations 

in response to disturbance from aircraft and vessel traffic (Richardson et al., 1995a). Females with 

dependant young are considered most vulnerable to disturbances. 

Aircraft- and vessel-noise and presence could displace birds from the local area. Little direct 

mortality is expected, but losses of eggs and young to predators when adults are displaced is likely to 

occur. 

Vessel traffic during the open water season is not expected to cause impacts to polar bears, because 

they generally do not linger in open water. Polar bears could experience short-term, localized 

aircraft-noise disturbance—effects that would cause some disruption in their harvest—but this is not 

expected to affect annual harvest levels. 

Aircraft traffic overhead of caribou and other terrestrial mammals (muskoxen, grizzly bears, and 

Arctic foxes) could cause localized disturbance to these animals and some short-term disruption to the 

harvest, but is not expected to cause caribou and other terrestrial mammals to become unavailable to 

subsistence hunters. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 115

An extensive discussion on traditional knowledge about noise and disturbance effects on subsistence 

resources and harvest is provided in Section IV.C.1.l(1)(a)6) of the Sale 193 FEIS. Many Inupiat 

whale hunters express a traditional belief that whales can detect sounds much farther than can be 

measured by scientific instruments. This traditional belief implies that whales can perceive sounds 

and changes in the environment that cannot be detected by hearing, as hearing is defined by science. 

One of the most serious concerns to North Slope Inupiat is that potential increases in noise from oil 

development could disrupt normal migration of bowhead whales, forcing subsistence whalers into 

longer hunts farther from shore. A common theme among the Northwest Alaska coastal communities 

and along the eastern shore of the Chukotka Peninsula is that beluga whales are sensitive to noise and 

to the noise of outboard motors in particular (Huntington and Mymrin, 1996; Huntington, 1999; 

Mymrin, 1999). The observations about the effects of noise on beluga whales are widespread and 

probably very old in traditional knowledge. Nuiqsut whaling captain Frank Long, Jr., stated that oilindustry activity offshore has affected not only whales but also seals and birds (Long, 1993). 

According to studies and public scoping comments, low-altitude helicopter and scientific survey 

flights divert caribou and other terrestrial subsistence species from air-transport corridors and survey 

transects. Nuiqsut residents have noted that aircraft have diverted subsistence resources away from 

areas where hunters were actively pursuing them, directly interfering with harvests or causing 

harvests to fail (USDOI, BLM, 2004a, 2004b). If resources are diverted from traditional areas, 

increased travel distances for hunters result in greater expenditures for fuel and equipment because of 

greater wear and tear on snowmachines, outboards, and four-wheel vehicles. 

Noise and disturbance from aircraft and vessel traffic would have localized and short-term effects, 

and could cause some disruption to the subsistence harvest but would not cause bowheads, belugas, 

seals, walrus, caribou and other terrestrial mammals, birds, or polar bears to become unavailable to 

subsistence hunters (Braund and Burnham, 1984; USDOI, MMS, 1987, 1990b, 1995, 1998b; USDOI, 

BLM, 2005). 

Restrictions on aircraft altitudes and vessel speed, and prohibitions on approaching marine mammals 

are expected to lessen the effects of noise disturbance to these subsistence species, and thus mitigate 

effects on subsistence activities. 

Onshore and offshore construction could displace key subsistence species such as bowhead and 

beluga whales, seals, walrus, caribou, waterfowl, fish, bears, wolves, and other furbearers. 

Consequently, subsistence hunters would travel farther, at greater costs and effort. 

Offshore pipeline effects on subsistence resources and harvest would be confined to the period of 

construction and, to some extent, would be mitigated through lease stipulations designed to minimize 

industry activities during critical subsistence-use periods. Noise, disturbance, and habitat alterations 

from offshore pipeline laying could have some adverse effects on marine mammals (USDOI, MMS, 

1987, 1990b, 1998b, 2003a, 2003b; USDOI, BLM, 2005). Disturbance from construction activities 

could cause some animals to avoid areas in which they normally are harvested or to become more 

wary and difficult to harvest. Scientific and local Native knowledge of the behavior of marine 

mammals and the nature of noise associated with offshore oil and gas activities suggest that intense 

noise causes startle, annoyance, and flight responses. Some whales could be displaced seaward by 

construction and noise disturbance. In terms of subsistence activities, this effect may be most adverse 

for construction noise during bowhead migration. Traditional Inupiat observation and experience 

affirms that whales are affected by noise at great distances and alter their swimming directions for 

long periods. Noise and disturbance and habitat alterations from offshore pipeline installation would 

have a short-term and local effect on the subsistence harvest of marine mammals (USDOI, MMS, 

1987, 1990b, 1998, 2003a, 2006b; USDOI, BLM, 2005). 

Depending on the construction season, the construction of an offshore pipeline could displace and/or 

disturb marine and coastal birds in a variety of pelagic, nearshore, and estuarine terrestrial habitats. 
BOEMRE Sale 193 Revised Draft SEIS 

116 CHAPTER IV. Environmental Consequences 

The construction of a pipeline between a production platform and an onshore base could cross many 

important bird habitats. Activities that take place in summer could temporarily displace birds using 

areas near such sites for one season or less. Local disturbance of birds within about 1 km of 

construction activities would be short term, and would have a short-term and local effect on the 

subsistence harvest. 

Construction activities related to expansion of the shore facilities would have disturbance effects on 

subsistence resources and the subsistence harvest specific to that area. If the shore facilities are in the 

vicinity of Wainwright, as assumed for this analysis, expansion of the facilities could disturb walrus 

in the vicinity of Peard Bay, a walrus harvest area preferred by Barrow and Wainwright residents. 

Onshore construction noise, lights, and traffic would divert and displace caribou and furbearers, 

resulting in decreased availability of these resources to hunters near these locations. Disturbance to 

caribou, moose, muskoxen, grizzly bears, wolves, wolverines, Arctic foxes, and small mammals 

would occur for the duration of expansion of the shore facilities and construction of a pipeline across 

NPR-A and would be most intense during the construction period, but would subside after 

construction is complete. 

Onshore, nesting sites are scattered at low density on the Arctic Coastal Plain. Relatively few sites are 

likely to become unavailable through pipeline location in areas of gravel extraction, and only small 

numbers of nesting birds are likely to be displaced away from the vicinity of onshore pipeline 

corridors (a few hundred meters) by construction activity, vehicle-traffic disturbance, or helicopter 

traffic for pipeline inspections. Routine disturbance effects would persist over the life of the field and 

would be localized primarily within about a kilometer of the pipeline. 

A small number of polar bears located within a few kilometers of the offshore pipeline landfall, 

shorebase expansion, and onshore pipeline construction could be disturbed and displaced. The effect 

on the subsistence harvest would be short-term and localized. 

It is expected that various Sale 193 lease stipulations (see II.C.1) would help reduce the potential for 

adverse impacts in the event that the sale is affirmed. Notable examples include Stipulation 2, which 

requires workers to be oriented regarding important local issues; Stipulation 4, which requires marine 

mammal monitoring; and Stipulation 5, which requires industry to coordinate with local leaders prior 

to engaging in activities that could affect subsistence-harvest patterns. It is also expected that the 

potential for adverse impacts to subsistence-harvest patterns is reduced through implementation of 

deferral areas. Moving activities such as platform construction and production, as well as vessel 

traffic, farther from coastal areas would reduce the potential for disturbing subsistence-harvest 

patterns. Alternative IV exhibits less potential than Alternative I for impacts to subsistence-harvest 

patterns, and Alternative III offers the greatest potential advantages in this area. 

Effects from Natural Gas Production 

During the natural gas production phase, after construction, effects on subsistence activities are 

expected to return to levels experienced during the oil production phase. Because gas processing 

would be accommodated by an expansion of the oil processing facility and the overland pipeline 

would be constructed along the same corridor as the oil pipeline, effects on subsistence resources and 

subsistence-harvest activities are expected to increase minimally, if at all, relative to the effects of 

development and production as analyzed in the Sale 193 FEIS. Moreover, the analysis in the FEIS 

concluded that no resource or harvest area would become unavailable or undesirable for use because 

of noise and disturbance, and no resource would experience overall population reductions. 

Conclusions 

While natural gas development and production is not expected to appreciably reduce any populations 

of subsistence species, it is possible that disturbance caused by these activities could alter the local 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 117

availability of these resources to harvesters. These impacts would be considered short-term and 

localized, and would not rise to the level of significant adverse effects. 

IV.C.15. Sociocultural Systems 

In determining the intensity of the potential adverse effects from Sale 193 natural gas development 

and production to sociocultural systems, we look at the magnitude and duration of disruption, with 

“significant” effects equated to conditions described as a chronic disruption of social organization, 

cultural values, and institutional organization for a period two to five years with a tendency toward 

displacement of existing social patterns. 

Potential effects on social organization could occur if Sale 193 natural gas development and 

production alter employment or income characteristics of the area, change the demographics of the 

area, result in changes to the workforce, or otherwise affect the social well-being of area residents. 

Although Sale 193 natural gas development and production are expected to provide significant 

revenues to the NSB, substantive changes in local employment and income characteristics are not 

expected to occur (Section IV.C.13). Short-term increases in local employment may occur related to 

gas development activities. Historically such employment opportunities, particularly as they translate 

into Native employment, have been insignificant; this is expected to continue. Though Native 

employment in oil-related jobs on the North Slope is currently low, Native leaders continue to push 

for programs and processes with industry that encourage more Native hires. In particular, hiring and 

employment practices that value and facilitate continued participation in subsistence activities are 

encouraged by the NSB and local residents. Increased employment opportunities would provide 

some economic benefits. 

Effects on cultural values could occur if Sale 193 natural gas development and production alter 

subsistence harvest, known archaeological or cultural sites, or cultural continuity. No resource or 

harvest area is expected to become unavailable or undesirable for use because of noise and 

disturbance and no resource would experience overall population reductions from Sale 193 natural 

gas development and production. Adverse effects on archaeological or cultural resources are not 

expected to occur as a result of Sale 193 natural gas development and production (see IV.C.16). 

Potential effects on institutional organization could occur if Sale 193 natural gas development and 

production affect how institutions are structured or how they function to provide services and foster 

community stability. Sale 193 gas production would represent a continuation of routine and 

maintenance activities related to operation of the platform, shorebase, and pipelines. Continuation of 

these activities is not expected to require any changes to community or Borough services. Local 

employment would stabilize population and density; it would also slow the rate of decline and 

increase the stability of the community in the short term. 

Sale 193 natural gas development activities could cause noticeable disruption to local sociocultural 

systems for a period of several years. Wainwright (the community nearest the shorebase) may 

experience significant short-term effects. Noticeable disruption most likely would result during 

development from the expansion of onshore infrastructure. The effect of expansion of the shorebase, 

however, would be much less than the effect of the initial construction of the shorebase and the 

introduction of a new level of industrialization. Overall, the level of effects would not be sufficient to 

displace existing social patterns at the regional level. 

The shorebase would serve as an enclave to house project-related workers, who would largely travel 

out of the area during shift changes. Sufficient housing is expected to be available to handle what 

influx may occur. Any influx of new residents from development and production related employment 

would be expected to have little direct and indirect consequences to local Inupiat sociocultural 

systems. The proximity of the shore base to Wainwright may bring non-resident workers at the 
BOEMRE Sale 193 Revised Draft SEIS 

118 CHAPTER IV. Environmental Consequences 

enclave and others into greater contact with local area residents. Positive and negative effects may 

result from this interaction. 

Conclusions 

The following conclusions may be drawn from the analyses: 

 At the regional level (NSB), effects to sociocultural systems from Sale 193 natural gas 

development and production should not exceed the significance threshold. 

 At the local level (Wainwright in the scenario), effects from Sale 193 natural gas 

development and production should not exceed the significance threshold. 

 Mitigation measures should prove effective in ameliorating many of the effects of Sale 193 

natural gas development and production. Social systems are expected to successfully respond 

and adapt to the change brought about by the continuation of production activities. This 

accommodation response represents circumstances that should not exceed the significance 

threshold. 

IV.C.16. Archaeological Resources 

Effects from Natural Gas Development 

Archaeological surveys and analyses are required in areas where potential archaeological resources 

are at risk from offshore operations. Under the National Historic Preservation Act (NHPA), 

consultation with the Alaska State Historic Preservation Office is required for any activities that may 

adversely affect archaeological resources or historic properties. Preconstruction surveys and 

additional mitigation measures, which may flow from the NHPA Section 106 process would largely 

preclude, or at least reduce, the potential for adverse impacts to these resources. 

Any offshore activity that disturbs the seafloor in water depths <60 m in areas not identified as having 

high-density ice gouging, has the potential to affect prehistoric and historic shipwreck archaeological 

resources. Prehistoric archaeological resources are not expected in areas where water depths exceed 

60 m, because these areas of the continental shelf would have become submerged by rising sea level 

prior to 13,000 years Before Present (B.P.). Any activity that disturbs the seafloor in water >50 m has 

the potential to affect historic resources such as shipwrecks, abandoned relics of historical 

importance, or airplanes. Physical disturbance of resources could damage or destroy shipwrecks or 

artifacts, or cause a loss of site context with resulting loss of archaeological data or artifacts. 

Activities related to gas development that have the potential to disturb offshore archaeological 

resources are anchoring and pipeline trenching. 

Pipeline construction in the area of Peard Bay and seaward in a northerly direction could disturb 

shipwreck resources, where historic accounts have identified five whaling barks wrecked since 1871, 

two steam whalers wrecked in 1897, and another steam freighter wrecked in 1924. Yet the potential 

is very small for a natural gas pipeline installed along the same corridor as a then-existing oil pipeline 

(for which archaeological clearance will have already been performed) to actually impact such 

resources. Comparing alternatives, there is a positive correlation between the size of the area deferred 

from leasing and potential impacts to archaeological resources, but the overall potential for impacts 

remains small under each action alternative. 

Any onshore activity that removes or disturbs soil and/or causes shallow permafrost to thaw has the 

potential to disturb archaeological resources. Activities related to gas development that could damage 

previously unidentified onshore archaeological resources are expansion of shore facilities, 

construction of a gas pipeline across NPR-A, and gravel mining, particularly along the trend of paleoriverbanks or buried over-bank deposits. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 119

We assume that onshore pipelines would be elevated with vertical support members (pilings). These 

probably would disturb <2 ft2

 (0.2 m2) of soil to a depth of several tens of feet (tens of meters), but 

could penetrate soil horizons of potential archaeological significance. Any archaeological site 

beneath or near the pipeline right-of-way has the potential for being disturbed by the construction of 

roads and installation of the pipelines. 

In sum, preconstruction survey requirements, Section 106 consultation, and other mitigation measures 

would greatly reduce the potential for natural gas development activities to adversely affect 

archaeological resources. Ideally, BEOMRE would already possess complete information on the 

location and characteristics of all archaeological resources in the action area, as well as the location 

and nature of any development projects which may be proposed. This missing information, while 

clearly useful, is not considered essential for a reasoned choice among alternatives at the lease sale 

stage. After all, additional information on project plans would become known if and when proposals 

are submitted at later stages of OCS environmental review. Additional information on the location of 

archaeological resources would be gathered through required preconstruction surveys and utilized to 

avoid or minimize impacts during the Development & Production phase. Also, other environmental 

laws and regulation (i.e. pipeline protocols, Section 106 of the NHPA) would further reduce the 

potential for significant adverse impacts under each alternative. At this stage, the missing 

information is also not essential to choosing between the alternatives because it is clearly understood 

that lengthening the distance of the pipeline increases the chances of encountering these unknown 

locations, thus allowing the decision maker a reasoned choice among the alternatives. 

Given applicable protocols and consultation processes, as well as anticipated mitigation measures, the 

overall potential for impacts to archaeological resources from natural gas development remains small 

under each alternative. 

Effects from Natural Gas Production 

Continued potential access to historic and prehistoric sites presents continuing potential for damage to 

these sites by human activities and possibly vandalism. 

Conclusions 

There is a small potential that certain natural gas development activities could cause irreversible 

adverse impacts to currently unknown archaeological resources. Such impacts could be significant. 

However, the potential for significant adverse impacts will be further reduced through adherence with 

standard pipeline construction protocols and measures identified during the NHPA Section 106 

consultation process. 

IV.C.17. Environmental Justice 

Alaska Inupiat Natives, a recognized minority, are the predominant residents of the NSB. There are 

no significant numbers of “other minorities” in potentially affected Inupiat communities. Inupiat 

Natives are the only minority population allowed to conduct subsistence hunts for marine mammals 

in the region. No “other minorities” are allowed to participate in subsistence marine mammal hunts 

and, therefore, would not constitute a potentially affected minority population (North Slope Borough, 

1999). Because of the nearly homogeneous Inupiat population, it is not possible to identify a 

“reference” or “control” group within the potentially affected geographic area (for purposes of 

analytical comparison) to determine if the Inupiat are affected disproportionately. 

Low income commonly correlates with Native subsistence-based communities in coastal Alaska; 

however, subsistence-based communities in the region qualify for Environmental Justice analysis 

based on their racial/ethnic minority definitions alone (USDOC, Bureau of the Census, 2000, 2002). 

The 2000 Census identifies no nonsubsistence-based coastal communities in the NSB with median 

household incomes that fall below the low income threshold. 
BOEMRE Sale 193 Revised Draft SEIS 

120 CHAPTER IV. Environmental Consequences 

“Significant” effects with respect to EJ are defined as: disproportionately high adverse impacts to 

low-income and minority populations. Coastal communities could experience impacts on subsistence 

resources and subsistence-hunting practices as a result of noise and disturbance from aircraft and 

vessel traffic; pipeline construction, shorebase expansion, and ice-road construction. Potential 

significant impacts to subsistence resources and harvests and consequent impacts to sociocultural 

systems could result in adverse EJ-related impacts. The potential effects of Sale 193 natural gas 

development and production would focus on the Inupiat communities of the region. 

Metabolic health effects may accrue if subsistence resources became unavailable or undesirable for 

use, if subsistence foods were displaced from the diet by increased availability or affordability of 

store-bought foods, or if subsistence were displaced as a primary source of nutrition because of 

cultural change. Displacement or contamination of resources that substantially reduce intake of 

subsistence foods would increase the risk of increased prevalence of metabolic disorders. 

Sale 193 natural gas development and production could contribute to various ambient and ongoing 

localized and regional effects on social pathology (assault, alcohol and drug abuse, domestic violence, 

suicide, and homicide). The associated health outcomes would be expected to parallel sociocultural 

changes to some extent. The most important sources of impacts would include: 

 Influx of temporary personnel into Inupiat villages, leading to cultural conflicts and the 

potential for alcohol and drug importation. 

 Stress, tension, and increased demands on individual time because of opposition to increasing 

potential on- and offshore development. 

 Acculturation stress, secondary to influences and disturbances such as the influx of outside 

oil and gas workers entering a community, marked and rapid socioeconomic changes, and 

altered availability of subsistence resources. 

 Potential local and regionwide increases in income and employment, leading to a general 

stabilization of social pathology. An important caveat is that increased income disparity, to 

the extent that it occurs, may tend to increase community tension and may thus worsen these 

problems. 

Injury rates could be affected by Sale 193 natural gas development and production through three 

pathways: 

 Displacement of subsistence animals resulting in increasing the time and effort needed to 

harvest resources. 

 More erratic and aggressive behavior of subsistence animals disturbed by gas development 

and production activities. 

 Social pathology leading to increased rates of alcohol and substance abuse and, hence, 

increasing the risk of accidents, as discussed above. 

The degree to which injury rates change as a result of the Sale 193 natural gas development and 

production will depend on the degree to which the potential impacts on sociocultural characteristics, 

subsistence, and drug and alcohol importation into the villages occur. 

Overall air quality impacts of Sale 193 natural gas development and production are projected to be 

low, therefore the impact to human health from emissions related to gas development and production 

is expected to be low. Regional, seasonal, and local variations could occur, which could have 

potential effects on human health. These variations would be determined and mitigated on a sitespecific basis at the time of consideration of the proposed siting of shorebase facilities. 

Increased travel, the introduction of new populations, and the influx of visitors and temporary 

workers from outside the North Slope region related to Sale 193 natural gas development and 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 121

production represents a potential source of infectious disease transmission, including sexually 

transmitted diseases, respiratory diseases, and other infections, to local residents. 

For many years, North Slope residents have expressed concerns regarding possible contamination of 

the environment, and in particular of subsistence foods, by local industrial development, and the 

potential effects on human health. Environmental contaminants may enter the human environment 

through airborne emissions (as discussed above), through consumption of contaminated vegetation, or 

through consumption of subsistence species that are contaminated or that have consumed 

contaminated prey or vegetation. As previously discussed, emissions related to Sale 193 natural gas 

development and production are expected to be within NAAQS standards, are not expected to 

adversely affect overall air quality of the Chukchi Sea Planning Area, or directly affect human health. 

Adverse effects on water quality from development activities are expected to be short term and 

localized. No discharges related to gas production are expected to occur. Therefore, absent an 

unforeseen accidental event, no health impacts from contaminated subsistence foods is expected as a 

result of Sale 193 natural gas development and production. It is possible that the deferral areas under 

Alternative IV and, to a greater extent, Alternative III could reduce the potential for adverse impacts 

by further removing any discharges, emissions, etc. from populated areas. 

The “social determinants of health” (SDH) is a term used to describe the powerful and highly 

reproducible association between an array of socioeconomic and environmental factors (many of 

which have been studied individually with regard to health outcomes)—including social hierarchy, 

social exclusion, social support networks, income inequity, employment, educational opportunity, 

cultural integrity, food security, early childhood environment, and stress—and specific health 

diagnoses. Summarizing the importance of the SDH to health, a conference in 2002 concluded: 

The socioeconomic circumstances of individuals and groups are equally or more important to health 

status than medical care and personal health behaviours, such as smoking and eating patterns.... The 

weight of the evidence suggests that the SDOH have a direct impact on the health of individuals and 

populations, are the best predictors of individual and population health, structure lifestyle choices, and 

interact with each other to produce health. (Health Canada, 2002). 

Oil and gas development (both onshore and offshore) has become a dominant socioeconomic force on 

the North Slope. Direct and indirect influences of development are experienced through, for example, 

the influx of people from a different culture entering previously isolated Inupiat villages; stress over 

perceived and actual threats to culture and subsistence; direct and indirect employment opportunities; 

and broad economic and infrastructure improvements. Effects on the SDH may create concomitant 

positive and negative effects on health status. For example, a local increase in employment may 

create benefits through economic opportunity and also adverse effects because of tensions between 

the imperative to provide for one’s family through subsistence activities and the pressure to be a 

successful wage earner. Effects on SDH from Sale 193 natural gas development and production 

would be greatest during development activities and then return to pre-gas development activities 

during the gas production phase. 

Conclusions 

No major adverse impacts from natural gas development or production are expected for Alaska 

Inupiat Natives, the only significant “minority” group within the action area. However, one can 

expect several forms of minor impacts related to potential effects on subsistence resources and 

practices, human health, and perhaps sociocultural systems. 

IV.D. Very Large Oil Spill (VLOS) 

The potential environmental effects of a low-probability, high impacts event—a hypothetical very 

large oil spill (VLOS) in the Chukchi Sea Planning Area—are analyzed below. This VLOS analysis 

comprises two parts or sections: (1) the first part (Section IV.D) describes the hypothetical VLOS 
BOEMRE Sale 193 Revised Draft SEIS 

122 CHAPTER IV. Environmental Consequences 

scenario by providing background and new information in light of the Deepwater Horizon (DWH) 

event and explaining the specific parameters that characterize the hypothetical VLOS; (2) the second 

part (Section IV.E) analyzes potential environmental impacts that could occur in the event of such a 

VLOS in the Chukchi Sea. 

IV.D.1. Background 

Background and context for this analysis is provided in light of the recent Deepwater Horizon (DWH) 

event and its ramifications for activities on the OCS, including the Chukchi Sea Planning Area. 

The Deepwater Horizon Event 

The Deepwater Horizon was a semi-submersible mobile offshore drilling unit operated by British 

Petroleum Exploration & Production, Inc. engaged in drilling the Macondo well on Mississippi 

Canyon Block 252 (MC252) in Outer Continental Shelf (OCS) waters located in the Gulf of Mexico, 

about 41 miles offshore of Louisiana. 

On April 20, 2010, an explosion and fire occurred aboard the Deepwater Horizon while the vessel 

was in the process of plugging the well prior to temporary abandonment. The blowout resulted in the 

spewing of oil in the Gulf of Mexico, the deaths of eleven men, and the injury of many others. 

Response teams were not able to control the fire and the vessel sank on April 22, 2010 in about 5,000 

feet of water and came to rest approximately 1,500 feet from the subsea wellhead. Before the rig 

sank, response teams were not able to stop the flow of oil and gas from the well. All attempts to 

completely close the blowout preventer failed. An estimated 4.9 million barrels of oil and an 

unknown quantity of natural gas was released (until the well was capped on July 15, 2010). On 

August 19, 2010, four months after the initial event, a relief well was completed and the well was 

permanently plugged and abandoned. 

The BOEMRE and the U.S. Coast Guard (USCG) are conducting a joint investigation to identify the 

factors which led up to the event, and developing conclusions and recommendations for future 

procedural and/or policy changes. On April 22, 2011, the Deepwater Horizon Joint Investigation 

Team released a preliminary report covering issues under Coast Guard jurisdiction. A final report 

was still being developed as this Revised Draft SEIS went to print (USCG and BOEMRE, 2011). The 

DWH event also precipitated several changes to BOEMRE’s regulation of oil and gas activities on the 

OCS; these are addressed in the subsections below. This VLOS analysis assesses the relevance of the 

DWH event and its consequences to potential operations in the Chukchi Sea, and incorporates into the 

present decision-making process the lessons learned from that tragic event. 

OCS Well Control Incident Rates 

This section updates information in the Sale 193 FEIS Appendix A, Section A.1.c which discussed 

OCS well control incidents from 1971-2005. The year 1971 is considered reflective of the modern 

regulatory environment. The term “loss of well control” was first defined in the 2006 update to the 

incident reporting regulations (30 CFR 250.188). Prior to this 2006 update, the incident reporting 

regulations included the requirement to report all blowouts, and the term blowout was undefined. 

Three relevant data sets are considered: (1) all well control incidents from 1971-2009 prior to the 

DWH event to update the Sale 193 FEIS information baseline, then (2) well control incident rates 

from exploration and development drilling including the DWH event, and finally (3) spills associated 

with well control incidents from exploration drilling including the DWH event (USDOI, BOEMRE, 

AIB, 2011). 

Exploratory and Development/Production Operations From 1971-2009. There were 249 well 

control incidents during exploratory and development /production operations on the OCS (this 

includes incidents associated with exploratory and development drilling, completion, workover, plug 

and abandon, and production operations). During this period, 41,514 wells were drilled on the OCS 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 123

and 15.978 billion barrels (Bbbl) of oil were produced. Of the 249 well control incidents that 

occurred during this period, 50 resulted in the spillage of condensate/crude oil ranging from <1 bbl to 

450 bbls. The total spilled from these 50 incidents was 1,829 bbls. This volume spilled was 

approximately 0.00001147% of the volume produced during this period. 

In 2010, four well control incidents occurred, including the DWH event. Although a final spillage 

volume from the DWH event has not been determined by BOEMRE, the current estimate from 

Lubchenco et al. (2010) is 4.9 million bbls. The three other well control incidents that occurred in 

2010 did not result in the spillage of condensate/crude oil. 

Development and Exploration Well Drilling From 1971-2010. There were a total of 41,781 wells 

drilled in the OCS comprising of 40,565 wells in the Gulf of Mexico, 1,086 wells in the Pacific 

Region, 46 wells in the Atlantic Region and 84 wells in the Alaska Region. Of these, 26,245 were 

development wells, 15,491 were exploration wells and 43 were core tests or relief wells. The overall 

drilling well control incident rate is 1 well control incident per 292 wells drilled, compared to 1 well 

control incident per 410 development wells drilled, and 1 well control incident per 201exploration 

wells drilled. These well control incident rates include all well control incidents related to drilling 

operations whether they spilled oil or not. 

Exploration Well Drilling From 1971-2010. Industry has drilled 223 exploration wells in the 

Pacific OCS, 46 in the Atlantic OCS, 15,138 in the Gulf of Mexico OCS, and 84 in the Alaska OCS, 

for a total of 15,491 exploration wells. During this period, there were 77 well control incidents 

associated with exploration drilling. Of those 77 well control incidents, 14 resulted in oil spills 

ranging from 0.5 bbl to 200 bbls, for a total 354 bbls, excluding the estimated volume from the DWH 

event. From 1971-2010 one well control incident resulted in a spill volume of 1,000 bbls or more and 

that was the DWH event. 

Government Reports and Recommendations 

Since the DWH event, several entities within or commissioned by the Federal government have 

offered formal recommendations regarding review and regulation of OCS oil and gas activities. 

Council on Environmental Quality (CEQ). As a direct result of the DWH event, the CEQ 

reviewed the MMS NEPA policies, practices and procedures relating to OCS oil and gas exploration 

and development and issued a report on August 16, 2010 (CEQ, 2010). This report recommended 

that MMS, since renamed BOEMRE, “ensure that NEPA documents provide decisionmakers with a 

robust analysis of reasonably foreseeable impacts, including an analysis of reasonably foreseeable 

impacts associated with low probability catastrophic spills for oil and gas activities on the Outer 

Continental Shelf.” This report also asked BOEMRE to “Consider supplementing existing NEPA 

practices, procedures, and analyses to reflect changed assumptions and environmental conditions, due 

to circumstances surrounding the [Macondo] Oil Spill.” 

Consistent with CEQ recommendations, this section supplements existing NEPA analyses related to 

Lease Sale 193 by evaluating new information and analyzing potential environmental impacts of a 

VLOS, which is a low probability, high impact event. 

National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling. On 

January 11, 2011, the National Commission on the BP Deepwater Horizon Oil Spill and Offshore 

Drilling (Commission) issued its final report. This report described the causes of the DWH event and 

recommended reforms intended to make offshore energy production safer. The Commission also 

reviewed and made recommendations concerning oil spill prevention and response. 

U.S. Coast Guard. BOEMRE and the USCG are conducting a joint investigation to identify the 

causes of the DWH event and any procedural or policy changes that could prevent such tragedies in 

the future. On April 22, 2011, the Deepwater Horizon Joint Investigation Team released a 
BOEMRE Sale 193 Revised Draft SEIS 

124 CHAPTER IV. Environmental Consequences 

preliminary report covering issues under Coast Guard jurisdiction. The investigation continues into 

the Deepwater Horizon’s blowout preventer issue and other issues under the jurisdiction of 

BOEMRE. 

In response to the DWH event and informed by these subsequent reports, the BOEMRE has 

undertaken rulemaking, issued NTLs and is currently conducting a review of catagorical exclusion 

policies under NEPA. 

Rule Changes Following the Deepwater Horizon Event 

The aftermath of the DWH event provided new information about drilling on the OCS; in particular, 

it provided new information about (1) systemic safety issues, (2) deficiencies of blowout containment 

technologies and strategies, and (3) shortcomings in oil spill response strategies and resources relative 

to spills in deepwater. The BOEMRE has addressed these issues by strengthening its regulations of 

OCS activities. Notable initiatives are discussed below. For additional discussion on advancements 

in safety and their meaning for OCS activities going forward, the reader is referred to an October 1, 

2010 memorandum from the Director of BOEMRE to the Secretary, which supported lifting the 

suspension of certain offshore permitting and drilling activities on portions of the OCS (available at 

http://www.doi.gov/news/pressreleases/loader.cfm?csModule=security/getfile&PageID=64703). 

New rules and rulemaking procedures, along with new and revised Notices to Lessees, are listed 

below. Further discussion of more notable developments is then provided. 

 The Drilling Safety Rule, Interim Final Rule to Enhance Safety Measures for Energy 

Development on the Outer Continental Shelf (Drilling Safety Rule). This rule strengthens 

requirements for safety equipment, well control systems, and blowout prevention practices on 

offshore oil and gas regulations. 

 The Workplace Safety Rule on Safety and Environmental Management Systems (SEMS 

Rule). This rule requires operators to develop and implement a comprehensive SEMS for 

identifying, addressing, and managing operational safety hazards and impacts; promoting 

both human safety and environmental protection; and improving workplace safety by 

reducing risk of human error. 

 NTL 2010-N06, “Information Requirements for Exploration Plans, Development and 

Production Plans, and Development Operations Coordination Documents on the OCS,” 

effective June 18, 2010 (Plans NTL). 

 NTL-2010-N10, “Statement of Compliance with Applicable Regulations and Evaluation of 

Information Demonstrating Adequate Spill Response and Well Containment Resources,” 

effective November 9, 2010 (Certification NTL). 

The Drilling Safety Rule. On October 14, 2010, BOEMRE issued an interim final rule entitled 

“Increased Safety Measures for Energy Development on the Outer Continental Shelf” (75 FR 63346). 

The interim rulemaking revises selected sections of 30 CFR 250 Subparts D, E, F, O, and Q. The 

Drilling Safety Rule includes new standards and requirements related to the design of wells and 

testing of the integrity of wellbores; the use of drilling fluids; and the functionality and testing of well 

control equipment including blowout preventers. To these ends, the rule is expected to promulgate 

OCS-wide provisions that will: 

 Establish new casing installation requirements 

 Establish new cementing requirements 

 Require independent third party verification of blind-shear ram capability 

 Require independent third party verification of subsea BOP stack compatibility 

 Require new casing and cementing integrity tests 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 125

 Establish new requirements for subsea secondary BOP intervention 

 Require function testing for subsea secondary BOP intervention 

 Require documentation for BOP inspections and maintenance 

 Require a Registered Professional Engineer to certify casing and cementing requirements 

 Establish new requirements for specific well control training to include deepwater operations 

Safety and Environmental Management Systems Rule. A new subpart to 30 CFR Part 250: 

Subpart S – Safety and Environmental Management Systems (SEMS) is designed to reduce the 

hazards associated with drilling operations and further reduce the likelihood of a blowout scenario 

such as described for this VLOS analysis. The SEMS Rule requires all OCS operators to develop and 

implement a comprehensive management program for identifying, addressing, and managing 

operational safety hazards and impacts, with the goal of promoting both human safety and 

environmental protection. The interim final rule was published on October 14, 2010 (75 FR 63345), 

requiring full implementation of a SEMS program as recommended by the rule’s effective date of 

November 15, 2011. The 13 elements of the industry standard (American Petroleum Institute, 

Recommended Practice 75) that 30 CFR 250 Subpart S now makes mandatory are as follows: 

 defining the general provisions for implementation, planning and management review, and 

approval of the SEMS program; 

 identifying safety and environmental information needed for any facility such as design data, 

facility process such as flow diagrams, and mechanical components such as piping and 

instrument diagrams; 

 requiring a facility-level risk assessment; 

 addressing any facility or operational changes including management changes, shift changes, 

contractor changes; 

 evaluating operations and written procedures; 

 specifying safe work practices, manuals, standards, and rules of conduct; 

 training, safe work practices, and technical training, including contractors; 

 defining preventative maintenance programs and quality control requirements; 

 requiring a pre-startup review of all systems; 

 responding to and controlling emergencies, evacuation planning, and oil-spill contingency 

plans in place and validated by drills; 

 investigating incidents, procedures, corrective action, and follow-up; 

 requiring audits every 4 years, to an initial 2-year reevaluation and then subsequent 3-year 

audit intervals; and 

 specifying records and documentation that describe all elements of the SEMS program. 

NTL (Notice to Lessees) 2010-N06. Though not a rulemaking, a recent NTL issued by BOEMRE 

warrants discussion here. Effective November 8, 2010, NTL No. 2010-NO6 requires that blowout 

intervention information be submitted with future Exploration or Development and Production Plans. 

The blowout scenarios required by 30 CFR 250.213(g) and 250.243(h) must include supporting 

information for any assertion that well bridging will constrain or terminate the flow or that surface 

intervention will stop the blowout. The availability of a rig to drill a relief well and rig package 

constraints must also be addressed. These scenarios must also specify as accurately as possible the 

time it would take to contract for a rig, move it on site, and drill a relief well, including the possibility 

of drilling a relief well from a neighboring platform or an onshore location. 
BOEMRE Sale 193 Revised Draft SEIS 

126 CHAPTER IV. Environmental Consequences 

NTL (Notice to Lessees) 2010-N10. Also released on November 8, 2010 was NTL 2010-N10. This 

NTL explains that applications for well permits must include a statement that all authorized activities 

will be conducted in compliance with all applicable regulations, to include the new measures 

discussed above. For operations using subsea BOPs or surface BOPs on floating facilities, BOEMRE 

will evaluate whether each operator has submitted adequate information demonstrating that it has 

access to and can deploy subsea containment resources that can adequately and promptly respond to a 

blowout or other loss of well control. The BOEMRE will also evaluate whether each operator has 

adequately described the types and quantities of surface and subsea containment equipment that the 

operator can access in the event of a spill or threat of a spill. 

Joint Industry Task Forces. In response to the DWH event, several entities within the oil and gas 

industry cooperatively formed Joint Industry Task Forces. The stated purpose of each Task Force is 

“to review and evaluate current capacities, and to develop and implement a strategy to address future 

needs and requirements in equipment, practices or industry standards” applicable to the studied 

activity. Where possible, information developed by these Tasks Forces will be augmented with input 

from regulatory agencies, oil spill response and well control specialists, investigation panels, and 

other public sector and non-governmental organizations. To date, Task Forces on “Oil Spill 

Preparedness and Response” and “Subsea Well Control and Containment” have submitted draft 

recommendations. Joint Industry Task Force recommendations will not have the force of regulation, 

but may provide the basis for enhanced industry standards or future rulemaking processes. 

IV.D.2. Very Large Oil Spill (VLOS) Scenario 

To facilitate analysis of the potential environmental impacts of a VLOS in the Chukchi Sea, it is first 

necessary to develop a VLOS scenario. Scenarios are conceptual views of the future and represent 

possible sets of activities. They serve as planning tools that make possible an objective and organized 

analysis of hypothetical events. This VLOS scenario is not to be confused with what would be 

expected to occur as a result of any of the action alternatives. 

The VLOS scenario is similar to worst-case discharge (WCD) anlaysis used to evaluate an EP to the 

extent that both calculations are performed using similar assumptions and identical analytical 

methods. However, these calculations differ in several important ways. Rather than analyzing a 

specific drilling proposal, the VLOS model selected a prospect within an area that maximizes the 

variables driving high flow rates. The VLOS scenario represents an extreme case in flow rate and 

discharge period that in turn represent the largest discharge expected at any site in the subject area. 

Site-specific WCDs at sites across the subject area would typically result in much lower initial rates 

and aggregate discharges if discharge periods are held equal. The calculations also differ in their 

purpose. Whereas the VLOS scenario is a planning tool for environmental impacts analysis, a WCD 

is the calculation required by 30 CFR part 250 to accompany an Exploration Plan and provide a basis 

for an Oil Spill Response Plan. 

The VLOS scenario is predicated on an unlikely event—a loss of well control during exploration 

drilling that leads to a blowout and a resulting VLOS. Information on OCS well control incidents 

was addressed in Section IV.D.1. To further contextualize these events, a qualitative discussion of 

the applicable OCS safety regulations and operational techniques is presented in the following 

paragraphs. 

Rate, Time and Composition of Hypothetical Spill 

The VLOS scenario assumes a blowout leading to a very large oil spill. In developing this scenario, 

BOEMRE first generated a hypothetical oil discharge model that estimates the highest possible 

uncontrolled flow rate that could occur from any known prospect in the proposed Sale 193 area, given 

real world constraints. The discharge model was constructed using a geologic model for a specific 

prospect in conjunction with a commercially-available computer program (AVALON/MERLIN) that 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 127

forecasts the flow of fluids from the reservoir into the well, models the dynamics of multiphase 

(primarily oil and gas) flow up the wellbore, and assesses constraints on flow rate imposed by the 

open wellbore and shallower well casing. This model utilized information and selected variables that, 

individually and collectively, provided a maximized rate of flow. The most important variables for 

the discharge model included thickness, permeability, oil viscosity, gas content of oil, and reservoir 

pressure. Many other variables of lesser importance were also required. 

Table 2 summarizes the results of the discharge model for the hypothetical well. The oil discharge 

climbs rapidly to over 61,000 bbls/day during Day 1. After peaking in Day 1, Figure 4 shows that the 

oil discharge declines rapidly through the first 40 days of flow as the reservoir is depressurized by 

approximately 1,400 psi (Table 2). The decline in the flow rate flattens somewhat after Day 40, 

falling to 20,479 bbls/day (33% of the Day 1 peak rate) by Day 74 when the near-wellbore reservoir 

pressure has fallen to 58% of the initial reservoir pressure (4,392 psi). The total oil discharge by the 

end of the flow period on Day 74 is 2,160,200 bbls. 

74-Day Discharge History for Chukchi Sea VLOS Well

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

1 11 21 31 41 51 61 71

Days of Discharge

Oil Discharge Rate (bbls/d) and Gas 

Discharge Rate (Mcf/d)

0

500

1,000

1,500

2,000

2,500

Cumulative Oil Discharge (*1,000 bbls) 

and Producing Gas-Oil Ratio (scf/stb)

Oil Discharge Rate

Gas Discharge Rate

Cumulative Oil Discharge

Producing Gas-Oil Ratio

Maximum Oil Discharge Rate=61,672 bbl/d

Day 74 Oil Discharge Rate=20,479 bbl/d

Total Oil Discharge=2,160,200 bbls

Oil Saturation Declines

Gas Saturation Rises

Figure 4. Decline in daily discharge rates and rising cumulative oil discharge for a 74-day period after a 

blowout at a hypothetical exploration well in the central Chukchi Sea planning area. 

The oil discharged from the hypothetical well is estimated to be 35° API crude oil like that recovered 

at the Klondike 1 well. This type of crude oil is believed to represent the dominant (Triassic-sourced) 

petroleum system in the central Chukchi Sea. The oil in the hypothetical reservoir is initiallysaturated (with gas) at a gas-oil ratio of 930 cf/bbl (quantities at standard conditions of 60°F and 1 

atm.) and this is reflected by the fact that the initial produced gas-oil ratio in the flow model (Day 0.1, 

see Table 2) is also 930 cf/bbl. As shown in Figure 4 and Table 2, the produced gas-oil ratio falls to a 

minimum of 757 cf/bbl thorugh the period from Day 15 to Day 27, as early production rates fall 

rapidly with de-pressurization of the reservoir near the wellbore. As a larger volume of the reservoir 

becomes de-pressurized below the bubble-point pressure, gas dissociates in larger quantities from the 

oil within the reservoir, and the produced gas-oil ratio steadily rises to a maximum of 1,202 cf/bbl by 
BOEMRE Sale 193 Revised Draft SEIS 

128 CHAPTER IV. Environmental Consequences 

Table 2. Results of AVALON/MERLIN discharge model for Chukchi Sea hypothetical VLOS well over 

maximum (74-day) time period estimated for mobilization, drilling, and completion of a relief 

well. 

Time 

(days)

Oil Discharge 

Rate (bbls/d)

Gas 

Discharge 

Rate (Mcf/d)

Producing 

Rsi (GOR) 

Gas-Oil Ratio 

(scf/stb)

Water 

Discharge 

Rate (bbls/d)

Cumulative 

Oil Discharge 

(Mbbls)

Cumulative 

Gas 

Discharge 

(MMcf)

Cumulative 

Water 

Discharge 

(bbls)

NearWellbore 

Reservoir 

Pressure 

(psi)

0 0 0 930 0 0 0 0 4,392

0.1 50,671 47,124 930 0.06 5.1 4.7 0.0 4,168

1 61,672 50,677 822 0.16 61.8 52.2 0.1 3,937

2 57,485 46,357 806 0.18 120.5 99.8 0.3 3,875

3 53,987 43,035 797 0.20 175.1 143.5 0.5 3,827

4 52,246 41,030 785 0.23 226.1 183.9 0.7 3,777

5 48,669 38,101 783 0.23 274.8 222.0 1.0 3,747

6 46,581 36,312 780 0.25 321.4 258.4 1.2 3,707

7 45,036 34,931 776 0.26 366.4 293.3 1.5 3,666

8 43,596 33,607 771 0.27 410.0 326.9 1.7 3,627

9 42,239 32,343 766 0.28 452.2 359.2 2.0 3,591

10 40,889 31,100 761 0.29 493.1 390.3 2.3 3,558

11 39,529 29,923 757 0.29 532.6 420.3 2.6 3,528

12 38,306 28,974 756 0.30 570.9 449.2 2.9 3,499

13 37,219 28,148 756 0.30 608.2 477.4 3.2 3,473

14 36,364 27,583 759 0.31 644.5 505.0 3.5 3,445

15 35,580 27,035 760 0.32 680.1 532.0 3.8 3,420

16 34,930 26,628 762 0.33 715.0 558.6 4.2 3,394

17 34,316 26,178 763 0.33 749.4 584.8 4.5 3,370

18 33,750 25,767 763 0.34 783.1 610.6 4.8 3,347

19 33,199 25,330 763 0.34 816.3 635.9 5.2 3,325

20 32,662 24,885 762 0.35 849.0 660.8 5.5 3,304

21 32,130 24,436 761 0.35 881.1 685.2 5.9 3,284

22 31,608 23,995 759 0.35 912.7 709.2 6.2 3,265

23 31,094 23,577 758 0.35 943.8 732.8 6.6 3,247

24 30,596 23,178 758 0.36 974.4 756.0 6.9 3,230

25 30,115 22,800 757 0.36 1,004.5 778.8 7.3 3,213

26 29,648 22,443 757 0.36 1,034.2 801.2 7.7 3,197

27 29,200 22,110 757 0.36 1,063.4 823.3 8.0 3,181

28 28,750 21,788 758 0.36 1,092.1 845.1 8.4 3,165

29 28,319 21,499 759 0.36 1,120.4 866.6 8.7 3,150

30 27,917 21,245 761 0.37 1,148.3 887.9 9.1 3,136

31 27,539 21,029 764 0.37 1,175.9 908.9 9.5 3,121

32 27,166 20,806 766 0.37 1,203.0 929.7 9.9 3,106

33 26,805 20,599 768 0.37 1,229.9 950.3 10.2 3,092

34 26,452 20,415 772 0.37 1,256.3 970.7 10.6 3,079

35 26,124 20,256 775 0.38 1,282.4 991.0 11.0 3,065

36 25,817 20,115 779 0.38 1,308.2 1,011.1 11.4 3,052

37 25,534 20,006 784 0.38 1,333.8 1,031.1 11.7 3,038

38 25,250 19,886 788 0.38 1,359.0 1,051.0 12.1 3,025

39 24,974 19,787 792 0.39 1,384.0 1,070.8 12.5 3,012

40 24,719 19,707 797 0.39 1,408.7 1,090.5 12.9 2,999

41 24,474 19,637 802 0.39 1,433.2 1,110.1 13.3 2,986

42 24,251 19,595 808 0.39 1,457.4 1,129.7 13.7 2,973

43 24,034 19,552 814 0.40 1,481.5 1,149.2 14.1 2,961

44 23,821 19,522 820 0.40 1,505.3 1,168.8 14.5 2,948

45 23,620 19,513 826 0.40 1,528.9 1,188.3 14.9 2,936

46 23,434 19,518 833 0.41 1,552.4 1,207.8 15.3 2,923

47 23,259 19,531 840 0.41 1,575.6 1,227.3 15.7 2,911

48 23,110 19,579 847 0.42 1,598.7 1,246.9 16.1 2,898

49 22,946 19,617 855 0.42 1,621.7 1,266.5 16.5 2,885

50 22,797 19,682 863 0.42 1,644.5 1,286.2 17.0 2,873

51 22,665 19,765 872 0.43 1,667.1 1,306.0 17.4 2,860

52 22,543 19,856 881 0.43 1,689.7 1,325.8 17.8 2,847

53 22,434 19,972 890 0.44 1,712.1 1,345.8 18.3 2,835

54 22,325 20,098 900 0.44 1,734.4 1,365.9 18.7 2,822

55 22,228 20,252 911 0.45 1,756.7 1,386.2 19.2 2,809

56 22,150 20,425 922 0.46 1,778.8 1,406.6 19.6 2,795

57 22,042 20,566 933 0.46 1,800.9 1,427.1 20.1 2,783

58 21,918 20,699 944 0.47 1,822.8 1,447.8 20.6 2,770

59 21,807 20,869 957 0.47 1,844.6 1,468.7 21.0 2,758

60 21,688 21,030 970 0.48 1,866.3 1,489.7 21.5 2,745

61 21,580 21,203 983 0.48 1,887.8 1,510.9 22.0 2,733

62 21,475 21,381 996 0.49 1,909.3 1,532.3 22.5 2,720

63 21,369 21,566 1,009 0.49 1,930.7 1,553.9 23.0 2,708

64 21,284 21,804 1,024 0.50 1,952.0 1,575.7 23.5 2,695

65 21,193 22,032 1,040 0.51 1,973.2 1,597.7 24.0 2,683

66 21,112 22,276 1,055 0.51 1,994.3 1,620.0 24.5 2,670

67 21,033 22,532 1,071 0.52 2,015.3 1,642.5 25.0 2,657

68 20,955 22,799 1,088 0.53 2,036.3 1,665.3 25.5 2,644

69 20,868 23,078 1,106 0.53 2,057.1 1,688.4 26.1 2,632

70 20,777 23,350 1,124 0.54 2,077.9 1,711.8 26.6 2,619

71 20,693 23,637 1,142 0.55 2,098.6 1,735.4 27.2 2,606

72 20,615 23,934 1,161 0.55 2,119.2 1,759.3 27.7 2,594

73 20,539 24,248 1,181 0.56 2,139.8 1,783.6 28.3 2,581

74 20,479 24,608 1,202 0.57 2,160.2 1,808.2 28.8 2,567

Mcf/d, thousands of cubic feet per day; scf/stb, standard cubic feet or gas per stock-tank barrel of oil at 1 atmosphere (101.6

kilopascals) and 60 °F (15.6 °C) or surface conditions; Mbbls, thousands of barrels; MMcf, millions of cubic feet; psi, pounds per square 

inch (6.895 kiloipascals). "Near-Wellbore Reservoir Pressure" represents the formation pressure in the cell penetrated by the well.
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 129

the end of the flow period on Day 74. Water production over the flow period is quite small (as shown 

in Table 2) because of the higher relative permeability to oil within the oil-saturated reservoir and the 

assumed absence of a brine-saturated reservoir in contact with the wellbore. Further discussion of the 

AVALON/MERLIN model and the variables selected in estimating flow rate is provided in Appendix 

D. 

Additional Parameters 

The following discussion describes additional parameters of the VLOS scenario. These parameters 

are based on reasonably foreseeable factors related to oil spills, based on past VLOS events (i.e. the 

Exxon Valdez Oil Spill (EVOS), DWH event, and the Ixtoc oil spill), published scientific reports, 

consideration of Arctic-specific conditions, and application of best professional judgment. The result 

is a framework for identifying the most likely and most significant impacts of the hypothetical VLOS 

event. Key aspects of the scenario are listed below: 

 A loss of well control during exploration drilling leads to a blowout and an ongoing, high 

volume release of crude oil and gas that continues for up to 39-74 days. 

 Oil remains on the surface of the water for up to a few weeks after flow has stopped or after 

meltout from sea ice during the Arctic spring. 

 The total volume of the oil is nearly 2.2 MMbbls (million barrels) and the volume of the gas 

is 1.8 Bcf (billion cubic feet)—within 74 days. 

 Roughly 30 percent of the VLOS evaporates. A small portion of the spill remains in the 

water column as small droplets. The remaining oil could be physically or chemically 

dispersed, sedimented, beached, weathered into tar balls, or biodegraded. 

 Information about where a very large spill could go and how long it takes to contact resources 

is estimated by an oil spill trajectory model. 

Cause of Spill 

This scenario begins with an unlikely event – a loss of well control during exploration drilling that 

leads to a long duration blowout and a VLOS. 

For the purpose of the analysis, an explosion and subsequent fire are assumed to occur. A blowout 

associated with the drilling of a single exploratory well could result in a fire that would burn for 1 or 

2 days. The exploration drilling rig or platform may sink. If the blowout occurs in shallow water, the 

sinking rig or platform may land in the immediate vicinity; if the blowout occurs in deeper water, the 

rig or platform could land a great distance away. For example, the Deepwater Horizon drilling rig 

sank, landing 1,500 feet from the subsea wellhead. Water depths in the majority of the Sale 193 area 

range from about 95 feet to approximately 262 feet; this range is considered shallow water. A small 

portion of the northeast corner of the Sale 193 area deepens to approximately 9,800 feet. 

For the purpose of modeling flow rates, the location of the blowout and leak was specified as 

occurring near the mudline (at the top of the BOP). For the purpose of environmental effects analysis, 

it is acknowledged that a blowout could occur in other locations, such as at the sea surface, along the 

riser anywhere from the seafloor to the sea surface, or below the seafloor (outside the wellbore). The 

forthcoming environmental effects analysis in Section IV.E encompasses all these possibilities. As 

different blowout and leak locations may have bearing on spill response and intervention options, 

additional discussion of these issues is provided in Section IV.D.3, Opportunities for Intervention and 

Response. 

Timing of the Initial Event 

For purposes of analysis, the hypothetical VLOS is estimated to commence between July 15 and 

October 31. These dates coincide with the open water drilling season. 
BOEMRE Sale 193 Revised Draft SEIS 

130 CHAPTER IV. Environmental Consequences 

Any exploration drilling associated with Lease Sale 193 would be anticipated to occur within ten 

years of affirming or modifying the lease sale at the conclusion of this NEPA process. The lease sale 

can also be canceled, in which case no drilling would occur as a result of Lease Sale 193. 

Duration of Spill 

The duration of the offshore spill from a blowout depends on the time required for successful 

intervention. Intervention may take a variety of forms. As discussed in Section IV.D.3., there exists 

a variety of methods by which an operator or responder can stop the flow of oil. The availability of 

some of these techniques could vary under individual drilling plans. Under NTL 2010-N06 

(discussed in Section IV.D.1, above), all exploration plans must specify as accurately as possible the 

time it would take to contract for a rig, move it on site, and drill a relief well. For purposes of 

analysis within this VLOS scenario, we estimate the discharge would be stopped within 74 days of 

the initial event. This duration reflects the longest of three estimated time periods for completing a 

relief well as described in Table 3, below. 

Table 3. Estimates for time periods required to drill a relief well and to kill the discharge at the Chukchi 

Sea VLOS well (provided by BOEMRE AKOCSR Field Operations). 

1. Use of Original Drilling Platform and Equipment to Drill Relief Well 

Activity Time Estimate (days) 

Cleanup and resupply of original vessel 5 

Construction of relief well cellar* 7 

Drilling of relief well 18 

Killing of VLOS (original) well 5 

Weather downtime* 4 

Total Time Required 39 

2. Use of Second Drilling Platform and Equipment Prepositioned Intheatre (within Chukchi Sea) for Relief Well 

Activity Time Estimate (days) 

Plug and temporarily abandon well being drilled by 

second drilling platform 

5 

Cleanup and resupply of relief well vessel 5 

Transport of relief well rig to VLOS well site 2 

Construction of relief well cellar* 7 

Drilling of relief well 18 

Killing of VLOS (original) well 5 

Weather downtime* 4 

Total Time Required 46 

3. Use of Second Drilling Platform and Equipment from Northern 

Hemisphere Pacific Rim for Relief Well 

Activity Time Estimate (days) 

Plug and temporarily abandon well being drilled by 

second (relief well) drilling platform 

5 

Cleanup of relief well vessel (performed en route—no 

additional time 

0 

Transport of relief well rig to VLOS well site 30 

Resupply of relief well vessel 5 

Construction of relief well cellar* 7 

Drilling of relief well 18 

Killing of VLOS (original) well 5 

Weather downtime* 4 

Total Required Time 74 

*estimates based upon previous operations in the area 

Volume of Spill 

Well blowouts generally involve two types of hydrocarbons, namely crude oil (or condensate) and 

natural gas. The volume ratio of these two fluids is a function of the characteristics of the fluids and 

the producing reservoir. 

Table 2 summarizes the results of the discharge model for the hypothetical VLOS. The oil discharge 

climbs rapidly to over 61,000 bbls/day during day one. After peaking in Day 1, Figure 4 shows that 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 131

the oil discharge declines rapidly through the first 40 days of flow as the reservoir is depressurized by 

approximately 1,400 psi (Table 2). The decline in the flow rate flattens somewhat after Day 40. As 

shown in Table 2, the cumulative oil discharge over a 74-day spill is 2,160,200 bbls. 

To simplify the analysis, we estimate 2.2 MMbbls (million barrels) of oil are spilled in the VLOS 

scenario. 

Area of Spill 

When oil reaches the sea surface, it spreads. The speed and extent of spreading depends on the type of 

oil and volume that is spilled. A spill of the size analyzed here would likely spread hundreds of square 

miles. Also, the oil slick may break into several smaller slicks, depending on local wind patterns that 

drive the surface currents in the spill area. Estimates of where the oil spill would go were taken from 

the OSRA trajectory analysis (see Appendix B). 

Oil in the Environment: Properties and Persistence 

The fate of oil in the environment depends on many factors, such as the source and composition of the 

oil, as well as its persistence (National Research Council, 2003c). Persistence can be defined and 

measured in different ways (Davis et al., 2004), but the National Research Council (NRC) generally 

defines persistence as how long oil remains in the environment (National Ressearch Council, 2003c; 

p. 89). Once oil enters the environment, it begins to change through physical, chemical, and 

biological weathering processes (Natianal Research Council, 2003c). These processes may interact 

and affect the properties and persistence of the oil through: 

 evaporation (volatilization), 

 emulsification (the formation of a mousse), 

 dissolution, 

 oxidation, and 

 transport processes (National Research Council, 2003c; Scholz et al., 1999). 

Horizontal transport takes place via spreading, advection, dispersion, and entrainment while vertical 

transport takes place via dispersion, entrainment, Langmuir circulation, sinking, overwashing, 

partitioning, and sedimentation (Sale 193 FEIS, Appendix A.1, Figure A.1 and A.2). The persistence 

of an oil slick is influenced by the effectiveness of oil-spill response efforts and affects the resources 

needed for oil recovery (Davis et al., 2004). The persistence of an oil slick may also affect the 

severity of environmental impacts as a result of the spilled oil. 

Crude oils are not a single chemical, but instead are complex mixtures with varied compositions. 

Thus, the behavior of the oil and the risk the oil poses to natural resources depends on the 

composition of the specific oil encountered (Michel, 1992). Generally, oils can be divided into three 

groups of compounds: (1) light-weight, (2) medium-weight, and (3) heavy-weight components. 

The oil discharged from the hypothetical Chukchi Sea VLOS well is 35° API crude oil. This oil 

would be considered light-weight as shown in Table 4, below. On average, light weight crude oils are 

characterized as outlined below in Table 4. 

Previous studies (Boehm and Fiest 1982) supported the estimate that most released oil in shallow 

waters similar to the Chukchi Sea would reach the surface of the water column. A small portion (1-

3%) of the Ixtoc oil remained in the water column (dispersants were used), although limited scientific 

investigation occurred and analytical chemical methods 30 years ago may not have been as sensitive 

as today (Boehm and Fiest, 1982; Reible, 2010). 
BOEMRE Sale 193 Revised Draft SEIS 

132 CHAPTER IV. Environmental Consequences 

Table 4. Properties and persistence for light-weight crude oil. (Sources: Michel, 1992; Reed et al. 2005 

[Sintef OWM]; Brandvik et al., 2010). 

Light-weight Crude Oil – Properties and Persistence 

Hydrocarbon compounds Up to 10 carbon atoms 

API o >31.1o 

Evaporation rate Rapid (within 1-3 days) and complete in summer; Slower (1-30 days) 

winter longer for complete evaporation 

Solubility in water High 

Acute toxicity High due to monoaromatic hydrocarbons (BTEX) 

Chronic toxicity Minor, does not persist due to evaporation 

Bioaccumulation potential Minor, does not persist due to evaporation 

Compositional majority Alkanes and cycloalkanes 

Persistence Low due to evaporation 

Sources: Michel, 1992; Reed et al. 2005 [Sintef OWM]; Brandvik, Resby, and Daling, et al., 2010 

Release of Natural Gas 

The quality and quantity of components in natural gas vary widely by the field, reservoir, or location 

from which the natural gas is produced. The oil in the VLOS reservoir is assumed to be initially 

saturated (with gas) at a gas-oil ratio of 930 cf/bbl (quantities at standard conditions of 60°F and 1.0 

atm.) and this is reflected by the fact that the initial (Day 0.1) produced gas-oil ratio in the model 

(Table 2) is also 930 cf/bbl. As shown in Table 2, the produced gas-oil ratio falls to a minimum of 

757 cf/bbl between Day 15 and Day 27—while early oil and gas production rates fall rapidly with depressurization of the reservoir near the wellbore—but then rises to 1,202 cf/bbl by Day 74 of the 

discharge. 

Gas discharge reaches a peak of 50,677 Mcf/d in Day 1 of the flow, falls to a minimum rate of 19,513 

Mcf/d by Day 45, then rises to 24,608 Mcf/d by Day 74. The pattern of gas flow reflects the process 

of gas break-out in the reservoir that progressively converts the initial oil reservoir into a gas 

reservoir. The cumulative gas discharge over the 74-day period (use of new platform and drilling 

equipment) estimated for completion of a relief well (very large discharge case) is 1,808 MMcf. For 

purposes of analysis we estimate 1.8 Bcf (billion cubic feet). Natural gas is primarily made up of 

methane (CH4) and ethane (C2H6) which make up 85-90% of the volume of the mixture. 

Duration of Subsea and Shoreline Oiling 

The duration of the shoreline oiling is measured from initial shoreline contact until the well is capped 

or killed and the remaining surface oil dissipates offshore. Depending on the spill’s location in 

relation to winds, ice and currents and the well’s distance to shore, oil could reach the coast within 10 

days to 360 days based on BOEMRE oil spill trajectory analysis (USDOI, MMS 2007). While it is 

estimated that the majority of spilled surface oil would evaporate and naturally disperse offshore 

within 30 days of stopping the flow or after meltout in the Arctic spring, some oil may remain in 

coastal areas until cleaned, as seen following the EVOS and DWH event (The State of Louisiana, 

2010a-d). The generation of oil suspended particulate material or subsurface plumes from the well 

head would stop when the well was capped or killed. Subsurface plumes would disspate over time 

due to mixing and advection (Boehm and Fiest, 1982). 

Volume of Oil Reaching Shore 

In the event of a VLOS, not all of the oil spilled would contact shore. The volume of oil recovered 

and chemically or naturally dispersed would vary. For example, the following are recovery and 

cleanup rates from previous high-volume, extended spills (Wolfe, et al., 1994; Gundlach and Boehm, 

1981; Gundlach, et al., 1983; Lubchenco, et al., 2010): 

 10-40 percent of oil recovered or reduced (including burned, chemically dispersed, and 

skimmed). 

 25-40 percent of oil naturally dispersed, evaporated, or dissolved. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 133

 20-65 percent of the oil remains offshore until biodegraded or until reaching shore. 

In the case of the DWH event, “it is estimated that burning, skimming and direct recovery from the 

wellhead removed one quarter (25%) of the oil released from the wellhead. One quarter (25%) of the 

total oil naturally evaporated or dissolved, and just less than one quarter (24%) was dispersed (either 

naturally or as a result of operations) as microscopic droplets into Gulf waters. The residual amount—

just over one quarter (26%)—is either on or just below the surface as light sheen and weathered tar 

balls, has washed ashore or been collected from the shore, or is buried in sand and sediments” (Interagency, 2010a). For planning purposes, USCG estimates that 5-30 percent of oil will reach shore in 

the event of an offshore spill (33 CFR Part 154, Appendix C, Table 2.). 

Length of Shoreline Contacted 

While larger spill volumes increase the chance of oil reaching the shoreline, other factors that 

influence the length and location of shoreline contacted include the duration of the spill and the well’s 

location in relation to winds, ice, currents, and the shoreline. As estimated from the OSRA model 

explained in more detail in Section IV.E.1 and Appendix B, the length of oiled shoreline increases 

over time as the spill continues (Table 5). 

Table 5. Length of discontinuous shoreline contacted in winter and summer within a 360 day period 

(estimated from OSRA model). 

Summer Length of 

Discontinuous 

Shoreline Contact in 

miles from LA1–13 

Chukchi Length of 

Shoreline Contacted 

during Winter in miles 

from LA1–13 

Days from Spill 

Release 

Summer 

Number of LS 

mi km 

Winter 

Number of LS 

mi km 

3 days * * * * 

10 days 0–3 0–150 0–241 0–3 0–150 0–241 

30 days 0–12 0–600 0–966 0–4 0–200 0–322 

60 days 0–13 0–650 0–1046 0–8 0–400 0–644 

180 days 0–14 0–700 0–1127 0–14 0–700 0–1127 

360 days 0–17 0–850 0–1368 0–15 0–800 0–1287 

Note: * = less than 0.5 percent of trajectories contacting; therefore, no length calculated 

Dependent upon winds and currents throughout the very large oil spill event, already impacted areas 

could have oil refloated and oil other areas increasing the estimates above. 

A VLOS from a nearshore site would allow less time for oil to be weathered, dispersed, and/or 

recovered before reaching shore. This could result in a more concentrated and toxic oiling of the 

shoreline. A release site farther from shore could allow more time for oil to be weathered, dispersed, 

and recovered. This could result in a broader, patchier oiling of the shoreline. 

Severe and Extreme Weather 

Wind and wave action can drive oil floating on the surface into the water column, and oil stranded on 

shorelines can be moved into nearshore waters and sediment during storms. Episodes of severe and 

extreme weather over the Arctic could affect the behavior of sea-surface oil, accelerate 

biodegradation of the oil, impact shoreline conditions, and put marine vessels at risk. For instance, 

recovery of sea-surface oil could be impeded by the formation of sea ice during severe cold outbreaks 

that occur typically over the Arctic winter. In addition, episodes of severe storms characterized by 

strong winds (25 to 30 miles per hour) and precipitation can dictate the movement of sea-surface oil 

drift and also direct oil toward the coastline following a VLOS occurring during summer or winter. 

The severe storms, referred to as mesoscale cyclones (MCs), form when a cold air mass over land (or 

an ice sheet) moves over warmer open water (Nihoul & Kostianoy, 2009). These storms are usually 

small-scale and short-lived; and the lower the atmospheric pressure in the storm center, the stronger 

the storm. More intense versions of MCs occur mainly during the Arctic winter when the lowest 

pressure polar mesoscale cyclones (PMCs) are associated with the semi permanent Aleutian low. 

These storms can cause extreme weather conditions in areas near ice/ocean or land/ocean boundaries 
BOEMRE Sale 193 Revised Draft SEIS 

134 CHAPTER IV. Environmental Consequences 

(Jackson & Apel, 2004). While less common, these storms cover a larger area and can cause surface 

winds at or near gale force, up to 45 miles per hour, with waves 15 to 20 feet. As such, a PMC is 

sometimes characterized as an arctic hurricane. Wind and wave action caused by these extreme 

storms can pose a risk to marine vessels, drive sea-surface oil into the water column, enhance 

weathering of the oil, or cause oil stranded on the coastline to move into nearshore waters and 

sediment. Any of these conditions could temporarily delay or stop the response and recovery effort. 

Recovery and Cleanup 

The hypothetical VLOS scenario outlined thus far would trigger an extensive spill recovery and 

cleanup effort. It is anticipated that efforts to respond to a VLOS in the Chukchi Sea would include 

the recovery and cleanup techniques and estimated levels of activities described below. A more 

detailed description of the available methods to respond to an oil spill is provided in the Arctic MultiSale Draft EIS, in Section 4.3.3.5.5 (USDOI, MMS, 2008a). It is noted that severe weather and/or the 

presence of ice could interfere with or temporarily preclude each of these methods. The effect of ice 

is discussed in greater detail below in “Effect of Ice on Response Actions.” For a comprehensive 

summary report of the 31 Arctic oil spill response research projects that BOEMRE has funded, the 

reader is referred to a report called “Arctic Oil Spill Response Research and Development Program: 

A Decade of Achievement.” This document is available at http://www.boemre.gov/ 

tarprojectcategories/ArcticOilSpillResponseResearch.htm. 

Mechanical Recovery. Both mechanical and non-mechanical methods of oil spill response can be 

utilized in the Chukchi Sea to mitigate the impacts of an oil spill on the environment. The preferred 

means of spill response is mechanical recovery of the oil, which physically removes oil from the 

ocean. Mechanical recovery is accomplished through the use of devices such as containment booms 

and skimmers. A containment boom is deployed in the water and positioned within an oil slick to 

contain and concentrate oil into a pool thick enough to permit collection by a skimmer. The skimmer 

collects the oil and transfers it to a storage vessel (storage barges or oil tankers) where it will 

eventually be transferred to shore for appropriate recycling or disposal. 

Dispersants. Use of chemical dispersants is a response option for the Chukchi Sea. Research has 

shown that dispersants can be effective in cold and ice infested waters when employed in a timely 

manner (S.L. Ross Environmental Research Ltd., 2002, 2003, 2006, 2007; Belore, 2003). Recently 

completed field scale tests conducted by Sintef (Sintef, 2010) as part of the Oil in Ice Joint Industry 

Project (JIP) in the Barents Sea has demonstrated that results from lab scale and large wave tank tests 

hold true in actual ocean conditions. Oil released into the ocean during broken ice conditions was 

readily dispersed and the dispersion was enhanced with the addition of vessel propeller wash for more 

energy in these conditions. It was also demonstrated that in these cold conditions weathering of the 

oil was significantly slowed providing a greater window of opportunity in which to successfully apply 

dispersants. Dispersant application can be accomplished by means of injection at the source or 

through aerial or vessel based application. There are dispersant stockpiles located in Prudhoe Bay, 

Anchorage and the Lower 48 states. Dispersant use is limited to ocean application in waters generally 

deeper than 10 meters; this depth restriction is used to avoid or reduce potential toxicity concerns to 

nearshore organisms. 

The State of Alaska does not have preapproved dispersant application zones for the Chukchi Sea so 

each request for dispersant application would be evaluated and approved or disapproved on a case-bycase basis by the Federal On-Scene Coordinator in consultation with the Alaska Regional Response 

Team (ARRT). The decision regarding how and when dispersants would be applied would also 

reside with the FOSC and the ARRT. Procedures governing the application of dispersants are 

provided in “The Alaska Federal and State Preparedness Plan for Response to Oil and Hazardous 

Substance Discharges and Releases” (Unified Plan) (ARRT, 2010). However, the FOSC is not limited 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 135

to this procedure and may utilize other sources of information in determining what the most 

appropriate dispersant method would be given a specific situation. 

In-situ Burning. In-situ burning is also a viable response method for the Chukchi Sea and could be 

approved by the Federal On-Scene Coordinator in consultation with the Unified Command and the 

ARRT. Any in-situ burning would be conducted in accordance with the Alaska Unified Plan In-situ 

Burn Guidelines (ARRT, 2010). In-situ burning is a method that can be used in open ocean, broken 

ice, near shore and shoreline cleanup operations. In broken ice conditions the ice serves to act as a 

natural containment boom limiting the spread of oil and concentrating it into thicker slicks, which aid 

in starting and maintaining combustion. In-situ burning has the potential to remove in excess of 90% 

of the volume of oil involved in the burn. In-situ burning experiments of oil in ice conducted as part 

of the Sintef JIP (Sintef, 2010) has likewise demonstrated that cold temperatures serve to slow 

weathering of the oil, in turn expanding the window of opportunity for in-situ burning application 

over that experienced in more temperate regions. 

Effect of Ice on Response Actions. For all response options the presence of ice can both aid and 

hinder oil spill response activities. Ice acts as a natural containment device preventing the rapid 

spread of oil across the ocean surface, it also serves to concentrate and thicken the oil allowing for 

more efficient skimming, dispersant application and in-situ burning operations. Once shore fast ice is 

formed, it serves as a protective barrier limiting or preventing oil from contacting shorelines. Cold 

temperatures and ice will slow the weathering process by reducing volatilization of lighter volatile 

compounds of the oil, reducing impact of wind and waves, and extending the window of opportunity 

in which responders may utilize their response tools. 

Conversely ice can limit responder’s ability to detect and locate the oil, access the oil by vessel, 

prevent the flow of oil to skimmers, require thicker pools to permit in-situ burning and eventually 

encapsulate the oil within a growing ice sheet making access difficult or impossible. Once 

incorporated into the ice sheet further recovery operations would have to cease until the ice sheet 

becomes stable and safe enough to support equipment and personnel to excavate and/or trench 

through the ice to access the oil. The other response option is embedding tracking devices in the ice 

and monitoring its location until the ice sheet begins to melt and the oil surfaces through brine 

channels at which time it could be collected or burned. 

Levels of Recovery and Cleanup Activities. The levels of activities required to apply the techniques 

described above are dependent on the specific timing and location of a spill. As weather, ice, and 

logistical considerations allow, the number of vessels and responders would increase exponentially as 

a spill continues. The levels of activities described below are reasonable estimates provided as a basis 

for analysis. These estimates are based on Subarea Contingency Plans for the North Slope and 

northwest Arctic subareas, past spill response and cleanup efforts including the EVOS and DWH 

events, and the best professional judgment of BOEMRE spill response experts. 

 Between 5 and 10 staging areas would be established 

 About 15 to 20 large skimming vessels (i.e. the Nanuq, Endeavor Barge, Tor Viking, other 

barges from Prudhoe Bay, USCG skimming vessels, vessels from Cook Inlet and Prince 

William Sound) could be used in offshore areas. The majority of open ocean vessels would 

be positioned relatively close to the source of the oil spill to capture oil in the thickest slicks, 

thus enabling the greatest rate of recovery. 

 Thousands of responders (from industry, the Federal government, private entities) could 

assist spill response and cleanup efforts as the spill progresses. Weather permitting, roughly 

300-400 skimming, booming, and lightering vessels could be used in areas closer to shore. 

Based on the trajectory of the slick, shallow water vessels would be deployed to areas 

identified as priority protection sites. 
BOEMRE Sale 193 Revised Draft SEIS 

136 CHAPTER IV. Environmental Consequences 

 Booming would occur, dependent upon the location of the potentially impacted shoreline, 

environmental considerations, and agreed upon protection strategies involving the local 

potentially impacted communities. About 100 booming teams could monitor and operate in 

multiple areas. 

 Use of dispersants and/or in-situ burning could occur if authorized by the Federal On Scene 

Coordinator (FOSC). Use of dispersants would likely concentrate on the source of the flow 

or be conducted so as to protect sensitive resources. In-situ burning operations would 

likewise be conducted in the area of thickest concentration to ensure the highest efficiency for 

the effort. In-situ burning may also be utilized in nearshore and shoreline response where 

approved by FOSC. 

 Dozens of planes and helicopters would fly over the spill area, including impacted coastal 

areas. Existing airport facilities along the Arctic coast (including airports at Kotzebue, Point 

Hope, Point Lay, Wainwright, Barrow, and any other suitable airstrips) would be used to 

support these aircraft. If aircraft are to apply dispersants, they could do so from altitudes of 

50 to 100 feet. 

 Workers could be housed offshore on vessels or in temporary camps at the 5–10 staging 

areas. 

Depending on the timing and location of the spill, the above efforts could be affected by seasonal 

considerations. In the event that response efforts continue into the winter season, small vessel traffic 

would come to a halt once the forming ice begins to cover the ocean surface. Larger skimming 

vessels could continue until conditions prevent oil from flowing into the skimmers. At this point, 

operations could shift to in-situ burning if sufficient thicknesses are encountered. The lack of daylight 

during winter months would increase the difficulties of response. 

As ice formation progresses, the focus of the response would shift to placing tracking devices in the 

forming ice sheet to follow the oil as it is encapsulated into the ice sheet. Once the ice sheet becomes 

solid and stable enough, recovery operations could resume by trenching through the ice to recover the 

oil using heavy equipment. This would most likely occur in areas closer to shore because the ice will 

be more stable. In late spring and early summer, as the ice sheet rots, larger ice-class vessels could 

move into the area and begin recovery or in-situ burning operations as the oil is released from the ice 

sheet. The ice would work as a natural containment boom keeping the oil from spreading rapidly. As 

the ice sheet decays, oil encapsulated in the ice would begin surfacing in melt pools at which time 

responders will have additional opportunities to conduct in-situ burn operations. Smaller vessels 

could eventually re-commence skimming operations in open leads and among ice flows, most likely 

in a free skimming mode (without boom) along the ice edge. 

While it is estimated that the majority of spilled oil on the water’s surface would be dissipated within 

a few weeks of stopping the flow (Inter-agency, 2010a) during open water or after meltout in the 

Arctic spring, oil has the potential to persist in the environment long after a spill event and has been 

detected in sediment 30 years after a spill (Etkin, McCay, and Michel, 2007). On coarse sand and 

gravel beaches, oil can sink deep into the sediments. In tidal flats and salt marshes, oil may seep into 

the muddy bottoms (USDOI, FWS, 2010g). 

Effectiveness of intervention, response and cleanup efforts depend on the spatial location of the 

blowout, leak path of the oil and amount of ice in the area. For the purpose of analysis, effectiveness 

of response techniques is not factored into the spill volume posited by this scenario and considered 

during OSRA modeling. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 137

Scenario Phases and Impact-Producing Factors 

This section specifically identifies the manners in which the hypothetical VLOS event described 

above could adversely impact the environment. The intent of this section is to facilitate thorough yet 

focused impacts analysis in Section IV.E. 

The events comprising the VLOS scenario are first categorized into five distinct phases. These 

phases, which range from the initial blowout event to long-term recovery, are presented 

chronologically. Within each phase are one or more components that may cause adverse impacts to 

the environment. These components are termed “Impact Producing Factors,” or IPFs, and will be 

used in Section IV.E. to guide the environmental impacts analysis. The specific IPFs listed here are 

intended to inform, rather than limit, the discussion of potential impacts in Section IV.E. 

Well Control Incident (Phase 1) 

Phase 1 of the hypothetical VLOS scenario is comprised of the catastrophic blowout and its 

immediate consequences. Potential IPFs associated with Phase 1 include the following: 

 Explosion. Natural gas released during a blowout could ignite, causing an explosion. 

 Fire. A blowout could result in a fire that could burn for 1 to 2 days. 

 Re-distribution of Sediments. A blowout could re-distribute sediment along the seafloor. 

 Sinking of Rig. The drill rig could sink to the sea floor. 

 Psychological/Social Distress. News and images of a traumatic event could cause various 

forms of distress. 

Offshore Spill (Phase 2) 

Phase 2 of the scenario encompasses the continuing release of an oil spill in Federal and State 

offshore waters. Potential IPFs associated with Phase 2 include the following: 

 Contact with Oil. Offshore resources (including resources at surface, water column, and sea 

floor) could be contacted with spilled oil. 

 Contamination. Pollution stemming from an oil spill may contaminate environmental 

resources, habitat, and/or food sources. 

 Loss of Access. The presence of oil could prevent or disrupt access to and use of affected 

areas. 

Onshore Contact (Phase 3) 

Phase 3 of the scenario focuses on the continuing release of an oil spill and contact to coastline and 

State nearshore waters. Potential IPFs associated with Phase 3 include the following: 

 Contact with Oil. Onshore resources could come into direct contact with spilled oil. 

 Contamination. Pollution stemming from an oil spill may contaminant environmental 

resources, habitat, and/or food sources. 

 Loss of Access. The presence of oil could prevent or disrupt access to and use of affected 

areas. 

Spill Response and Cleanup (Phase 4) 

Phase 4 of the scenario encompasses spill response and cleanup efforts in offshore Federal and State 

waters as well as onshore Federal, State and private lands along the coastline. Potential IPFs 

associated with Phase 4 include the following: 

 Vessels. Vessels could be used in support of spill response and cleanup activities. 
BOEMRE Sale 193 Revised Draft SEIS 

138 CHAPTER IV. Environmental Consequences 

 Aircraft. Aircraft could be used in support of spill response and cleanup efforts. 

 In-situ burning. Remedial efforts may include burning of spilled oil. 

 Animal Rescue. Animals may be hazed or captured and sent to rehabilitation centers. 

 Dispersants. Dispersants could be introduced into the environment. 

 Skimmers. Boats equipped to skim oil from the surface. 

 Booming. Responders could deploy booms—long rolls of oil absorbent materials that float 

on the surface and corral oil. 

 Beach cleaning. Cleanup efforts including hot water washing, hand cleaning using oil 

absorbent materials, and placement and recovery of sorbent pads, could be used on beaches 

and other coastal areas contacted by an oil spill. 

 Drilling of Relief Well. A relief well could be drilled by the original drilling vessel or by a 

second vessel with additional support. 

 Co-opting of resources. Funds, manpower, equipment, and other resources required for spill 

response and cleanup would be unavailable for other purposes. 

 Bioremediation. Contaminated material could be removed or treated by adding fertilizers or 

microorganisms that “eat” oil. 

Post-Spill, Long-Term Recovery (Phase 5) 

Phase 5 of the scenario focuses on the long-term. The exact length of time considered during this 

Phase will vary by resource. Potential IPFs associated with Phase 5 include the following: 

 Unavailability of environmental resources. Environmental resources and food sources may 

become unavailable or more difficult to access or use. 

 Contamination. Pollution stemming from an oil spill may contaminate environmental 

resources, habitat, and/or food sources. 

 Perception of contamination. The perception that resources are contaminated may alter 

human use and subsistence patterns. 

 Co-opting of human resources. Funds, manpower, equipment, and other resources required 

to study long-term impacts and facilitate recovery would curtail availability for other 

purposes. 

 Psychological/Social Distress. Distress stemming from a VLOS could continue into the longterm. 

IV.D.3. Opportunities for Intervention and Response 

In providing a duration for the hypothetical oil spill described above, it is stated for the purposes of 

analysis that the discharge would cease within 74 days of the initial event. The use of 74 days 

corresponds to the longest of three time periods estimated for a second drilling vessel to arrive on 

scene and complete a relief well (see Table 3). This is a reasonable, but conservative estimate, 

because it does not take into consideration the variety of other methods that would likely be employed 

to halt the spill within this period. Moreover, specific exploration plans may include intervention and 

response methods that could control or contain the flow of oil sooner than 74 days. This point is 

illustrated by recent explorations plans submitted for the Alaska OCS, such as the Shell Gulf of 

Mexico, Inc. 2009 approval of an exploration plan for leases in the Chukchi Sea. Between the 

Chukchi Sea Regional Exploration Oil Discharge Prevention and Contingency Plan (cPlan) (available 

at http://alaska.boemre.gov/fo/ODPCPs/2010_Chukch_cPlan.pdf) submitted with the EP application 

and additional safety measures submitted by Shell Gulf Mexico, Inc. after the Deepwater Horizon 

event, this proposal contained measures including: 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 139

 Enhanced BOP mechanisms 

 Criteria and procedures for moving the drilling unit off location in event of abnormal 

conditions 

 Pre-positioning of response vessels at the drill site and close to the shoreline 

 Use of an Oil Spill Response Vessel capable of deploying and operating recovery equipment 

within an hour of notification 

 Availability of a second BOP stack 

 Maintaining supplies and equipment for relief well purposes 

Potential intervention and response methods are qualitatively discussed below because their inclusion 

in individual exploration plans could serve to substantially decrease the duration, volume, and 

environmental effects of a VLOS. These methods are not mutually exclusive; several techniques may 

be employed if necessary. It may also be possible to pursue multiple techniques contemporaneously. 

Again, these opportunities for intervention and response could be employed prior to drilling a relief 

well, and are not factored into the estimated spill duration as described in the VLOS scenario above. 

The availability and effectiveness of these techniques may vary depending on the nature of the 

blowout as well as seasonal considerations, including the seasonal presence of sea ice. 

Well Intervention. If a blowout occurred, the original drilling vessel would initiate well control 

procedures. The procedures would vary given the specific blowout situation, but could include: 

 activating blowout preventer equipment; 

 pumping kill weight fluids into the well to control pressures; 

 replacing any failed equipment to remedy mechanical failures that may have contributed to 

the loss of well control; and/or 

 activating manual and automated valves to prevent flows from coming up the drill string. 

These techniques cure loss-of-well-control events the vast majority of the time without any oil being 

spilled. 

Natural bridging or plugging could also occur. These terms refer to circumstances where a dramatic 

loss of pressure within the well bore (as could occur in the event of a blowout) causes the surrounding 

formation to cave in, thereby bridging over or plugging the well. While natural bridging or plugging 

could render certain forms of operator-initiated well control infeasible, it could also impede or block 

the release of hydrocarbons from the reservoir from reaching the surface. 

Containment Domes. In the event that well intervention is unsuccessful and the flow of oil 

continues, a marine well containment system (MWCS) could be deployed with associated support 

vessels. The design for a MWCS specific to Arctic operations is currently in progress and will 

receive BOEMRE review under future permitting activities. The MWCS is anticipated to provide 

containment domes, well intervention connections, ROV (remotely operated vehicle) capabilities, 

barge with heavy lift operations, separation equipment, and oil and gas flaring capabilities. 

Relief Wells. If the above techniques are unavailable or unsuccessful, a relief well could be drilled. 

The relief well is a second well, directionally drilled, that intersects the original well at, near, or 

below the source of the blowout. Once the relief well is established, the operator pumps kill weight 

fluids into the blowout well to stop the flow and kill the well. Both wells are then permanently 

plugged and abandoned. 

Some exploratory drilling vessels are capable of drilling their own relief well. Mobile Offshore 

Drilling Units, or MODUs, can disconnect from the original well, move upwind and up current from 
BOEMRE Sale 193 Revised Draft SEIS 

140 CHAPTER IV. Environmental Consequences 

the blowout location, and commence the drilling of a relief well. Bottom-founded vessels are by 

definition not capable of maneuvering in this manner. 

Second Vessel. Should the original drilling vessel sustain damage or prove otherwise incapable of 

stopping the blowout, a second vessel could be brought in to terminate or otherwise contain the 

blowout. A second vessel, with support from additional vessels as needed, could employ similar 

techniques to those described above. The time required by a second vessel to successfully stop the 

flow of oil must factor in the time needed for travel to the site of the blowout. The location of a 

second vessel is thus critical when considering a scenario in which same vessel intervention or 

response is unavailable. The estimate used in the VLOS scenario described above conservatively 

allots 30 days for transporting a second vessel across the Pacific Ocean. The availability of a second 

vessel in-theater (within the Chukchi Sea or possibly the Beaufort Sea) or on site would substantially 

reduce transport time and, therefore, the time needed for successful intervention. This could equate to 

shorter spill duration and smaller overall spill volume. 

As previously mentioned, the availability and/or effectiveness of certain response and intervention 

techniques can depend on the type and exact location of the blowout. Four major distinctions with 

respect to the specific location of a blowout are important to consider. A blowout and leak could 

occur (1) at the sea surface (but the rig is not destroyed or sunk on location), (2) along the riser 

anywhere from the seafloor to the sea surface, (3) at the seafloor through leak paths on the 

BOP/wellhead, (4) below the seafloor, outside the wellbore, or (5) at the sea surface (but the rig is 

destroyed and sinks at the location). Opportunities for operational intervention and response vary in 

each of these circumstances (Table 6) and are, ultimately, important in determining the potential 

effects of the spill. 

Table 6. Blowout scenarios and key differences in impacts, response, and/or intervention. 

Location of Blowout 

and Leak 

Key Differences in Impacts, Response, 

and/or Intervention 

1. At the sea surface but rig is not 

destroyed or sunk on location. 

Drilling unit is damaged and unable to drill, but is available for well intervention 

efforts or can be removed from the site. Offers the best chance for oil recovery due 

to access to the release point if vessel can remain on station or other intervention 

vessels can access the site.This allows for other intervention measures such as 

capping and possible manual activation of Blow-Out-Preventer (BOP) rams using 

the existing drilling unit. Greatest possibility for recovery of oil at the source, until 

the well is capped or killed. 

2. Along the riser anywhere from the 

seafloor to the sea surface. 

Divers or ROVs could be used in intervention to trace and seal leak points, 

depending on water depths. There is a possibility for recovery of oil at the source. 

In addition to relief wells, there is potential for other intervention measures, such as 

capping and possible manual activation of BOP rams. 

3. At the seafloor, through leak paths 

on the BOP/wellhead 

With an intact subsea BOP, intervention may involve the use of drilling mud to kill 

the well. If the BOP is heavily damaged it may be removed and replaced with an 

operable BOP. 

4. Below the seafloor, outside the 

wellbore (i.e., broached) 

Disturbance of a large amount of sediments resulting in the burial of benthic 

resources in the immediate vicinity of the blowout. The use of subsea dispersants 

would likely be more difficult (PCCI, 1999). Stopping this kind of blowout would 

probably involve relief wells. Any recovery of oil at the seabed would be very 

difficult. 

5. At the sea surface; rig is destroyed 

and sinks at the location. 

Area surrounding well is unavailable due to sunken vessel or ice incursions. Offers 

the least chance for oil recovery due to the restricted access to the release point. 

IV.E. Effects of a VLOS 

This section presents detailed analysis of the environmental impacts that could occur in the event of 

the hypothetical VLOS scenario described in the preceding section—potential impacts on 17 

categories of unique resources are analyzed. For each resource, the types of potential direct, indirect, 

and cumulative impacts are evaluated. This evaluation proceeds by identifying the critical IPFs 

(impact producing factors) in each phase of the scenario that could affect the resource, and then 

providing a discussion of those potential effects for each component (e.g. a species) of the resource. 

Following this treatment of the types of potential effects, an OSRA model of simulated oil spill 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 141

trajectories is used to evaluate the potential for oil from specific hypothetical launch areas to reach a 

given resource. The model and its components are further explained below and discussed in detail in 

Appendix B. A conclusion is provided for each resource area. Each Conclusion section also 

discusses the difference in potential impacts to a resource under the three action alternatives. If the 

decisionmaker selects Alternative II, the No Action alternative, no VLOS or VLOS-related impacts 

would result from Sale 193. 

The reader may notice that this VLOS effects analysis is organized slightly differently than the Sale 

193 FEIS environmental effects analysis and the portion of this SEIS evaluating potential effects from 

natural gas development and production. Here, the organization of environmental resources is driven 

more by biological characteristics as opposed to regulatory distinctions. For instance, potential 

impacts to marine and coastal birds are considered in one section that includes both ESA-listed and 

non-listed species. All cetaceans are considered together; the practice of separating Threatened and 

Endangered Marine Mammals from Other Marine Mammals is not applied in this case. Walrus and 

ice seal are each provided their own sections. 

This format was deemed preferable for the VLOS analysis for two reasons. First, ongoing evaluation 

of several species for changes in status under the ESA may have led to confusing document reorganizations as the Revised Draft SEIS progresses to Final. Second, different organization may 

remind one of the unique purpose of this section: to analyze an extremely low probability, high 

impact event. This VLOS scenario is conditioned on the occurrence of many events, including but 

not limited to: 

 Secretarial approval of Lease Sale 193 in some form 

 Industry submittal and BOEMRE approval of an Exploration Plan and an Application for 

Permit to Drill 

 Drilling of an exploratory well 

 Encountering a significant oil accumulation in a permeable reservoir (in an exploratory well) 

 A loss of well control while drilling 

 An uncontrolled blowout 

 An inability to stop the flow of oil for up to 74 days 

IV.E.1. OSRA Model (Oil Spill Trajectories) 

The BOEMRE uses an OSRA (Oil Spill Risk Analysis) model to simulate estimated oil spill 

trajectories; in other words, the OSRA model is a method for estimating where a VLOS may go. It is 

an exercise in probability. For this analysis, BOEMRE presumes an oil spill occurs and the model 

estimates the percentage of oil spill trajectories that could contact environmental resource areas 

(ERAs), land segments, boundary segments, or grouped land segments. Uncertainty exists regarding 

every parameter of a hypothetical VLOS because this is a highly unlikely event for which location 

and environmental conditions (e.g. wind, ice, and currents) must be estimated based upon the best 

available data. Although some of the uncertainty reflects imperfect data, a considerable amount of 

uncertainty exists simply because it is difficult to predict events 15-40 years into the future. For 

purposes of analysis, BOEMRE estimates the source of the accidental spill, its size, where potential 

trajectories may travel to, and how it might weather. A consistent set of estimates about a VLOS is 

used to analyze the impacts to social, economic, and environmental resources. The source, size and 

general weathering of a very large oil spill have been addressed in Section IV.D.2. and Appendix B. 

There are some differences between this anlaysis and BOEMRE’s earlier analysis of a large oil spill 

in the Sale 193 FEIS (Appendix A, Section C; incorporated by reference). The Sale 193 FEIS 

evaluated a large oil spill (>1,000 bbls) using the conditional probabilities of contact assuming a large 

oil spill occurred. The Sale 193 FEIS analysis used 13 launch areas (LAs) within the sale area 
BOEMRE Sale 193 Revised Draft SEIS 

142 CHAPTER IV. Environmental Consequences 

representing the places where a spill could originate from an exploration or development activity. 

The analysis also used 87 environmental resource areas (ERAs), 126 land segments (LSs), 39 

boundary segments (BSs) and 15 grouped land segments (GLS) representing biological, economic or 

social resources (see the Sale 193 FEIS, Appendix A: Maps A.1-1-A.1-3 and Tables A.1-12-A.1-16). 

The larger scope of the VLOS scenario warranted consideration of more ERAs than were used in the 

Sale 193 FEIS OSRA. Analysts were asked to identify any additional ERAs useful for understanding 

potential impacts of a VLOS. Three additional ERAs for whales in Russian waters were incorporated 

from the Arctic Multi-Sale Draft EIS (USDOI, MMS, 2008a) and EFH polygons were analyzed 

where no other Sale 193 conditional probability data was available. Further information is provided 

in Appendix B. 

We use the Sale 193 conditional probabilities for a VLOS analysis to estimate the percentage of 

trajectories from a VLOS contacting biological, social and economic resources of concern in and 

adjacent to the Sale 193 area. No special OSRA run was conducted to estimate the percentage of 

trajectories contacting from a hypothetical future catastrophic blowout and high volume, long 

duration flow resulting in a very large oil spill. The Arctic OSRA calculations are run for as long as 

360 days and were appropriate for a very large oil spill with long duration. For purposes of this 

VLOS analysis, the conditional probabilities were considered to represent the estimated percentage of 

trajectories contacting an environmental resource area, land segment, boundary segment or grouped 

land segment. Higher percentages of trajectories contacting a given location could mean more oil 

reached the location depending upon weathering and environmental factors. 

The hypothetical scenario provided in Section IV.D.2 suggests that a very large oil spill could begin 

at any point during the drilling season, which is between July 15 and October 31. The time period for 

a relief well ranges from 39 to 74 days. For the shortest period we considered that spilled oil remains 

on the surface of the water for a few weeks, and a 60 day contact period for the summer open-water 

season is appropriate (S.L. Ross Environmental Research Ltd., et al., 2003; Ramseur, 2010). For the 

longer period we considered that spilled oil could freeze into the sea ice, remain through the winter, 

and be released in the spring, a period of up to 360 days. We analyze oil spill trajectories for 60 and 

360 days during summer. A very large oil spill continuing after October 31 is also treated as a winter 

spill. Trajectories launched on or after November 1 are treated as winter spills. Oil released during 

this period could freeze into the sea ice, remain all winter, and be released in the spring, a period of 

up to 360 days. We analyze oil spill trajectories for 360 days during winter. The percentage of 

“trajectories contacting” for summer 60 and 360 days and for winter 360 days are shown in Appendix 

B (Tables B-7 to B-22). Appendix B (Tables B-23 to B-25) shows the estimated percentage of 

trajectories for EFH illustrated in Appendix C (Figures C-1, C-6 to C-8). 

Within each resource for which these distinctions are meaningful, the subsection Oil Spill Trajectory 

Analysis considers the percentage of trajectories contacting the particular environmental, social or 

economic resource. The percentage of trajectories is the fraction of the total trajectories launched 

from a given location (launch area) that are estimated to contact a given resource (ERA, LS, etc.). 

These percentages provide a relative estimate of how likely it is that oil from a VLOS will reach that 

resource. In addition, these trajectories are estimated separately for winter and summer seasons. In 

this way, the trajectory analysis also helps BOEMRE evaluate how the timing (season) and location 

of a VLOS relates to potential impacts of a VLOS on each resource. Below, a general summary is 

provided with respect to differences in timing and location as estimated by the model. 

Launch Areas (LAs) 1 through 13 are the areas where a VLOS could originate from a well control 

incident (Appendix B, Figure B-10). The primary differences in contact between hypothetical launch 

areas are geographic in the perspective of west to east and nearshore versus offshore. Oil originating 

from offshore spill locations takes longer to contact the coast and nearshore ERAs, if contact occurs 

at all. Winter spill contact to nearshore and coastal resources is less frequent and would affect a 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 143

lesser extent of the coastline due to the landfast ice generally in place from December to April. 

Specific groups of LAs show the following trajectory patterns: 

 Hypothetical trajectories from LAs 7, 8 and 13 show the stochastic influence of the Beaufort 

Gyre. 

 Hypothetical trajectories from LAs 1, 4, 5 and 10 have a stochastic northerly direction 

influenced by flow through the central channel as well as a southwestward component. 

 LA 9 has a stochastic southwestward direction influenced by counterclockwise flow in the 

southern Chukchi Sea. 

 LAs 5, 11, and 12 are influenced both in a northerly direction from flow in the central 

channel as well as from the Beaufort Gyre. 

A VLOS trajectory anlaysis was evaluated for all resources except economy, air quality, 

sociocultural, and archaeology. Specific environmental resource areas and their vulnerability are not 

identified for these resources. However, the general results of the trajectory analysis were considered 

in estimating impacts on these resources. 

IV.E.2. Water Quality 

This section assesses the potential for the hypothetical VLOS scenario to impact water quality in the 

Chukchi Sea and the State of Alaska waters contiguous with the OCS areas (Figure B-1). The Sale 

193 FEIS and the Arctic Multi-Sale Draft EIS detail the results of a large oil spill analysis and its 

effects on water, and they are incorporated here by reference (USDOI, MMS, 2007, 2008a). 

Water quality is a term used here to describe the chemical, physical, and biological characteristics of 

water and sediment, usually in respect to its suitability for a particular purpose. 

A waterbody in its natural state is characterized by its biological diversity and species abundance. 

Water quality naturally varies throughout the year related to seasonal biological activity and naturally 

occurring processes, such as formation of surface ice, seasonal plankton blooms (occurring primarily 

in spring and fall), naturally occurring hydrocarbon seeps, seasonal changes in turbidity and nutrients 

due to terrestrial runoff and localized upwelling of cold water. 

Water quality can be affected by anthropogenic (human-generated) pollution, habitat disturbance or 

destruction and other negative stressors such as aquatic invasive species. The Chukchi Sea OCS 

water quality to date has had relatively little exposure from land-based and marine anthropogenic 

pollution. The rivers that flow into the area remain relatively unpolluted by human activities. 

Industrial and shipping impacts on water quality have been and are relatively low at this time. 

Existing degradation of water quality is primarily related to aerosol transport and deposition of 

pollutants, pollutant transport into the region by sea ice, biota and currents, and effects from 

increasing greenhouse gasses in the atmosphere which affect water temperature and acidity (AMAP, 

1997, 2004; Hopcroft, et al., 2006). 

The U.S. Environmental Protection Agency (USEPA) administers and enforces the Clean Water Act 

in cooperation with other federal agencies, Native tribes, state governments, municipal governments 

and industries. Currently, the water quality of the Chukchi Sea OCS is within the criteria for the 

protection of marine life according to Clean Water Act, Section 403 and no waterbodies are identified 

as impaired (Clean Water Act, Section 303) within the Arctic region by the State of Alaska (ADEC, 

2011). 

When determining whether a marine discharge would cause unreasonable degradation of water 

quality, the USEPA considers 10 criteria (40 CFR 125.122): 

 The quantities, composition, and potential for bioaccumulation or persistence of the 

pollutants to be discharged. 
BOEMRE Sale 193 Revised Draft SEIS 

144 CHAPTER IV. Environmental Consequences 

 The potential transport of such pollutants by biological, physical, or chemical processes. 

 The composition and vulnerability of the biological communities that may be exposed to such 

pollutants, including the presence of unique species or communities of species, the presence 

of species identified as endangered or threatened pursuant to the Endangered Species Act, or 

the presence of those species critical to the structure or function of the ecosystem, such as 

those important for the food chain. 

 The importance of the receiving water area to the surrounding biological community, 

including the presence of spawning sites, nursery/forage areas, migratory pathways, or areas 

necessary for other functions or critical stages in the lifecycle of an organism. 

 The existence of special aquatic sites including, but not limited to, marine sanctuaries and 

refuges, parks, national and historic monuments, national seashores, wilderness areas, and 

coral reefs. 

 The potential impacts on human health through direct and indirect pathways. 

 Existing or potential recreational and commercial fishing, including finfishing and 

shellfishing. 

 Any applicable requirements of an approved Coastal Zone Management Plan. 

 Such other factors relating to the effects of the discharge as may be appropriate. 

 Marine water and sediment quality criteria developed pursuant to Section 304(a)(1). 

Federally promulgated water quality standards adopted by the State of Alaska regarding toxic 

substances, including human health criteria and aquatic life criteria, are at 40 CFR 131.36. The 

Alaska water quality regulations are within 18 AAC 70. 

Hydrocarbon concentrations in water have been measured in various major oil spills around the 

world. Four months into the Ixtoc blowout (Gulf of Mexico, 1979–80), liquid hydrocarbons in the 

spill plume measured >10 ppm within 8 km of the blowout, to 0.02 ppm at 24-km from the blowout, 

and to <0.005 ppm at 40-km from the blowout (Boehm et al., 1982). The dispersant, Corexit 9527, 

had been applied to surface waters via aerial application to disperse oil in the region of the Ixtoc spill. 

Similarly, relative decreases were found for specific toxic compounds such as benzene and toluene 

(National Research Council, 1985). 

At the Ekofisk Bravo blowout in the North Sea (1977, surface) concentrations of volatile liquid 

hydrocarbons (present mostly as an oil-in-water emulsion) ranged up to 0.35 ppm within 19 km of the 

site when measured, starting 1.5 days into the 7.5 day blowout (Grahl-Nielsen, 1978). Lesser 

amounts of oil (<0.02 ppm) were detectable in some samples, at 56-km from the site, but not at 89-

km. In more restricted waters during flat calm, a test spill during the Baffin Island Oil Spill Project 

resulted in maximum hydrocarbon concentrations in the water column of 1-3 ppm (Green, Humphrey, 

and Fowler, 1982). These concentrations were reached within 2 hours of the spill and persisted 

through 24 hours. No oil was detected deeper than 3 m, and the most oil and highest concentrations 

were in the top meter (Mackay and Wells, 1983). 

Camilli, et al. (2010) conducted a subsurface hydrocarbon study two months after the Deepwater 

Horizon (DWH) seafloor blowout (depth 1,500 m) in the Gulf of Mexico. They found a continuous 

oil plume at a depth of approximately 1,100 m that extended for 35 km from the blowout site. The 

plume consisted of monoaromatic hydrocarbons (benzene, toluene, ethylbenzene and xylene) at 

concentrations greater than 50 micrograms per liter. The plume persisted for months at this depth with 

no substantial biodegradation. They also measured concentrations throughout the water column and 

found similarly high concentrations of aromatic hydrocarbons in the upper 100 m. Polycyclic 

aromatic hydrocarbons were found at very high concentrations (reaching 189 micrograms per liter) by 
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CHAPTER IV. Environmental Consequences 145

Dierks, et al. (2010) after the DWH at depths between 1,000 and 1,400 m extending as far as 13 km 

from the subsurface blowout site. 

Joye, et al. (2011) estimated that the DWH released 500,000 tons of hydrocarbon gasses at depth, 

which would comprise 40% of the total hydrocarbons released from the DWH. Methane, ethane, 

propane, butane and pentane were measured throughout the water column. They found high 

concentrations of dissolved hydrocarbon gasses in a water layer between 1,000 and 1,300 m. These 

concentrations exceeded the background concentration of hydrocarbon gasses by up to 75,000 times. 

Results from a study by Yvon-Lewis, et al. (2011) showed that there was a low flux of methane from 

the DWH blowout to the atmosphere, concluding that the majority of methane from the blowout 

remained dissolved in the deep ocean waters. Valentine, et al., (2010) reported that 2 months after the 

DWH blowout, propane and ethane gases at depth were the major gasses driving rapid respiration by 

bacteria. They also found these gases at shallower depths but at concentrations that were lower by 

orders of magnitude. Multiple plumes transported in different directions were detected at depth, 

indicating complex current patterns. 

Methane release in the DWH blowout and biodegradation by methanotrophs was studied by Kessler, 

et al (2011). They found that a deepwater bacterial bloom respired the majority of the methane in 

approximately 120 days. Similarly, Hazen, et al. (2010) found indigenous bacteria at 17 deepwater 

stations biodegrading oil 2-3 months after the DWH blowout. The fate of 771,000 gallons of chemical 

dispersants injected at the DWH wellhead near the seafloor (1,500 m) was studied by Kujawinski, et 

al. (2011). Their results show that the dispersants injected at the wellhead were concentrated in 

hydrocarbon plumes at 1,000-1,200 m depth 64 days after dispersant application was stopped and as 

far away as 300 km. They concluded that the chemical dispersants at this depth underwent slow rates 

of biodegradation. 

The conditions in the waters of the Gulf of Mexico (and specifially at the Deepwater Horizon site) 

differ from the conditions present in the Chukchi Sea. The DWH blowout occurred in at a depth of 

1,500 m; potential Chukchi Sea drilling would be at <50 m. This depth difference is important given 

how gas and liquids behave differently at various pressures, with more gas staying in solution at 

greater depths. A greater depth may also present a greater liklihood that distinct density layers and 

currents that could entrain and transport hydrocarbons. In the summer, the shallower Chukchi Sea is 

stratified, which would make conditions more conducive to the formation of subsurface plumes 

(Rudels, et al., 1991; Rye, Brandvik, and Strom, 1997). Meanwhile, water temperatures in the 

shallow Chukchi Sea are similar to the deepwater temperatures in the Gulf of Mexico, suggesting the 

Chukchi could support similar levels of hydrocarbon (including methane) degradation. Both methane 

and petroleum hydrocarbon degraders are present and active in the Chukchi Sea (and in the Arctic in 

general) ice, water, and sediment (Gerdes et al., 2005; Damm et al., 2007; Atlas, Horowitz, and 

Busdosh, 1978; Braddock, Brannon, and Rasley, 2004). Differences between the Gulf of Mexico and 

the Chukchi Sea in seasonality, weather and wind patterns, sea ice, and surface water temperatures 

also make extrapolations from the DWH blowout and a hypothetical blowout in the Chukchi Sea 

problematic. 

The following subsections describe the types of effects that could occur during each Phase of the 

VLOS scenario. 

Phase 1 (Initial Event) 

The initial blowout event could impact water quality via the release of natural gas. When natural gas 

(primarily methane) is released into the water, it rises through the water column as a function of 

pressure and temperature. When released in a blowout or rupture at depth, the quality of the water 

would be altered temporarily and in deeper, colder waters some of the natural gas enters the water as 

a water-soluble fraction. Upon reaching the surface the gaseous methane would react with air, 

forming water and carbon dioxide (CO2), which would then disperse into the atmosphere. The near-
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146 CHAPTER IV. Environmental Consequences 

surface water quality would have higher concentrations of CO2 than is natural and could therefore 

affect processes and reactions at the microlayer at the water-air interface, such as egg and larvae 

respiration (GESAMP, 1995). 

Phase 2 (Offshore Spill) 

Hydrocarbons spilled into the sea can behave in several ways depending on the types of hydrocarbon 

compounds in the mix and the depth and temperature at which the spill occurs. Hydrocarbons can 

volatilize into the air, dissolve into the water column or water surface, oxidize via ultraviolet radiation 

or microbial activity, or emulsify and float or sink to the subsurface, depending on the water uptake 

plus initial density of the spilled oil (National Research Council, 2003c). 

Oil moves through the water in horizontal and vertical directions. This movement of oil occurs 

through several processes including spreading, dispersion, advection (tides, current, Langmuir 

circulation), entrainment, deposition to seafloor sediments, re-suspension from seafloor, uptake and 

excretion by biota, and stranding on shorelines. Waves and winds can mix oil droplets on the surface 

into subsurface waters. The various mechanisms by which oil moves in sea water is also influenced 

by the type and degree of sea ice present and the location of the spilled oil (on the water, under the 

ice, encapsulated in the ice or on top of the ice). 

The more volatile compounds in an oil slick, particularly aromatic volatiles, are usually the most toxic 

components of an oil spill. In-situ, cold-water measurements (Paine and Levin, 1981, 1982, 1985; 

Payne et al., 1984a,b) have demonstrated that concentrations of individual components in an oil slick 

decrease significantly in concentration over a period of hours to tens of days. 

The highest dissolution rates of aromatics from a slick occur in the first few hours of a spill and 

accumulate in the underlying water (Paine and Levin, 1981). By the time dissolved oil reaches depths 

of 10 m in the water column, it becomes diluted and may spread horizontally over about 10,000 m. 

The slick would become patchy, with the total area—containing widely separated patches of oil—

stretching orders of magnitude larger than the actual amount of surface area covered by oil. 

A small portion of the oil from a surface spill would be deposited in the sediments in the immediate 

vicinity of the spill or along the pathway of the slick. The observed range in deposition of oil in 

bottom sediments following offshore spills is 0.1-8% of the slick mass (Jarvela, Thorsteinson, and 

Pelto, 1984). Generally, the higher percentage of deposition occurs in spills nearshore where surf, 

tidal cycles, and other inshore processes can mix oil into the bottom. Farther offshore, where 

suspended sediment loads are generally lower, only about 0.1% of the crude would be incorporated 

into sediments within the first 10 days of a spill (Manen and Pelto, 1984). 

An offshore spill could create tarballs. One study of spilled oil with a slightly heavier composition 

than analyzed in this VLOS scenario indicated that about 68% of the spilled oil could persist as 

individual tarballs dispersed in the water column after the slick disappeared. Slow photo-oxidation 

and biological degradation would continue to slowly decrease the residual amount of oil. Through 

1,000 days, about 15% of the tarballs would sink, with an additional 20% of slick mass persisting in 

the remaining tarballs (Butler, Norris, and Sleeter, 1976, as cited in Jordan and Payne, 1980). During 

the slow process of sinking, as the oil drifts over hundreds or thousands of kilometers, sunken tarballs 

would be widely dispersed in the sediments, resulting in widespread distribution but relatively lower 

concentrations in any one area of sediment. 

Decomposition and weathering processes for oil are much slower in cold waters than in temperate 

regions. Prudhoe Bay crude remained toxic to zooplankton in freshwater ponds for 7 years after an 

experimental spill, demonstrating persistence of toxic-oil fractions or their weathered and 

decomposition products (Barsdate, et al., 1980). In marine waters, advection and dispersion would 

reduce the effect of release of toxic oil fractions or their toxic degradation products, including 

products resulting from photo-oxidation. Isolated waters of embayments, shallow waters under thick 
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CHAPTER IV. Environmental Consequences 147

ice, or a fresh spill in rapidly freezing ice, however, would not be exposed to this advection and 

dispersion. 

An oil spill that occurs in broken-ice or under-pack ice during the deep Arctic winter would freeze 

into the ice, move with the ice and melt out of the ice the following summer. Spills in first-year ice 

would melt out in late spring or early summer. Spills in multiyear ice would melt out later in the 

summer or in subsequent summers. Spills released from the ice would be relatively unweathered and 

would have the characteristics of fresh oil. Before the oil was released from the ice, the contaminated 

ice could drift for hundreds of kilometers. 

Phase 3 (Onshore Contact) 

If oil contacted a shoreline, mixed into the shoreline, and then dispersed, elevated concentrations of 

hydrocarbons could occur in the water and sediments offshore of the oiled shoreline. 

Phase 4 (Spill Response and Clean-up) 

Dispersants 

Dispersants are a combination of surfactants and solvents that work to break surface oil into smaller 

droplets which then disperse on the surface and into the water column. Many factors affect the 

behavior, efficacy, and toxicity of a particular dispersant, including water temperature, surface 

salinity, wave and wind energy, light regime, water depth, type of oil, concentration of dispersant, 

how the dispersant is applied (constant or intermittent spikes), and exposure time to organisms. 

Dispersants are used to degrade an oil spill more quickly through increasing surface area and to 

curtail oil slicks from reaching shorelines (Word, et al., 2008). 

As oil breaks into smaller droplets it can distribute vertically in the water column. If oil droplets 

adhere to sediment, the oil can be transported to the seafloor and interstitial water in the sediment. In 

shallow nearshore waters, wind, wave and current action would more likely mix the dispersant-oil 

mixture into the water column and down to the seafloor environment. The water toxicity effects of 

dispersant application in a VLOS in the Chukchi Sea would be similar to the effects outlined above 

under Phase 2. Chemically dispersed oil is thought to be more toxic to water column organisms than 

physically dispersed oil, but the difference is not clearcut, and generally the toxicity is within the 

same order of magnitude (National Research Council, 2005b). 

In-Situ Burning 

In-situ burning is used to reduce an oil spill more quickly and to curtail oil slicks from reaching 

shorelines. In-situ burning could increase the surface water temperature in the immediate area, and 

produce residues. The upper-most layer of water (upper millimeter or less) that interfaces with the air 

is referred to as the microlayer. Important chemical, physical and biological processes take place in 

this layer and it serves as habitat for many sensitive life stages and microorganisms (GESAMP, 

1995). Disturbance to this layer through temperature elevation could cause negative effects on 

biological, chemical, and physical processes. 

Residues from in-situ burning can float or sink depending on the temperature and age of the residue. 

Floating residue can be collected; however, residues that sink could expose the benthic waters and 

sediment to oil components as the residue degrades on the seafloor. 

The NOAA Office of Response and Restoration states, “Overall, these impacts [from open water insitu burning] would be expected to be much less severe than those resulting from exposure to a large, 

uncontained oil spill” (DOC, NOAA, 2011a). If an oil spill occurred in winter, in-situ burning would 

be limited by the lack of open water to collect oil and open water in which to burn it. If burning could 

occur in winter on a limited scale, sea ice would melt in the immediate vicinity of the burn. 
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148 CHAPTER IV. Environmental Consequences 

Offshore Vessels and Skimmers 

Vessels can affect water quality through deck drainage, sanitary and domestic discharges, brine and 

cooling water discharges, small spills, anchoring in benthic habitat, disturbance of microlayer and 

potential for introduction of invasive species from foreign or out-of-state vessels. In winter, icebreakers could affect the movement of spilled oil that may be trapped beneath or in the ice. Vessel 

discharges are permitted by USEPA under the Vessel General Permit. The effects of vessels on water 

quality are described in detail in the Sale 193 FEIS (USDOI, MMS, 2007a). 

Drilling of Relief Well 

Drilling an emergency relief well would entail discharge of drilling muds and cuttings. These 

discharges are regulated by the USEPA under NPDES General Permit 280000, Oil and Gas 

Exploration in the OCS. There is potential for accidental spills, and potential for introduction of 

invasive species from vessels or equipment placed overboard. Drilling of a relief well would cause an 

increase in suspended sediment and turbidity in the water column and potential increase in 

contaminants in the water and sediments. The effects on water quality from well-drilling are 

described in detail in the Sale 193 FEIS (USDOI, MMS, 2007a). 

Beach Cleaning and Booming 

The cleaning up of oiled beaches (and booming and rescue of oiled animals) could entail small boat 

and aircraft landings on marine and freshwater shorelines and waters; large numbers of people 

walking and wading through aquatic habitats; collection of oiled sediment and beach wrack; possible 

booming of coastal waterways; possible hydraulic washing with hot water; possible application of 

fertilizer to enhance degradation of oil; and possible raking of fine sediments. 

These activities could result in effects from suspended sediment in waters and resettlement of 

sediments elsewhere, runoff of treatment-laden waters that could affect nearshore temperature and 

nutrient concentrations, removal of beach wrack nutrient sources from intertidal zones, and potential 

for introduction of invasive species from small boats and waders and clothing worn by workers from 

outside of the Alaska Arctic region. 

Phase 5 (Long-term Recovery) 

During long-term recovery, there could be reoccurring visitation by monitoring and research 

personnel, which could result in the same sort of effects encountered during beach cleaning. 

Over the long-term, contamination of aquatic environments from oil (and possibly dispersant residue 

on the seafloor) leaching would continue from sedimented and resuspended oil, and from possible 

resuspension of polycyclic aromatic hydrocarbons (PAHs). Sunlight (UV radiation) increases the 

toxicity of leached PAHs, so summer sunlight in Arctic Alaska could exacerbate the amount and 

degree of toxicity. 

Oil Spill Trajectory Analysis 

A 2.2 MMBbl oil spill would cause significant impacts to water quality no matter which portion of 

the Chukchi Sea it originated in and no matter which time of year it occurred. 

The daily spill sizes range from approximately 60,000 bbl to 20,000 bbl per day over the life of the 

VLOS, and weathering estimates were calculated for these two spill sizes, assuming no spill response 

for summer and winter conditions. Approximately 30% of a 60,000 bbl oil spill during summer 

would remain in the water column, in bottom sediments, ingested by biota or beached within 30 days 

(Appendix B, Table B-4). It is estimated that within 30 days in a summer spill, 33% of the oil spill 

would disperse and 37% would evaporate (Appendix B, Table B-4). Within 60 days after a very large 

oil spill in summer, it is estimated that between 245,800 and 364,200 km2

 of discontinuous ocean 

surface would be contacted by oil trajectories from Launch Areas 1-13. The greatest discontinuous 
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CHAPTER IV. Environmental Consequences 149

ocean surface area contacted would be generated by LA 8; the least by LA 9 (Appendix B, Table B5). 

It is estimated that approximately 48% of a hypothetical 60,000 bbl crude oil spill during winter 

would remain on the water surface, in bottom sediments, ingested by organisms, or beached within 30 

days. It is estimated that 15% of the oil spill would disperse and 37% would evaporate within 30 

days in winter melt-out spill (Appendix B, Table B-4). Within 360 days after a VLOS in winter, it is 

estimated that between 368,400 and 507,200 km2

 of discontinuous ocean surface would be contacted 

by oil trajectories from Launch Areas 1-13. The greatest discontinuous ocean surface area contacted 

would be generated by LA 4; the least by LA 3 (Appendix B, Table B-6). 

It is estimated that between 0 and 1,368 km of discontinuous shoreline length could be contacted by 

oil trajectories in the Chukchi Sea depending on the location of a VLOS, the season, and the number 

of days after the spill release (see OSRA model results in Section IV.C.4-Fish). The type of shoreline 

that would be contacted along the Chukchi coast includes salt and brackish water marshes, mixed 

sand and gravel beaches and fine to medium sand beaches (NOAA-ORR, 2011). 

Conclusion 

A very large oil spill and gas blowout would present sustained degradation of water quality from 

hydrocarbon contamination in excedence of State and Federal water and sediment quality criteria. 

These effects would be significant. Additional effects on water quality would occur from response 

and cleanup vessels, in-situ burning of oil, dispersant use, discharges and seafloor disturbance from 

relief well drilling, and activities on shorelines associated with clean-up, booming, beach cleaning, 

and monitoring. 

The selection of Alternative III or IV (coastwise corridor deferrals), which removes parts of Launch 

Areas 8-13 from the Lease Sale area, could reduce the chance of a very large spill from contaminating 

nearshore, estuarine, intertidal, and riverine waters. The larger deferral associated with Alternative III 

has greater potential to reduce nearshore impacts as compared with Alternative IV. The effects of 

degradation of offshore water quality would not be reduced under either Alternative III or IV. 

IV.E.3. Air Quality 

A very large oil spill (VLOS) event, initiated by an explosive blowout, would release potentially 

harmful emissions into the atmosphere, particularly those pollutants regulated under the Clean Air 

Act (CAA). Pollutants regulated under the CAA include nitrogen dioxide (NO2), carbon monoxide 

(CO), sulfur dioxide (SO2), particulate matter (PM10 and PM2.5), and would also include volatile 

organic compounds (VOC). Following the initial explosion, emissions would occur during each 

phase of the event due to fires (including in-situ burning), evaporative emissions from the oil, and 

emissions from sources operating during the oil spill recovery and clean-up process. The behavior of 

emissions released into the atmosphere over the Chukchi Sea, should a VLOS occur there, would be 

influenced by the Arctic climate as well as the severity of the oil spill and the characteristics of the 

pollutant sources. The Arctic climate is highly variable by season, is influenced by the polar 

maritime characteristics of the Arctic Sea, and reflects the polar continental characteristics of the 

large adjacent Alaskan land mass. Meteorological conditions, such as temperature inversions, wind, 

and precipitation, define the atmospheric stability of the area and dictate the amount of turbulence and 

mixing that can occur. Thus, these parameters affect the build up of emissions and concentration of 

harmful pollutants that could threaten human health and wildlife. Therefore, the severity of impacts 

to air quality from a VLOS would depend largely on whether the spill occurs in the winter or in the 

summer. As explained in the following subsections, an oil spill or oil spill recovery occurring during 

the winter would likely result in greater impacts to air quality than a spill occurring during the 

summer. 
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150 CHAPTER IV. Environmental Consequences 

Winter Spill 

Weather conditions in the Arctic winter are dominated by the Siberian high pressure system over 

central Russia, and by the semipermanent Aleutian low, which resides over the Bering Sea (Ahrens, 

2009). Air within a high pressure system has a tendency to rotate clockwise and the heavy cold air 

has a tendency to flow down and away from the pressure center creating cold dry conditions defined 

as stable air. Conversely, air within a low pressure system has a tendency to lift, is buoyant, and rises 

counterclockwise toward the center of lower pressure causing precipitation and unstable conditions. 

The interaction of these two systems results in light to moderate (5 to 18 miles per hour) east to 

northeast winds with episodes of strong breezes (25 miles per hour) from the east during storms. 

Higher winds have a tendency to peak during October through December and there is little to slow 

down the wind over open water (Veltkamp & Wilcox, 2007). 

There are episodes of much lighter winds during frequent winter temperature inversions. An 

inversion is a surfaced-based phenomenon that occurs in stable air where a colder layer of air is 

‘capped’ from above by a layer of warmer air. Inversions are characterized by relatively low wind 

speeds that restrict the dilution and mixing of pollutants with the surrounding air (Ahrens, 2009). The 

layer of air within a temperature inversion, particularly shallow layers like those associated with the 

Siberian high, is compressed close to the surface. Therefore, harmful emissions are confined within a 

shallow layer increasing pollutant concentrations and the severity of air quality impacts. 

Wind will transport pollutants away from a source, so the most severe impacts to air quality would 

occur in the immediate vicinity of the source and further downwind from the source region. Thus, the 

most severe wintertime impacts from a VLOS occurring within any of the hypothetical launch areas 

would most likely occur downwind along the northwest coastline of Alaska, from Barrow to Point 

Hope. There would be few impacts to the northeast coast of Alaska. 

The infrequent occurrence of winter precipitation, which has a tendency to deplete the atmosphere of 

some pollutants, would do nothing to decrease the accumulation of emissions. Therefore, a VLOS 

occurring during the Arctic winter would likely result in more severe impacts to air quality conditions 

than under summer conditions. 

Summer Spill 

During summer months, the Arctic experiences less frequent surface-based temperature inversions 

and more frequent precipitation. When they do occur, inversion layers are deeper, allowing 

unrestricted mixing and dilution of pollutants with the surrounding air, while precipitation tends to 

remove some pollutants from the atmosphere. This results in lower pollutant concentrations that have 

less of an impact on air quality conditions. 

Summer Arctic weather is driven by two semipermanent pressure systems, the Icelandic low over 

Greenland and the Pacific high positioned in the Gulf of Alaska (Ahrens, 2009). The interaction of 

these two systems results in northwest winds over the Arctic in summer. Breezes are moderate, 

averaging 12 to 18 miles per hour, with higher winds during storms. There could be four to six 

storms a month over the Arctic increasing the precipitation over the sea and over land (NSIDC, 

2000). 

The windy rising air and precipitation destabilize the lower atmosphere allowing dilution and mixing 

of pollutants. Gaseous pollutants rise with the surrounding air and are caught up in higher steering 

winds that allow maximum dispersing of pollutants. Consequently, the most severe summertime 

impacts from a VLOS would likely occur within launch areas (LA) 1 through 6, and LA 9 through 12, 

where northwest winds would drive pollutants over Alaska’s northwest coastline. Less severe 

impacts would occur from LA 7, 8, and 13, where northwest winds would direct pollutants generally 

parallel to the northeast coastline. 
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CHAPTER IV. Environmental Consequences 151

Black Carbon 

The burning of fossil fuels creates particles of soot that are carried away by the wind from the source. 

Referred to as black carbon (BC), the particles are deposited on local and regional surfaces 

surrounding the source of burning. Accumulation of BC would be expected primarily following the 

initial oil well explosion and to a lesser extent, following in-situ burning. Should a VLOS occur in 

the Chukchi Sea, BC particles would likely settle on nearby areas of exposed sea ice and would be 

transported and deposited over nearby land. 

The presence of BC on ice and snow surfaces has a warming effect on the atmosphere because the 

blackness of the carbon absorbs heat, inhibits the reflective properties of the ice and snow, and 

accelerates melting of sea ice and land ice and snow. This is referred to as radiative forcing. When 

incoming solar radiation equals the reflected outgoing energy from the earth, the earth-atmosphere 

system is in radiative equilibrium. When the reflective characteristics of the earth’s surface 

decreases, such as occurs when BC is deposited on ice and snow, the equilibrium is shifted and there 

is more incoming energy than outgoing energy. Thus, the system experiences radiative forcing, or 

warming (Ahrens, 2009). 

Shindell and Faluvegi (2009) suggest that a constant presence of BC is necessary for consistent 

radiative forcing to affect climate change. Also, particles of BC have a relatively short atmospheric 

life span of less than a week (Bice, Eil, Habib, Heijmans, Kopp, Nogues, Norcross, SweitzerHamilton, & Whitworth, 2009). When also considering the BC sources from a VLOS are temporary, 

and deposits over ice and snow would diminish following melting, BC deposits would be temporary, 

short-term, and local. The presence of BC would be experienced primarily following a VLOS that 

occurs in the winter. The deposit of BC, should a VLOS occur in the summer, would be mitigated by 

the increased occurrence of precipitation and the decreased presence of ice and snow. Additional 

information relating to black carbon is included in the air quality section of the Sale 193 FEIS 

(USDOI, MMS, 2007a). 

Phase 1 (Initial Event) 

The initial explosion of gas and oil due to a VLOS would result in a large black smoke plume 

containing PM and the other products of combustion, such as NOx, SOx, CO, VOC, and CO2. The 

fire could also produce polycyclic aromatic hydrocarbons (PAHs), which are known to be hazardous 

to human health. In particular, the intense heat of the fire would elevate the level of NOx emissions, 

and concentration of PM in the initial smoke plume would have the potential to temporarily degrade 

visibility in the immediate area and in any affected Prevention of Significant Deterioration (PSD) 

Class I areas and other areas where visibility is of significant value. 

The heat of the fire would immediately cause the pollutants within the plume to disperse in an upward 

buoyant flow. The location of high pollutant concentrations due to the smoke depends on the stability 

of the atmosphere at the time of the explosion. Should the VLOS occur during winter months, the 

upward transport of the pollutants could be constrained by fumigation conditions limiting dilution and 

mixing with the surrounding air, and restricting transport by the wind. In this case, pollutant 

concentration levels at nearby locations would likely reach levels that exceed the federal and state 

thresholds that define impacts as significant. Otherwise, the rising plume of pollutants would become 

diluted with height and surface concentration levels would not be as high in the immediate vicinity of 

the fire (Evans, Walton, Baum, Mulholland, & Lawson, 1991). In either case, over time the smoke 

would be transported by the wind and would eventually affect surface areas at a distance from the 

fire. The initial fire could burn for up to two days and the pollutants of concern would include PM, 

black carbon, and VOC. It would be during this initial event when the majority accumulation of BC 

would occur. The deposits would be more severe if the initial explosion were to occur in the winter 

when the maximum amount of sea ice and land ice and snow are present. Also, BC would be more 

likely to reach the shoreline if the VLOS were to occur in LAs 9 through 13. Emissions of VOC 
BOEMRE Sale 193 Revised Draft SEIS 

152 CHAPTER IV. Environmental Consequences 

would be high during Phase 1 due to evaporation of freshly surfaced oil. A laboratory analysis of oil 

spilled during the Deepwater Horizon (DWH) event showed the first 23 percent of the oil evaporated 

within the first two hours following the initial explosion. During this time, the emissions of VOC 

were confined to a relatively narrow plume as the sea surface transport of oil did not exceed a few 

kilometers (de Gouw, Middlebrook, Warneke, Ahmadov, Atlas, et al., 2011). Consequently, the 

VOC impacts would be most severe immediately following the explosion and decrease as the oil slick 

spreads. With increasing distance from the location of the fire, some of the gaseous pollutants, 

particularly VOC, would undergo chemical reactions resulting in the formation of secondary organic 

aerosols, which are mostly semi-volatile organic material. 

Computer modeling conducted to evaluate emissions from a large oil spill considered several 

different VOC and other compounds, including benzene, ethylbenzene, toluene, and o-xylenes, which 

are classified by the USEPA as hazardous air pollutants (HAP). The results showed that these 

compounds vaporize almost completely within a few hours following a spill. The ambient 

concentrations would peak within the first several hours after a spill and would be reduced by two 

orders of magnitude after about 12 hours. The heavier compounds would take longer to vaporize and 

may not peak until about 24 hours after spill occurrence. Additional information of air quality 

impacts from oil spills is included in the air quality section of the Sale 193 FEIS (USDOI, MMS, 

2007a). 

Air quality impacts would be expected to be more severe during Phase 1 if the VLOS were to occur 

during winter months when fumigation conditions are more likely and precipitation is less frequent. 

Consequently, the Phase 1 fire and spread of surface oil would cause moderate to major impacts from 

PM and VOC emissions, especially in the vicinity of the explosion. With distance from the fire and 

with further spreading of surface oil, the concentrations of VOC would be less severe but moderate 

impacts could still occur along the northwest coastline. 

Phase 2 (Offshore Oil) 

Impacts from this phase of the VLOS will continue until the sea is clear of all or most of the oil. As 

long as there is an oil slick on the sea surface there will be evaporative emissions and some level of 

air quality degradation until most volatile hydrocarbons are depleted from the oil. As such, impacts 

from this phase would occur simultaneously and in combination with the impacts occurring during 

Phase 3, 4, and 5. 

Evaporation contributes to weathering of the oil, the natural chemical and physical processes that lead 

to the disappearance of oil from the sea surface. However, the rate of evaporation differs depending 

on volatility of the oil and increases with higher temperatures. Higher temperatures also allow an oil 

slick to spread more quickly, thinning out the layer of oil, and decreasing the emissions of VOC. 

Evaporation decreases the oil’s toxicity because the lighter more toxic hydrocarbons dissipate. 

Fifteen to 30 percent of the oil could evaporate within the first 30 days, depending on the season 

(Polar Research Board, 2003). 

Evaporative emissions of VOC will combine with aromatic volatile compounds, and some HAP 

emissions. During the Deepwater Horizon event, air samples were collected through the inter-agency 

efforts of British Petroleum (BP), Occupational Safety and Health Administration (OSHA), and the 

U.S. Coast Guard. The samples showed concentration levels of HAPs, such as benzene, toluene, 

ethyl benzene, and xylene to be below the OSHA Occupational Permissible Exposure Limits (PEL) 

and the more stringent ACGIH (American Conference of Governmental Industrial Hygienists) 

Threshold Limit Values (TLVs) (U.S. Department of Labor, 2010). However, even in low 

concentrations, some HAPs emissions may be hazardous to personnel working in the vicinity of the 

spill site, which could be reduced by monitoring and using protective gear, including respirators. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 153

Concentrations of pollutants depend largely on the volume of the oil over the sea surface and wind 

conditions in the vicinity of the oil slick. As a general rule emissions of VOC would be highest at the 

source of the spill because the rate of evaporation depends on the volume of oil present at the surface. 

However, with time the emissions will decrease because even if the oil were not recovered, VOC 

concentrations would decrease as the surface oil area increases and gets thinner through transport by 

the current. This phase of the VLOS could continue for months so that emissions will eventually 

disperse in the wind even allowing for frequent temperature inversions during winter when winds are 

very light. Average wind speeds over the Arctic are sufficient to disperse the pollutants over such a 

long period of time. Air quality impacts could be major in the areas where oil is thick over the sea 

surface, which would likely be at the beginning of Phase 2 and could occur during a winter VLOS. 

However, impacts are expected to be minor to moderate as time goes by and the oil slick decreases. 

Phase 3 (Onshore Contact) 

As the spill nears shore, evaporative emissions from the sea surface oil slick would continue to occur 

as described under Phase 2. As such, a portion of the most volatile hydrocarbons would have 

evaporated by the time the oil reaches the shoreline. Therefore, potential for harmful VOC emissions 

would depend on the remaining volatility of the oil and the thickness of the oil accumulating on the 

shore. Combined with the other effects of weathering, such as dissolution and dispersion, further 

harmful emissions from the oil would likely be limited. 

Once the oil is onshore, even minor emissions could cause short-term human effects. The emissions 

may cause temporary eye, nose, or throat irritation, nausea, or headaches, but the doses are not 

thought to be high enough to cause long-term harm (U.S. Environmental Protection Agency, 2010). 

Conversely, responders could be exposed to levels higher than the permissible exposure levels (PEL) 

established under the Occupational Safety and Health Administration (OSHA) guidelines (U.S. 

Department of Labor, 2010). During the Deepwater Horizon event, 15,000 air samples collected near 

shore by BP, OSHA, and the U.S. Coast Guard (USCG) showed most levels of benzene, toluene, 

ethylbenzene, and xylene were under detection levels. Among the many samples taken by BP, there 

was only one indicating benzene exceeded the OSHA PEL (USDOI, BOEMRE, 2011: Appendix B, 

Section 4.1.1.1). All other sample concentrations were below the more stringent American 

Conference of Governmental Industrial Hygienists (ACGIH®) threshold limit values (TLVs) (U.S. 

Department of Labor, 2010). All measured concentrations of toluene, ethylbenzene, and xylene were 

within the OSHA PELs and ACGIH TLVs. 

The impact of VOC emissions from oil collecting onshore would be negligible to minor, short-term, 

and not expected to cause permanent harm. However, responders are at risk for exposure to harmful 

levels of benzene and should take safety precautions to avoid exposure. 

Phase 4 (Spill Response and Cleanup) 

The sheer volume of petroleum estimated for release during a VLOS would require an array of spill 

response and cleanup techniques and strategies. No longer concerned primarily with VOC emissions, 

efforts during this phase of the VLOS event would engage new sources of emissions, such as 

dispersants, in-situ burning, and the use of offshore vessels. To support these efforts requires the use 

of aircraft and surface vehicles, which also produce potentially harmful emissions. 

Dispersants 

The use of dispersants and in-situ burning are the two non-mechanical techniques used most 

commonly in response to an oil spill. Dispersants and in-situ burning focus on changing the 

characteristics of the oil within the environment rather than using mechanical equipment (physical 

containment and recovery equipment, such as booms and skimmers) to recover or remove the oil 

(Ocean Studies Board, 2005). Dispersants, which may be applied by marine vessels or by aircraft, are 

chemical agents, such as surfactants, solvents, and other compounds, that break up the oil slick by 
BOEMRE Sale 193 Revised Draft SEIS 

154 CHAPTER IV. Environmental Consequences 

decreasing interfacial tension between water and oil. The result is small oil droplets that do not 

merge with other droplets. The droplets stay suspended in the water column and are transported by 

waves. The objective of using a dispersant is to transfer oil from the sea surface into the water 

column (Ocean Studies Board, 2005). While the use of dispersants can decrease the size of the oil 

slick, toxic emissions are possible from the chemicals and solvents used in dispersants that could be 

potentially harmful. Following the DWH event, the USEPA mobilized the Trace Atmospheric Gas 

Analyzer (TAGA) buses that are self-contained mobile laboratories that conduct air quality 

monitoring (USEPA, 2011a). The EPA conducted monitoring for two chemicals in dispersants that 

have the greatest potential for air quality impacts: EGBE (2-butoxyethanol) and diproplyene glycol 

monobutyl ether. The TAGA analysis detected levels of the chemicals in the air along the Gulf Coast 

that were below the threshold that would be likely to cause adverse health effects. Consequently, 

EPA suggests that using dispersants for oil spill cleanup would cause negligible impacts on air quality 

(USEPA, 2011b). 

In-situ Burning 

In-situ burning (ISB) is controlled burning of oil intended to decrease the volume of sea surface oil 

after an oil spill. Burning the oil results in emissions of NO2, SO2, CO, VOC, and CO2 within a 

plume of black smoke. Monitoring studies of controlled oil burning at sea showed levels of NO2, 

SO2, and CO were below detection levels (Fingas, Ackerman, Lambert, et al., 1995). The study 

found that VOC emissions were below levels detected from the unburned oil and PAH were not at a 

level considered harmful. Results of smoke-plume modeling showed concentrations of PM did not 

exceed the health criterion of 150 mg/m3 when measured three miles downwind of the burning 

(USDOI, BOEMRE, 2011). Considering the low concentrations of pollutants found in monitoring 

and modeling, and the short-term nature of in-situ burning, the air quality impacts would be minor. 

Additional information of air quality impacts from in-situ burning is included in the air quality section 

of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Offshore Vessels 

Offshore vessels would be used to remove oil from a spill at sea, apply dispersants, and to drill a new 

well. The oil-skimming vessels use devices to skim oil off the surface of the water, such as belts, 

disks, tubes, and suction devices. A VLOS may require up to 1,600 diesel-powered oil-skimming 

vessels, and other marine equipment such as ice breakers, over the course of time required to confine 

and remove oil from the surface. It is a time-consuming process that would likely take weeks or 

months to complete and would result in thousands of tons of emissions, particularly NO2, but also 

including CO, PM, SO2, VOC, and CO2 (Discovery News, 2010; USEPA, 1996). Emissions from this 

number of vessels would likely result in temporary major air quality impacts. 

Aircraft and Surface Vehicles 

A portion of dispersants used to decrease the size of the oil slick may be applied using aircraft. 

During the response and cleanup process other aircraft may be needed for personnel and equipment 

transport, including helicopters, small piston-powered aircraft, and large commercial jets. Aircraft 

emissions depend partly on the physical characteristics and performance parameters of each unique 

aircraft type. These include the airframe type, the type and number of engines, takeoff weight, and 

approach angle. In addition to the physical characteristics of the aircraft operating at the site, 

emissions further depend on the time that each aircraft type operates in the various modes that define 

a landing and takeoff cycle. A landing and takeoff cycle (LTO) consists of the approach, landing roll, 

taxi to and from the parking area, idle time, takeoff, and climbout. In addition to aircraft, surfacebased vehicles are necessary. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 155

Phase 5 (Long-term Recovery) 

Following the removal or other disposition of the oil by burning, evaporation, or weathering, few, if 

any, additional recovery efforts would be required relative to air quality impacts. However, during 

the long-term recovery process, there would be a continued presence in the area of the VLOS and the 

affected areas onshore. In order for this recovery effort to proceed on a long-term basis, the 

continued use of marine vessels, small boats, aircraft, and surface vehicles will be required. 

Emissions from these sources would be far below the levels experiences during any of the previous 

phases of the VLOS. Considering the decrease in pollution sources and the meteorological conditions 

existing over the Arctic, particularly the potential for Arctic winds to disperse air pollutants, the 

expected air quality impacts during this phase would be considered minor. 

Oil Spill Trajectory Analysis 

The types of impacts to air quality discussed above would be expected to occur regardless of the 

location of the spill’s source. An oil spill trajectory analysis is not provided. 

Conclusion 

A VLOS in the Chukchi Sea could emit large amounts of regulated potentially harmful pollutants into 

the atmosphere. This will cause major air quality impacts during some phases of the event. The 

greatest impacts to air quality conditions would occur during Phase 1 and Phase 4, particularly if the 

spill occurs in the winter. Impacts continue for days during Phase 1 but could continue for months 

under Phase 4. Therefore, while the impacts are estimated to be major during these two phases, the 

emissions from the VLOS would be temporary and over time, air quality in the Arctic would return to 

pre-oil-spill conditions. These impacts are not anticipated to vary under Alternatives III or IV. 

IV.E.4. Lower Trophic-Level Organisms 

This section assesses the potential for the hypothetical VLOS scenario described in Section IV.D to 

impact the lower trophic organisms found within the physical environment of the OCS in the Chukchi 

Sea planning area and shoreward zone Alaska state waters. This physical environment is described in 

the Sale 193 FEIS (USDOI, MMS, 2007a), and the effects of a large oil spill are described in the Sale 

193 FEIS and the Arctic Multi-Sale Draft EIS (USDOI, MMS, 2008a). These descriptions are 

incorporated here by reference. 

Lower trophic and benthic populations in the Chukchi Sea could be strongly impacted by a VLOS, 

with a same-season to one-year loss of major proportions to all components of known lower trophic 

communities. In all phases of a VLOS, one or more of the lower trophic communities described in 

this section would be affected by the byproducts of oil created by natural and anthropogenic 

processes. Furthermore, many lower trophic organisms have the capacity to accumulate oil and oil 

toxins if they are not killed outright, thereby leading to bioaccumulation and biomagnification in 

upper levels of the foodweb (Neff, 2002; Newman and Clements, 2008). In particular, this includes 

copepods and other crustaceans (Hansen, et al., 2011; USDOI, MMS, 2004). 

This lower trophic section will define and describe in brief the potentially affected communities of 

lower trophic organisms, summarize pertinent information from the above documents concerning the 

effects of a VLOS on lower trophic organisms, and describe effects on lower trophic communities 

resulting from each of the five phases of a hypothetical VLOS as described in Section IV.D of this 

document. 

Phase 1 (Initial Event) 

The initial explosive blowout and ensuing fire proposed in the VLOS scenario would result in two 

separate impact producting contexts, one of subsurface explosion and potential fire at the wellhead 

and the other of fire at the drilling rig above the water surface. Each of these is discussed in turn: 
BOEMRE Sale 193 Revised Draft SEIS 

156 CHAPTER IV. Environmental Consequences 

Explosion and Fire at Wellhead 

An explosion and ensuing fire created by natural gas at the wellhead would result in an increase of 

pressure and temperature of the immediate environment. Near instantaneous changes in the chemical 

composition of the surrounding environment in the form of heat energy, followed by gas and oil being 

released to the surrounding sea water would initiate the release of oil to the water column. Severity of 

effects would be dependent upon released energy. The explosion and chemical changes in the water 

column would result in the loss of pelagic and epibenthic lower trophic organisms in the near vicinity 

of the well head. A localized event at that stage of the timeline would likely not cause effects at a 

population level. Sediment upheaval and re-distribution of sediments into the water column and their 

subsequent deposition on the seafloor could affect pelagic organisms within the plume and all benthic 

organisms buried by the sediments, respectively. The severity of the cumulative effects would depend 

on the force of the explosion, concentration within the water column, density of ejected sediments, 

and duration of the sediment plume within the water column before deposition to the sea floor. 

Fire at Drilling Vessel – Above Surface 

A fire at the surface on the rig would create localized effects on plankton populations due to heat of 

the fire and release of material as a result of the event, including oil, melting plastics and rubbers, and 

chemicals used by response crews in attempting to control the fire on the rig. Should the sinking of an 

oil rig occur this could potentially have the greatest effect on lower trophic organisms at all 

community levels. This event would create a separate oil plume as it sank. The final location of the 

rig on the sea floor could create further disturbance of the benthos and likely create a separate source 

of oil plumes in the water column. Overall, the cumulative effects of this first phase would likely not 

affect the lower trophic communities at a population level. 

Phase 2 (Offshore Oil) 

Oil is highly toxic to organisms with a small body size. Phytoplankton, zooplankton, and other lower 

trophic organisms are in contact with their aqueous environment through thin layers of membranous 

tissue, have short distances between those layers and internal organs, and rapid metabolic rates (Jiang, 

et al., 2010; Newman and Clements, 2008; Suter, 2007). The smallest developmental stages of 

organisms with complex life cycles, such as the nauplii larvae of copepods and other crustaceans, are 

especially vulnerable to those effects (Hanson, et al., 2011; USDOI, MMS, 2004). The complex 

physical environment of the Chukchi Sea creates unpredictable advective pathways and changes the 

relative positioning of pycnoclines (density gradients) that separate sub-surface water masses. It also 

influences the movements of particle flow through the surface and subsurface pelagic environments 

(Belkin, Cornillon, and Sherman, 2009; Pickart, et al., 2005). This makes the extent of effects 

dependent upon numerous factors, including duration and volume of spill, persistence and dispersion 

of oil in the water column and the benthic surface, chemical composition of the oil and where it has 

accumulated (at the water surface, in the water column, or at the benthic surface), the efficacy of 

chemical dispersants should they be approved and utilized, the depth and influence of pycnoclines 

(density gradients that influence the capacity of water masses to mix with one another) on the 

movement of oil through the pelagic water column, hours of daylight and UV intensity, seasonality 

and presence or absence of ice, how oil is incorporated into the ice during its formation, classification 

of ice, and presence or absence of polynyas and reaches. Potential effects of these factors on lower 

trophic populations are dependent upon their various combinations and include: 

 Rapid accumulation of toxins within single cell algae and rapid death of these organisms 

within surface areas affected by oil slicks. 

 If phytoplankton cell death does not instantly occur, drift and later ingestion by other 

organisms could lead to bioaccumulation at potentially large numerical scales. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 157

 Although immediate effects of surface oil slicks could be serious to all affected components 

of neuston plankton populations, multi-year studies from previous oil spill events indicate 

population-level recovery should be relatively rapid (one year or less) in marine 

phytoplankton populations, particularly in productive waters of the Chukchi Sea. 

 Populations of meroplankton (including instars, zooids, and nauplii; early larval 

developmental stages of numerous benthic and pelagic species) and adults of those species, 

depending upon factors listed above, may take one year or more to recover to pre-spill 

population levels if adults are affected by population-level losses from settling of oil on 

benthic surfaces. 

 Results of experiments conducted on calanoid copepods indicated exposure to both sunlight 

and weathered Alaska North Slope crude oil resulted in mortality and morbidity (impairment 

of swimming ability and discoloration of lipid sacs) of 80-100% in test treatments of Calanus 

marshallae, while oil-only or sunlight-only treatments resulted in a 10% effect on mortality 

and morbidity. 

 Adult copepods have a strong affinity for accumulation of PAC’s within lipid storage 

vacuoles and an affinity to act as bioaccumulators of these toxins, enabling them to 

potentially be distributed by movements of water masses and affect upper level predators 

away from primary spill area. 

 Studies carried out with larval benthic King crabs and seagrass shrimp exposed to 2 ppm 

crude oil showed >50% mortality in the first 6 hours of exposure. 

 Pelagic communities including squid, jellyfish, ctenopohores, larvaceans, and pteropods are 

rarely affected by surface oil, but subsurface oil would affect these organisms and population 

effects would depend upon the area covered and persistence of oil in the water column. Use 

of dispersants could potentially negatively affect populations of these organisms, as 

knowledge of the efficacy of dispersants in cold water is limited. 

 Benthic communities are affected by accumulation of oil at the ocean bottom, particularly 

when oil covers developing eggs and larvae of organisms that use the benthic surface for 

substrate attachment of these life stages, and when it penetrates the burrows of polychaetes, 

amphipods, and other organisms that create pathways through the upper surface layers of the 

benthic sediment. 

 Likewise, epontic communities would similarly be affected by oil that accumulates under the 

subsurface of the ice, as many organisms live on that surface (i.e., concentrations of ice algae) 

and within the interstitial brine layers of the ice architecture. 

 Persistence of oil through winter months to spring breakup could affect recovery and 

subsequent productivity of benthic communities, as ice algae in affected areas will not 

contribute to benthic productivity, and crustaceans (krill, for example) may not survive at 

population levels adequate to compare with pre-VLOS contributions to the productivity of 

under-ice pelagic and benthic communities and spring plankton blooms. 

 Presence of oil in water or ice could affect attenuation (penetration) of light through the water 

column and ice by way of absorption and scattering of solar radiation. 

 Presence of oil within polynyas and reaches will affect the capacity of these open water 

biological hotspots to support algae and invertebrate populations that are sustained 

throughout the months of ice cover and contribute to benthic and pelagic productivity after 

the ice retreat. 

(Barron, 2007; Barron, et al., 2008; Brandvik and Faksness, 2009; Brodersen, 1987; Deibel and Daly, 

2007; Iken, Bluhm, and Dunton, 2010; Hanson, et al., 2011; Jiang, et al., 2010; Newman and 
BOEMRE Sale 193 Revised Draft SEIS 

158 CHAPTER IV. Environmental Consequences 

Clements, 2008; NRC, 2005; Suter, 2007; USDOI, MMS, 2003, USDOI, MMS, 2004, USDOI, 

MMS, 2008) 

Phase 3 (Onshore Contact) 

Onshore and nearshore environments of the Chukchi Sea are summarized in the Chukchi Sale 193 

FEIS (USDOI, MMS, 2007), and an Environmental Sensitivity Index (ESI) shoreline classification of 

the Alaska Beaufort and Chukchi Seas study funded by the MMS (USDOI, MMS, 2003), both 

incorporated here by reference. State and Federal lands along the Chukchi Sea coastline include the 

Bering Land Bridge National Preserve, Cape Krustenstern National Monument, two segments of the 

Alaska Maritime National Wildlife Refuge, and the National Petroleum Reserve-Alaska. The Chukchi 

Sea shoreline features bays, inlets, lagoons, and barrier islands, with physical environments consisting 

of eroding thermokarst inclusions, wave and tidal undercut permafrost bluffs and peat shorelines, 

inundated lowland tundra, course-grained sand or cobblestone beaches, and estuaries of rivers and 

small streams along the shores (Hartwell, 1973; Taylor, 1981). Approximately 50% of the shoreline 

consists of permafrost overlaid with peat, interspersed with low-lying permafrost bluffs. 

The Sale 193 FEIS describes locations and physical environments of kelp beds near Skull Cliffs and 

southeast of Wainwright. Neither the spatial extent nor diversity and abundance of these biological 

communities have been investigated. This is in contrast to the Boulder Patch, a well-studied kelp bed 

community located in Stefansson Sound in the nearshore Beaufort Sea (Dunton and Schonberg, 

2000). Known locations of kelp beds are outside of the sale area but near potential gas pipeline routes. 

Studies by Dunton and Schonberg (2009) and Konar (2007) indicate the Boulder Patch kelp beds are 

slow to recover from disturbance. Dunton and Schonberg carried out experiments removing kelp from 

their holdfast attachment sites, after three years there was only a 50% recovery in the denuded 

patches. Suspecting invertebrate grazing as a factor, Konar repeated the experiment using cages to 

prevent access by potential herbivores and reported no recruitment after 2 years, again demonstrating 

the slow recovery rate of these communities. No experiments have been conducted on kelp bed 

communities in the Chukchi Sea. Other areas of special interest include the Ledyard Bay Critical 

Habitat Unit, used by endangered Spectacled Eiders as a molting area from July to November, and 

Kasegaluk Lagoon, a known bird, spotted seal, and beluga whale habitat (Frost, Lowry, and Carrol, 

1993). These types of coastal marine environments, with intertidal and subtidal floral and faunal 

communities, would likely experience the longest term effects resulting from contact with oil 

(USDOI, MMS, 2003) and are discussed in Section IV.E.12. 

As discussed in Section IV.E.1, the potential of a VLOS of 74 days duration projects a wide area of 

onshore exposure to weathered oil products, including the shorelines of the Chukchi Sea and the 

eastern shores of Siberia. Organisms inhabiting these diverse environments are subject to similar 

effects as those listed in the previous section, but some factors are specific to onshore contact. Among 

these are the affects of solar irradiance and the risks of photo-enhanced toxicity from oil in shallow 

water environments. Although this mainly refers to oil spills as opposed to drifting and previously 

weathered oil, it is of relevance to the intent of this section. The ultraviolet regions of solar radiation 

can substantially increase toxicity and risks of PAHs through photochemical modification of oil 

(Barron, et al., 2008). A 2004 study funded by the MMS investigated persistence of PAH compounds 

in laboratory tests using shoreline soils collected from the Beaufort Sea, Port Valdez, and Cook Inlet 

areas. Through experimental work they concluded that some interactions between aromatic 

hydrocarbons and sediment organic matter may be irreversible, with field tests indicating they persist 

in all their collection areas from previous oils spills and natural seeps. River and creek delta areas 

exhibiting estuarine habitats would be adversely affected through wind and tidal exposure from oil, 

and the potential impact of storm events. In 1970, Reimnitz and Maurer (1979) observed the effects 

of tidal surges from a major storm event that inundated low-lying tundra and delta regions on the 

Beaufort Sea shoreline, leaving debris lines from flotsam as far as 5,000 m (16,500 ft) inland. A storm 

of equal or greater magnitude could force weathered oil far inward and leave residue over wide areas 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 159

of tundra and river shores. The OSRA model estimates that 1–3 days of time could elapse before oil 

reaches the shoreline. The length and location of shoreline contacted depends on duration of the spill, 

The type of oil released in this scenario would likely be light weight crude, with a rapid evaporation 

time and low persistence. The OSRA model also states that for planning purposes, the USCG 

estimates 5%-30% of the spilled oil could reach shore, resulting in a large volume of oil potentially 

contacting environments that are slow to recover from disturbance. The effects to shoreward lower 

trophic communities would be reliant upon factors such as seasonality of spill, locations of onshore 

contact, and persistence of oil within the water before contact. The relatively low productivity of the 

near shore waters (Grebmeier, et al., 2006) may influence the recovery rate for onshore populations. 

Effects to lower trophic populations where oil contacts the shore zone could result in one to several 

years for recovery, depending upon area of contact and duration and severity of exposure. 

Phase 4 (Spill Response and Cleanup) 

Spill response activities vary in their capacity to affect lower trophic populations. The efficacy of the 

application of dispersants is dependent upon water temperature, water density, energy from wind and 

waves, solar radiation intensity, and exposure time, or residence time, of the dispersant in an 

environment (NRC, 2005). The application of dispersants can cause sinking of droplets and 

subsequent aggregation on the benthic surface (Word, et al., 2008; NRC, 2005) and increased 

exposure of small organisms to oil due to the increased surface area from small particles created by 

dispersants. In-situ burning would cause elevated surface temperatures and creation and introduction 

of residues into the water column (Buist, 2003), and disturbance of the surface layers of the ocean, 

including the microlayer that serves as a concentration point for many forms of plankton (Wurl and 

Obard, 2004). All activities requiring the use of watercraft will increase the disturbance of the lower 

trophic organisms and their habitats, particularly when these activities are carried out in nearshore 

environments. The length of time that response and cleanup activities continue will determine effects 

on lower trophic communities. In general, effects to phytoplankton and pelagic populations will likely 

be minor, but benthic and shore zone lower trophic populations could suffer greater effects of one or 

more years of recovery time. 

Phase 5 (Long-Term Recovery) 

Impacts affecting lower trophic organisms in long-term recovery are similar to the previously 

described scenarios. Phytoplankton populations should recover quickly due to the tremendous influx 

of phytoplankton and nutrients from the Bering Sea and Anadyr waters. Long-term and chronic 

effects will be most evident in populations of benthic and pelagic animals. Even with the advection of 

zooplankton through the currents of surrounding waters and the reproductive capacity of resident 

populations of benthic and pelagic invertebrates, the recovery of invertebrate populations may take 1-

2 years if the impacting factors discussed in earlier sections should culminate in causing populationlevel effects to this diverse group of organisms. 

Oil Spill Trajectory Analysis 

The types of impacts on lower trophic level organisms discussed above would be expected to occur 

regardless of the location of the spill’s source. An oil spill trajectory analysis is not provided. 

Conclusion 

A VLOS would likely have less than a one year effect on phytoplankton populations in the Chukchi 

Sea due to the influx of phytoplankton carried into the Chukchi Sea by the waters of the Gulf of 

Anadyr, the Bering Sea, and the Alaska Coastal currents that would supplement remaining endemic 

populations. However, short-term, local-level effects would have greater potential to affect local food 

webs. Severity of effects would be determined by duration of oil spill, weather patterns, and the 

resultant distribution and geographic coverage of surface oil slicks. Ice algae population effects would 

be determined by similar factors, as the presence of oil within polynyas and reaches, and if 
BOEMRE Sale 193 Revised Draft SEIS 

160 CHAPTER IV. Environmental Consequences 

incorporated into first year ice would likely have at least a one-year effect on local populations due to 

effects on primary productivity and the probable inability of epontic communities reliant on ice algae 

to survive within oil-influenced ice. 

Invertebrate populations within benthic, pelagic, and onshore environments are at greater risks from a 

VLOS due to their slower reproductive rate, longer life spans, and the potential of adult breeding 

populations being negatively affected by the VLOS and leading to a longer recovery rate.. If 

population level effects resulting from a VLOS occur in breeding stocks of invertebrates of these 

Chukchi Sea environments, the recovery potential of populations would not be enhanced by the flow 

of Bering Sea and Anadyr waters as it is with phytoplankton populations. Phytoplankton and 

zooplankton populations extirpated by oil slicks that are constantly shifting and forming in new areas 

due to influences of wind, weather, and waves, would not be available to organisms that depend on 

them for food and survival. Food webs can be very short in the Arctic, with interactions between 

megafauna (i.e. whales, seals, walrus) and lower trophic organisms often comprising one or two 

trophic levels due to the tight benthic and pelagic coupling on the shallow continental shelf off the 

Alaskan Arctic coast (Dunton, et al., 2005; Grebmeier, et al., 2006). Bioaccumulation and 

biomagnification in these foodwebs is a concern. Long lived copepods (such as Calanus glacialis) 

may live 2-3 years, store lipids in the body cavity, undergo diapause (a form of hibernation), and be 

consumed by upper level predators (atlantic cod, bowhead whales, etc.) at a later date (USDOI, 

MMS, 2004). Toxicity studies carried out with benthic crabs and shrimp indicate they may not 

immediately die from toxins (living 24-96 hrs, depending on exposure and oil type), thus allowing 

greater opportunities for consumption by upper-level predators and biomagnification to occur 

(Brodersen, 1987). Phytoplankton themselves may not die immediately from the effects of exposure 

to oil; therefore, advective drift following bioaccumulation in their populations may allow them to be 

consumed by other organisms in locations away from contamination sites (Jiang, et al., 2010). 

Recovery rates of one or more years may result from these effects on invertebrate populations. 

These impacts are expected to occur to the same extent under each action alternative. 

IV.E.5. Fish Resources 

The Sale 193 FEIS and the Arctic Multi-Sale Draft EIS detail the effects of a large oil spill (USDOI, 

MMS, 2007a, 2008a) and are incorporated here by reference. The following text summarizes salient 

points on oil effects on fish from these two documents and adds new pertinent information that has 

come available since 2007. Common fish names are used within the text in this section; 

corresponding family and species binomial names are presented in the Appendix C, Table C-1. 

Phase 1 (Initial Event) 

An explosion would send percussive shock waves through the water, causing rapid increase in 

pressure, density and temperature in the immediate area of the explosion. Fish eggs, larvae and adults 

on the seafloor and in the water column would be injured or killed from shock waves from an 

explosive event when pressure, density and temperature rise rapidly in the immediate vicinity. The 

lateral lines and swim bladders of fish could be severely damaged. Fish injured by the explosion 

would have physical, physiological and behavioral effects that could interfere with swimming, 

feeding, reproduction and predator escape. Acute or chronic effects on fish from an explosion could 

carry into longer term effects on a population if a large proportion of the individuals were killed from 

a rare benthic community. 

An explosion would damage benthic habitat and cause high levels of suspended sediment and 

turbidity, which in turn could affect fish gills and respiration. Visibility for fish would be affected by 

the turbidity in the immediate area. 

Although most natural gas (primarily methane) quickly rises to the water surface, some can enter the 

water as a water-soluble fraction, especially at greater depths and pressures. In this case of a shallow 
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CHAPTER IV. Environmental Consequences 161

water blowout scenario, most natural gas would reach the surface rapidly and pass through the waterair microlayer into the air. Important physical, chemical and biological processes occur in the 

microlayer (GESMAP, 1995) and fish occurring in that layer, particularly floating eggs and larvae, 

would be injured or killed. If a natural gas/oil blow-out occurred at the seafloor, benthic fish in the 

immediate area would be injured or killed. The type and severity of effects on fish would be 

dependent on the concentration of methane, the duration of exposure, the time of year (reproductive 

cycle), the species and life stage of fish and the presence or absence of sea ice. 

A fire would cause the surface water temperature to rise immediately which would be lethal for 

epipelagic fish, eggs and larvae. Subsurface water temperature would increase more slowly and could 

cause changes in physiological processes, particularly for benthic fish that are more sedentary. If a 

fire continued and sub-surface temperatures continued to rise, subsurface egg and larvae mortality 

could occur over time. Free-swimming fish not obligated to a specific habitat would likely move out 

of the area if the temperature continued to rise. Chemical reactions in the water, such as oxygen 

concentration, would be altered by rising temperature and this could also affect the physiology of fish. 

A drilling rig could physically impact the seafloor habitat if it sinks. Longer term impacts would 

occur if a drilling rig has materials that would leach into the near environment. In other places in the 

world, rigs in place appear to serve as structural habitat for some species of fish (Caselle, et al., 2002). 

If the rig broke apart and drifted across the seafloor, there could be structural hazards. 

Table C-1 (Appendix C) presents a summary of fish that occur in the Chukchi Sea and the 

environments they depend upon. In a VLOS explosion, demersal and pelagic fish would both be 

affected. The effects would differ somewhat if the explosion occurred at the seafloor (<50 m) or if it 

occurred along the riser (midwater pelagic) or at the surface of the rig (epipelagic environment). 

Sensitive life stages in the surface waters (such as floating eggs of Arctic cod and drifting fish larvae) 

would be particularly affected by the explosion (shock wave, methane) and fire (heat and chemical 

reactions). The freshwater stages of anadromous fish would not be affected directly by the explosion 

and fire phase. 

Phase 2 (Offshore Spill) 

Given the complex life cycles of many species in this region, it is often difficult to maintain a clear 

distinction between impacts that could occur during Phase 2 of the VLOS scenario and impacts that 

could occur at Phase 3. The discussion below describes potential effects on fish associated with both 

of these Phases. 

A very large oil spill in the Chukchi Sea could affect marine and anadromous fish and fish habitat 

through many pathways. Acute and chronic exposures could occur in riverine, estuarine and marine 

environments which includes habitats in the water column, bottom sediment and sea ice. The 

exposure pathways for fish include adsorption to outer body, respiration through gills, ingestion, and 

absorption of dissolved fractions into cells through direct contact. 

The severity of the effects on fish would depend on several factors including the type of oil/gas 

mixture spilled, the thickness of the oil spill, the duration of exposure on the surface, the season of the 

year (open-water, ice) and the life stage of the fish (egg, larvae, juvenile, adult). Following are the 

types of effects that could occur to fish from a very large oil/gas spill or blowout: 

 Mortality of eggs and immature stages due to acute toxicity of oil and its weathered products 

 Mortality of epipelagic eggs and larvae from acute coating with oil layer 

 Mortality of adult fish in shallow coastal water bodies with slow water-exchange rates 

 Mortality of eggs, immature and adult fish from shock waves from explosive event when 

pressure, density and temperature rise rapidly in the immediate vicinity 

 Immediate loss of some marine, estuarine and riverine habitats from physical oiling 
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162 CHAPTER IV. Environmental Consequences 

 Contaminant effects on organs, tissues and gills, causing physiological responses including 

stress and altered respiration, irregular or reduced heart rate, and fluid accumulation; these 

effects can, in turn, affect swimming, feeding, reproductive and migratory behaviors and the 

physiologic adjustment for anadromous fish as they move between freshwater and saltwater 

environments 

 Genetic damage to embryos resulting in morphological abnormalities which can affect ability 

to swim, feed, avoid predators and migrate 

 Contaminant exposure in spawning or nursery areas causing abnormal development, or 

delayed growth through adsorption and ingestion; this abnormal development may repeat 

through generations if the population continues to spawn and/or rear offspring in 

contaminated areas 

 Displacement of individuals or portions of a population from preferred habitat due to oiling 

 Blocked or impeded access to or from spawning, feeding or overwintering freshwater habitats 

of anadromous fishes due to oiling of estuarine and freshwater environments 

 Disruption or re-direction of coastwise migration of migratory and anadromous fish 

 Reduction or elimination of prey populations normally available for consumption 

 Reduction of individual fitness and survival, thereby increasing susceptibility to predation 

 Long-term chronic contaminant effects in fish habitats from weathering oil which produces 

highly toxic polycyclic aromatic hydrocarbons (PAHs), especially to lipid-rich eggs 

 Decreased recruitment into the population due to mortality, abnormal development of eggs 

and larvae, truncated adult lifespan, reduced adult fitness, increased predation, increased 

parasitism, and zoonotic diseases 

 Intraspecific cascade effects, such as loss of key individuals in social groups, which may 

show delayed effects on reproduction or feeding behaviors 

 Modification of community structure due to increased mortality, reduced recruitment, 

decreased prey availability, loss of year classes and increased predation 

 Modification of ecosystem due to reduction of fish eggs, larvae and adult fish available to 

predators including seals, sea birds, other fish species and toothed whales, indirectly to polar 

bears 

 Cumulative effects from acute and chronic oil effects overlain on other contemporary 

stressful events such as water temperature rise, ocean acidity increase and decreasing sea ice 

(Nahrgang, et al., 2010a,b,c; Boertmann, et al., 1998; Jonsson, et al., 2010; Pearson, et al. 1984; Pinto, 

et al., 1984; Moles and Wade, 2001; Heintz, et al., 2000; Patin, 1999; Rye, et al., 2000; Christiansen 

and George, 1995; Christiansen et al., 2010; Mahon, et al., 1987; Ott, Peterson, and Rice, 2001; Rice 

et al., 2000; Carls et al., 2005; Short et al., 2003; Peterson et al., 2003; GESAMP, 1995). 

Section IV.E.4 analyzes the potential for reduction of lower trophic species, bioaccumulation, and 

contamination of these organisms that serve as important prey species to fish in the Chukchi Sea. 

Anadromous fish, because they depend on several environments in their complex life history, can be 

particularly impacted if oil reaches mouths and deltas of anadromous streams and rivers. Oil on the 

coastline presents a barrier to access (or egress) to spawning, feeding, overwintering and coastwise 

migration for anadromous species. A VLOS could wash over river deltas, into river mouths and be 

transported upstream by tidal action or salmon returning to spawn and die in their natal waters. Oil in 

anadromous water bodies would present contaminants to sensitive spawning areas and life stages. 

There are many anadromous rivers, streams and lagoons along the Chukchi Sea Coast and Western 

Beaufort Coast from the Bering Strait to Nuiqsut. The list of anadromous waterbodies in Table 7 are 

those that have been reported to and documented by the Alaska Department of Fish and Game 
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CHAPTER IV. Environmental Consequences 163

through the Alaska Anadromous Waters Catalog (ADFG, 2011). Anadromous fish that would be 

affected by a VLOS in the Chukchi Sea include: Pacific salmon (pink, chum, king, coho, sockeye), 

least cisco, Bering cisco, Dolly Varden, broad whitefish, humpback whitefish and Arctic char. 

Figures C-1 to C-5 (in Appendix C) display the anadromous waterbodies used by these species in 

Northwest Alaska. Although Arctic char are primarily lake dwellers and spawners, it is estimated 

they spend approximately 10% of the year in nearshore areas feeding in summer before returning to 

inland waters to spawn (Craig, 1989). 

Of the 41 anadromous waterbodies listed in Table 7, 28 of the waterbodies support salmon species. 

In most cases, the waterbody supports 1 or 2 salmon species, most commonly pink and chum salmon. 

In a few cases, a waterbody supports 3-5 species of salmon. The Noatak and Kobuk rivers in the 

southeastern study area support all five species of salmon. 

It is estimated that between 0 and 1,368 km of discontinuos shoreline length could be contacted by oil 

depending on location of a very large oil spill, the season and the number of days after the spill 

release (see OSRA model results below). 

Table 7. Anadromous waters in Northwest Alaska from Bering Strait to Nuiqsut. 

River/Stream Name Species Type 

Aukulak Lagoon Whitefish 

Ayugatak Creek Pink Salmon 

Fish Creek 

Chum Salmon, King Salmon, Pink Salmon, Dolly Varden, 

Whitefish 

Grouse Creek Dolly Varden, Pink Salmon 

Ikpikpuk River Pink Salmon 

Imikruk Creek Whitefish 

Inmachuk River Chum Salmon, Pink Salmon 

Jade Creek Dolly Varden 

Kiligmak Inlet Dolly Varden,Whitefish 

Killak River Dolly Varden 

Kitluk River Pink Salmon 

Kivalina River Chum Salmon,Coho Salmon 

Kiwalik River Chum Salmon, Pink Salmon, Dolly Varden 

Kobuk River 

Chum Salmon, Pink Salmon, Sockeye Salmon, King Salmon, 

Coho Salmon, Dolly Varden, Whitefish 

Kokolik River Chum Salmon, Pink Salmon, Dolly Varden 

Kougachk Creek Pink Salmon 

Kugrua River Chum Salmon, Pink Salmon 

Kuchiak Creek Chum Salmon, Coho Salmon 

Kuk River Pink Salmon 

Kukpowruk River Chum Salmon, Dolly Varden 

Kukpuk River Pink Salmon 

Kukukpilak Creek Dolly Varden 

Lewis River Channel 

Chum Salmon, King Salmon, Pink Salmon, Dolly Vardens, 

Whitefish 

Mint River Chum Salmon, Pink Salmon, Sockeye Salmon, Dolly Varden 

New Heart Creek Dolly Varden 

Noatak River 

Chum Salmon, Pink Salmon, Sockeye Salmon, King Salmon, 

Coho Salmon, Dolly Varden, Whitefish 

North Channel Kiwalik River Chum Salmon, Pink Salmon, Dolly Varden 

Nuluk River Chum Salmon, Pink Salmon, Dolly Varden, Whitefish 
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164 CHAPTER IV. Environmental Consequences 

River/Stream Name Species Type 

Omikviorok River Dolly Varden, Whitefish 

Piasuk River Whitefish 

Pinguk River Chum Salmon, Pink Salmon, Dolly Varden, Whitefish 

Pitmegea River Chum Salmon, Pink Salmon, Dolly Varden 

Rabbit Creek Chum Salmon, Sockeye Salmon 

Smith River Dolly Varden, Least Cisco, Whitefish 

Sulupoaktak Channel Pink Salmon, Dolly Varden 

Trout Creek Dolly Varden, Whitefish 

Ublutuoch River 

Chum Salmon, King Salmon, Pink Salmon, Dolly Varden, 

Whitefish 

Upkuarok Creek Dolly Varden 

Utukok River Chum Salmon, Pink Salmon, Dolly Varden 

Wulik River Pink Salmon 

Yankee River Dolly Varden 

Source: Data from Alaska Department of Fish and Game, Anadromous Waters Catalog 

Several fish species such as capelin, sand lance, saffron cod, and some sculpin species are not 

considered anadromous but they use nearshore substrates for spawning and rearing habitats. 

Nearshore species would be affected through similar pathways as anadromous fish if an oil spill hit 

the nearshore or shoreline, particularly during critical spawning or rearing times. 

Figure IV.C.1 in the Sale 193 FEIS (USDOI, MMS, 2007a) presents a model of the acute and chronic 

effects of oil on nearshore and intertidal fish, eggs and larvae and the cascade of effects on fish 

populations. Sand lance would be especially affected in their nearshore habitats because they burrow 

in sand when they are not out foraging in the water column and they also overwinter in those burrows. 

Experiments have shown that sand lance are affected negatively by oiled sediments (Pearson, et al., 

1984; Pinto, et al., 1984; Moles and Wade, 2001). 

Offshore fish species would experience a variety of effects from a very large oil spill depending on its 

life history stage (adult, sub adult, egg, larvae); its habitat association (bottom dwelling, mid-water 

column, upper water column, beneath ice or in ice crevices); the range of depth inhabited; the breadth 

of the species habitat, prey and range; the life history and behaviors of the species (migratory, 

sedentary, reproductive strategy, etc); and plasticity of the species to adjust to environmental 

stressors. Fish found widespread in the Chukchi Sea offshore (and some also nearshore) include 

Arctic cod, capelin saffron cod, Alaska plaice, yellowfin sole and certain species of sculpin, flounder, 

poachers, snailfish and eelpouts. 

Sedentary, burrowing, territorial, benthic-obligated fish, fish eggs and fish larvae exposed to oil or 

gas would be limited in their ability to escape or avoid contaminants due to their limited swimming 

behaviors, obligate life history characteristics, behavioral traits, or spatial limitations. The exposure 

concentration that these species (including some poachers, eelpouts, sculpin, flounders, snailfish, 

nesting saffron cod) would experience could be greater than that to which free-swimming fusiform 

fish would be exposed. Fish that can swim relatively faster and more efficiently (such as salmon, cod, 

smelt, herring, and sharks) would more likely avoid some of the effects of oil at various 

concentrations if they have the sensory ability to detect oil or gas components. 

Some fish species associate with sea ice to feed, hide and spawn. Most notable of these in the 

Chukchi Sea is the Arctic cod which associates with ice in various life stages and seasons for shelter 

and as a forage habitat to feed on microorganisms on the underside of the ice. Under-ice amphipods 

are an important food source for Arctic cod (Lonne and Gulliksen, 1989; Gradinger and Bluhm, 

2004). Rough, irregular textures of the underside-ice may provide preferred habitat for Arctic cod to 

avoid predators (Cross, 1982). Arctic cod migrate between offshore and onshore areas for seasonal 
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CHAPTER IV. Environmental Consequences 165

spawning. They spawn under the ice during winter months (Craig, et al, 1982; Craig, 1984; 

Bradstreet, et al., 1986). Eggs hatch under the sea ice after 40-60 days and young larvae remain 

under the ice, eventually settling towards the bottom in September (Craig 1984; Graham and Hop 

1995). For further discussion of the effects of oil on Arctic cod, see Essential Fish Habitat, Section 

IV.E.6. 

Oil and gas released in a winter scenario would pool under the ice in pockets presenting prolonged 

exposure to Arctic cod eggs and larvae, hiding adults, and amphipods inhabiting the under-ice 

environment. Pooled under-ice oil could take several pathways between winter and summer months: 

remain pooled on underside of ice and drifting with ice; remain pooled in open leads; entrain or 

encapsulate in ice; dissolution into water column; or sinking adhered to sediment (Figures A.1-1, A.1-

2). Melt-out of annual sea ice in spring and summer would release oil pooled underneath and trapped 

in ice and leads. All of these pathways would affect offshore and nearshore Arctic cod and other fish 

species, including those living in association with ice and those in the water column below ice and 

ultimately the benthic species affected by sinking oil-laden particulate. 

Table C-1 (Appendix C) presents a list of the fish that are known to occur in the Chukchi Sea, the 

environments they depend upon and a summary of how they could be affected by a very large oil 

spill, from the time of explosion (Phase 1), to offshore and onshore contact (Phases 2 and 3) and the 

response, clean-up and long-term recovery (Phases 4 and 5). 

Phase 3 (Onshore Contact) 

As previously explained, analysis of potential effects on fish during both Phases 2 and 3 of the VLOS 

scenario are discussed together within Phase 2. 

Phase 4 (Spill Response and Cleanup) 

Dispersants 

Dispersants are a combination of surfactants and solvents that work to break surface oil into smaller 

droplets which then disperse on the surface and into the water column. Many factors affect the 

behavior, efficacy, and toxicity of a particular dispersant including water temperature, surface 

salinity, wave and wind energy, light regime, water depth, type of oil, concentration of dispersant, 

how the dispersant is applied (constant or intermittent spikes) and exposure time to organisms. 

Dispersants are used to degrade an oil spill more quickly through increasing surface area and to 

curtail oil slicks from reaching shorelines (Word, et al., 2008). 

Application of dispersants can cause toxic effects in fish and particularly fish eggs and larvae. Fish 

can be affected by dispersed oil through adsorption, ingestion, absorption of dissolved components 

and respiration (Word, et al., 2008). As oil breaks into smaller droplets and sinks in the water 

column, the droplets are more likely to be ingested by fish that inhabit the water column. Because the 

surface area of oil increases as it is broken into droplets, there is an increased chance of fish, eggs and 

larvae in the water column coming into contact with the dispersed oil (Word, et al., 2008). If oil 

droplets adhere to sediment and sink to the seafloor, benthic fish eggs and larvae would then be 

exposed to oil. In shallow nearshore waters, wind, wave and current action would more likely mix 

the dispersant-oil mixture into the water column and down to the seafloor environment oil-dispersant 

mixtures can foul gills and cause changes in histopathology of the gills (Khan and Payne, 2005). 

The effect of dispersant application in a very large oil spill in the Chukchi Sea would be similar to the 

toxicity and fouling effects outlined above under Phases 2 and 3 of the oil spill itself (Offshore Spill 

and Onshore Contact). Epipelagic fish eggs and larvae would be particularly sensitive to effects of 

dispersant application. Fish in the water column and the benthos would be variably affected as a 

function of the species, life stage, depth inhabited, time of reproductive cycle, feeding strategy and 

ability to adapt by sensing the chemical changes and moving out of the range of toxic effects. 
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166 CHAPTER IV. Environmental Consequences 

In-Situ Burning 

In-situ burning is used to remove oil from the surface and to curtail oil slicks from reaching 

shorelines. In-situ burning could affect fish through elevation of surface-water temperature; boom 

dragging for oil collection; and sinking of residues. These effects on fish would differ depending on 

the time of year (open-water vs. ice-cover) and the size and duration of the burn. 

The upper-most layer of water (upper millimeter or less) that interfaces with the air is referred to as 

the microlayer. Important chemical, physical and biological processes take place in this layer and it 

serves as habitat for many sensitive life stages including fish eggs, fish larvae, and microorganisms 

important as prey for fish (GESAMP, 1995). Disturbance to this layer through boom-dragging to 

collect oil and temperature elevation from burning could cause lethal effects on fish life stages in this 

layer. In open water, the effects would be limited to the surface area burned and to the duration of a 

burn in any one area. Free-swimming adult fish not obligated to a specific habitat would likely move 

out of the area. 

If an oil spill occurred in winter, in-situ burning would be limited by the lack of open water to collect 

oil and the area of open water in which to maneuver vessels and contain oil to an optimal thickness to 

burn (greater than 1-2 mm). If it could occur on a limited scale, sea ice would melt in the immediate 

vicinity of the burn and fish associated with the ice would be negatively affected by the operation. 

Residues from in-situ burning can float or sink depending on the temperature and age of the residue. 

Floating residue can be collected; however, residues that sink could foul gills and expose benthic 

organisms to oil components as the residue degrades on the seafloor. 

The NOAA Office of Response and Restoration states that, “Overall, these impacts [from open water 

in-situ burning] would be expected to be much less severe than those resulting from exposure to a 

large, uncontained oil spill” (http://response.restoration.noaa.gov, In-Situ Burning). 

Offshore Vessels and Skimmers 

During the spill response and cleanup and phase, fish could be exposed to a variety of effects from 

offshore vessel traffic including: 

 noise from engines, equipment and propellers; 

 seismic surveys used to locate debris and drill relief well; 

 potential for introduction of invasive species from foreign or out-of-state vessels; 

 regulated and unregulated discharges into the ocean; 

 potential for vessel groundings and accidental spills; 

 anchoring in benthic habitat; breaking of ice habitat from ice-breaker operations; and 

 surface skimming or vacuuming of oil from microlayer by collection skimmers. 

Noise from ships, sound from seismic surveys and other sound sources would affect fish through 

interference with sensory orientation and navigation, decreased feeding efficiency, scattering of fish 

away from a food source and redistribution of fish schools and shoals (Fay, 2009; Radford et al., 

2010; Simpson, Meekan, Larsen, et al., 2010; Slabbekoorn, et al., 2010; Purser and Radford, 2011). 

Pelagic species, such as adult Arctic cod, adult salmon and similar species would startle and scatter as 

noise continues and, in theory, receive reduced levels of sound. Sedentary, burrowing, territorial, 

benthic-obligated fish, shallower near-shore fish, fish eggs and fish larvae in the area of the rig and oil 

spill would be exposed to higher noise levels due to their limited swimming behaviors, obligate life 

history characteristics, behavioral traits or spatial limitations. Foraging and reproduction behaviors of 

these benthic-obligate fish could be affected negatively by seismic activities and noise. 
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CHAPTER IV. Environmental Consequences 167

There is a low probability risk of introducing invasive species brought in from other seas through 

vessel hulls and equipment deployed overboard. Invasive species, including microorganisms, could 

affect fish due to disease, competition for food or competition for habitat. 

Skimming or vacuuming the microlayer would disturb chemical, physical and biological processes 

that take place in this layer and would injure or kill sensitive pelagic life stages including fish eggs, 

fish larvae and microorganisms that are important prey for fish (GESAMP, 1995). Ice-breakers 

would cause disturbance to ice habitat, and depending on the time of year, could affect the eggs and 

young larvae or Arctic cod. 

Drilling of Relief Well 

Drilling an emergency relief well would entail vessel noise, seismic surveys, drilling noise and 

vibration, discharge of drilling muds and cuttings, wastewater discharges as permitted by regulation, 

potential for accidental spills, and potential for introduction of invasive species from vessel or 

equipment placed overboard. These actions could cause startle and disorientation behavior in fish, 

exposure to contaminants, physical disturbance to seafloor habitat, increased suspended sediment and 

reduced visibility in the water column. 

Benthic-obligate fish could be affected more than pelagic free-swimming fish by relief well drilling 

because of their relative inability to escape noise, disturbance, or contaminants, and due to 

disturbance of benthic habitat around the drill site. The effects of well-drilling on water quality and 

fish were discussed in detail in the Sale 193 FEIS (USDOI, MMS, 2007a). 

Beach Cleaning 

The cleaning up of oiled beaches (and rescue of oiled animals) could entail small boat and aircraft 

landings on marine and freshwater shorelines; large numbers of people walking and wading through 

aquatic habitats; collection of oiled sediment and beach wrack; possible hydraulic washing with hot 

water; possible application of fertilizer to enhance degradation of oil; and possible raking of fine 

sediments. 

These activities could result in effects on fish including trampling of intertidal and nearshore, riverine 

and riparian habitats, crushing of eggs and benthic larvae, aberrant behaviors due to noise, suspended 

sediment in waters and resettlement of sediments elsewhere, runoff of treatment-laden waters that 

could affect nearshore temperature and nutrient concentrations, removal of beach wrack nutrient 

souces, removal of intertidal hiding habitat, and potential for introduction of invasive species from 

small boats, aircraft pontoons, and waders and clothing worn by workers from outside of the Alaska 

Arctic region. 

Phase 5 (Long Term Recovery) 

In long-term recovery, there would be a continued presence of people in the area for monitoring and 

research which would entail small boat and aircraft landings on marine and freshwater shorelines; and 

people walking and wading through aquatic habitats. These activities could result in effects on fish 

including trampling of intertidal and nearshore, riverine and riparian habitats, noise and disturbance 

and removal of fish from the system for research purposes. 

Over the long-term, contamination of aquatic environments from oil (and possibly dispersant residue 

on the seafloor) would continue from oil breakdown products such as polyaromatic aromatic 

hydrocarbons (PAHs). Sunlight (UV radiation) increases the toxicity of PAHs so summer sunlight in 

Arctic Alaska may exacerbate the amount and degree of toxicity exposure. 

Long-term chronic effects from oil would occur in fish that occupy estuarine, intertidal and 

freshwater habitats where oil accumulates and weathers, producing PAHs especially toxic to lipidrich eggs (as would be the case with pink salmon and capelin). If chronic exposures persist, stress 
BOEMRE Sale 193 Revised Draft SEIS 

168 CHAPTER IV. Environmental Consequences 

may manifest sublethal effects later in the form of histological, physiological, and behavioral 

responses, including impairment of feeding, growth, and reproduction (Heintz, et al., 2000). Chronic 

toxicity and stress may also reduce fecundity and survival through increased susceptibility to 

predation, parasite infestation, and zoonotic diseases. The frequency of a single symptom does not 

necessarily reflect the effects of oil on the organism, so the cumulative effects of all symptoms of 

toxicity must be considered in evaluating acute and chronic effects of oil on fish. 

Contaminant exposure can make a spawning site unavailable for multiple generations if the oil is 

detectable by the fish. If a population continues to spawn and/or rear offspring in oil-contaminated 

areas, abnormal development, genetic alterations or abnormal behavior may repeat through successive 

generations. The likely results would be fewer juvenile fish survive, so that recruitment from the 

early lifestages is reduced and adult populations decline. Declining adult populations may not be 

replaced at sustainable levels. Ultimately, these cumulative effects on individuals can affect the 

population abundance and, subsequently, community structure (Patin, 1999 Ott, Peterson, and Rice, 

2001 Rice et al., 2000). Moles and Norcross (1998) documented deleterious effects on juvenile 

flatfish species, including yellowfin sole, that were exposed to sediments laden with Alaska North 

Slope crude oil. The effects of this controlled laboratory experiment included changes in tissues and 

significant decreased growth rates in yellowfin sole juveniles at 30, 60 and 90 days of exposure. 

Table C-1 (in Appendix C) presents a list of the fish that are known to occur in the Chukchi Sea, the 

environments they depend upon and a summary of how they could be affected by a very large oil 

spill, from the time of explosion (Phase 1), to offshore and onshore contact (Phases 2 and 3) and the 

response, clean-up and long-term recovery (Phases 4 and 5). 

Oil Spill Trajectory Analysis 

The following paragraphs present results estimated by the OSRA model from a very large oil spill 

contacting coastal land segments and resource areas that are important to fish and their habitats. The 

trajectory estimates are based on the assumption that a spill has occurred (Appendix B). The resultant 

summaries recognize that models are simulations representing typical or average interactions of 

highly variable factors, and are used here in a broad sense in drawing conclusions about anticipated 

effects on fish resources. The effects of subsurface transport of oil in water, tarballs washed onto 

beaches, and persistence of oil once it has reached coastlines is evaluated through relevant scientific 

literature. 

Summer 60 Days 

Alaska Coastline. The OSRA model estimates that <0.5 – 11 % of the trajectories from LA1–LA13 

would contact some portion of the Alaska coastline (LSs 64–89)(Appendix B, Table B-9, Figure B-7). 

Table 7 lists the coastal streams and rivers important to anadromous fish. Tables 8 and 9 (below) list 

the coastal water bodies in each land segment. Some of the most biologically important water bodies 

along the U.S. Chukchi Sea coastline include Leynard Bay, Kasegaluk Lagoon, Ledyard Bay, Peard 

Bay, Pitimega River, Kugra River, Noatak River, Kobuk River and Kukpowruk River. Overall, it is 

estimated that 0-1,046 km of discontinuous shoreline could be contacted from LAs 1-13. 

The OSRA model estimates that <0.5-11% of the trajectories from a very large oil spill starting at 

LA1-LA13 contacts land segments (LS) containing streams important to spawning chum salmon 

including (among others) Pitmegea River (LS 67), Kukpowruk River (LS 71), Kugrua River (LS 80) 

(Appendix B, Table B-9 and Appendix C, Figure C-1). 

The OSRA model estimates that a <0.5-11% of the trajectories from LA1-LA13 contacts land 

segments that have streams important to spawning pink salmon in the Kuk, Kokolik, Utukok, 

Ikpikpuk and Kukpowruk (among other) rivers along the Chukchi Sea coast. 
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CHAPTER IV. Environmental Consequences 169

The greatest percentage of trajectories that contact LSs that contain chum and pink salmon streams 

occurs from Launch Areas 12 and 13 (<0.5-11%); these two land segments are in closer proximity to 

the coastline than the other Launch Areas. The OSRA model estimates that trajectories from LA 10 

would contact the greatest number of land segments (9 total); trajectories from LA 11 would contact 

the next greatest number (8) of land segments. 

While the entrances to salmon-spawning streams are relatively easy to identify, other resource areas 

important to fish also exist along the Chukchi Sea coastline. For example, the Kasegaluk Lagoon 

complex (LSs 73-75) includes an estuary important to rearing fish, including outmigrating salmon 

smolts from the Kukpowruk, Kokolik, and Utukok rivers. Also, adult salmon appear to make use of 

the area as evidenced by the capture of 17 adults there (Craig and Halderson, 1986, citing Craig and 

Schmidt, 1985). Salmon and other fish appear to be the attractant for very large numbers of 

migratory birds that make use of the area during May-October (Kinney, 1985). The OSRA estimates 

that <0.5–4% of the trajectories from LA11 would contact Kasegaluk Lagoon (Appendix B, Table B7; Figure B-7). 

The Bering Sea lies south of Bering Strait. Many pelagic Bering Sea fish species inhabit the Bering 

Strait. The OSRA model estimates that 1% of the trajectories would contact the western Bering Strait 

waters (BS2) from LA9 (Appendix B, Table B-13; Figure B-1). The OSRA model estimates that < 

0.5-4% of trajectories from LA1-LA13 would contact northeast Chukchi Sea Boundary Segments 17-

22, which is habitat for epipelagic fish including Arctic cod sensitive life stages. (Appendix B, Table 

B-13 and Figure B-1). 

Approximately 30% of a 60,000 bbl crude oil spill during summer would remain (in water column, in 

bottom sediments, ingested, beached) after 30 days. It is estimated that 33% of the oil spill would 

disperse and 37% would evaporate after 30 days in a summer spill (Appendix B, Table B-4). 

Through 60 days after a very large oil spill in summer, the OSRA model estimates that between 

245,800 and 364,200 km2 of discontinuous ocean surface would be contacted by trajectories from 

LA1–LA13. The greatest discontinuous ocean surface area contacted would be generated by LA8; 

the least by LA9 (Appendix B, Table B-5). Ocean surface is an important habitat for epipelagic fish, 

eggs and larvae which including life stages of Arctic cod. 

The OSRA trajectory model estimates movement of a surface oil slick, however, it does not assess 

subsurface transport of oil in water, tarballs washed onto beaches or persistence of oil once it has 

reached spawning beaches, rearing areas or spawning streams. The Sale 193 FEIS, Appendix A, 

Section B.3 discusses shoreline type and oil persistence. 
BOEMRE Sale 193 Revised Draft SEIS 

170 CHAPTER IV. Environmental Consequences 

Table 8. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting from a given 

location that will contact Alaska coastal land segments (LS) within 60 or 360 days. 

Russia Far East Coastline. The Russia Far East coast has many coastal rivers, lagoons and bays 

(Appendix C, Figure C-9), with habitat that supports fish including: Uelen Lagoon and River( LS39); 

Inchoun Lagoon and River (LS 38); Chetigun River (LS 37); Koluychin Bay and Koluychin Islands 

(LS 30-31); and Vankarem Lagoon and River (LS 29-30). King, sockeye, coho, chum and pink 

salmon have been documented in coastal waters from Uelen Lagoon to Koluychin Bay. The 

Chetigun River is noted for supporting spawning and juvenile populations of king, sockeye, pink and 

chum salmon. 

The OSRA model estimates that <0.5- 2% of the trajectories from LAs 1-13 would contact the 

Russian Far East coastline (Land Segments 27, 32-39) within 60 days, during summer. Launch Area 

9 has the highest percentage of trajectories that would reach the coast. All the Russia Far East land 

segments with percentage of trajectories contacting (LSs 27, 32-39) contain coastal rivers. (Appendix 

B, Table B-9) 

Table 9. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting from a given 

location that will contact Russia coastal land segments (LSs) with 60 or 360 days. 

Season / 

Analysis 

Period 

% Range of Contact to LSs LSs Contacted from 

LA1–LA13 

LSs with Anadromous 

Waters Contacted from 

LA1–LA13 >0.5% 

Summer 

60 days 

<0.5–11% 

from Launch Areas 3-13 

#64–89 

from Launch Areas 3–13 #64, 66-68, 70–74,78–80 

Summer 

360 days 

<0.5–13% 

from Launch Areas 2-13 

#64– 89, 91 

from Launch Areas 3-13 #64, 66-68, 70–74,78–80 

Winter 

360 days 

<0.5–7% 

from Launch Areas 1-13 

#64-65, 70–76, 78–79, 

80–88 

from Launch Areas 1-13 

#64,70–74, 78–80 

Geographic Name of Land Segments: 64- Aiautak Lagoon, Ipiutak Lagoon, Kowtuk Point, Kukpuk River, Pingu 

Bluff, Point Hope, Sinigrok Point, Sinuk; 65- Buckland, Cape Dyer, Cape Lewis, Cape Lisburne;66- Ayugatak 

Lagoon: 67- Cape Sabine, Pitmegea River; 68- Agiak Lagoon, Punuk Lagoon; 69- Cape Beaufort, Omalik Lagoon; 70- 

Kuchaurak Creek, Kuchiak Creek; 71- Kukpowruk River, Naokok, Naokok Pass, Sitkok Point; 72- Epizetka River, 

Kokolik River, Point Lay, Siksrikpak Point; 73- Akunik Pass, Tungaich Point, Tungak Creek; 74- Kasegaluk Lagoon, , 

Solivik Island, Utukok River; 75- Akeonik, Icy Cape, Icy Cape Pass; 76- Akoliakatat Pass, Avak Inlet, Tunalik River; 

77- Mitliktavik, Nivat Point, Nokotlek Point, Ongorakvik River; 78- Kilmantavi, Kuk River, Point Collie, Sigeakruk 

Point; 79- Point Belcher, Wainwright, Wainwright Inlet; 80- Eluksingiak Point, Igklo River, Kugrua Bay; 81- Peard Bay, 

Point Franklin, Seahorse Islands, Tachinisok Inlet: 82- Skull Cliff:83- Nulavik, Loran Radio Station:84- Walakpa River, 

Will Rogers and Wiley Post Memorial; 85- Barrow, Browerville, Elson Lagoon; 86- Dease Inlet, Plover Islands, 

Sanigaruak Island; 87- Igalik Island, Kulgurak Island, Kurgorak Bay, Tangent Point; 88- Cape Simpson, Piasuk River, 

Sinclair River, Tulimanik Island; 89- Ikpikpuk River, Point Poleakoon, Smith Bay; 91- Lonely AFS Airport, Pitt Point, 

Pogik Bay, Smith River 

Season / Analysis 

Period % Range of Contact to LSs LSs with Anadromous Waters Contacted from LA1–LA13 >0.5% 

Summer 

60 days 

<0.5 - 2% 

 from Launch Areas 4 and 9 27, 32-39 

Summer 

360 days 

<0.5 - 10% 

from Launch Areas 4,8,9, 10 8, 26-39 

Winter 

360 days 

<0.5 - 5% 

from Launch Areas 1,2,4,9,11 7,8, 25-39 

Geographic Name of Land Segments Contacted in Far East Russia: 7- Kosa Bruch; 8- Klark, Mys Litke, Mys 

Pillar, Skeletov, Mys Uering; 25- Laguna Amguema, Ostrov Leny, Yulinu; 26- Ekugvaam, Reka Ekugvam, Kepin, 

Pil'khin; 27- Laguna Nut, Rigol; 28- Kamynga, Ostrov Kardkarpko, Kovlyuneskin, Mys Vankarem, Vankarema, Laguna 

Vankarema; 29- Akanatkhyrgyn, Nel'teyveyam, Mys Onman, Vel'may; 30- Laguna Kunergin, Nutepynmyn, 

Pyngopil'khin, Laguna Pyngopil'khin; 31-Alyatki, Zaliv Tasytkhin, Kolyuchin Bay; 32- Mys Dzhenretlen, Eynenekvyk, 

Lit'khekay-Polar Station; 33- Neskan, Laguna Neskan, Mys Neskan; 34- Emelin, Ostrov I dlidlya, I, Memino,Tepken; 

35- Enurmino, Mys Keylu, Netakeniskhvin, Mys Neten; 36- Mys Chechan, Mys Ikigur, Keniskhvik, Mys Serditse 

Kamen; 37-Chevgtun, Utkan, Mys Volnistyy; 38- Enmytagyn, Inchoun, Inchoun, Laguna Inchoun, Mitkulino, Uellen, 

Mys Unikin; 39- Cape Dezhnev, Mys Inchoun, Naukan, Mys Peek, Uelen, Laguna Uelen, Mys Uelen 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 171

Summer within 360 Days 

Alaska Coastline. The OSRA model estimates that <0.5- 13% of the trajectories from LAs 1-13 

would contact some portion of the Alaska coastline (LSs 64- 89, 91) (Appendix B, Table B-10, Figure 

B-7). 

The greatest percentage of trajectories that contact chum and pink salmon streams (<0.5-13%) occurs 

from LAs 12 and 13, which are in closer proximity to the coastline than the other LAs. Trajectories 

from LAs 10 and 11 would contact the greatest number (9, 8 respectively) of land segments with 

anadromous waters. It is estimated that 0–1,368 km of discontinuous shoreline could be contacted 

from LAs 1-13 (Table 5 in Section IV.D.2). 

The OSRA model estimates that a percent of trajectories from a very large oil spill starting at LA1-

LA13 would contact land segments containing important salmon spawning streams including the 

Kukpowruk River (LS 71; <0.5-2%), Kuk River (LS 64, <0.5-3%) and Kugrua River (LS 80, <0.5-

5%). 

The greatest percentage of trajectories that contact the coastline occurs at part of Kasegaluk Lagoon 

(LS 73-75), where <0.5-4% of the trajectories from LAs10 and 11 contact (Appendix B. Table B-17). 

The percentage of trajectories that contact Kasegaluk Lagoon is highest because the OSRA model’s 

launch area and the land segments are in close proximity to each other (Figures B-3, B-10). The LAs 

10 and 11 contact the greatest number of land segments with anadromous waters (Appendix C, 

Figures C-1, C-2, C-3, and C-5). 

Capelin and sand lance use beaches throughout the northeastern Chukchi Sea for spawning. 

Shoreline habitats are predominantly fine-to medium-grained sand beaches or mixed sand and gravel 

beaches between Point Hope (LS 64) and Skull Cliffs (LS 82) (USDOI, MMS, 2007a, Appendix ATable A.1-8). The OSRA model estimatess that <0.5-31% of the trajectories from LA1-LA13 would 

contact the United States Chukchi Coast (Grouped Land Segments 96) within 360 days during 

summer. LA10–LA13 has the highest percentage of trajectories that would contact this area 

(Appendix B, Table B-12). 

As the Chukchi Sea Sale 193 area is adjacent to the Beaufort Sea, the potential was estimated for a 

VLOS originating in the Chukchi Sea to contact the Beaufort Sea coast. The model estimates that 

between <0.5-20% of trajectories from LAs 1-13 contact the United States Beaufort Coast (GLS 97). 

Launch Areas 8 and 18, the most northeast launch areas, have the greatest percentage of trajectories 

that contact the Beaufort Sea land segments (Appendix B, Table B-12). This region is an important 

area for nearshore and anadromous fish migration and spawning. 

The Bering Sea lies south of Bering Strait. Many pelagic Bering Sea fish species inhabit the Bering 

Strait. The OSRA model estimates that <0.5-1% of the trajectories from LA9 would contact the 

western Bering Strait waters (BS 2). All other LAs are <0.5%. The OSRA model estimates that 

<0.5-12% of trajectories from LA1-LA13 would contact northeast Chukchi Sea BSs 17-22, which is 

habitat for epipelagic fish including sensitive life stages of Arctic cod (Appendix B, Table B-13; 

Figure B-1). 

Approximately 30% of oil spill during summer would remain (in the water column, in bottom 

sediments, ingested, beached) after 30 days. It is estimated that 33% of the oil spill would disperse 

and 37% would evaporate after 30 days in a summer spill (Appendix B, Table B-4). Through 360 

days after a very large oil spill in summer has frozen into the sea ice, it is estimated that between 

264,500 and 547,600 km2 of discontinuous ocean surface would be contacted by oil trajectories from 

LA1-LA13. The greatest discontinuous ocean surface area contacted would be generated by LA8; the 

least by LA9 (Appendix B, Table B-5). Ocean surface is an important habitat for epipelagic fish, eggs 

and larvae, including Arctic cod. 
BOEMRE Sale 193 Revised Draft SEIS 

172 CHAPTER IV. Environmental Consequences 

The OSRA trajectory model predicts movement of a surface slick, however, it does not assess 

subsurface transport of oil in water, tarballs washed onto beaches or the persistence of oil once it has 

reached spawning beaches, rearing areas, or spawning streams. The Sale 193 FEIS, Appendix A, 

Section B.3 discusses shoreline type and oil persistence. 

Russia Far East Coastline. The OSRA model estimates that <0.5-10% of the trajectories from LAs 

4,8,9, 10 would contact the Russia Far East coastline (Land Segments 8, 26-39), including Wrangel 

Island. The LA8 has the highest percentage of trajectories that would reach the mainland coast. The 

model estimates that <0.5% of the trajectories from all other LAs would contact the Russia Far East 

Coast or Wrangel Island. All the Russia Far East and Wrangel Island land segments with percentage 

of trajectories contacting (Land Segments 8, 26-39) have coastal rivers (Appendix C, Figure C-9). 

Winter 360 Days 

Alaska Coastline. The OSRA model estimates that <0.5-7 % of the trajectories from LA1-LA13 

would contact some portion of the Alaska coastline (Land Segments 64-65, 70-76, 78-79, 80-88) 

(Table B-10). 

The OSRA model estimates that a percent of trajectories from a very large oil spill starting at LA1-

LA13 would contact land segments containing important salmon spawning streams including the 

Kukpowruk River (LS 71; <0.5-3%), Kuk River (LS 64, <0.5-1%), Kugrua River (LS 80, <0.5-4%) 

and Kasegluk Lagoon (LS 73-74, <0.5-5%). 

The greatest percentage of trajectories that contacts the coastline occurs at part of Kasegaluk Lagoon 

(LS 73), where 5% of the trajectories from LA10 contact (Appendix B. Table B-17). The percentage 

of trajectories that contact Kasegaluk Lagoon is highest because the OSRA model’s launch area and 

the land segments are in close proximity to each other (Figures B-3, B-10). The LAs 10 and 11 

contact the greatest number of land segments with anadromous waters (8 and 7 respectively) 

(Appendix C, Figures C-1, C-2, C-3, and C-5). It is estimated the 0–1,287 km of discontinuous 

shoreline could be contacted from LAs 1–13 (Section IV.D.2, Table 5). 

There are many locations where oil may contaminate substrates in, estuarine, intertidal and freshwater 

habitats that are used for spawning and rearing fish populations such as pink salmon or capelin. The 

OSRA trajectory model estimates the trajectories of a surface oil spill; however, it does not assess 

subsurface transport of oil or the fate or persistence of oil once it has reached spawning beaches, 

rearing areas or spawning streams. The Sale 193 FEIS, Appendix A, Section B.3 discusses shoreline 

type and oil persistence. PAHs in weathered oil can persist in these spawning and rearing habitats for 

long periods and remain as a source of toxicity to sensitive lifestages. 

The OSRA model estimates that <0.5-10% of trajectories from LA1–LA13 would contact the United 

States Beaufort Sea Coast (GLS 97) (Appendix B, Table B-20). An oil spill that occurs in winter 

during broken-ice in fall or under-ice would melt out of the ice the following summer. It is estimated 

that approximately 48% of oil spilled during winter would remain (in the water column, in bottom 

sediments, ingested by organisms or beached) after 30 days after meltout. It is estimated that 15% of 

the winter oil spill would disperse and 37% would evaporate in 30 days after meltout (Appendix B, 

B-4). Through 360 days after a very large oil spill in winter, it is estimated that between 368,400 and 

507,200 km2 of discontinuous ocean surface would be contacted by oil trajectories from LA1-LA13. 

The greatest discontinuous ocean surface area contacted would be generated by LA4; the least by 

LA3 (Appendix B, Table B-6). Ocean surface and sea ice are important habitats for epipelagic fish, 

eggs and larvae, including sensitive life stages of Arctic cod. 

Russia Far East Coastline. The OSRA model estimates that <0.5-5% of the trajectories from LAs 

1,2,4,9,11 would contact the Russia Far East and Wrangel Island coastline (Land Segments 7,8, 25-

39). The LA9 has the highest per cent trajectories that would reach the Russia Far East mainland 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 173

coast. All the Russia Far East and Wrangel Island land segments that have some percentage of 

trajectories contacting (LSs 7,8, 25-39) have coastal rivers (Table B-10 and Figure C-9). 

Conclusion 

The level of effects of a very large oil spill in the Chukchi Sea on a fish species and its population 

would depend on many factors including: 

 life stage affected (egg, larvae, juvenile, adult) 

 species distribution and abundance (widespread, rare) 

 habitat dependence (ocean water column, sea surface, benthos, sea ice, estuarine, freshwater), 

 life history (anadromous, migratory, reproductive behaviors and cycle, longevity,etc) 

 extent and location of spawning areas in the estuarine or riverine systems 

 species exposure and sensitivity to oil and gas (toxicology, swimming ability) 

 effect on prey species 

 location of the oil spill (nearshore, further offshore), depth at which spill/blow-out occurs 

(seafloor, mid-column or surface), ratio of the mixture of oil and gas released, and time of 

year oil spill occurs 

Considering all these factors, some species or life stages of a species could be significantly affected 

(defined here as greater than 3 generations to return) at a population level. 

The species that would be particularly vulnerable to effects at individual and population levels 

include: pink and chum (eggs, larvae, juveniles); Arctic cod (eggs, larvae, juveniles, adults); sand 

lance (adults, eggs, larvae); capelin (adults, eggs, larvae); nearshore sculpin species (eggs, larvae, 

adult); nearshore flounders and plaice (eggs, larvae, adults); saffron cod (adults, eggs, juveniles); 

migratory least cisco (adults, juveniles); migratory Dolly Varden; migratory Arctic char; rainbow 

smelt; stickleback; and migratory whitefish. Other fish species that could be affected by a VLOS 

include: offshore sculpin, eelpouts, poachers; snailfish, alligatorfish, eelblennies, lamprey, herring, 

coho, sockeye and king salmon (Appendix C, Table C-1). 

The selection of Alternative III or Alternative IV (coastwise corridor deferrals), which includes parts 

of LAs 8-13, would reduce the chance of a very large spill from contacting important nearshore, 

estuarine, intertidal and riverine habitats. Direct effects of an oil spill would be reduced on 

anadromous, migratory, nearshore and estuarine fish, fish eggs, fish larvae and their populations. The 

larger deferral associated with Alternative III has greater potential to reduce nearshore impacts as 

compared with Alternative IV. 

IV.E.6. Essential Fish Habitat 

The Sale 193 FEIS and the Arctic Multi-Sale Draft EIS detail the effects of a large oil spill on EFH 

(USDOI, MMS, 2007a, 2008a) and are incorporated here by reference. 

Arctic Fishery Management Plan 

Two Fishery Management Plans apply to the area under consideration in this VLOS analysis: the 

Fishery Management Plan for Fish Resources of the Arctic Management Area (Arctic FMP) 

(NPFMC, 2009); and the Salmon Fishery Management Plan for Coastal Alaska (Salmon FMP) 

(NPFMC, 1990). The Arctic FMP was approved by the Secretary of Commerce in 2009. The Plan 

closed the U.S. Arctic area to commercial fishing. The Arctic FMP does not regulate subsistence or 

personal-use harvests of any fish, shellfish, birds, or marine mammals. 
BOEMRE Sale 193 Revised Draft SEIS 

174 CHAPTER IV. Environmental Consequences 

Based on the best scientific information available at the time of publication in 2009, the Arctic FMP 

identified three species as potential commercial target species and defines Essential Fish Habitat 

(EFH) for certain life stages of those species (Table 10). 

Table 10. Target species and life stage for which EFH has been described in the Arctic Fishery 

Management Plan for the Chukchi Sea. 

Arctic Fishery Management 

Plan: EFH Species 

Eggs 

EFH 

Larvae 

EFH 

Late 

Juvenile 

EFH 

Adults 

EFH 

Arctic cod (Boreogadus saida), X X 

saffron cod (Eleginus gracilis) X X 

opilio crab (Chionoecetes opilio) X X X 

Note: NMFS has not yet determined EFH for eggs and larvae of some species 

Text descriptions of the three target species identified in the Arctic Fishery Management Plan (Arctic 

cod, saffron cod, and opilio crab – adult and late juvenile for each species), as well as discussion of 

eight ecosystem component species, is provided in Section III.B.3. The EFH designations are shown 

in Appendix C, Figures C-6, C-7, and C-8. 

Arctic Cod 

Arctic cod is widely distributed in the U.S. Arctic in the pelagic, demersal and nearshore 

environments. The distribution and density of Arctic cod in the Chukchi and Beaufort Seas depends 

on the time of year and the stage of their life history. Norcross, et al. (2009) collected Arctic cod 

adults in bean trawls in the Chukchi Sea in summer 2004 at depths from 33 to 96 m. They also 

collected Arctic cod eggs, larvae and juveniles in plankton tows between 22 and 81 m; Arctic cod 

icthyoplankton was numerically the most dominant species. The absolute numbers of Arctic cod and 

their biomass is one of the highest of any finfish in the region (Logerwell, et al., 2010; Frost and 

Lowry, 1983). Results of a 2008 NOAA survey showed that Arctic cod were the most abundant finfish caught in a summer survey in the Central Beaufort Sea, both by weight and absolute numbers. 

Pelagic yearling and-older Arctic cod were most abundant at the continental shelf-break (100 m, 328 

ft); pelagic young-of-year were most commonly found inshore (Logerwell, et al., 2010). Frost and 

Lowry (1983) found smaller Arctic cod more often in water less than 100 m deep. Craig et al. (1982) 

found adult and juvenile Arctic cod in shallow nearshore waters (1-12 m) in the Beaufort Sea in 

winter and summer. Arctic cod were identified in high densities using acoustic measurements in the 

bottom of Barrow Canyon at depths of 200-250 m and along the steep canyon walls between 125-and 

200 m during a research cruise from early September to early October 2002 (Crawford, 2003). 

Arctic cod are associated with sea ice, using it at various life stages and seasons for shelter and as a 

forage habitat to feed on microorganisms on the underside of the ice. Amphipods are an important 

food source for Arctic cod on the underside of ice (Lonne and Gulliksen, 1989; Gradinger and Bluhm, 

2004). Rough, irregular textures of the underside-ice may provide preferred habitat for Arctic cod to 

avoid predators (Cross, 1982). Gradinger and Bluhm (2004) and Lonne and Gulliksen (1989) 

observed and photographed Arctic cod in summer months using ice crevices and cracks on the 

underside of textured ice floes for escape and shelter. 

Arctic cod also inhabit offshore and nearshore areas without ice during warmer times of year 

(Bradstreet and Cross, 1982; Bradstreet, 1982; Cross, 1982; Crawford and Jorgenson, 1993; 

Gradinger and Bluhm, 2004). Copepods and amphipods are common prey for Arctic cod in open 

water (Lowry and Frost, 1981; Benoit, et al. 2010). 

Arctic cod move and feed in different groupings – as dispersed individuals, in schools, and in huge 

shoals. These distribution patterns appear to be dependent on several interacting factors including 

season, presence or absence of ice, salinity, water temperature, surface wind, currents, and underside 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 175

texture of ice. Inter-annual variation also plays a role in the pattern of distributions. Welch, et al., 

(1993) documented huge, dense schools of Arctic cod pooling in deep basins in bays and inlets during 

open water in the Canadian Beaufort. Benoit, et al. (2010) found diel vertical migration of Arctic cod 

in the Eastern Canadian Beaufort was dependent on daylight length and presence of prey; by May, in 

prolonged daylight, vertical migration stopped and Arctic cod increased their schooling and feeding 

activity. 

Arctic cod migrate between offshore and onshore areas for seasonal spawning. They spawn under the 

ice during winter (Craig, et al, 1982; Craig, 1984; Bradstreet, et al., 1986). Arctic cod eggs and larvae 

are pelagic. Studies suggest that the egg incubation period is between 45-90 days (Sameto, 1984). 

Ringed seals, ribbon seals, spotted seals, beluga whales and several seabird species depend heavily on 

Arctic cod (Bradstreet, 1982; Bradstreet and Cross, 1982). Ice seals particularly depend upon Arctic 

cod in the winter (Bluhm and Gradinger, 2008; Dehn et al, 2007; Divoky, 1987; Frost and Lowry, 

1984; Welch et al, 1993). The biomass of Arctic cod (as both predator and prey) transfers energy 

throughout the food web (Crawford and Jorgenson, 1996; Bradstreet, et al., 1986). The abundance, 

wide distribution and the role in the food web of Arctic cod in the Beaufort Sea make this species 

very important in the ecosystem of the U.S. Arctic region. 

Saffron Cod 

Saffron cod occurs in the Chukchi Sea primarily in nearshore waters. Unlike Arctic cod, they do not 

specifically associate with ice. Saffron cod move seasonally from summertime feeding offshore to 

inshore for spawning. They enter coastal waters and tide-influenced riverine environments. Adults 

and juveniles forage on the epibenthos, opportunistically taking small crustaceans and fish (Froese 

and Pauly, 2010). Saffron cod are important in the diet of several seabirds (Piatt, et al., 1989), ringed 

seals, spotted seals and beluga whales (Frost and Lowry, 1984; Lowry, et al., 1980). 

Saffron cod have been captured in several surveys in the Chukchi Sea. Saffron cod was one of the ten 

most dominant fish captured by Alverson and Wilimovsky (1966) in their field investigation of the 

Chukchi Sea in 1959. Barber, et al. (1997) caught a high abundance of saffron cod in a demersal fish 

survey during August and September in 1990 and 1991 at sampling sites in the Chukchi Sea from 

Point Hope north. In 2004, saffron cod were collected in the Chukchi Sea in depths from 34-51 m as 

part of the Russian-American Long-term Census of the Arctic (RUSALCA) (Mecklenburg, et al., 

2007, Norcross, et al., 2010). These studies indicate that saffron cod are influcenced by water 

temperature, salinity and substrate type and are commonly found nearhore in warmer coastal waters. 

Pacific Salmon 

Pacific salmon (Oncorhynchus sp.) occur in the Beaufort Sea (Craig and Haldorson, 1986; Babaluk et 

al., 2000). Pink and chum salmon are the most common of the five species. In 1986, Craig and 

Haldorson summarized the distribution of Pacific salmon in Arctic Alaska: 

All five North American Pacific salmon species occur in small numbers in arctic waters, but only pink 

and chum salmon appear to have viable populations north of Point Hope, Alaska. Pink salmon are the 

most common species and constitute 85% of salmon caught in biological surveys. Pink salmon 

apparently have small runs in eight arctic drainages, while chum salmon may have small runs in six. 

Arctic pink salmon are smaller in size than individuals to the south but have similar meristic 

characteristics. It is likely that minimal use of freshwater habitats by pink and chum salmon has 

allowed them to colonize characteristically cold arctic rivers. 

Seventeen waterbodies (rivers, streams, lagoons) between Point Hope and the Alaska-Canada border 

were identified by Craig and Haldorson (1986) that apparently support small populations of pink and 

chum salmon. A few isolated spawning stocks of chum and pink salmon occur in the Beaufort Sea 

area, primarily the Sagavanirktok and Colville rivers. Records of individual king, coho and sockeye 

salmon were also identified in these waterbodies, which Craig and Haldorson attributed as probable 
BOEMRE Sale 193 Revised Draft SEIS 

176 CHAPTER IV. Environmental Consequences 

strays. Alaska Department of Fish and Game maintains the Anadromous Waters Catalog of Alaska 

for the waterbodies and species documented to date (ADFG, 2011). In 2000, Babaluk, et al. reported 

capture records of sockeye, pink, chum, and coho salmon in the western Canadian Arctic. Eight of the 

sockeye salmon caught in a Banks Island subsistence fishery were sexually mature. These records 

documented significant extensions of the previously known ranges for Pacific salmon in the Canadian 

Arctic. 

Substantial populations of salmon may have a difficult time establishing and persisting in the Arctic, 

most likely because of the limitation of freshwater spawning habitats which freeze over in winter and 

are not suitable for overwintering eggs and young (Craig, 1989; Fechhelm and Griffiths, 2001). 

In the marine environment, adult pink and chum salmon in Alaska seas can be found down to 200m 

(660 ft) depth. Moss, et al. (2009) trawled high densities of juvenile pink and chum salmon at or near 

the surface offshore in the Chukchi Sea in September, 2007. 

The quality of Essential Fish Habitat in the U.S. Arctic can be affected by coastal construction and 

runoff, vessel discharges, underwater noise, and ongoing oil and gas industry activities including 

petroleum spills. Climate change in the Arctic is a past and ongoing factor that affects the quality of 

EFH in several ways including: changes in seawater temperature and acidity; changes in extent and 

quality of sea ice habitat; and changes in freshwater discharge and nearshore salinities (Hopcroft, et 

al, 2006). These climate change factors could affect the range of EFH species, particularly Pacific 

salmon extending north and eastwards from the Bering and Chukchi seas and also affect the 

characteristics of freshwater waterbodies in winter. 

The effects of a very large oil spill in the Chukchi Sea as set out in this analysis would overlap for the 

most part with the discussion of the effects on fish in Section IV.E.5. The major factors that would 

cause negative effects on EFH are provided for each Phase and summarized in Table C-1 in Appendix 

C. 

Phase 1 (Initial Event) 

An explosion and fire in or near marine EFH could directly impact all life stages of Arctic cod (and in 

particular their eggs and larvae), all life stages of saffron cod, and adult and late juvenile salmon. 

Direct impacts of an explosion and fire are not expected to reach opilio crab EFH. 

Phase 2 (Offshore Oil) 

Released oil and gas could impact marine EFH at the surface and subsurface. 

Phase 3 (Onshore Contact) 

Oil could contact estuarine and freshwater EFH used for spawning, rearing and overwintering. 

Phase 4 (Spill Response and Cleanup) 

Response and cleanup efforts can impact EFH through vessel and drilling noise, seismic surveys for 

response activities, human activity in estuarine and freshwater EFH critical to spawning and rearing, 

and use of dispersants. 

Phased 5 (Long Term Recovery) 

The long-term presence of weathering oil (and possibly dispersant residue) in marine, estuarine and 

freshwater EFH can cause lasting adverse impacts. 

Appendix C, Figures C-1, C-6, C-7, and C-8 display the marine and freshwater EFH of these species. 

Table 11 presents a summary of effects on EFH of five phases of a very large oil spill described in the 

scenario in this document. The effects on a particular EFH species would vary depending on the 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 177

location of the spill (see OSRA analysis of EFH below) and the time of the year (reproductive cycle 

of the species). The table summarizes the possible effects over the full year of seasons. 

Table 11. The effects of a VLOS on EFH of Arctic cod, saffron cod, oplio crab and salmon in the Alaska 

Chukchi Sea. 

Phase Arctic Cod EFH Saffron Cod EFH Opilio Crab EFH Salmon EFH 

Phase 1 

Explosion 

and Fire 

All life stages, 

particularly eggs and 

larvae 

All life stages (EFH out of range of 

explosion) Adult and late juvenile 

Phase 2 

Offshore Spill 

All life stages, 

particularly eggs and 

larvae 

All life stages All life stages Adult and late juvenile 

Phase 3 

Onshore 

Contact 

(no onshore life stage) (no onshore life stage) (no onshore life stage) All life stages 

Phase 4 

Response, 

Clean-up 

All life stages, 

particularly eggs and 

larvae 

All life stages All life stages (minimal 

contact of EFH) All life stages 

Phase 5 

Long-term 

Recovery 

All life stages All life stages All life stages (minimal 

contact of EFH) All life stages 

Some EFH may be more vulnerable to a VLOS than others. Salmon freshwater and estuarine EFH 

used for spawning and rearing would be very vulnerable and have a very high potential for major 

effects, especially during spring and summer. Young salmon use estuaries and shallow coastal waters 

as rearing and feeding grounds and migration areas (Costello, Elliott, and Thiel, 2002; Elliott, 2002). 

Juvenile salmon EFH within the intertidal, estuarine, and nearshore zone in the Chukchi Sea would be 

among the areas considered more vulnerable to effects from oil-related activities. Juvenile salmon 

would also be vulnerable offshore in the pelagic EFH. Moss, et al. (2010) trawled high densities of 

juvenile pink and chum salmon in the offshore pelagic environment of the Chukchi Sea in September, 

2007. 

Arctic cod pelagic environment EFH would have a very high potential for major effects, particularly 

if a spill occurred in winter when adults were spawning under-ice and eggs and larvae developing. 

Arctic cod eggs float and therefore inhabit the microlayer of the sea where important important 

physical, chemical and biological processes take place. Individuals and schools of adult and juvenile 

Arctic cod in the epipelagic EFH would be vulnerable to contact with a spill. If the oil/gas blowout 

occurred at the seafloor, adult and juvenile Arctic cod in the demersal EFH could be affected 

immediately and in the longer term if oil were entrained in the water column or sediments. 

Saffron cod nearshore adult and juvenile EFH would have a very high potential for major impacts if a 

very large oil spill came towards shore and dispersants were used to break up and sink the oil 

particulate. 

Opilio crab EFH would be most affected by an offshore spill that drifted south and east, contacting 

egg, adult and late juvenile EFH in the region of Kotzebue Sound. 

Oil Spill Trajectory Analysis 

The following subsection describes the range estimated by the OSRA model expressed as percentage 

of trajectories that will contact some part of Essential Fish Habitat from LA1-LA13. 

Opilio Crab EFH 

Offshore Oil Spill and Onshore Contact (Phase 2-3). Summer 60 Days: The OSRA model 

estimates that <0.5 – >99.5% of the trajectories from LAs 4, 9 and 10 would contact Opilo Crab 

Essential Fish Habitat EFH. The model estimates that <0.5% of the trajectories from the other Launch 

Areas would contact Opilio Crab. LA 9 overlaps a portion of opilio crab EFH, and therefore 

percentage of trajectories is up to >99.5% (Table 12; Appendix C, Figure C-8). 
BOEMRE Sale 193 Revised Draft SEIS 

178 CHAPTER IV. Environmental Consequences 

Summer or Winter 360 Days. The OSRA model estimates that <0.5 – >99.5 % of the trajectories 

from LAs 4, 9 and 10 would contact Opilo Crab Essential Fish Habitat (EFH) . The model estimates 

that <0.5% of the trajectories from the other LAs would contact Opilio Crab EFH within 360 days 

during summer or winter. LA9 overlaps a portion of opilio EFH and, therefore, the percentage of 

trajectories is up to >99.5% (Table 12). 

Table 12. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting from a given 

location that will contact a portion of Opilio Crab EFH within 60 or 360 days. 

Season / 

Analysis 

Period 

Percentage from LA4* Percentage from LA9 Percentage from LA10 

Summer 

60 Days <0.5 – 1 <0.5 - > 99.5 <0.5 – 2 

Summer 

360 Days <0.5 – 1 <0.5 - > 99.5 <0.5 – 2 

Winter 

360 Days <0.5 – 1 <0.5 - > 99.5 <0.5 – 1 

* All other LAs over the three time periods have <0.5% of trajectories contacting. Launch Area 9 overlaps with opilio EFH, and

therefore is up to >99.5%. 

Saffron Cod EFH 

Summer 60 Days. The OSRA model estimates that <0.5 – >99.5% of the trajectories from LAs 1-13 

would contact Saffron Cod Essential Fish Habitat (EFH). The LAs 9, 12 and 13 overlap a portion of 

saffron cod EFH, and therefore is up to >99.5% (Table 13, below; Appendix C, Figure C-7). 

Summer and Winter 360 Days. The OSRA model estimates that <0.5 – >99.5% of the trajectories 

from LAs 1-13 would contact Saffron Cod Essential Fish Habitat (EFH) within 360 days during 

summer. The LAs 9, 12 and 13 overlap a portion of saffron cod EFH, and therefore is >99.5% 

(Table 13; Appendix C, Figure C-7). 

Table 13. Range of fractions of a VLOS (expressed as percentages) starting from a given location that 

will contact a portion of Saffron Cod EFH within 60 or 360 days. 

Season / Analysis 

Period LAs 1-5 (%) LAs 6,7,8 (%) LAs 10,11 (%) LAs 9, 12,13 (%) 

Summer 60 Days 

 <0.5 – 2 <0.5 – 4 <0.5 – 9 <0.5 – >99.5 

Summer 360 Days 

 <0.5 – 3 <0.5 – 8 <0.5 – 9 <0.5 – >99.5 

Winter 360 Days <0.5 – 5 <0.5 – 4 <0.5 – 8 <0.5 – >99.5 

*LAs 9, 12 and 13 overlap with saffron cod EFH, and therefore the results are up to >99.5%. 

Salmon-Marine EFH and Arctic Cod EFH 

Summer within 60 Days, Summer within 360 Days, and Winter within 360 Days. The OSRA 

model estimates that up to >99.5 % of the trajectories from LA1-LA13 would contact Arctic cod and 

saffron cod Essential Fish Habitat (EFH) within 60 days and 360 days during summer and 360 days 

during winter. All LAs (1-13) overlap Arctic cod and salmon (marine) EFH, and therefore is up to 

>99.5% (Table 14, below; Appendix C, Figures C-1 and C-6). 
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CHAPTER IV. Environmental Consequences 179

Table 14. Range of fractions of a VLOS (expressed as percentages) starting from a given location that 

will contact a portion of Arctic cod or salmon (marine) EFH within 60 or 360 days. 

Launch Areas* Summer 60 Days 

Percent (%) 

Summer 360 Days 

Percent (%) 

Winter 360 Days 

Percent (%) 

1-13 <0.5 – >99.5 <0.5 – >99.5 <0.5 – >99.5 

LAs 1-13 overlap salmon (marine) and actic cod Essential Fish Habitat; and therefore percentages are 

up to >99.5%. 

Shoreline Habitat Contacted 

It is estimated that between 0 and 1,368 km of discontinuous shoreline length could be contacted by 

oil trajectories in the Chukchi Sea depending on the location of a very large oil spill, the season and 

the number of days after the spill release. The type of shoreline that would be contacted along the 

Chukchi coast includes salt and brackish water marshes, mixed sand and gravel beaches and fine to 

medium sand beaches. These types of shorelines are considered "most sensitive" to oil contact and oil 

persistence in the Environmental Sensitivity Index (NOAA-ORR, 2011). 

Conclusion 

The level of effects of a very large oil spill in the Chukchi Sea on Essential Fish Habitat would 

depend on several factors including: 

 location of the oil spill (nearshore, further offshore);depth at which spill/blowout occurs 

(seafloor, mid-column or surface), ratio of the mixture of oil and gas released, and time of 

year oil spill occurs 

 extent and location of spawning areas in the estuarine or riverine systems 

 species abundance and distribution (widespread, rare) 

 the species and the sensitivity of their life stage affected (egg, larvae, juvenile, adult) 

 life history and reproductive cycle 

Considering these factors, EFH of some species’ life stages could be significantly impacted. 

The EFH of the following species and life stages would be particularly vulnerable: Arctic cod (eggs, 

larvae, juveniles, adults); pink and chum salmon (eggs, larvae, juveniles, adults); and saffron cod 

(eggs, juveniles, adults). Opilio crab (eggs, juveniles, adults) would be less vulnerable due to the 

location of the EFH on the southern edge of the possible oil spill launch areas. Coho salmon 

(juveniles, adults), sockeye salmon (juveniles, adults) and king salmon (juveniles and adults) EFH 

would be less vulnerable to a very large oil spill in the Chukchi Sea due to the distribution of the 

species at its far northern range (Appendix C, Table C-1). 

Of the eight EFH ecosystem component species listed in the Arctic Fishery Management Plan, 6 

could be affected by a very large oil spill in the Chukchi Sea. Yellowfin sole, Alaska plaice, starry 

flounder and Bering flounder are widely distributed, however, they are relatively poor benthic 

swimmers and would be less able to escape oil or gas effects. Capelin and rainbow smelt are also 

widespread but depend on nearshore habitat for reproduction and therefore those life stages could be 

affected. 

The selection of Alternative III or IV (coastwise corridor deferrals), which include parts of LAs 8-13, 

would reduce the chance of a very large spill contacting important nearshore, estuarine, intertidal and 

riverine habitats used by salmon, saffron cod and Arctic cod. Direct effects of an oil spill would be 

reduced on anadromous, migratory, nearshore and estuarine fish and their populations. The larger 
BOEMRE Sale 193 Revised Draft SEIS 

180 CHAPTER IV. Environmental Consequences 

deferral associated with Alternative III has greater potential to reduce nearshore impacts as compared 

with Alternative IV. 

IV.E.7. Cetaceans 

A VLOS (very large oil spill) originating in the Chukchi Sea Planning Area could affect cetaceans 

(i.e. whales, dolphins, and porpoises) in a variety of ways. While all cetacean species that use the 

Chukchi Sea do so at least seasonally, and perhaps year round, distribution and habitat selection are 

often species specific, which may put some species at greater risk of contact (depending on the 

location, timing, and season) with oil from a VLOS. The biology and population status of each 

cetacean species is described in detail in Sections III.B.4.a. and III.B.6.b. of the Sale 193 FEIS 

(incorporated by reference) and is further supplemented in Chapter III of this SEIS. Therefore, 

biology and population status are not discussed here. 

Effects of a VLOS on each cetacean species are discussed below for each of the five phases of the 

hypothetical scenario. Phase 2 (Offshore Oil) has the greatest potential for effects. Three ESA listed 

endangered whales (bowhead, fin and humpback whales), five unlisted species of cetaceans (gray, 

minke, beluga, and killer whales and harbor porpoise) and their associated habitats occur in the sale 

area. Refer to Section IV.C.1.f(1)(g) (pp. IV-114 to IV-122) of the Sale 193 FEIS for detailed 

discussion of the potential effects of oil on endangered whales and Section IV.C.1.h(4) (pp. IV-157-

IV-161 for unlisted species of cetaceans). During the response to a VLOS, the response contractor(s) 

would be expected to work with NOAA/NMFS and State officials on marine mammal management 

activities. In an actual spill, the two aforementioned groups most likely would have a presence at the 

Incident Command Post to review and approve proposed activities and monitor their impact on 

marine mammals. As a member of the team, NOAA/NMFS personnel would be largely responsible 

for providing critical information affecting response activities to protect marine mammals. Specific 

marine mammal protection activities would be employed as the situation requires and would be 

modified as needed to meet the current needs. In all cases long-term recovery to pre-spill abundance, 

distribution, and productivity is likely, but recovery period would be variable and require access to 

unaffected/restored habitat during the period of recovery. 

Phase 1 - Initial Event 

Phase 1 of the hypothetical VLOS scenario encompasses a well-control incident resulting in a 

blowout and its immediate consequences. For all species considered, this Phase would cause only 

negligible, temporary, non-lethal adverse effects on cetaceans, with the exception of individuals 

experiencing Permant Threshold Shift hearing injuries or injury or mortality to individuals within a 

very small radius around an underwater blowout. This phase does not consider the release of oil or the 

effects of supporting aircraft or vessels; these will be discussed in Phase 2 and Phase 4 respectively. 

Potential IPFs (impact producing factors) and associated effects on cetaceans from Phase 1 include 

the following: 

Explosion. Natural gas released during a blowout could ignite, causing an explosion. An explosion 

from the ocean bottom or within the water column would create a single pulse sound event that could 

injure cetacean hearing, depending on sound levels. It is possible that any individual cetaceans within 

the vicinity could experience Temporary Threshold Shift (TTP) or Permanent Threshold Shift (PTS). 

PTS would be considered a permanent injury, decreasing the ability of an individual to function in 

their environment and, ultimately, leading to declining health and potential mortality. However, most 

cetaceans tend to avoid active drilling rigs and associated operations and, therefore, it is unlikely that 

individuals would be close enough to an explosion to experience TTS or PTS. However, those 

cetaceans which may be present at greater distances from the drilling vessel could still experience 

some level of adverse impacts. The explosion could cause non-lethal and temporary effects in the 

form of a startle response. Startle events (McCauley, 2000) may cause cetaceans to display shortterm avoidance activity such as change of swim direction and/or speed that may be accompanied by 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 181

short-term endocrine response. Injury or mortality could occur in individuals within a very small 

radius of an underwater blowout event. 

Fire. A blowout could result in a fire. The fire would remain localized as would potential 

suppression response activities once on site. Negligible effects are likely as cetaceans would likely 

remain at avoidance distances from the active drilling/blowout and fire response noise and activity. A 

rig fire resulting from an accidental event poses no threat to cetaceans because cetaceans would be 

expected to be beyond the avoidance distances from active rig noise if a fire event occurred, and 

would continue to avoid the immediate area of a rig fire in response to emergency suppression and 

fire response vessel and aircraft activities. 

Re-distribution of Sediment. A blowout could re-distribute discharged drilling muds into the water 

column to be suspended there and/or to be deposited on the seafloor in a pattern reflecting currents, 

temperature, and other oceanographic factors. Localization of sediment re-distribution is negligible 

relative to the amount of sea floor available to cetaceans and the food sources that may be found or 

produced on or near the sea floor in the Chukchi Sea. 

Sinking of Rig. The localized nature of a rig that sinks is negligible to cetaceans in terms of a hazard 

to movement or accidental contact with hazardous materials or structures associated with a sunken 

rig. Petroleum or other chemical compounds may be introduced to the marine environment from the 

damaged rig. These compounds, with the exception of a VLOS, would be limited in quantity, rapidly 

diluted (if soluble), float, sink and be deposited on the sea floor or recovered and disposed of. 

Depending on the nature of the compound, localized fate of the compound, and capability for clean 

up of surface or sea bottom materials, a negligible impact to cetaceans is likely. Most cetaceans 

would remain at avoidance distances away from the local rig site operations and noise when received 

sounds are strong, but not when sounds are barely detectable (Richardson, et al., 1995:284-289). 

Phase 2 - Offshore Spill 

Phase 2 of the scenario focuses on the continuing release of oil into offshore and nearshore waters. Of 

all the phases, the Offshore Spill has the greatest potential to adversely affect cetaceans and their 

habitats. More severe impacts could also occur, and in some cases cetaceans may require three or 

more generations coincident with restored and unaffected habitat to restore distribution and 

populations. 

Below are potential IPFs associated with Phase 2 that have the potential to affect cetaceans. 

Contact with Oil. Cetaceans could experience adverse effects from contact with hydrocarbons, 

including: 

 Inhalation of liquid and gaseous toxic components of crude oil and gas. 

 Ingestion of oil and/or contaminated prey. 

 Fouling of baleen (bowhead, fin, humpback, minke, and gray whales). 

 Oiling of skin, eyes, and conjunctive membranes causing corneal ulcers, conjunctivitis, 

swollen nictitating membranes and abrasions. 

Contamination. Impacts may include ingestion of contaminated prey (prey that have consumed or 

absorbed oil fractions that remain in their bodies) and/or reduction of food source. Pollution 

stemming from an oil spill may contaminate environmental resources, substrates (water, air, and 

sediments), habitat, and/or food sources. Contamination may also cause mortality and or 

contamination of food sources during the long term (multi year) and short term (current year 

production, ice and oceanographic cycles). 

Loss of Access (Disturbance and Displacement). Cetaceans may be displaced from feeding areas, 

migration routes, and critical life function habitats. The latter include areas critical to the 
BOEMRE Sale 193 Revised Draft SEIS 

182 CHAPTER IV. Environmental Consequences 

maintenance of individuals and populations, including birthing, feeding, breeding, migration, 

rearing/nursing, and resting. Moreover, whales may lose access to feeding areas or to areas where 

prey concentrate due to avoidance of spilled oil—displacement, or movement away. For further 

discussion see the Sale 193 FEIS (USDOI, MMS, 2007a). 

This analysis will address each of these potential effects for each species of cetaceans using the 

Chukchi Sea. 

Bowhead Whale 

Bowhead whales migrate in spring through the Chukchi Sea to summer feeding areas and in fall to the 

Bering Sea wintering area with a relatively small number possibly staying in the Chukchi Sea 

throughout the summer (Moore and Reeves 1993, Brueggeman 1992). The spring migration is well 

documented with whales following the open leads in the sea ice running parallel to the Chukchi Sea 

coastline before veering eastward through the Beaufort Sea (Braham et al. 1984; Moore and Reeves 

1993). Most whales pass through the Chukchi Sea by late June as documented from traditional 

environmental knowledge (TEK) and research (Huntington and Quakenbush 2009). TEK indicates 

that the spring migration occurs earlier than in the past (Huntington and Quakenbush 2009). 

Since 2006, the fall migration has been more specifically documented by tracking 20 satellite-tagged 

bowhead whales from Barrow through the Chukchi Sea into the Bering Sea (Quakenbush et al., 

2009). Most of the whales migrated westward above 71o N latitude from Barrow to Wrangel Island 

and then down the Chukotka Coast before entering the Bering Sea. Some whales apparently migrated 

in a more southwesterly direction from Barrow to the Chukotka Coast, crossing through or near the 

survey areas (Quakenbush, et al. 2010b). Aerial and vessel surveys conducted in the Chukchi Sea in 

the 1980s and 1990s also suggest a southwesterly route based on scattered bowhead whale sighting 

locations (Ljungblad et al. 1984, 1986, 1987; Brueggeman et al., 1991, 1992; and others). Recent 

acoustic studies conducted from 2007 to 2009 indicated calling bowheads migrated across the 

Chukchi Sea in both a westerly direction following the 71° N latitude and a less defined route after 

leaving the Barrow area (Hannay et al 2009; Martin et al. 2008). Eskimo whalers report whales travel 

westward and later during light ice years and southwestward during heavy ice years (Figure 26 in 

Huntington and Quakenbush, 2009). These collective results suggest the location of the fall migration 

route may comprise a variety of paths dispersed widely across the Chukchi Sea. The fall migration of 

bowheads through the Chukchi Sea generally begins in early October and ends sometime in 

December, as sea ice advances into the Bering Sea. 

Contact with Oil. Bowheads are the most likely of the ESA listed baleen whales to experience 

adverse effects of a VLOS as described in the hypothetical scenario. They commonly occur in areas 

of the Chukchi and Beaufort seas (Harwood et al. 2010) when and where spills could occur during 

spring and fall migrations, feeding, calving, resting and limited breeding and could come into direct 

contact with spilled oil during the open water season (Quakenbush, 2010a) as well as during periods 

when various amounts of ice cover are present. Acoustic studies indicate some bowheads may 

inhabit the Chukchi Sea year-round; however, most pass through in the spring and fall during 

migration between the Bering Sea and Canadian Beaufort Sea (Moore et al. 2010). Calling bowheads 

have been recorded in the Chukchi Sea during summer and winter (Berchok et al. 2009, Funk et al., 

2010). A recent acoustic study monitoring for bowhead calls in the western Beaufort Sea and 

northeastern Chukchi Sea between October and May reported calling bowhead whales during 

October and November but not again until late March (Moore et al., 2010), indicating most bowheads 

do not overwinter in this region. The presence (or absence) of bowhead whales in and adjacent to the 

lease area from December through March has not been confirmed through acoustic or other means of 

monitoring or observation. Bowheads may be present in this area during this time but would not be 

particularly vulnerable to adverse impacts as compared with any other time of year. Nothing 

indicates that the potential for adverse impacts in this case would differ as between the action 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 183

alternatives. Additional information on bowhead presence in the western Beaufort Sea and 

northeastern Chukchi Sea from December through March is not essential to a reasoned choice among 

lease sale alternatives. 

There are few post-spill studies with sufficient details to reach firm conclusions about the effects, 

especially the long-term effects, of an oil spill on free-ranging populations of marine mammals. 

Given the very low probability of a VLOS event occurring and affecting large numbers of cetaceans, 

and the fact that the overall potential for impacts would vary only slightly under each action 

alternative, additional studies on the potential effects of oil exposure on free-ranging marine mammal 

populations is not essential to a reasoned choice among lease sale alternatives. Nonetheless, 

evaluation of available science permits the application of scientific judgment regarding potential 

effects. 

Available evidence suggests that mammalian species vary in their vulnerability to short-term damage 

from surface contact with oil and ingestion. While differences in acute vulnerability to oil 

contamination do exist due to ecological (for example, nearshore versus offshore habitat) and 

physiological reasons (for example, dependence on fur rather than on blubber for thermal protection), 

species also vary greatly in the amount of information that has been collected about them and about 

their potential oil vulnerability. These facts are linked, because the most vulnerable species have 

received the most focused studies. However, it also is the case that it is more difficult to obtain 

detailed information on the health, development, reproduction and survival of large cetaceans than on 

some other marine mammals. The logistical, physical capability, technology and cost limitations that 

would provide data collection and evaluation of the potential for long-term sublethal effects on large 

cetaceans are prohibitive at this time. Thus, impacts such as the sublethal impacts observed on sea 

otters (for example, reduced body condition, abnormal health, etc.) (see Rotterman and Monnett, 

2002, and references cited therein) after the Exxon Valdez oil spill are unlikely to be documented in 

cetaceans because the data needed to determine whether or not such impacts exist cannot be 

effectively collected. On the other hand, it may be that ecological and physiological characteristics 

specific to large cetaceans serve to buffer them from many of those same types of impacts. Unless 

impacts are large and whales die and are necropsied, most effects must be measurable primarily using 

tools of observation. Unless baseline data are exceptionally good, determination of an effect is only 

possible if the effect is dramatic. With whales, even when unusual changes in abundance occur 

following an event such as the Exxon Valdez oil spill (as with the disappearance of relatively large 

numbers of killer whales from the AB pod in Prince William Sound) (see Dahlheim and Matkin, 1994 

and the following discussion), interpretation of the data is uncertain or is often controversial due to 

the lack of supporting data, such as oiled bodies or observations of individuals in distress (and, in that 

case, the existence of a viable alternate explanation of the probable mortality). Thus, predicting 

potential long-term sublethal (for example, reduced body condition, poorer health, reduced 

productivity, later sexual maturation, longer reproductive interval, or longer dependency periods) or 

lethal effects on cetaceans from a VLOS is difficult. 

The greatest threat to large cetaceans is likely from the inhalation of the volatile toxic hydrocarbon 

fractions of fresh oil. Prolonged inhalation of volatile toxic hydrocarbon fractions of fresh oil induces 

severe adverse effects. Inhalation of volatile hydrocarbon fractions of fresh crude oil can damage the 

respiratory system (Hansen, 1985; Neff, 1990), cause neurological disorders or liver damage (Geraci 

and St. Aubin, 1982), have anaesthetic effects (Neff, 1990) and, if accompanied by excessive 

adrenalin release, cause sudden death (Geraci, 1988). Bowhead mortality could occur if they surfaced 

and breathed repeatedly in the fresh oil of a VLOS and freshly evaporated toxic aromatic hydrocarbon 

compound vapors occur at the sea surface. Effects upon bowhead whales range from negligible to 

acute toxic poisoning resulting in endocrine system and organ impairment or death. Lighter-than-air 

aromatic vapors dissipate rapidly into the atmosphere. Heavier than air components may linger near 

the surface during periods of calm winds, but otherwise atmospheric mixing allows these vapors to 
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184 CHAPTER IV. Environmental Consequences 

dissipate rapidly. The dissipation of volatile components varies with temperature, wind, and 

characteristics of encapsulation of oil components into ice and the ice conditions that determine rate 

of release. Oil trapped in the mixed and fractured ice and interspersed open water characteristic of 

polynya systems allows for varying amounts of toxic aromatic components to evaporate and dissipate 

during the winter period before migrating bowheads arrive in the Chukchi Sea spring lead system. 

Spilled oil that has aged to the point where initial evaporation of light toxic fumes is no longer present 

reduces the risk of prolonged inhalation exposure to toxic fumes. There may be cases of inhalation of 

small amounts of crude oil that might adhere to skin around the blowhole. 

Two situations of higher risk to bowhead whales could occur. These exceptions involve prolonged 

exposure of migrating or feeding bowheads to inhalation of volatile toxic components of fresh oil in 

the Chukchi Sea spring lead system during migration of the majority of the Western Arctic Bowhead 

population through the lead system and when feeding aggregations (such as those that occur northeast 

of Barrow in the fall) are similarly exposed to toxic fumes from a very large oil spill. During spring 

migration, females with newborn calves, whose movement is somewhat constrained by the polynya 

system, may endure exposure to some released toxic fumes from fresh oil trapped in ice since October 

31 of the previous year to as late as January 4. It is likely that a major portion of the toxic fumes 

would have evaporated over the winter through the active cracks, ice movement, and movement 

through brine channels in the polynya ice cover when temperatures are at or above critical 

temperature (NOCOR, 1975; Fingas and Hollebone, 2003). Toxic fumes are likely to have dispersed 

in the atmosphere by May and early June, when most females with calves migrate through the 

Chukchi spring lead system, and would not pose a prolonged toxic exposure. If high toxic vapor 

levels should occur and prolonged exposure of females with calves occurs, mortality could occur and 

volatile toxic fractions may be particularly toxic to newborn calves that must take more frequent 

breaths and spend more time at the surface than their mothers. As unlikely as it may seem, such 

exposure is not beyond the range of possibilities, and depending on the timing and numbers of 

females with calves contacting toxic vapors of fresh oil, mortality of a large portion of a year’s cohort 

of calves and perhaps some individual females and other age and sex classes could occur. Options to 

migrate through adjacent ice covered waters are fewer for newborns as compared to older animals 

that may or may not be able to detect the spill and exercise alternate migration routing options. These 

adults may travel through considerable areas of up to 100% ice cover, which appears not to limit 

bowhead distribution (Quakenbush et al., 2010b). There are anatomical data and observations that 

bowhead whales have the olfactory organs (Thewissen, et al., 2010) and ability to detect smoke from 

dumps and potentially spilled oil such that they may modify movements to avoid a large or very large 

oil spill. Spring migration could be delayed or deflected around spilled oil (females with calves, and 

other age and sex classes, may attempt to detour through adjacent ice covered waters around the spill 

and associated toxic fumes). Newborn calves—having short breathing intervals and less capability to 

break breathing spaces in ice cover while following their mothers—risk separation, abandonment or 

mortality. A portion of an annual cohort of newborn calves and some older individuals could 

potentially experience such mortality under those conditions. Depending on numbers of calves that 

might die, loss of an annual cohort would be reflected in an immediate reduction in population that 

may take several years to replace. Also, there may be in the future reduced contribution of the 

individual females and their progeny to recruitment into the breeding female population (these 

females would have become sexually mature in 18-20 years). The loss of the lifetime reproductive 

contribution of these females to the population could depress population rate of increase slightly for 

several decades. 

Another circumstance whereby adverse effects could be experienced by large numbers of bowheads is 

when one or more large aggregations of bowheads contact a fresh oil spill (with high concentrations 

of toxic aromatic vapors) during the open water season. Aggregations of between 50 and 100 

bowheads have been observed in some, but not all years, during BOEMRE and NMFS aerial surveys 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 185

and particularly in the feeding area identified northeast of Barrow under bowhead feeding studies 

(Moore, George, Sheffield, et al., 2010). 

Spilled oil appears to have limited impact on cetacean skin. In a study on nonbaleen whales and other 

cetaceans, Harvey and Dahlheim (1994) observed 80 Dall’s porpoises, 18 killer whales, and 2 harbor 

porpoises in oil on the water’s surface from the EVOS. They observed groups of Dall’s porpoises on 

21 occasions in areas with light sheen, several occasions in areas with moderate-to-heavy surface oil, 

once in no oil, and once when they did not record the amount of oil. Thirteen of the animals were 

close enough to determine if oil was present on their skin. They confirmed that 12 animals in light 

sheen or moderate-to-heavy oil did not have oil on their skin. The 18 killer whales and 2 harbor 

porpoises were in oil but had none on their skin. None of the cetaceans appeared to alter their 

behaviors when in areas where oil was present. The authors concluded their observations were 

consistent with other reports of cetaceans behaving normally when oil is present. Some temporary 

irritation or permanent damage to conjunctive tissues, mucous membranes, around the eyes, 

abrasions, conjunctivitis and swollen nictitating membranes could occur (Geraci and Smith, 1976b; 

Davis, Schafer, and Bell, 1960). 

Ingestion. Ingestion of dissolved, suspended, or floating oil components while feeding on or near the 

surface could occur during the open water period, or if bowheads come into contact with oil in/on the 

seafloor during near-bottom feeding. Oil components or chemical oil dispersant derived compounds 

could be consumed by bowheads feeding on prey anywhere in contaminated water column layers to 

the sea floor. Bowheads may ingest oil fractions that sink to (and may persist in) the sea floor 

sediments that are disturbed when near-bottom feeding. Ingestion of petroleum hydrocarbons can 

lead to subtle and progressive organ damage or to rapid death in mammals. Many polycyclic 

aromatic hydrocarbons are teratogenic and embryotoxic in at least some mammals (Khan et al., 

1987). Maternal exposure to crude oil during pregnancy may negatively impact the birth weight of 

young. While the potential effects on bowhead to exposure to polycyclic aromative hydrocarbons 

(PAHs) through their food are largely unknown, the very low probability of a VLOS event occurring 

and leading to widespread ingestion of PAHs, and the fact that the potential for such impacts would 

vary only slightly under each action alternative, means that additional studies of this potential are not 

essential to a reasoned choice among lease sale alternatives. That said, there currently exists 

information with pertinence to this issue. Oil ingestion can decrease food assimilation of prey eaten 

(for example, St. Aubin, 1988). Decreased food assimilation could be particularly important in very 

young animals, those that seasonally feed, and those that need to put on high levels of fat to survive 

their environment. Because of their extreme longevity, bowheads are vulnerable to incremental longterm accumulation of pollutants. With increasing development within their range and long-distance 

transport of other pollutants, individual bowheads may experience multiple large and small polluting 

events within their lifetime. Tissue studies by Geraci and St. Aubin (1990) revealed low levels of 

naphthalene in the livers and blubber of baleen whales. This result suggests that prey have low 

concentrations in their tissues, or that baleen whales may be able to metabolize and excrete certain 

petroleum hydrocarbons. 

Temporary baleen fouling could also occur, but the light weight of the spilled oil probable for the 

Chukchi Sea is not as likely to adhere to and impair the hydraulic function of the baleen fibers as 

would more viscous, weathered or emulsified oil. Lighter oil should result in less interference with 

feeding efficiency. In a study in which baleen from fin, sei, humpback, and gray whales was oiled, 

Geraci (1988) found that 70% of the oil adhering to baleen plates was lost within 30 minutes (Geraci, 

1990) and in 8 of 11 trials, more than 95% of the oil was cleared after 24 hours. The study could not 

detect any change in resistance to water flowing through baleen after 24 hours. The baleen from these 

whales is shorter, and in some cases finer, than that of bowhead whales, whose longer baleen has 

many hairlike filaments. Lambertsen et al. (2005, p. 350) concluded that results of their studies 

indicate that Geraci’s analysis of physiologic effects of oiling on mysticete baleen “considered baleen 
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186 CHAPTER IV. Environmental Consequences 

function to be powered solely by hydraulic pressure,” a perspective they characterized as a “gross 

oversimplification of the relevant physiology.” A reduction in food caught in the baleen could have 

an adverse affect on the body condition and health of affected whales. If such an effect lasted for 30 

days, as suggested by the experiments of Braithwaite (1983), this could potentially be an effect that 

lasted a substantial proportion of the period that bowheads spend on the summer feeding grounds. 

Repeated baleen fouling over a long time, however, might also reduce food intake and blubber 

deposition, which could harm the bowheads. Geraci (1990) also pointed out the greatest potential for 

adverse effects on bowheads would be if spilled oil occurred in the spring lead system. 

Contamination and Reduction of Food Sources. Data from a recent study (Duesterloh, Short, and 

Barron, 2002) indicated that aqueous polyaromatic compounds (PACs) dissolved from weathered 

Alaska North Slope crude oil are phototoxic to subarctic marine copepods at PAC concentrations that 

would likely result from an oil spill and at UV levels that are encountered in nature. Calanus 

marshallae exposed to UV in natural sunlight and low doses (~2μg of total PAC per liter of the water 

soluble fraction of weathered North Slope crude oil for 24 hours) showed an 80-100% morbidity and 

mortality as compared to less than 10% with exposure to the oil-only or sun-light only treatments. 

One hundred percent mortality occurred in Metridia okhotensis with the oil and UV treatment, while 

only 5% mortality occurred with the oil treatment alone. Duesterloh, Short, and Barron (2002) 

reported that phototoxic concentrations to some copepod species were lower by a factor of 23 to 

>4,000 than the lethal concentrations of total PAC alone (0.05-9.4 mg/L). 

This research also indicated that copepods may passively accumulate PACs from water and could 

thereby serve as a conduit for the transfer of PAC to higher trophic level consumers. 

Bioaccumulation factors were ~2,000 for M. okhotensis and about ~8,000 for C. marshallae. Calanus 

and Neocalanus copepods have relatively higher bioaccumulation than many other species of 

copepods because of their characteristically high lipid content. The authors concluded that phototoxic 

effects on copepods could conceivably cause ecosystem disruptions that have not been accounted for 

in traditional oil spill damage assessments. Particularly in nearshore habitats where vertical migration 

of copepods is inhibited due to shallow depths and geographical enclosure, phototoxicity could cause 

mass mortality in the local plankton population (Duesterloh, Short, and Barron, 2002, p. 3959). 

The potential effects on bowheads of exposure to PACs through their food are unknown. Bowheads 

may swallow some oil-contaminated prey and ingest some dissolved or floating oil fractions 

incidental to food intake, but it likely would be only a small part of their food. It is not known if 

bowheads would leave a feeding area where prey was abundant following a VLOS. Some 

zooplankton (eaten by bowheads) consume contaminated oil particles contained in their prey. Tissue 

studies by Geraci and St. Aubin (1990) revealed low levels of naphthalene in the livers and blubber of 

baleen whales. This result suggests that prey have low concentrations in their tissues, or that baleen 

whales may be able to metabolize and excrete certain petroleum hydrocarbons. The probability that a 

VLOS would occur and affect bowhead whales through exposure to PACs or displacement from 

productive feeding areas is very small, and would vary only slightly under each action alternative. 

Additonal information on these subjects is therefore not essential for a reasoned choice among lease 

sale alternatives. 

A VLOS probably would not permanently affect zooplankton populations, the bowhead’s major food 

source, and major effects are most likely to occur nearshore (Richardson et al., 1987, as cited in 

Bratton et al., 1993). The amount of zooplankton lost in a very large oil spill could be very small 

compared to what is available on the whales’ summer-feeding grounds (Bratton et al., 1993). A 

VLOS, depending on the timing and location relative to the distribution and aggregations of 

zooplankton could reduce feeding opportunities for a majority of the bowhead population during that 

year. The significance of the loss of that opportunity to bowhead health is dependent upon major 

feeding opportunities bowheads may find later in the year to meet annual energy demands. Fate, 

recovery, and availability of zooplankton populations to bowheads in similar quantities and locations 
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CHAPTER IV. Environmental Consequences 187

as pre-spill conditions in the Chukchi and western Beaufort seas in subsequent years would depend on 

a variety of factors, as is discussed in Section IV.E.4. Oceanographic and climatic factors combine to 

aggregate zooplankton in some areas. Sources, transport of, and year to year persistence of plankton 

populations utilized by bowhead whales in and adjacent to the sale area remain unclear. 

While controlled studies of the potential effects on bowheads of exposure to PACs through their food 

remain infeasible at this time, bowheads are believed to be vulnerable to incremental long-term 

accumulation of pollutants given their extreme longevity. With increasing development within their 

range and long-distance transport of other pollutants, individual bowheads may experience multiple 

large and small polluting events, as well as chronic pollution exposure, within their lifetime. 

Displacement From and Avoidance of Habitat. Western scientists have not had the opportunity to 

observe bowhead response to a VLOS, and any displacement caused by subsequent spill response and 

cleanup operations. However, there are first-hand accounts of displacement effects on bowhead 

whales from a 25,000-gallon (595-bbl) oil spill at Elson Lagoon (Plover Islands) in 1944. Traditional 

knowledge provided by Tommy Brower, Sr (1980) explained that for the four years that oil was still 

present, bowhead whales made a wide detour out to sea when passing near Elson Lagoon/Plover 

Islands during fall migration. Bowhead whales normally moved close to these islands during the fall 

migration (when no oil was present). These observations indicate that some displacement of whales 

may occur in the event of a VLOS, and that the displacement may last for several years. Based on 

these observations, it also appears that bowhead whales may have some ability to detect an oil spill 

and avoid surfacing in the oil by detouring around the area of the spill. Anatomical data and 

observations that suggest that bowhead whales have the olfactory organs (Thewissen, et al., 2010) and 

ability to detect spilled oil to such a degree that they may modify movements to avoid a VLOS. 

Several other investigators have observed various cetaceans in spilled oil, including fin whales, 

humpback whales, gray whales, dolphins, and pilot whales. Typically, the whales did not avoid slicks 

but swam through them, apparently showing no reaction to the oil. During the spill of Bunker C and 

No. 2 fuel oil from the Regal Sword, researchers saw humpback and fin whales, and a whale 

tentatively identified as a right whale, surfacing and even feeding in or near an oil slick off Cape Cod, 

Massachusetts (Geraci and St. Aubin, 1990). Whales and a large number of white-sided dolphins 

swam, played, and fed in and near the slicks. The study reported no difference in behavior between 

cetaceans within the slick and those beyond it. None of these observations prove whether cetaceans 

can detect oil and avoid it, or whether long-term impacts occurred from exposure. Some researchers 

have concluded that baleen whales have such good surface vision that they rely on visual clues for 

orientation in various activities. In particular, bowhead whales have been seen “playing” with 

floating logs and sheens of fluorescent dye on the sea surface of the sea (Wursig et al., 1985, as cited 

in Bratton et al., 1993). These observations suggest that if oil is present on the sea surface and is of 

such quality or in such quantity that it is readily optically recognizable, bowhead whales may be able 

to recognize and avoid it (Bratton et al., 1993). However, the observation of their playing with dye 

may also indicate that they may not avoid spilled oil. 

After the EVOS, researchers studied the potential effects of an oil spill on cetaceans. Dahlheim and 

Loughlin (1990) documented no effects on the humpback whale. Von Ziegesar, Miller, and 

Dahlheim (1994) found no indication of a change in abundance, calving rates, seasonal residency 

time of female-calf pairs, or mortality in humpback whales as a result of that spill, although they did 

see temporary displacement from some areas of Prince William Sound. 

The presence of oil could prevent or disrupt access to and displace whales from habitat areas. 

Depending on oceanographic and climatic variables, zooplankton food concentrations that may 

normally result in feeding aggregations of bowhead whales may not be available. A VLOS could 

displace feeding whales from an active feeding event(s) or cause whales to avoid an otherwise 

available aggregated food source and feeding opportunity. Depending on the specifics and magnitude 
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188 CHAPTER IV. Environmental Consequences 

of a lost feeding opportunity and its contribution to the annual energy and nutrient requirement of 

individual whales, adverse effects upon health and reproduction could occur. Situations where effects 

could be more important include impaired access to the relatively consistent food aggregations north 

east of Barrow and any large aggregations of food attracting and holding large numbers of whales for 

an extended period of time (from a few days to weeks). Loss of access and use of the spring polynya 

system by migrating bowhead and beluga whales could result in variable mortality of newborn 

bowhead calves, delayed migration, and/or migration route avoidance or deflection and redistribution 

of migrating and spring feeding whales to adjacent areas with greater ice cover. Depending on the 

specifics of a given event, mortality of a portion of an annual cohort of calves could result, which in 

turn, could have longer term effects on population level recruitment and reproduction. It could also 

result in modification of migration pattern effects, as well as shorter term adverse body condition and 

health effects. 

In most cases, a VLOS event would occur at a time of year when the toxic fumes would dissipate into 

the atmosphere rapidly so as not to allow for prolonged exposure to the majority of whales in the 

open water and fall migration period. There is a potential that spilled oil could persist and be 

transported during ice covered seasons. A portion of the toxic volatile hydrocarbon fractions are 

likely to evaporate and dissipate into the atmosphere before remaining oil could be contacted by 

migrating bowheads during the next year. Thus, toxic fractions would occur in low enough densities 

to disallow prolonged (if any) exposure for cetaceans in the spring lead system. The northernmost 

portions of the spring lead system appear to be used by some spring migrating bowheads in the 

Chukchi Sea where contact with freshly spilled oil and fumes due to the shorter distance to an event 

site and shorter period that fresh oil has to age in the lead system could occur. There may be an 

opportunity for the individuals that have migration paths in those areas to be much closer to potential 

spill sites on existing leases, and they could be exposed to prolonged inhalation of toxic fumes if they 

do not exercise detection and avoidance responses. The potential for significant impacts to an annual 

cohort of the bowhead population could occur under a narrow set of conditional circumstances during 

the spring migration through the spring lead system in the Chukchi Sea and the far western Beaufort 

Sea. 

Fin Whale 

Fin whales are present only during the open water season in the Chukchi Sea. These whales occur 

rarely and as individuals or small groups within the Lease Sale 193 area (Funk et al., 2010); 

COMIDA, 2009; Roseneau, 2010), but are more frequently observed in waters of the southwestern 

Chukchi Sea adjacent to the Chukotka Peninsula, Russia. Fin whales are widespread and relatively 

abundant in the Bering Sea (Melinger, et al., 2010). They may, upon contacting fresh spilled oil, 

experience effects similar to bowheads from inhalation, ingestion, baleen fouling, skin and 

conjunctive tissue irritation. Fin whales also may exhibit detection and avoidance of spilled oil. It is 

even possible that fin whales could be killed if they surfaced repeatedly in the midst of a large fresh 

oil slick and inhaled high concentrations of volatile components of crude oil. However, based on 

available data following both the EVOS and the Glacier Bay oil spills in Alaska, it is unlikely that 

large numbers of fin whales would be adversely affected by a VLOS in the Sale193 area. 

Because of their frequency of occurrence and distribution in the Russian Chukchi Sea, the primary 

additional potential adverse effect on fin whales could be from a large or VLOS that contacted waters 

adjacent to the Chukotka Peninsula in the southwestern Chukchi Sea. During the summer and fall, fin 

whales could potentially be negatively impacted by a VLOS that contacted the waters adjacent to the 

north side of the Chukotka Peninsula, especially near Cape Dezhnev in the summer. 

Humpback Whale 

Humpback whales are present during the open water season in the Chukchi Sea and far western 

Beaufort Sea. Humpbacks occur rarely and as individuals or small groups in and adjacent to the Sale 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 189

193 area. Humpbacks are more frequently observed in waters of the southwestern Chukchi Sea 

adjacent to the Chukotka Peninsula and are widespread and relatively abundant (Central North Pacific 

stock) in the eastern Bering Sea. They may, upon contacting spilled oil, experience similar 

inhalation, ingestion, baleen fouling, skin and conjunctive tissue irritation; but also may exhibit 

detection and avoidance of spilled oil as may bowhead and fin whales. Repeated surfacing within a 

VLOS with fresh oil with high levels of volatile toxic hydrocarbon fractions present could potentially 

lead to organ damage and/or mortality of humpbacks. These whales prey on schools of forage fish 

(capelin, sand lance, herring) species as well as copepods and euphausids in the water column and on 

or near the surface which may have spilled oil present. Consumption of contaminated prey, the 

reduction or mortality of local forage fish populations could create periods whereby summer prey 

would not be available for an undetermined time period depending on prey recovery rates and 

pioneering use of the restored prey. Compared to the Central North Pacific population of humpback 

whales, a negligible number of contacted whales would experience temporary and non-lethal affects 

within the Sale 193 area. However, if even some of the humpback whales in the Sale 193 and 

adjacent Chukchi Sea originate from the Western North Pacific stock (a smaller and less wellunderstood stock), the injury or loss of even an individual may be an important population level 

effect. Under such circumstances, three or more generations could be required to re-establish 

distribution and abundance in the Alaska Chukchi and Beaufort seas. Studying the EVOS, von 

Ziegesar, Miller, and Dahlheim (1994) found no indication of a change in abundance, calving rates, 

seasonal residency time of female-calf pairs, or mortality in humpback whales as a result of that spill, 

although they did see temporary displacement from some areas of Prince William Sound. As 

discussed in previous paragraphs, literature on the effects of crude oil on mammals indicates that 

humpback whales could be vulnerable to such a spill. 

Because of their distribution, the primary additional potential adverse effect on humpback whales 

could be from a VLOS that contacted waters adjacent to the Chukotka Peninsula in the southwestern 

Chukchi Sea. During the summer and fall, humpback whales could potentially be negatively impacted 

by a VLOS that contacted the waters adjacent to the north side of the Russian Chukchi Peninsula, 

especially near Cape Dezhnev in the summer. Given that the high Arctic environment is changing 

rapidly and the period of time when the Chukchi Sea is ice-free is increasing, we may expect 

increases in humpback whale use of this area in the foreseeable future. Should the Chukchi Sea 

become a routine part of the range of the humpback whales, potential impacts on the population from 

a VLOS would increase. As discussed in the previous paragraphs, literature on the effects of crude 

oil on mammals indicates that humpback whales could be vulnerable to such a spill. There is no 

evidence humpacks were negatively impacted by the EVOS (von Zeigesar, Miller, and Dahlheim, 

1994); however, EVOS occurred before most humpbacks arrive for the summer in Prince William 

Sound. 

Gray Whale 

Gray whales summer in the Chukchi Sea where they feed before returning to wintering grounds in 

Mexico (Rugh et al. 1999, Rugh et al. 2001; Roseneau, 2010). Gray whales occupy the Chukchi Sea 

during the open water season, generally arriving behind the retreat of the sea ice and leaving ahead of 

the early winter advance of the ice (Clarke et al., 1989; Brueggeman et al., 1992; Funk et al., 2010; 

Goetz et al. 2009). Gray whales are the most abundant cetacean reported in the Chukchi Sea during 

summer (Funk et al., 2010; Brueggeman et. al., 1992). Gray whales are widespread in the Chukchi 

Sea but most occur near shore (< 40 km or 25 mi from shore) between Wainwright and Barrow with 

highest concentrations north and east of Wainwright. Recent acoustic data suggest some gray whales 

may over-winter in the Chukchi Sea (Stafford, et al., 2007), but the numbers are likely small (Moore 

et al. 2000). Most occurred nearshore between Wainwright and Cape Belcher during both 2008 and 

2009 survey seasons (Brueggeman, 2010). Gray whales observed during a shallow hazards survey 

conducted by CPAI (Conoco Phillips Alaska Incorporated) at Klondike prospect area and a coring 
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190 CHAPTER IV. Environmental Consequences 

program between Klondike and the coast in 2008 were entirely nearshore (Brueggeman et al. 2009). 

Similarly, the 2009 and 2010 COMIDA (COMIDA, 2009; 2010) surveys found most gray whales 

feeding nearshore between Pt. Lay and Barrow from June to October. Gray whale movements vary 

annually depending on prey abundance and distribution (Nerini, 1984). Gray whales feed in soft 

sediments which contain their primary prey: benthic ampeliscid amphipods (Nerini, 1984). Smaller 

numbers of gray whales historically concentrated in the region of Hanna Shoal, north and east of the 

Burger survey area between 160o and 165o W, but none were seen there during the 2009 and 2010 

COMIDA surveys Clarke, et al., 2011). 

Contact with Oil. Gray whales are present in the Chukchi Sea and far western and eastern Beaufort 

Sea (Rugh, 1981; Moore, et. al. 2000) during the open water season, but there is acoustic evidence 

that individuals may spend the winter period in the Alaska Arctic as well (Stafford, et al.,2007). 

These whales occur in shallow shelf nearshore and offshore shoal habitats to feed on benthic prey. 

They may, upon contacting spilled oil, experience effects from inhalation, ingestion, baleen fouling, 

skin and conjunctive tissue irritation, but also may exhibit detection and avoidance of spilled oil 

similar to whale species discussed earlier. Migrating gray whales show only partial avoidance to 

natural oil seeps off California. 

After EVOS, gray whales were observed swimming through surface oil along the Alaskan coast. 

Laboratory tests suggest gray whale baleen and possibly skin, may be resistant to oil damage. Gray 

whales exhibiting abnormal behavior were observed in oil after the EVOS in an area where fumes 

from the spill were very strong (J. Lentfer, cited in Harvey and Dalheim, 1994). Subsequently large 

numbers of gray whale carcasses were discovered. One of three of these had elevated levels of 

polycyclic aromatic hydrocarbons (PAHs) in its blubber. Loughlin (1994) concluded it was unclear 

what caused the death of the gray whales. An estimated 80,000 barrels of oil may have entered the 

marine environment off Santa Barbara in 1969, when gray whales were beginning the annual 

migration north. Whales were observed migrating through the slick. Subsequently, six dead gray 

whales were observed and recovered as well as a number of other marine mammals. No evidence of 

oil contamination was found on any of these whales. The Battelle Memorial Institute concluded the 

whales were either able to avoid the oil, or were unaffected when in contact with it. 

Based on all available information, if individual, small or large groups of gray whales were exposed 

to large amounts of fresh oil from a VLOS, especially through inhalation of highly toxic aromatic 

fractions, they might be seriously injured or die from such exposure. Although there is little definitive 

evidence linking cetacean death and serious injury to oil exposure, the deaths of large numbers of 

gray whales coincided with EVOS and observations of gray whales in oil. If fresh oil from a VLOS 

contacted important coastal or shoal habitats, the gray whale population could be at risk for multiple 

cases of injury or mortality when concentrated on summer feeding grounds, and could have limited 

options to avoid a spill and still meet annual nutrient and energy requirements in the Chukchi. 

Recovery of distribution, abundance, and habitats may take decades to recover or possibly more than 

three generations. 

Ingestion. Gray whales may ingest oil fractions that sink to (and may persist in) the sea floor 

sediments that are disturbed when bottom feeding on benthic invertebrates, as is characteristic of the 

gray whale. Chronic consumption of bottom accrued oil fractions or contaminated prey may result in 

impaired endocrine function, reproductive impairment, or mortality. Baleen whales may have the 

capability to metabolize ingested oil compounds. 

Contamination and Reduction of Food Sources. In the Chukchi Sea spilled oil could adversely 

effect gray whales by contaminating benthic prey and sediments (please refer to Section IV.E.4, 

Lower Trophic Organisms), particularly in prime feeding areas (Wursig, 1990; Moore and Clark, 

2002). Any perturbation, such as a VLOS, which caused extensive mortality within a high latitude 

amphipod population with low fecundity and long generation times would result in marked decreases 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 191

in secondary production (Highsmith and Coyle, 1992). For example, populations of amphipods off 

the coast of France were reduced by 99.3% following the Amoco Cadis oil spill in 1978 

(approximately 70 million gallons). Ten years after the spill, amphipod populations had recovered to 

39% of their original maximum densities (Dauvin, 1989, as cited by Highsmith and Coyle, 1992). 

Chukchi sea amphipod populations with longer generation times and lower growth rates, probably 

would take considerably longer to recover from any major population disruption (Highsmith and 

Coyle, 1992). 

Displacement From and Avoidance of Habitat. Reduction or mortality in benthic prey larval 

stages that live in the water column, reduced benthic biomass, and productivity of near shore and 

offshore shoals may force gray whales to seek alternate, less optimal foraging areas of the shelf 

offshore for up to several years until nearshore or shoal benthic communities recover. Impacts to 

these whales could occur over a period of years depending on numbers and amounts of oil fractions 

chronically consumed or reduced from a VLOS and the quality and availability of alternate feeding 

habitat in the Alaska Arctic. Restoration of distribution and abundance of gray whales along the 

Alaska Chukchi Sea coast could take more than three generations to recover from a VLOS. 

Minke Whale 

Contact with Oil. These whales occur regularly in low numbers in the Chukchi Sea and Beaufort 

Sea during the open water season only (Ireland, et al., 2008; Funk, et al., 2010; Brueggeman, 2010; 

Roseneau, 2010). These whales are observed commonly as individuals or small groups. Minke 

whales may, upon contacting spilled oil, experience inhalation, ingestion, baleen fouling, skin and 

conjunctive tissue irritation similar to other whales, but also may exhibit detection and avoidance of 

spilled oil. Temporary and/or permanent, non-lethal injury could occur. When considering the 

numbers projected for the North Pacific and the potential numbers in the Alaska Arctic, population 

level effects are not anticipated; however, abundance, distribution patterns and frequency of 

occurrence in the Alaska Chukchi Sea could be reduced in response to possible reduction in 

abundance and distribution of prey resources. Recovery of minke whale to pre-spill abundance and 

distribution may be most dependent upon prey recovery timeframes. 

Ingestion. Minke whales prey on schools of forage fish (capelin, sand lance, and herring) species as 

well as copepods and euphausids in the water column and on or near the surface which may have 

spilled oil present. Consumption of contaminated prey, the reduction or mortality of local forage fish 

populations could create periods whereby summer prey would not be available for an undetermined 

time period depending on prey recovery rates and pioneering use of the restored prey (see Section 

IV.E.5, Fish Resources). Compared to the Alaska stock/population of minke whales, a small number 

venture north of the Bering Strait and into the Chukchi Sea and the sale area. Minke whales 

contacting oil could experience temporary and non-lethal effects within the Sale 193 area. 

Contamination and Reduction of Food Sources. These whales prey on schools of forage fish 

species (see IV.E.5, Fish Resources), as well as copepods and euphausiids in the water column and on 

or near the surface which may have spilled oil present. Oil contacted whales would likely experience 

minor temporary and non-lethal effects similar to those described for humpback whales. When 

considering the numbers projected for the North Pacific, population level effects are not anticipated. 

Displacement From and Avoidance of Habitat. Minke whales may be able to detect and choose to 

avoid a VLOS, causing displacement to other habitat areas that may or may not be as optimal as those 

affected by a VLOS. Impacts to the distribution and abundance of prey, if they should occur, would 

largely determine the seasonal distribution and habitat use by minke whales. When considering the 

numbers projected for the North Pacific, population level effects are not anticipated; however, 

distribution and abundance in the Chukchi Sea could be modified or reduced in relation to the 

potential modification to food source distribution and abundance as result of a VLOS. 
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192 CHAPTER IV. Environmental Consequences 

Beluga Whale 

Beluga whales of three different stocks use habitats from along the Alaska Chukchi Sea coastline 

seaward to beyond the shelf break. The distribution of these stocks are seasonal, wintering in the 

Bering Sea and migrating to summer habitats in the Canadian Beaufort, Alaskan Beaufort and 

Chukchi Seas (Suydam, et al, 2001; Suydam , et al., 2005; Roseneau, 2010). Some belugas migrate 

through the Chukchi spring lead system concurrent with the bowhead migration during April through 

June. Summer aggregations of molting belugas and females with calve occur in coastal lagoons and 

there is apparently habitat preference for waters near the continental shelf edge during summer and 

fall. 

Contact with Oil. Contamination of the spring ice- lead system from a VLOS could result in direct 

contact with spilled oil. Notable increased vulnerability of belugas exists in spring and early summer 

when concentrations occur in the warm shallow waters of Kasegaluk Lagoon to molt. Concentrations 

of large numbers of beluga whales are observed in some years in unpredictable places and numbers. 

In July of 2010 650+ belugas were observed for a number of days in Elson Lagoon north of Barrow 

(Monnett, 2010; NMFS, 2011). Belugas are present in the Chukchi Sea and far western Beaufort Sea 

during the open water season offshore as well as in coastal lagoons (Suydam et al. 2001; Suydam et 

al., 2005, and Ireland et al., 2009). Summer and fall observations indicate concentrations of belugas 

along and beyond the shelf edge, fall migration along the shelf edge, and some use throughout the 

shelf areas in the Chukchi and Beaufort Seas. There is acoustic evidence that some individuals may 

spend the winter period in the Alaska Arctic as well. They may, upon contacting spilled oil, 

experience similar inhalation, ingestion, skin and conjunctive tissue irritation similar to other whales, 

and also may exhibit detection and avoidance of spilled oil. Substantial injury and mortality due to 

physical contact inhalation and ingestion is possible to beluga whales, especially calves of the year 

and juveniles using habitats along the Alaska Chukchi Sea coast and the shallow lagoons situated 

there. Restoration of seasonal use patterns and abundance could take multiple generations and the 

potential for no recovery exists, depending on the extent of injury and mortality experienced. DFO 

(2010) indicates the factors and potential causes that may be hindering the recolonization of historic 

St. Lawrence beluga habitats after habitat degradation and loss of learned site fidelity through 

overharvest and extermination. 

Ingestion. Beluga whales prey on fish (Arctic cod, saffron cod, herring, pollock) species as well as 

large copepods in the water column and on or near the surface which may have spilled oil present. 

Consumption of contaminated prey, the reduction or mortality of local forage fish populations could 

create periods whereby summer prey would not be available for an undetermined time period 

depending on prey recovery rates and pioneering use of the restored prey. The fish populations in 

lagoons along the Chukchi coast used by belugas for migration, moulting and nursing are vulnerable 

oil contamination and subsequent ingestion by large numbers of beluga whales (see Section IV.E.5, 

Fish Resources). 

Oil components or chemical oil dispersant derived compounds could be consumed by belugas feeding 

on prey anywhere in contaminated water column layers to the sea floor. Belugas may ingest oil 

fractions from contaminated prey items. Ingestion of petroleum hydrocarbons can lead to subtle and 

progressive organ damage or to rapid death in mammals. Many polycyclic aromatic hydrocarbons are 

teratogenic and embryotoxic in at least some mammals (Khan et al., 1987). Maternal exposure to 

crude oil during pregnancy may negatively impact the birth weight of young. Oil ingestion can 

decrease food assimilation of prey eaten (for example, St. Aubin, 1988). Decreased food assimilation 

could be particularly important in very young animals, those that seasonally feed, and those that need 

to put on high levels of fat to survive their environment. Wilson, et al. (2005) examined CYP1A1 

protein expression immunohistochemically in multiple organs of beluga whales from two locations in 

the Arctic and from the St. Lawrence estuary. These beluga populations have some of the lowest 

(Arctic sites) and highest (St. Lawrence estuary) concentrations of PCBs in blubber of all cetaceans. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 193

Cytochrome P450 1A1 (CYP1A1) is induced by exposure to polycyclic aromatic hydrocarbons 

(PAHs) and planar halogenated aromatic hydrocarbons (PHAHs) such as non-ortho polychlorinated 

biphenyls (PCBs). The systemic high-level expression of CYP1A1 in Arctic beluga suggests that 

effects of PAHs or PHAHs may be expected in Arctic populations. The high-level expression of 

CYP1A1 in the Arctic beluga suggests that this species is highly sensitive to CYP1A1 induction by 

aryl hydrocarbon receptor agonists. Samples from these populations might be expected to have 

different contaminant-induced responses, reflecting their different exposure histories. The pattern and 

extent of CYP1A1 staining in whales from all three locations were similar to those seen in animal 

models in which CYP1A has been highly induced, indicating a high-level expression in these whales. 

CYP1A1 induction has been related to toxic effects of PHAHs or PAHs in some species. The 

systemic high-level expression of CYP1A1 in Arctic beluga suggests that effects of PAHs or PHAHs 

may be expected in Arctic populations, as well. The high-level expression of CYP1A1 in the Arctic 

beluga suggests that this species is highly sensitive to CYP1A1 induction by aryl hydrocarbon 

receptor agonists. 

Contamination and Reduction of Food Sources. Abundance and distribution may be modified or 

reduced in near shore areas in response to prey (fish and large copepods) reduction and contamination 

resulting from a VLOS. Prey recovery periods would determine recovery periods for beluga whale 

distribution and abundance to pre-spill levels (see Section IV.E.5, Fish Resources). 

Displacement From and Avoidance of Habitat. The presence of oil could displace belugas from, 

prevent or disrupt access to affected habitat areas. The loss of nearshore and lagoon habitats by 

beluga females with calves and juveniles for nursing and molting, depending upon the extent of injury 

or mortality experienced may not be recoverable or take multiple generations to recover the use and 

abundance of whales using these seasonally important habitats. Impacts to the distribution and 

abundance of prey, if they should occur, would largely determine the seasonal distribution and habitat 

use by belugas. 

Killer Whale 

Killer whales have been observed in the Chukchi Sea during various surveys and other observations 

(Funk et al., 2010, 2011; George and Suydam, 1998; Roseneau, 2010). Killer whales have been 

primarily observed near the coast rather than farther offshore (Brueggeman et al. 1992, George and 

Suydam 1998; Roseneau, 2010), but this could be due to higher levels of human activity and 

observation opportunity nearshore. Conversely, acoustic recorders detected killer whale calls in 2007 

and 2009 offshore between Cape Lisburne and Barrow from July until October (Delarue and Martin, 

2010; Hannay et al., 2009; Martin et al., 2008). The combination of acoustic and visual data suggests 

killer whales occur both offshore and near shore with no clear inshore/offshore trend. 

Contact with Oil. Killer whales are observed infrequently by Native hunters and others in very low 

numbers throughout the Alaska Chukchi and western Beaufort Seas (Frost, et al., 1983; Lowry, et al., 

1987; Brueggman, et al., 1992 as cited in Brueggeman, 2009; Roseneau, 2010). Russian observations 

along the southwestern Chukchi Sea along the Chukotka Peninsula coast indicate greater abundance 

of killer whales in that area. They may, upon contacting spilled oil, experience inhalation, ingestion, 

skin and conjunctive tissue irritation similar to whales discussed earlier, and also may exhibit 

detection and avoidance of spilled oil. Matkin, et al. (1994) reported killer whales had the potential to 

contact or consume oil, because they did not avoid oil or avoid surfacing in slicks. In the two years 

following EVOS, significant numbers (13) of individual whales, primarily reproductive females and 

juveniles, disappeared from the AB pod. Dahlheim and Matkin (1994) observed AB pod members 

swimming through heavy slicks of oil and 18 killer whales including 3 calves surface in a patch of oil. 

They concluded that there is a spatial and temporal correlation between loss of the whales and the 

EVOS, but there is no clear cause-and-effect relationship. Matkin, e. al. (2008) note the synchronous 

33% and 41% initial losses from the AB Pod and the AT1 Group in the year following the EVOS, and 
BOEMRE Sale 193 Revised Draft SEIS 

194 CHAPTER IV. Environmental Consequences 

that 16 years post spill the AB has not recovered to former numbers and the AT1 Group has 

continued to decline and is now listed as depleted under the MMPA. The synchronous losses of 

unprecedented numbers of killer whales from these two genetically and ecologically separate groups 

and the absence of other obvious perturbations strengthens the link between mortalities and the lack 

of recovery and the EVOS. The link, however, remains circumstantial and there is not agreement 

among the scientific community as to whether or not there likely was an oil-spill impact on killer 

whales after the EVOS. 

Contamination and Reduction of Food Sources. The killer whales in the Alaska Arctic are likely 

marine mammal predators as suggested by the few accounts of predation documented (George and 

Suydam, 1998). The fate of other marine mammals, and of potential prey fisheries, in detection and 

avoidance of a VLOS, declining or contaminated food sources causing redistribution, injury, 

contamination and fluctuations in prey numbers, and recovery of prey post spill will determine the 

persistence and use of the Sale 193 area and adjacent areas. As an apex predator, killer whales could 

bioaccumulate petroleum residues in tissues, While they indicate some ability to metabolize 

hydrocarbon factions ingested or otherwise absorbed, they also indicate sensitivity to CYP1A1 

induction by hydrocarbon receptors; however, abundance, distribution patterns and frequency of 

occurrence in the Alaska Chukchi Sea could be reduced in response to possible reduction in 

abundance and distribution of prey resources. Recovery of killer whale to pre-spill abundance and 

distribution would be dependent upon prey (marine mammals and fisheries) recovery timeframes. 

Displacement from and Avoidance of Habitat. No clear patterns of habitat use have merged from 

killer whales observations in the Alaska Arctic. The fate of other marine mammals (prey base for 

killer whales in the Arctic) in detection and avoidance of a VLOS, declining or contaminated food 

sources causing redistribution, injury or mortality, contamination and fluctuations in prey numbers, 

and recovery of prey post-spill will determine the persistence and use of the LS 193 area and adjacent 

areas. Odonocetes (toothed whales) do not seem to consistently avoid oil, although they can detect it 

(Geraci, 1990). Matkin, et al. (1994) reported killer whales had the potential to contact or consume 

oil, because they did not avoid oil or avoid surfacing in slicks. In the two years following EVOS, 

significant numbers (13) of individual whales, primarily reproductive females and juveniles, 

disappeared from the AB pod. Dahlheim and Matkin (1994) observed AB pod members swimming 

through heavy slicks of oil and 18 killer whales, including 3 calves, surfaced in a patch of oil. 

Harbor Porpoise 

Harbor porpoise are recorded in the Chukchi Sea and Barrow areas (Suydam and George. 1992; 

Roseneau, 2010) and by surveys in the northeastern Chukchi by Funk et al. (2010). It appears that 

small numbers of harbor porpoise transit through and feed in the Chukchi Sea during summer. 

Contact with Oil. Harbor porpoise are present in the Alaska Chukchi Sea during the open water 

period (Suydam and George, 1992). They may, upon contacting spilled oil, experience inhalation, 

ingestion, skin and conjunctive tissue irritation similar to bowhead whales, and also may exhibit 

detection and avoidance of spilled oil. 

Contamination and Reduction of Food Sources. The fisheries prey base of harbor porpoise could 

experience reduction in abundance, distribution and diversity from contact with oil and experience 

injury from consuming contaminated food items or from direct contact with oil fractions. The fate of 

nearshore forage fish in the Alaska Arctic, in detection and avoidance of a VLOS, declining or 

contaminated food sources causing redistribution, injury or mortality, contamination and fluctuations 

in prey numbers, and recovery of prey post-spill will determine the persistence and use of the LS 193 

area and adjacent areas (see Section IV.E.5, Fish Resources). 

Displacement from and Avoidance of Habitat. The fate of nearshore forage fish presence and 

abundance in the Alaska Arctic, in detection and avoidance of a VLOS, declining or contaminated 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 195

food sources causing redistribution, injury or mortality, contamination and fluctuations in prey 

numbers, and recovery of prey post-spill will determine the persistence and use of the Sale 193 area 

and adjacent areas. Harbor porpoise could be excluded from the Chukchi Sea if the forage fish prey 

base was substantially reduced or eliminated for even a short period of time. It could take many years 

for porpoises to reestablish the current seasonal use of the Alaska Chukchi Sea even after or if prey 

populations become restored (see Section IV.E.5, Fish Resources). 

Phase 3 – Onshore Contact 

Onshore contact (Phase 3) with oil and gas would have no effects on Chukchi Sea or Beaufort Sea 

cetaceans as the pelagic habitats of these species do not include any onshore resources. 

Phase 4 – Oil spill Response, Cleanup, Restoration, and Remediation 

Oil spill response, cleanup, restoration, and remediation (Phase 4) has the potential to adversely affect 

the three ESA listed endangered whales (bowhead, fin and humpback), five unlisted species of 

cetaceans (gray, minke, beluga, killer whales and harbor porpoise), and their habitats that occur in the 

sale area. The potential impact producing factors may be the following: 

 Noise and disturbance from vessel presence and activity including boom and skimming 

operations. 

 Aircraft overflights, including potential application of dispersants from low flying aircraft. 

 In-situ burning, including noise and disturbance from support operations. 

 Animal rescue, scientific recovery and disposal of contaminated carcasses. 

 Skimmer and boom team composition, number, distribution and noise. 

 Relief well drilling and discharges, including support activities such as ice breakers, and 

vessel discharges. 

 Bioremediation activities, including short and long term monitoring and research studies to 

evaluate effectiveness of cleanup actions, that treat affected areas to neutralize toxic effects or 

removal and disposal operations to eliminate risk from oil contaminated soil, water, and 

equipment (booms, cleaning wastes, and sewage from operations, personnel. 

Please refer to Section IV.C.1.f(1) of the Sale 193 FEIS (pp. IV-80 through IV-116; USDOI, MMS, 

2007a) for detailed discussion of the potential effects of noise and disturbance from most of these oil 

and gas related activities on endangered whales, and refer to Section IV.C.1.h. (pp. IV-149 through 

IV-156; USDOI, MMS, 2007a) for potential effects on unlisted species of cetaceans. In most cases 

noise and disturbance (including collisions) from vessels, aircraft, drilling, and discharges are as 

described for the effects of these same types of operations associated with exploration, development, 

and production, including drilling and support activities. In most cases temporary, non-lethal effects 

would result from contact with a VLOS. In some cases a cetacean species may require two or more 

generations coincident with restored and unaffected habitat to restore distribution and populations. 

The analysis below is organized by species, with IPFs discussed for each. Thorough discussion of 

potential impacts to the endangered bowhead whale will often serve to introduce concepts applicable 

to other species. 

Bowhead Whale 

Noise and disturbance from vessel presence and activity. Cleanup operations following a large or 

very large spill would be expected to involve multiple marine vessels operating in the spill area for 

extended periods of time, perhaps over multiple years. Based on information provided in the above 

section on vessel traffic, bowheads react to the approach of vessels at greater distances than they react 

to most other industrial activities, and vessel and associated cleanup activities may be encountered by 
BOEMRE Sale 193 Revised Draft SEIS 

196 CHAPTER IV. Environmental Consequences 

bowheads frequently and would likely induce avoidance responses that would cause extra 

expenditures of energy. According to Richardson and Malme (1993), most bowheads begin to swim 

rapidly away when vessels approach rapidly and directly. Avoidance usually begins when a rapidly 

approaching vessel is 1-4 km (0.62-2.5 mi) away. A few whales may react at distances from 5-7 km 

(3-4 mi). Vessels deployed on skimmer/boom teams likely would be less than 75 feet in length 

(about the size of a fishing vessel) and booming operations would be operating at low speeds. These 

vessels and smaller vessels produce higher frequency noise that certainly add to the ambient noise 

levels but may not be in the frequency range for bowhead and other low frequency whales in some 

cases. Cavitation noise, onboard engine and equipment noise is not likely to propagate noise levels 

harmful to or causing avoidance response from bowhead whales more than 1 km from the vessel. 

Therefore, bowheads would likely avoid the vessels at a distance of over 1 km; however, during 

transit operations at high speeds at night or during low visibility conditions collision or propeller 

strikes could occur. Larger vessels for a relief well drilling operations create noise levels from 

propeller cavitation, and onboard engine noise that propagates at levels causing reaction from 

bowhead whales. Avoidance may be related to the fact that bowheads have been commercially hunted 

within the lifetimes of some individuals in the population and they continue to be hunted for 

subsistence use throughout many parts of their range. Avoidance usually begins when a rapidly 

approaching vessel is 1-4 km (0.62-2.5 mi) away. A few whales may react at distances from 5-7 km 

(3-4 mi), and a few whales may not react until the vessel is less than 1 km (less than 0.62 mi) away. 

Received noise levels as low as 84 dB re 1 μPa or 6 dB above ambient may elicit strong avoidance of 

an approaching vessel at a distance of 4 km (2.5 mi) (Richardson and Malme, 1993). 

In the Canadian Beaufort Sea, bowheads observed in vessel-disturbance experiments began to orient 

away from an oncoming vessel at a range of 2-4 km (1.2-2.5 mi) and to move away at increased 

speeds when approached closer than 2 km (1.2 mi) (Richardson and Malme, 1993). Vessel 

disturbance during these experimental conditions temporarily disrupted activities and sometimes 

disrupted social groups, when groups of whales scattered as a vessel approached. Reactions to slowmoving vessels, especially if they do not approach directly, are much less dramatic. Bowheads often 

are more tolerant of vessels moving slowly or in directions other than toward the whales. Fleeing 

from a vessel generally stopped within minutes after the vessel passed, but scattering may persist for a 

longer period. After some disturbance incidents, at least some bowheads returned to their original 

locations (Richardson and Malme, 1993). Some whales may exhibit subtle changes in their surfacing 

and blow cycles, while others appear to be unaffected. Bowheads actively engaged in social 

interactions or mating may be less responsive to vessels. 

If drill vessels engaged in drilling relief wells are attended by icebreakers, as typically is the case 

during the fall in the Chukchi Sea, the drilling vessel noise frequently may be masked by icebreaker 

noise, which often is louder. Response distances would vary, depending on icebreaker activities and 

sound-propagation conditions. Based on models, bowhead whales likely would respond to the sound 

of the attending icebreakers at distances of 2-25 km (1.24-15.53 mi) from the icebreakers (Miles, 

Malme, and Richardson, 1987). This study predicts that roughly half of the bowhead whales show 

avoidance response to an icebreaker underway in open water at a range of 2-12 km (1.25-7.46 mi) 

when the sound-to-noise ratio is 30 dB. The study also predicts that roughly half of the bowhead 

whales would show avoidance response to an icebreaker pushing ice at a range of 4.6-20 km (2.86-

12.4 mi) when the sound-to-noise ratio is 30 dB. 

Based on all of the above information, there could potentially be displacement of bowhead whales 

from a feeding area following a VLOS, and this displacement could last as long as there are spill 

response and clean-up vessels present and possibly longer. The severity of impacts depends on the 

value of the feeding area affected. In the event that a high value area is affected and alternate feeding 

areas of similar value are scarce, adverse effects to nutritional fitness, reproductive capacity, fetal 

growth rates, and neonatal survivorship could occur. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 197

Noise and disturbance from aircraft. After a VLOS, it is likely that overflights using helicopters 

and fixed-winged aircraft would track the spill and determine distributions of wildlife that may be at 

risk from the spill. Most bowheads are unlikely to react noticeably to occasional single passes by 

helicopters flying at altitudes above 150 m (500 ft). At altitudes below 150 m (500 ft), some 

bowheads probably would dive quickly in response to the aircraft noise (Richardson and Malme, 

1993; Patenaude et al., 1997) and may have shortened surface time (Patenaude et al., 1997). 

Bowhead reactions to a single helicopter flying overhead probably are temporary (Richardson et al., 

1995a). Whales are likely to resume their normal activities within minutes. 

Fixed-wing aircraft flying at low altitudes often cause hasty dives. Reactions to circling aircraft are 

sometimes conspicuous if the aircraft is below 300 m (1,000 ft), uncommon at 460 m (1,500 ft), and 

generally undetectable at 600 m (2,000 ft). Repeated low-altitude overflights at 150 m (500 ft) 

sometimes caused abrupt turns and hasty dives (Richardson and Malme, 1993). The effects from an 

encounter with aircraft are brief, and the whales should resume their normal activities within minutes. 

Under the intensive and frequent overflight patterns of large aircraft dispensing chemical dispersants 

at low level flight altitudes (less than 300 meters), bowheads would likely respond more severely and, 

depending on the situation, could harass bowheads and haze them in the direction of flight lines for 

considerable distances. 

Based on all of the above information, the conclusion is that there could potentially be harassment of 

bowheads away from movement corridors and displacement of bowhead whales from feeding areas 

following a VLOS, and this displacement could last as long as there is a large amount of oil and 

related clean-up aircraft (especially dispersant application operations) present. Intensive and frequent 

low elevation overflights associated with spill response and assessment, monitoring, wildlife 

monitoring, and media operations could potentially harass and displace bowheads within the spill area 

or between the VLOS and shore based facilities. Hazing of whales away from a hazardous spilled oil 

slick is possible. This is especially true during the fall migration when large numbers of whales 

attempt to cross the Chukchi Sea or take advantage of feeding opportunities where there is exposure 

to hazardous oil (that associated with large amounts of aromatic components, concentrations of prey 

lying within the spill contaminated surface slick, or where consumption of oil by surface feeding 

whales is a hazard). Hazing of migrating whales, while stressful, may be justified to prevent whales 

from intercepting or migrating through extended areas of spilled oil, and to encourage them to detour 

around hazardous accumulations of oil and continue migration to the west. 

In-situ burning. Deployment of burning operations would primarily occur near the localized 

origination point of the spill and in prioritized nearshore areas. Spill origination site boom and burn 

operation noise would likely be masked by the noise emanating from the relief drilling effort, which 

bowhead whales could avoid as is described in the next subsection. There would also be monitors 

ensuring that marine species would not be in the vicinity of the burning. 

Noise and disturbance associated with skimmer and boomer operations. Booming efforts and 

associated skimmers utilize vessels to conduct operations, and noise effects as described above apply 

to bowhead whales. Offshore skimmer operations appear to be restricted to the localized area of the 

spill source and the specific high value nearshore and coastal sites where infrastructure and facilities 

for crews and equipment are available. Effects on bowhead whales from these operations are likely to 

be minor because the nearshore operations, noise, and sensitive coastal sites are not important fall 

migratory habitat to these whales. Effects are expected to be negligible. 

Noise and disturbance from drilling a relief well and support activities. Drilling a relief well is a 

source of noise and disturbance to bowhead whales with essentially the same impacts as the drilling 

of the exploration well that failed and would require a relief well. Relief well drilling operations are 

likely to employ drilling vessels (with ice-breaker support vessels, if necessary) and are estimated to 

operate at a given well site for a period of about 34 days. The greatest potential for bowhead whales 
BOEMRE Sale 193 Revised Draft SEIS 

198 CHAPTER IV. Environmental Consequences 

to encounter relief well operations would occur during the fall migration when the majority of the 

population migrates westerly across the Chukchi Sea and the Sale 193 area. Since 2006, satellite 

tagging studies since 2006 indicate that migrating whales could be migrating across the Chukchi Sea 

from September to mid December and could encounter drilling throughout the entire migration 

period. 

Some bowheads in the vicinity of drilling operations would be expected to respond to noise from 

drilling units by adjusting their migration speed and swimming direction to avoid closely approaching 

these noise sources. Miles, Malme, and Richardson (1987) predicted the zone of responsiveness to 

continuous noise sources. They predicted that roughly half of the bowheads likely would respond at a 

distance of 1-4 km (0.62-2.5 mi) from a drillship drilling when the signal-to-noise ratio is 30 dB. A 

smaller proportion would react when the signal-to-noise ratio is about 20 dB (at a greater distance 

from the source), and a few may react at a signal-to-noise ratio even lower or at a greater distance 

from the source. Bowhead whales are likely to detour around an operating relief drilling effort and 

continue their westward migration. These whales may encounter noise from booming, skimming, 

support vessels and other activities after detouring around a relief drilling operation. Reactions are 

likely to be localized, temporary and non-lethal. Please refer to the previous sections on noise (in this 

SEIS) and disturbance from vessel presence and activity, and noise and disturbance from aircraft, as 

well as Sale 193 FEIS (Section IV.C.1.f[1][d][3] - Effects of Noise from Icebreakers; Section 

IV.C.1.f[1][d][3] - Effects from Other Vessel Traffic Associated with Seismic Surveys; and Section 

IV.C.1.f[1][d][3] - Effects from Aircraft Traffic) for detailed discussions of effects from these similar 

support activities associated with relief well drilling efforts (USDOI, MMS, 2007a). 

Drilling a relief well would also result in discharges that could impact bowhead whales; there could 

be alterations in bowhead habitat as a result of exploration-related localized pollution and habitat 

destruction. Bottom founded drilling units may cover areas of epibenthic invertebrates used for food 

by bowhead and gray whales, but would be localized and inconsequential in comparison to the vast 

foraging habitat available in the Chukchi Sea. Any potential adverse effects on whales from 

discharges are directly related to whether or not any potentially harmful substances are released into 

the marine environment; what their fate in that environment is (for example, different hypothetical 

fates could include rapid dilution or biomagnification through the food chain); and thus, whether they 

are bioavailable to the species of interest. Effects likely would be negligible, because bowheads feed 

primarily on pelagic zooplankton and the areas of sea bottom that are impacted would be 

inconsequential in relation to the available habitat. 

Animal rescue, scientific recovery, rehabilitation, and disposal. Bowhead whale rescue actions 

are not anticipated; however, rescue efforts for some other species may bring small vessels into the 

vicinity of bowheads. Negligible effects are anticipated from small vessels as bowheads would likely 

avoid the activity and larger vessel operations that would serve as facilities from which smaller craft 

may be operating (see the above section on noise and disturbance from vessel presence and activity). 

Recovery of stranded, floating, or otherwise dead or severely injured bowheads or other marine 

species would be on shore (stranded) or not likely to be in the company of other bowheads at sea. 

Rehabilitation and treatment facilities likely would be on board a ship or land based and not practical 

for large whales. Disposal of contaminated carcasses (if any), tissues and oil contaminated materials 

(absorbent pads, protective gear, etc.) would likely be at an authorized disposal site onshore. 

Negligible effects are anticipated. 

Bioremediation and restoration (short and long term). Bowhead whales would experience a wide 

variety of exposure to aircraft and vessel noise and traffic and effects would be similar to those 

discussed above under sections for noise and disturbance from vessel presence and activity, and noise 

and disturbance from aircraft, as well as Sale 193 FEIS (Section IV.C.1.f[1][d][3] - Effects of Noise 

from Icebreakers; Section IV.C.1.f[1][d][3] - Effects from Other Vessel Traffic Associated with 

Seismic Surveys; and Section IV.C.1.f[1][d][3] - Effects from Aircraft Traffic) (USDOI, MMS 2007) 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 199

Effects from aircraft traffic for detailed discussions effects from these support activities. Aircraft and 

vessel operations would be supporting many short-term efforts during spill initial response as well as 

throughout the spill containment and treatments to minimize volume, spread, and environmental 

consequences. These include a wide variety of surveillance missions, placement of transmitter 

equipped buoys (to track spill edge in real time), media coverage, monitoring wildlife, dispersant 

application, treatments to shorelines and waters, as well as various activities associated with spill 

research, monitoring, and evaluation. The fate of and effects of dispersant application upon 

productivity, survivorship and contamination of benthic sediments and invertebrates are addressed in 

Section IV.E.4. Overall it is possible that the use of dispersants, if permitted, could lead to adverse 

affects through either reduction of food availability, bio-accumulation, or contamination. 

Fin Whale 

Potential impacts to fin whales during Phase 4 are similar to those described for bowhead whales, 

except as noted below. Fin whales are low frequency sensitive whales and although thresholds for 

response to noise may be species specific, the general discussion relative to bowhead whales applies 

to fin whales. 

The summary of information about the current and historic distribution of fin whales indicates that a 

few individuals or small groups of these species could be exposed to potential noise impacts. Such 

effects should be temporary and minor. 

Humpback Whale 

Potential impacts to humpback whales during Phase 4 are similar to those described for bowhead 

whales, except as noted below. Humpback whales are low frequency sensitive whales and although 

thresholds for response to noise may be species specific, the general discussion relative to bowhead 

whales applies to humpback whales. 

The summary of information about the current and historic distribution of humpback whales indicates 

that a few individuals or small groups of these species could be exposed to potential noise impacts. 

Such effects should be temporary and minor. 

Gray Whale 

Potential impacts to gray whales during Phase 4 are similar to those described for bowhead whales, 

except as noted below. 

Gray whales feed upon benthic invertebrates that occur on and in the bottom sediments. Exploration 

drilling muds and cuttings may cover portions of the seafloor and cause localized pollution. 

However, the effects likely would be negligible, because areas of sea bottom that are impacted would 

be inconsequential in relation to the available habitat. 

Chemical dispersants used to break up surface oil and and disperse it into the water column, some of 

which may sink and affect benthic organisms preyed upon by gray whales. If their use is permitted, 

dispersants could potentially affect productivity, survivorship and contamination of benthic sediments 

and invertebrates (the primary prey for gray whales) as well as pelagic zooplankton near shore and in 

the Arctic marine and ice environments over the shallow continental shelf in the Chukchi Sea. 

Adverse impacts to food availability and potential bioaccumulation could occur. 

Minke Whale 

Potential impacts to minke whales during Phase 4 are similar to those described for bowhead whales. 

Beluga Whale 

Potential impacts to beluga whales during Phase 4 are similar to those described for bowhead whales, 

except as noted below. Belugas are high frequency sensitive odonocete whales and are sensitive to 
BOEMRE Sale 193 Revised Draft SEIS 

200 CHAPTER IV. Environmental Consequences 

high frequency noise produced by industrial activities including icebreakers (Cosens and Dueck, 

1993). Avoidance and flight responses have been observed. 

Icebreaker cavitation noise modeled by Erbe and Farmer (2000) indicated icebreaker noise was 

audible over ranges of 35-78 km and zone of behavioral disturbance was only slightly smaller. 

Masking of beluga communication signals is predicted at 14-71 km off the Canadian Coast Guard 

icebreaker Henry Larson. 

Beluga whale rescue actions during a VLOS are considered highly improbable by NMFS. In the 

event that any rescue attempts are possible, they would occur in the lagoons, where contact with oil 

could occur in nearshore waters close facilities, equipment, and personnel. Rescue efforts for injured 

or stranded belugas may bring small vessels into the vicinity of other belugas already stressed from 

oil contact and watercraft. Further injury or mortality could occur during rescue operations as well as 

during post rescue treatment and recovery. Recovery of stranded, floating, and otherwise dead or 

severely injured belugas or other marine species likely would be on shore (stranded) or shallow water 

and not likely to be in the company of other live belugas at sea. Stranded belugas may be in groups 

of live animal or with injured and mortalities included. Rehabilitation and treatment facilities likely 

would be on board a ship or land based and some mortality and injury could occur during transport 

from rescue site to such facilities. Population level defects are not expected from rescue operations 

that are likely handling animals already injured and may be predisposed to mortality. 

Killer Whale 

Potential impacts to killer whales during Phase 4 are similar to those described for bowhead whales. 

Harbor Porpoise 

Potential impacts to harbor porpoise during Phase 4 are similar to those described for bowhead 

whales. 

Phase 5 - Long Term Recovery 

Over the long term, marine mammals including cetaceans would experience continued exposure to 

aircraft and vessel noise and traffic. Effects would be similar to those discussed in the sections above. 

Aircraft and vessel operations would be supporting many longer term efforts for monitoring the 

recovery of resources, fate of oil and/or dispersants in the Arctic environment, and research and 

monitoring on the effectiveness of various cleanup and restoration practices. It would be speculative 

at this time to provide an estimate of the numbers, spatial and temporal framework, diversity of or 

effects of various post-spill research, monitoring, follow-up treatments, or intensity of post-spill 

activities. The BOEMRE acknowledges the need and reality of long term post-spill activities as such 

events offer the unique opportunity to prevent, mitigate, and restore damaged resources and human 

values in the future. Research monitoring and studies are subject to scientific research permits issued 

by NMFS, while industrial monitoring and resource studies are subject to MMPA authorizations 

issued by NMFS. These MMPA permits and authorizations contain provide stipulations and best 

practices to protect cetaceans from adverse effects, as well as enforcement measures. Vessel 

maneuvers, aircraft elevation limitations, limits to seasonal period of activity, tagging and handling 

limits, requiring marine mammal observers are some of these. Minimum impacts to individuals and 

large numbers of animals are the objective of these required actions. Effect to any given species of 

cetaceans area expected to be minimal, as subsequent determinations of studies and other efforts are 

to be carried out through MMPA authorizations from NMFS. 

Bowhead Whale 

Bowhead whales are and have been the subject of numerous research and monitoring efforts by 

agencies and industry for over three decades. New efforts are likely to continue into the future with or 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 201

without a VLOS event, which may serve to increase the level of research and monitoring of this 

species. 

Fin Whale 

Fin whales have not been subject to directed research or monitoring in the Alaska Arctic OCS and 

information regarding them has been coincidental to other studies. They have been exposed to noise 

and disturbance from industry and agency activities and from monitoring and research aircraft and 

vessel traffic. Fin whales may experience an increase in research and monitoring effort directed at 

them, as well as increases in post-spill research and monitoring actions. It is reasonable to assume 

some direct monitoring effort to be directed at post-spill fin whale response to a VLOS event. 

Humpback Whale 

Humpback whales have not been subject to directed research or monitoring in the Alaska Arctic OCS 

and information regarding them has been coincidental to other studies. They have been exposed to 

noise and disturbance of industry and agency activities, monitoring and research aircraft and vessel 

traffic. Humpback whales may experience an increase in research and monitoring effort directed at 

them as well as by other potential increases post-spill research and monitoring actions. It is 

reasonable to assume some direct monitoring effort to be directed at post-spill humpback whale 

response to a VLOS event. 

Gray Whale 

Gray whales have been the subject of numerous studies in the 1980 and 1990’s in the Bering, 

Chukchi and Beaufort seas. Since that time they have been subject to BWASP, COMIDA, 

BOWFEST and industry research and monitoring activities. Aircraft (fixed wing) and vessel traffic 

are currently and would remain the main impact producing factors upon gray whales. It is reasonable 

to assume some direct monitoring effort to be directed at post-spill gray whale response to a VLOS 

event. 

Minke Whale 

Minke whales have not been the subject of numerous studies in the Bering, Chukchi and Beaufort 

Seas. They have been subject to BWASP, COMIDA, BOWFEST, other agency and industry research 

and monitoring activities. Aircraft (fixed wing) and vessel traffic are currently and would remain the 

main impact producing factors upon minke whales. 

Beluga Whale 

Beluga whales have been the subject of numerous studies in the in the Bering, Chukchi and Beaufort 

Seas. They have been indirectly affected by other ongoing efforts including BWASP, COMIDA, 

BOWFEST and industry research and monitoring activities. Aircraft (fixed wing) and vessel traffic 

are currently and would remain the main impact producing factors upon beluga whales. It is 

reasonable to expect direct monitoring efforts to be directed at post-spill beluga whales in the Arctic 

Chukchi Sea as result of a VLOS event. 

Killer Whale 

Killer whales, being infrequently observed and occurring in low numbers, have been observed in the 

Chukchi and Beaufort Seas incidental to other studies. They have been indirectly observed as result 

of BWASP, COMIDA, BOWFEST, other native, agency and industry traditional knowledge and 

research and monitoring activities. Aircraft (fixed wing) and vessel traffic are currently and would 

remain the main impact producing factors upon killer whales. 
BOEMRE Sale 193 Revised Draft SEIS 

202 CHAPTER IV. Environmental Consequences 

Harbor Porpoise 

Harbor porpoise, being infrequently observed and occurring in low numbers, have been observed in 

the Chukchi and Beaufort Seas incidental to other studies. They have been indirectly observed as a 

result of BWASP, COMIDA, BOWFEST and other Native, agency, and industry traditional 

knowledge and research and monitoring activities. Aircraft (fixed wing) and vessel traffic are 

currently and would remain the main impact producing factors upon killer whales. 

Oil Spill Trajectory Analysis 

A hypothetical VLOS could contact offshore areas when and where ESA listed and non-ESA listed 

cetaceans may be present. The location, timing and magnitude of a VLOS and the concurrent 

seasonal distribution and movement of cetaceans would determine whether or not contact with the oil 

occurs. The Oil Spill Risk Analysis (OSRA) models oil spill trajectories from 13 launch areas (LAs). 

The LAs are shown in Figure B-10. 

This section describes the results estimated by the OSRA model for a hypothetical VLOS originating 

within 13 LAs) in the Chukchi Sea Sale 193 Area contacting specific Environmental Resource Areas 

(ERAs). ERAs noted in this section are spatial representations (polygons) that indicate a geographic 

area important to one or more cetacean species (USDOI, MMS 2007a, Appendix A, Table A.1-15). 

For the purpose of this analysis, the hypothetical the initial event for a very large oil spill could occur 

any time between July 15 and October 31 and represents a “summer spill.” A 60 day contact period 

for a summer open water season spill considers that a spill could persist on the surface of the water 

for up to three weeks before it has dissipated. Oil could continue to spill after October 31 and spilled 

oil could freeze into the newly forming ice, remain encapsulated in ice throughout the winter and be 

released as the ice warms and thaws in the spring; therefore, continued spillage of oil after October 31 

is considered a “winter spill” with a conservative spilled oil contact period of 360 days. To complete 

a relief well would take between 39 and 74 days. Fresh oil contributed to the marine environment 

after October 31 would be considered a “winter spill”. The effectiveness of oil spill response 

activities is not factored into the results of the OSRA model. 

The following discussion presents the results estimated by the OSRA model of the hypothetical 

VLOS contacting ERAs important to cetacean species. The dynamics of oceanographic, climatic, and 

biotic factors affecting the distribution and abundance of prey, timing of accessibility to habitats, and 

corridors for movement determine the opportunity for cetaceans and oil to come into contact. There 

are situations where aggregations of cetaceans of one or more species can contact oil. Trajectory 

contact with an ERA does not indicate the entire ERA is oiled, only that it is contacted somewhere. 

Bowhead Whale 

Summer Spill. The OSRA model results, unless otherwise noted, are expressed as percent of spill 

trajectories contacting within 60 days during summer (Table B-7). The OSRA model estimates that 

trajectories from LAs 1-13 could contact ERAs important to bowhead whales. The OSRA model 

estimates <0.5 to 36% of the spill trajectories starting at LA1-LA13 contact a foraging area for 

aggregations of gray whales and bowheads in some summer-fall periods (ERA 6). A spill originating 

within LAs 11, 12 and 13 represent the highest percentage of trajectories contacting with 16%, 35% 

and 36% respectively. These LAs are adjacent to or in the immediate proximity of ERA 6. 

ERAs 29-35 and 42 represent the fall migration corridor and periodic fall feeding aggregations for 

bowheads in September and October. The percentage of trajectories from LA1-LA13 contacting 

these ERAs during the September-October period are ≤5% with the exception of the Barrow 

subsistence area (ERA 42) which is a major bowhead feeding aggregation in most years and for some 

gray whales each year. The OSRA estimates the percentage of trajectories contacting ERA 42 ranges 

from <0.5 to 12% from LA1-LA13. A spill originating in LAs 8 and 13 have 12% and 10% 

trajectories contacting ERA 42 respectively. These LAs are immediately adjacent ERA 42. 
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CHAPTER IV. Environmental Consequences 203

Fall migration across the U.S. Chukchi Sea is more widespread across ERAs 35, 36 and 56. The 

OSRA model estimates <0.5 to 60% of the spill trajectories starting at LA1-LA13 contact ERAs 35, 

36 and 56. A spill originating in LAs 12 and 13 would have 50 and 60 percent of trajectories, 

respectively, contacting ERA 35, and percentages of trajectories range between 16% and 22% for 

spills originating in LAs 6, 7, 8 and 11. All other LAs have percentages less than 15%. The 

percentage of trajectories contacting ERA 36 from LAs 10 and 11 are 38% and 51% respectively. The 

percentage of trajectories contacting ERA 56 are 40%, 40%, 56%, and 27% from LAs 6, 7, 12, and 

13, respectively. Peripheral ERAs that experience fall migrating bowheads across the U.S. and 

Russian Chukchi Sea (ERAs 63, 70, 74, 82, and 91) have percentages of trajectories contacting ≤10% 

for LAs 1–13. 

Winter Spill. Winter spills, which include fresh oil entering the marine environment after October 

31 can, within 60 days, contact ERAs through which bowhead whales migrating in late fall across the 

Chukchi Sea during the month of November. Satellite tracking bowheads in 2006 through 2010 

(Quakenbush, 2010b) have indicated bowhead movement through ERAs 16, 46, 61,74, 82, 83, and 

91 during November however; the OSRA estimates only ERAs 16 and 61 have 3% within 60 days 

from LA6. 

Winter spilled oil trapped under ice in early winter that becomes free of ice in spring could contact 

ERAs important to spring migrating and calving bowhead whales within 360 days of a winter spill. 

The Chukchi spring lead systems (ERAs 19-23 and 45) are critical to spring migrating and calving 

bowhead whales from late March to mid-June. Winter spilled oil that entered the marine environment 

on or before January 4 (74 days after a spill event October 31) would have been trapped in ice and 

released over winter and spring. Much of the toxic aromatic hydrocarbon component would have had 

the winter period to dissipate into the atmosphere through cracks and moving ice and open water of 

the polynya system through which many bowheads calve and migrate; thereby much of the inhalation 

hazard is somewhat reduced. From LA1-LA13 the OSRA model estimates range from <0.5-14% 

within 360 days for ERAs 19-23 and from LAs 4, 9, 10 and 11 are ≥5%. For ERA 22 the percentage 

of trajectories contacting from LAs 5, 10 and 11 is 6%, 12% and 14% respectively. For ERAs 20 and 

21 the percentage of trajectories contacting from LA10 are 8% and 10% respectively. For ERA 45 

the percentage of trajectories contacting from LA9 is 7% within 360 days; all other LAs are less than 

5%. 

The percentage of trajectories contacting ERAs 12 and 24-28 (Beaufort Sea spring polynya system 

through which bowheads migrate from Late March to late June) within 360 days during winter from 

LA1-LA13 does not exceed 5%. 

Fin Whale 

Summer Spill. Fin whales are present only during the open water season and a summer VLOS, 

occur in very low numbers and appear widely distributed in the U.S. Chukchi Sea with greater 

abundance occurring in the Russian portions of the Chukchi Sea. The observation and data records 

regarding fin whales observed in the lease sale area indicate so few occur that habitats have not been 

identified. The summer spill discussion noted above for bowhead whales may best represent the fin 

whale habitats contacted by a VLOS emanating in the Chukchi Sea. 

Humpback Whale 

Summer Spill. Humpback whales, which are only present during the open water season and a 

summer VLOS, occur in very low numbers and appear to be distributed within 80 miles of the 

Chukchi Sea Alaska shore. The observation and data records regarding humpback whales observed 

in the lease sale area and adjacent areas indicate so few occur there that habitats have not been 

identified. Gray whale percentage of trajectories contacting ERAs are discussed below for a summer 

VLOS, and may best represent humpback habitat use at this time. 
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204 CHAPTER IV. Environmental Consequences 

Gray Whale 

Summer Spill. Probabilities in the following discussion, unless otherwise noted, are results 

estimated by the OSRA model expressed as percentage of trajectories contacting within 60 days 

during summer (Table B-8). Gray whales are primarily present in the Chukchi and Beaufort Seas 

during the open water season and vulnerable to a summer VLOS. ERAs 6, 35 and 42 represent 

consistent annual feeding aggregations gray whales and bowhead whales during the summer and fall 

period (Ljungblad, et al. 1988; Clark, et al. 2011; COMIDA, 2009). Prey injury, mortality, and long 

tern exposure of gray whale prey, benthic invertebrates, to contact with oil present emphasis on these 

ERAs. The OSRA model estimates <0.5 to 36% of the spill trajectories starting at LA1-LA13 contact 

a foraging area for aggregations of gray whales and bowheads in some summer-fall periods (ERA 6). 

A spill originating from LAs 11, 12 and 13 represent the highest percentage of trajectories contacting 

with 16%, 35% and 36 % respectively. The OSRA estimates the percentage of trajectories from LA1-

LA13 contacting ERA 35 ranges from <0.5% to 60%. A spill from LAs 5, 6, 7, 8, 11, 12, and 13 

within 60 days represents the highest percentage trajectories; 8%, 16%, 20%, 20%, 22%, 60%, and 

50%, respectively. The percentage of trajectories from LA1-LA13 contacting ERA 42, ranges from 

<0.5% to 10% and the highest percentages are 8% and 10% from LAs 8 and 13 respectively. LAs 5, 

6, 7, 8, 11, 12, and 13 are adjacent to or in the immediate proximity of ERA 6 having percentage of 

trajectories contacting ERA 6 of 6%. 8%, 11%, 15%, 16%, 35%, and 36%, respectively. Historically 

other shallow shoals (ERA 48, Hanna Shoal) have been used by feeding gray whales. Industry 

observations (Funk et al., 2010 and 2011) indicate summer presence of gray whales in the general 

areas of current leases east and south of Hanna Shoal in the U.S. Chukchi Sea. A percentage of 

trajectories contact ERA 6 from all LAs except LA9. Of these, all but two have percentage of 

trajectories contacting ≥5% and ≤47%. The OSRA estimates the percentage of trajectories 

contacting from LAs 2, 3, 5, 6, 7, 11, 12 and 13 are 15%, 18%, 17%, 47%, 17%, 20%, 15% and 8%, 

respectively. 

Gray whales that summer in the U.S. and Alaska Chukchi Sea migrate in early summer and fall along 

the U.S. and Alaska Chukchi coastline. Migrating gray whales could contact spilled oil from a VLOS 

in ERAs 38, 39, and 40. The OSRA estimates the percentage of trajectories contacting these ERAs 

vary from <0.5 to 27% with the ≥5% from LAs 5, 9, 10, 11, 12 and 13. 

Minke Whale 

Summer Spill. Minke whales are present only during the open water season, occur in low numbers 

and appear widely distributed in the Alaska Chukchi Sea. The observation data regarding minke 

whales observed in the lease sale area indicate so few occur there that habitats have not been 

identified. The Chukchi Sea summer spill discussion noted above for bowhead whales may best 

represent the minke whale use area contact with a VLOS. 

Beluga Whale 

Summer Spill. Deaths attributable to oil contamination are more likely to occur during periods of 

natural stress such as during molting, times of food scarcity, birthing/nursing, or disease or parasite 

infestations. Beluga whales may be more vulnerable to VLOS effects when large numbers of belugas 

gather in Kasegaluk Lagoon each summer to molt. According to OSRA modeling, the percentage of 

trajectories contacting Kasegaluk Lagoon (ERA 6) for LA1-LA13 ranges from <0.5 to 32% over a 

period of 60 days (Appendix B, Table B-7). If a VLOS did contact the shoreline, oil could persist up 

to more than a decade in the sediments (USDOI, MMS, 2003: Section IV.C.2.a[3][b][2]). The OSRA 

estimates ERA 40, the Wainwright subsistence area, has 23% and 27% trajectories contacting from 

LAs 11 and 12 respectively. All other LAs have 8% or less. The percentage of trajectories 

contacting the Elson Lagoon 2010 beluga aggregation area and Barrow subsistence area north east of 

Barrow (ERA 42) from LAs 9 and 13 are 10% and 12%, respectively, with the remainder of LAs 

ranging from < 0.5% to 2%. 
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CHAPTER IV. Environmental Consequences 205

Winter Spill. Beluga whales would also be vulnerable to oil contact during the spring migration 

(April through June) throughout the spring lead system. Direct contact with some spilled oil could 

occur portions of the spring lead system were contaminated with oil slick. According to OSRA 

modeling, the percentage of trajectories contacting the spring lead system (ERA’s19-23) from LA10 

is 11% and the remainder of the LAs range from <0.5% to 8% within 360 days. The OSRA model 

estimates the percentage of trajectories contacting ERA 13, the Kivalina Subsistence are <0.5% for all 

LAs and for ERA 38, the Point Hope subsistence area, are all <2%. 

Killer Whale 

Summer Spill. Killer whales are present only during the open water season and a summer VLOS, 

occur in very low numbers and appear widely distributed in the Alaska Chukchi and Beaufort Seas. 

The observation data regarding killer whales observed in the lease sale area indicate so few occur 

there that habitats have not been identified. The Chukchi Sea summer spill discussion noted above 

for bowhead whales may best represent killer whale use areas that could be contacted by a VLOS. 

Harbor Porpoise 

Summer Spill. Harbor Porpoise are present only during the open water or ice free season, occur in 

low numbers and appear distributed along the Alaska Chukchi coast and the Arctic lagoons (Elson 

Lagoon, Kugrua Lagoon) and along the coast between Wainwright and Barrow and (Suydam and 

George, 1992; Roseneau, 2010)). The observation data regarding harbor porpoise observed in the 

lease sale area indicate so few occur there that habitats have not been identified. The Chukchi Sea 

summer spill discussion noted above for Gray whales and beluga whale nearshore ERAs may best 

represent the harbor porpoise use areas that could be contacted by a VLOS. 

Conclusion 

Direct contact with spilled oil resulting from a VLOS would have the greatest potential to adversely 

affect cetacean species when toxic fumes from fresh oil are inhaled at times and places where 

aggregations of cetaceans may be exposed. Cetaceans would avoid oil spill response and cleanup 

activities, causing displacement from preferred feeding habitats, and could deter from migration paths 

for the duration of those activities. Presence of oil on and in the water may be avoided by some and 

not other cetaceans. Cetaceans as a general group would likely experience some loss of seasonal 

habitat, reduction of prey, and contamination of prey. Consumption of contaminated prey may 

adversely affect distribution, abundance and health of cetaceans. Human activities brought about by 

implementation of Oil Spill Response Plans, cleanup and remediation, and post-spill event follow-up 

treatment and research and monitoring efforts may displace cetaceans. A variety of adverse effects on 

cetaceans could result from contact with and exposure to a VLOS event ranging from simple 

avoidance to mortality of large numbers of cetaceans depending on timing, location, cetacean species 

involved, and circumstances unique to a given spill event. 

It may be possible to mitigate some of these potential impacts, or at least reduce the potential for 

certain impacts to occur, by implementing one of the deferral corridors included in Alternatives III 

and IV. Selection of Alternative III would implement the 60-mile Corridor I Deferral illustrated in 

Figure 1. This corridor would reduce the areas of Launch Areas 8, 9, 10, 11, 12, and 13 available for 

lease. Hypothetical spills from these LAs exhibit comparatively higher potential for impacts to 

bowhead whales as compared to other LAs. This tendency is due to the proximity of these LAs to the 

spring and fall bowhead migration routes. Hypothetical spills emanating from LAs 8-13 also have 

increased potential to contact coastal areas used by gray whales, beluga whales and harbor porpoises. 

The proposed deferral corridors are of less consequence for species lacking affinity for nearshore 

areas. Another manner in which the 60-mile corridor could reduce potential impacts is by increasing 

the minimum distance of a potential spill source from shore. Longer distances between spill source 
BOEMRE Sale 193 Revised Draft SEIS 

206 CHAPTER IV. Environmental Consequences 

and shore could allow more time for response to mobilize, and allow increased oil weathering before 

contact with shoreward ERAs. 

Alternative IV contemplates a 30-mile deferral area known as the Corridor II Deferral. Corrdidor II 

could mitigate the potential for impacts to cetaceans in the same manners as Corridor I. The 

reduction in leasable area and the minimum distance of leases from shore would be less than 

Alternative III, meaning a smaller chance of mitigation. 

More species-specific summary and conclusions are provided below: 

Bowhead Whale 

Bowhead whales could experience contact with fresh oil during summer and fall feeding event 

aggregations and migration in the Chukchi Sea and western Beaufort Sea. Skin and eye contact with 

oil could cause irritation and various skin disorders. Toxic aromatic hydrocarbon vapors are 

associated with fresh oil. Prolonged inhalation within fresh oil could result in impaired endocrine 

system function that may result in reduced reproductive function (that may be temporary or 

permanent) and/or bowhead mortality in situations where prolonged exposure to toxic fumes occurs. 

The rapid dissipation of toxic fumes into the atmosphere from rapid aging of fresh oil and disturbance 

from response related noise and activity limits potential exposure of whales to prolonged inhalation of 

toxic fumes. Exposure of aggregations of bowheads, especially if calves are present could result in 

multiple mortalities. It would be likely that surface feeding bowheads would ingest surface and near 

surface oil fractions with their prey, which may or may not be contaminated with oil components. 

Incidental ingestion of oil factions that may be incorporated into bottom sediments can also occur 

during near-bottom feeding. Ingestion of oil may result in temporary and permanent damage to 

bowhead endocrine function and reproductive system function; and if sufficient amounts of oil are 

ingested mortality of individuals may also occur. Population level effects are not expected; however 

in a very low probability, high impact circumstance where large numbers of whales experience 

prolonged exposure to toxic fumes and/or ingest large amounts of oil, injury and mortality is possible 

to a population level effect. 

Exposure to bowheads could occur in the spring lead system during the spring calving and migration 

period. Exposure to aged winter spill oil (which has had a portion or all of the toxic aromatic 

compounds dissipated into the atmosphere through the dynamic open water and ice activity in the 

polynya) presents a much reduced toxic inhalation hazard. Some inhalation, feeding related ingestion 

of surface and near surface oil fractions may occur during this period and may result in temporary 

and/or permanent effects on endocrine and reproductive performance. It is possible that a winter spill 

would result in a situation where toxic aromatic hydrocarbons would be trapped in ice for the winter 

period and released in toxic amounts in the spring polynya system when bowheads are migrating 

through in large numbers. In this low probability situation, large numbers of calves could die and 

recovery from the loss of a large portion of an age class cohort and its contribution to recruitment and 

species population growth could take decades. 

Bowhead whales could be exposed to a multitude of short and longer term additional human activity 

associated with initial spill response, cleanup and post event human activities that include primarily 

increased and localized vessel and aircraft traffic associated with reconnaissance, media, research, 

monitoring, booming and skimming operations, in-situ burning, dispersant application and drilling of 

a relief well. These activities would be expected to be intense during the spill cleanup operations and 

expected to continue at reduced levels for potentially decades post event. Specific cetacean 

protection actions would be employed as the situation requires and would be modified as needed to 

meet the needs of the response effort. The response contractor would be expected to work with 

NMFS/NOAA and State officials on wildlife management activities in the event of a spill. The two 

aforementioned groups most likely would have a presence at the Incident Command Post to review 

and approve proposed activities and monitor their impact on cetaceans. As a member of the team, 
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CHAPTER IV. Environmental Consequences 207

NMFS/NOAA personnel would be largely responsible for providing critical information affecting 

response activities to protect cetaceans in the event of a spill. 

Bowheads would be expected to avoid vessel supported activities at distances of several kilometers 

depending on the noise energy produced by vessel sound sources; drill rig; numbers and distribution, 

size and class of vessels. Migrating whales would be expected to divert up to as much as 20-30 km 

around relief well drilling operations and up to a few km around vessels engaged in a variety of 

activities. Temporary and non-lethal effects are likely from the human activities that would be related 

to VLOS response, cleanup, remediation, and recovery. Displacement away from or diversion away 

from aggregated prey sources could occur, resulting in important feeding opportunity relative to 

annual energy and nutrition requirements. Frequent encounters with VLOS activities and lost feeding 

opportunities could result in reduced body condition, reproductive performance, increased 

reproductive interval, decreased in vivo and neonatal calf survival, and increased age of sexual 

maturation in some bowheads. Effects from displacement and avoidance of prey aggregations and 

feeding opportunities as a result of human activities associated with spill response, clean-up, 

remeditation and recovery are not expected to result in population level effects. 

Fin Whale 

A few individual fin whales could experience similar effects as noted for bowheads above if 

contacted by oil during the ice free period. Fin whale prey (schooling forage fish and zooplankton) 

could be reduced or contaminated, leading to modified distribution of fin whales and/or ingestion of 

oil contaminated prey. Temporary and/or permanent injury and non-lethal effects are likely and 

mortality or population level effects are considered to be unlikely. 

Fin whales would likely avoid the noise related to VLOS response, cleanup and post-event human 

activities similar to that noted for bowhead whales. 

Humpback Whale 

A few individual humpback whales could experience similar effects as noted for bowheads above if 

contacted by oil during the ice free period. Humpback whale prey (primarily schooling forage fish) 

could be reduced and/or contaminated, leading to modified distribution of humpback whales or 

ingestion of oil contaminated prey. Temporary and/or permanent injury and non-lethal effects are 

likely and mortality or population level effects are considered unlikely. If prey populations, presence, 

productivity and distribution are reduced due to VLOS effects, humpback habitat value would be lost 

unless the humpbacks in the Alaska Chukchi and Beaufort Seas originate from the Western North 

Pacific stock. In the latter case, mortality may take three generations or more to restore. The few 

individual humpbacks in the Alaska OCS and nearshore may be exhibiting pioneer behavior and 

recovery of even a few animals may require similar pioneer behavior from areas of the Bering Sea 

and southwestern Chukchi where these whales are more abundant. 

Humpback whales would likely avoid the noise related to VLOS response, cleanup and post-event 

human activities similar to that noted for bowhead whales. 

Gray Whale 

Gray whale aggregations have consistently occurred near shore along the Alaska Chukchi Sea coast 

from west of Wainwright to northeast of Barrow. This zone would likely be the location of much of 

the cleanup operations to protect the coastline, lagoons, and river mouths. Avoidance of intense 

activities could displace gray whales from preferred feeding areas. Oil contamination of benthic 

sediments and/or mortality of benthic invertebrates that these whales require could result in a 

recovery period of many years, and result in abandonment of these primary summer feeding areas that 

provide the majority of the annual nutritional and energy requirement of these whales. Reduction in 

body condition, and potential mortality from insufficient body energy to complete the long distance 
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208 CHAPTER IV. Environmental Consequences 

migration of this species to and from as far south as Mexico could occur. Reduction or loss of the 

portion of the Western North Pacific stock of gray whales using the Chukchi Sea would likely take 

three generations or more to recover. Population level adverse effects from loss or reduction of prey 

resources nearshore could result in changes in distribution, habitat use, and/or presence in the 

Chukchi Sea. Loss of food sources could be reflected in individual body condition and mortality 

during the long stressful migrations this species endures. 

Minke Whale 

Individual minke whales could experience similar effects as noted for bowheads above if contacted 

by oil during the ice free period. Minke whale prey could be reduced or contaminated, leading to a 

modified distribution of minke whales or ingestion of oil contaminated prey. Temporary and/or 

permanent and non-lethal effects are likely and mortality or population level effects are considered to 

be unlikely. Changes in distribution of minke whales in the Alaska Chukchi Sea are not likely. 

Minke whales would likely avoid the noise related to VLOS response, cleanup, and post-event human 

activities they may encounter, similar to that noted for bowhead whales. 

Beluga Whale 

Beluga whales are vulnerable to contact with a VLOS when large aggregations are gathered in the 

lagoons and nearshore habitats along the Alaska Chukchi Sea coast during molting and nursing. The 

fate of beluga prey, especially Arctic cod and other Arctic fisheries, would affect seasonal habitat use, 

determine if toxic amounts of contaminated fish are ingested, or possibly change distribution of these 

whales until fisheries recovery occurs. Temporary and/or permanent injury and non-lethal effects are 

likely. Toxic levels of ingestion could alter endocrine system function and reproductive system 

function and in severe cases result in mortality of individual whales. 

Belugas would come into contact with the human activities associated with cleanup operations when 

near shore, where localized intensive boom and skimming efforts to protect lagoons and other coastal 

resources occur. Avoidance behavior and stress to belugas (that have also experienced small boat 

supported subsistence hunting) in coping with concentrated cleanup activities is likely. Once 

offshore, belugas could experience inhalation of fumes of fresh spilled oil. Prolonged inhalation of 

toxic fumes or accidental inhalation of surface oil could result in temporary and/or permanent injury 

or mortality to some individuals. Displacement from or avoidance of important nearshore habitats are 

anticipated in subsequent years after a spill could redistribute seasonal use of the Chukchi Sea 

nearshore areas to less optimal molting and nursing areas and potentially reduce population 

productivity and recruitment. Should cleanup activities occur in or near lagoons or nearshore feeding 

areas, molting, or birthing habitats, beluga would abandon these areas for as long as spill related 

activities persisted. Post spill recovery of belugas to pre-spill abundance and habitat use patterns 

would be dependant upon the recovery periods necessary to restore pre-spill levels of prey 

populations and the quality of near-shore preferred habitats. Recovery would also depend on the 

level of human activity in and adjacent to preferred habitats. 

Killer Whale 

Individual killer whales could experience similar effects as noted for bowheads above if contacted by 

oil during the ice free period. Killer whale marine mammal prey abundance and distribution could be 

reduced, or contaminated, leading to modified distribution of killer whales and/or ingestion of oil 

contaminated prey. Temporary and/or permanent injury and non-lethal effects are likely and 

mortality or population level effects are considered to be unlikely. 

Killer whales would likely avoid the noise related to VLOS response, cleanup and post-event human 

activities they may encounter, similar to that noted for bowhead whales. 
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CHAPTER IV. Environmental Consequences 209

Harbor porpoise 

Individual harbor porpoise could experience similar effects as noted for bowheads above if contacted 

by oil during the ice free period. Harbor porpoise prey could be reduced or contaminated, leading to 

modified distribution of harbor porpoise or ingestion of oil contaminated prey. Temporary and/or 

permanent injury and non-lethal effects are likely and mortality or population level effects are 

considered to be unlikely. 

Harbor porpoise would likely avoid the noise related to VLOS response, cleanup, and post-event 

human activities. The apparent distribution of the porpoises near shore and in the various lagoons 

where forage fish are abundant puts these animals at risk of frequent contact with spill clean up 

activities. Such activities are concentrated (to place booms and skim oil) near the mouths of rivers and 

near lagoons to protect coastline resources. A reduction of coastal fisheries could reduce the capacity 

of the Chukchi Sea near shore to support harbor porpoise and, consequently, redistribution of 

porpoises could occur. Ingestion of contaminated fish could reach toxic levels and result in impaired 

endocrine function, reproductive impairment, or mortality. Reduction or loss of harbor porpoise in 

this region requires pioneering individuals or the memory of individuals now using the area to “teach” 

others that the region is available. A substantial reduction in the low numbers that occur in offshore 

Alaska Chukchi Sea may take greater than three generations to recover due to the remoteness of this 

part of their range and the pioneering behavior required to recover. 

IV.E.8. Polar Bears 

Polar bears are listed under the Endangered Species Act (ESA) as threatened throughout their range. 

Critical habitat is established for this species and consists of barrier islands, sea ice and terrestrial 

denning habitat (75 FR 76086 [December 7, 2010]). A very large oil spill (VLOS) could affect polar 

bears and polar bear critical habitat on sea ice, barrier islands or on the coast. Effects could result 

from direct contact with oil, inhalation or exposure to toxic fumes from the oil (such as polycyclic 

aromatic hydrocarbons or PAHs), ingestion of oil or contaminated prey, habitat loss or a lack of 

available prey. Additional effects could occur during clean up. These impacts could include inhalation 

or exposure to toxic fumes from clean up products, fouling of fur, disturbance at important on ice or 

terrestrial sites, and continued contamination or loss of prey species or contamination of important ice 

habitats. 

The impacts that occur during each phase of a blowout and subsequent clean up are discussed below. 

The most direct impacts would occur as a result of Phases 2 and 3, which entail an offshore oil spill 

and onshore contact. 

Phase 1 (Initial Blowout Event) 

The initial phase would likely consist of a large explosion of natural gas and a fire. The rig may or 

may not be disabled or sink at that point. The impact producing factors that might effect polar bears 

would be the explosion itself (depending upon the size of the explosion) and the smoke and debris 

resulting from the fire. As drilling would occur during the open water season, polar bears are not 

likely to be in the area when the explosion occurs. Polar bears are known to swim long distances 

between shore and sea ice (Schliebe, et al., 2008; Gleason and Rode, 2009), but would likely avoid 

the noise and activity associated with drilling (Anderson and Aars, 2008). 

Phase 2 (Offshore Oil Spill) 

Polar bears rely on their fur and a subcutaneous layer of fat for insulation and any oiling would cause 

the fur to lose its insulating ability. Hurst and Oritsland found that polar bear pelts were similar to 

those of sea otters and fur seals in terms of the loss of insulation once oiled (Hurst and Oritsland, 

1982). Once oiled, polar bears could ingest oil while grooming. Exposure to oil or associated fumes 

could cause respiratory distress and inflammation of mucous membranes and eyes, leading to damage 
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210 CHAPTER IV. Environmental Consequences 

such as abrasions and ulcerations. High levels of exposure would likely result in death. Chronic low 

levels of exposure may result in long term sub-lethal effects that reduce fitness. Oiling could lead to 

hypothermia and result in increased energetic costs or death. Polar bears could also ingest oil by 

eating oiled seals or carcasses, which could lead to impacts to kidney or liver function. 

Polar bears rely primarily on ringed and bearded seals as prey in the Chukchi Sea, but they will also 

take beluga and walrus. Polar bears will scavenge marine mammal carcasses when available, and do 

not show an aversion to petroleum products. Polar bears have been observed biting cans of 

snowmobile oil and neoprene bladders of fuel. One polar bear died as the result of eating a car 

battery, while another died after ingesting ethylene glycol (Geraci and St. Aubin, 1990; Amstrup et al 

1989). Polar bears scavenging on oiled seal carcasses could ingest lethal doses of oil. Studies on seal 

species have indicated that seals intent on feeding will not avoid an area due to oil or oil sheens 

(Geraci and St. Aubin, 1990). Polar bears may pursue seals in oiled waters. Ringed and Bearded seals 

have the ability to metabolize small amounts of hydrocarbons so that such tissue damage is temporary 

unless the exposure is chronic over time (Kooyman, Gentry and McAlister, 1976). Long term or 

chronic oil ingestion may result in kidney damage, liver damage, or ulcers in the digestive tracts of 

seals and the polar bears that feed upon them. 

Phase 3 (Onshore Contact) 

Depending upon the location of the spill site and other factors, BOEMRE has estimated that oil could 

contact shore within 10 days (see Table 5). Polar bears could come into contact with oil as they move 

along the coast or barrier islands, or while moving between shore and the ice edge. Regardless of 

whether contact occurred at sea, on ice or on land, the results to the physical health of the polar bear 

would be the same as those listed under Phase 2. If polar bears avoid coastal areas that have been 

fouled by oil, they may be excluded from important resting or denning areas, which may impact 

fitness or breeding success. 

Phase 4 (Spill Response and Cleanup) 

Spill response and clean up activities would involve large number of boats of various sizes, skimmers, 

airplanes and helicopters. In-situ burning and corralling oil with boom material, or booming off 

sensitive nearshore habitats may occur. Although the U.S. Coast Guard (USCG) has not previously 

approved the use of dispersants in the Arctic, their use in the event of a VLOS is foreseeable. 

In the initial aftermath of a spill, activity would be concentrated in the immediate area of the spilled 

oil. Polar bears would not be found in large numbers in an open water environment and would likely 

avoid the area due to the large amount of noise and activity. This may reduce the likelihood that they 

would be immediately exposed to oil or be exposed to PAHs which tend to evaporate relatively 

quickly (within a few days, unless frozen into ice). Gas (primarily methane and ethane) would quickly 

dissipate into the atmosphere at the spill site and polar bears are not likely to be exposed to gas in the 

event of an explosion and spill. Immediate responses, in addition to seeking to control the well and 

stop the flow of oil, may include attempts to cap the flow or repair the rupture. In-situ burning has 

been shown to be very effective with freshly spilled oil, but the oil becomes more difficult to ignite as 

it ages and the aromatic hydrocarbons burn or evaporate. In-situ burning would release soot and other 

pollutants into the air, if the soot is carried by air currents to shore or to ice floes, polar bears may be 

exposed to enough smoke and soot to suffer respiratory effects, or may have their coats soiled by 

pollutants, which they then might ingest while grooming. 

As the spill response continues, the oil (and thus the response) will become spread out over a larger 

area. The amount of oil being discharged daily would decrease as the pressure remaining in the well 

decreases. BOEMRE has estimated that the flow of oil would decrease from a high of 60,000 

bbls/day to a little over 20,000 bbls/day over a 74-day uncontrolled well incident. Depending upon 

the location of the spill site and the time of the spill, the BOEMRE estimates that a discontinuous area 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 211

of 162,200 square kilometers (km2) to 547,600 km2 would be contacted by oil. As the spill continues, 

clean up efforts would likely focus on the spill site, villages and areas deemed to be critically 

important to fish or wildlife. If the spill begins late in the open water drilling season (September to 

October), then the longer that the spill goes on, the more likely it becomes polar bears will encounter 

oil and/or disturbance from clean up efforts. In recent years, more polar bears have congregated on 

shore while waiting for the sea ice to form. Large aggregations of bears from the SBS stock now 

occur near Cross Island and Barter Island, where bears scavenge on whale carcasses. Wrangel Island 

also has large numbers of bears from the CBS stock. Were oil to contact one of these aggregations of 

bears, it would constitute a significant impact to the population. 

The next phase after the VLOS has been stopped would involve cleaning of any remaining oil that 

can be located. Clean up efforts could focus on oiled shoreline, and hot washing methods or 

dispersants could be used. While dispersants can be effective at breaking oil up into smaller droplets, 

they also contain toxic chemicals such as hydrocarbon solvents and glycols. Dispersants may cause 

skin irritations, respiratory impacts or impacts to sensitive tissues around the eyes, nose or mouth. 

Polar bears may be drawn to the area by human activity or carcasses, or they may avoid the areas. 

Additional human-polar bear interactions could result in an increase in polar bear take through hazing 

or in defense of human life. It may be possible in some instances to sedate and capture oiled polar 

bears, and to clean their coats. However, if these bears had already ingested oil, they would not be 

likely to survive. A study of polar bear reactions to snowmobiles found sex and age class differences 

in reaction. Females with cubs and single smaller bears reacted more strongly by avoidance than did 

adult males or single adult females (Anderson and Aars, 2008). Similarly, anecdotal information from 

ice breakers suggests that bears are likely to move away from ice breaking activities unless they are 

actively feeding. 

The clean up process may be continued the year following the spill. Oil frozen in ice over winter 

would melt out in the spring, through brine channels and into leads and polynyas (Fingas and 

Hollebone, 2003). Skimmers and other methods may be used to try to capture this remaining oil the 

spring/summer following the spill. This could lead to additional disturbance to polar bears in the 

leads and polynyas where they tend to focus their hunting efforts. Polar bears may also be exposed to 

oil in the leads and open water between floes or on the floes themselves depending upon the 

distribution of the remaining oil once it melts out of the winter ice. 

Phase 5 (Long Term Recovery) 

After clean up efforts have ceased, the remaining oil will continue to weather and be subject to 

microbial degradation. This process is likely to be very slow in Arctic waters. Oil that has been 

suspended in the water column or in the sediment may continue to be ingested by the benthic 

organisms that bearded seals and walrus prey upon. Ringed seals are less likely to accumulate 

hydrocarbons through the fish that they eat (Geraci and St. Aubin, 1990). Polar bears that are eating 

bearded seals or walrus may continue to be exposed to hydrocarbons through their prey, which may 

lead to reduced fitness over time. 

Damage assessment studies will occur as a part of the natural resource damage assessment process 

(NRDA). Depending upon the types of studies conducted, some may lead to increased disturbance by 

adding additional boat, plane and shoreline traffic to the Chukchi Sea. 

Oil Spill Trajectory Analysis 

A VLOS could contact offshore or onshore areas where polar bears may be present. The degree of 

contact with oil would depend upon the location, timing, and magnitude of the spill. The OSRA 

model divides the 193 lease sale area into 13 launch areas (LAs) to model the spill trajectories from 

different sources of origin. The LAs are found in Appendix B, Figure B-10. In many instances, the 
BOEMRE Sale 193 Revised Draft SEIS 

212 CHAPTER IV. Environmental Consequences 

differences between launch areas are less important than the magnitude of the spill given the large 

area that a VLOS could encompass. 

The drilling season in the Chukchi Sea is the open water season, typically between July 15 and 

October 31. The time period for stopping the spill with a relief well ranges from 39 to 74 days. The 

BOEMRE estimates that spilled oil could remain on the surface of the water for up to 3 weeks. A 

spill beginning early in the open water season and stopped within 39 days would therefore persist for 

60 days. A spill which started late in the open water season or was not stopped for 74 days would 

likely freeze into the ice and persist over winter, melting out in the spring. The BOEMRE therefore 

analyzed a summer spill that persists for 60 days and 360 days, and a winter spill that persists for 360 

days. 

This section describes the results estimated by the Oil Spill Risk Analysis (OSRA) model of a 

hypothetical very large oil spill in the Chukchi Sea contacting specific Environmental Resource Areas 

(ERAs), Land Segments (LSs) or Grouped Land Segments (GLSs) where polar bears may be found. 

With the exceptions of Cross Island, Barter Island and Wrangel Island, CBS and SBS polar bears are 

not usually found in large aggregations. Reductions in sea ice may be resulting in more bears coming 

ashore and in individual bears spending more time on shore during the fall open water season 

(Schliebe et al, 2007). Both ringed seal distribution and ice conditions affect polar bear densities. 

Polar bear populations have been observed to increase or decline as seal populations increase or 

decline (Stirling, 2002). Polar bears hunt ringed seals in spring leads, pack ice, and at their breathing 

holes. In spring, polar bears preferentially hunt pups in lairs (Stirling and Archibald, 1977). In 

addition to areas where polar bears concentrate while waiting to den or for the sea ice to freeze 

(Wrangel Island, Barter Island and Cross Island, and to a lesser extent Kolyuchin Island, and the Pt. 

Barrow area), this analysis is focused on the Chukchi and Beaufort sea spring lead systems, and on 

near shore ice in the Beaufort Sea. The estimated percentage of trajectories contacting the Russian, 

Chukchi or Beaufort Sea coastlines in the event of a very large oils spill have also been analyzed. A 

VLOS that occurred during the summer open water period or during the fall broken ice period is 

likely to have the greatest impact on polar bears (Amstrup et al, 2006). 

An Environmental Resource Area (ERA) is a polygon that represents a geographic area during a 

specific time period. The ERA locations are incorporated from USDOI, MMS (2007a) and found in 

Appendix B, Figures B-2 to B-5. The ERAs are summarized in Appendix A, Tables A.1–13 through 

A.1–15 of the Lease Sale 193 EIS. The vulnerability of an ERA is based on the seasonal use patterns 

of polar bears (USDOI, MMS, 2007a, Appendix A, Table A.1–12). LS and GLS are sections of the 

coastline and are not seasonal. For this analysis, we do not consider the effectiveness of clean up 

methods. We make the assumption that if oil contacts the coastline, the oil will remain there. 

In the Sale 193 FEIS, the OSRA analysis focused on Wrangel Island, Kolyuchin Island, the Russian 

coastline of the Chukchi Sea and the Barrow area. Since that time, there have been changes in polar 

bear distribution related to sea ice loss. Polar bear critical habitat has also been established which 

includes the U. S. Chukchi Sea coastline and offshore barrier islands. Additional ERAs and GLSs 

from the original EIS that were not used in relation to polar bears at that time to capture this new 

information about where polar bears may come into contact with oil have been incorporated. Where 

possible, ERAs have been used with a year round vulnerability (Jan-Dec). In the event that oil was to 

contact these ERAs in December through February, it would freeze into the ice and snow over winter 

and remain frozen in the ice until spring. The oil would then melt out of the thawing ice in the spring. 

The additional ERAs and GLSs that we have analyzed in this VLOS analysis all occur on the U. S. 

side of the Chukchi Sea. The full list of ERAs and GLSs analyzed are in Table 15. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 213

Table 15. Polar bear habitat areas analyzed in the VLOS OSRA analysis. 

ERA or GLS Geographic Description Period of 

Vulnerability 

Figure in 

Appendix 

B 

ERA 2 Pt Barrow, Plover Islands area May-Oct B-2 

ERA 8 Maguire and Flaxman Islands May-October B-4 

ERA 11 Wrangel Island with 12 mile buffer Jan - Dec B-2 

ERA 20 Southern portion of Chukchi spring lead system April-June B-3 

ERA 21 middle portion of Chukchi spring lead system April-June B-3 

ERA 22 Northern portion of Chukchi spring lead system April-June B-3 

ERAs 24-28 Beaufort Sea spring lead system April-June B-3 

ERAs 29-34 Beaufort Sea nearshore ice Sept-Oct B-4 

ERA 43 Nuiqsut subsistence area / Cross Island Aug-Oct B-5 

ERA 44 Kaktovik subsistence area/ Barter Island Aug-Oct B-4 

ERA 59 Kolyuchin Island May - Nov B-2 

ERA 69 Harrison Bay / Colville Delta May-Oct B-3 

ERA 71 Simpson Lagoon, Thetis and Joe’s Islands May - Oct B-4 

ERA 72 Gwyder Bay, Cottle Return Islands and West Dock May - Oct B-4 

GLS 95 Russian coastline, LSs 1-39 Jan-Dec B-9 

GLS 96 US Chukchi Sea coastline, LSs 40-84 Jan-Dec B-9 

GLS 97 US Beaufort Sea coastline, LSs85-111 Jan-Dec B-9 

Summer Spills (June 1 – October 31) 

The following information is summarized from Tables B-7, B-8. B-11, and B-12. A summer spill is 

defined as a spill taking place during the open water season between June 1 and October 31. The 

OSRA model estimates that 2% or fewer of the trajectories launched during this time period would 

contact Wrangel Island or Kolyuchin Island within 60 days or within 360 days. The OSRA model 

estimates that 4% or fewer of the trajectories would contact any section of the Russian coastline in 60 

days with one exception, from LA9 12% of the trajectories would contact some section of the Russian 

coastline, though not necessarily where polar bears may be. Over 360 days, the percentage of 

trajectories that would contact some section of the Russian coastline is 6% or fewer, again with the 

exception of LA9 where the percentage of trajectories contacting the coastline would be 19%. 

On the U. S. side of the Chukchi Sea, results are more variable. The percentage of trajectories 

contacting the Pt. Barrow/Plover Islands area within 60 days is 2% or less from all launch areas 

except LA8 (9%) and LA13 (8%). Within 360 days, the percentage of trajectories contacting this 

area is 2% or fewer from all LAs except LA7 (6%), LA8 (13%) and LA13 (10%). For the Chukchi 

Sea spring lead system, 3% or fewer of the trajectories would contact the spring lead system within 

60 days. Within 360 days, 4% or fewer trajectories will contact the Chukchi Sea spring lead system. 

The highest percentage of trajectories contacting the spring lead system are from LAs 10, 11 and 12. 

Fewer than 1% of trajectories from any LA would contact the Beaufort Sea spring lead system within 

60 days. Within 360 days fewer than 6% of trajectories would contact any portion of the Beaufort Sea 

spring lead system. We also analyzed the percentage of trajectories that would contact nearshore sea 

ice in the Beaufort Sea, 1% or fewer trajectories would contact any portion of the nearshore ice within 

60 days, with the exception of spills originating in LA8 (1-5%) and LA13 (0.5-5%). Over 360 days, 

fewer than 1% of trajectories would contact the sea ice nearshore with the exceptions of spills 

originating in LA7 or LA8 (2-6%) and LA13 (0.5-6%). Over 60 days, <0.5% of trajectories would 

reach the Harrison Bay/ Colville Delta area. This rises to 1% for LA8 and LA13 over 360 days. 
BOEMRE Sale 193 Revised Draft SEIS 

214 CHAPTER IV. Environmental Consequences 

Over 60 or 360 days, <0.5% of trajectories reach Maguire, Flaxman, Cross, or Barter Islands. Over 60 

or 360 days, <0.5% of trajectories reach Simpson Lagoon, Thetis or Joe’s Islands, Gwyder Bay, 

Cottle or Return Islands. 

Over 60 days, 1% of trajectories from LA1, LA2, or LA3 reach the U.S. Chukchi Sea coastline; 4-6% 

from LA4, LA6, LA7, or LA8; 9% from LA5 or LA9; 17-26% from LA10, LA11, LA12 and LA13. 

Over 360 days, 1-3% of trajectories from LA1, LA2, or LA3 reach the U.S. Chukchi Sea coastline; 6-

11% from LA4, LA5, LA6, LA7, LA8 or LA9; 20-31% from LA10, LA11, LA12 and LA13. Over 60 

days, fewer than 0.5-1% of trajectories from LAs 1-6 or from LAs 9-12 reach the U.S. Beaufort Sea 

coastline; 4% from LA7, 14% from LA8; and 15% from LA13. Over 360 days, <0.5-3% of 

trajectories from LAs 1-6 and LAs and LAs 9-12 reach the U.S. Beaufort Sea coastline; 7% from 

LA7, 20% from LA8 and 19% from LA13. 

Winter Spills (November 1 – May 31) 

The following information is summarized from Tables B-16, B-19, and B-20. A winter spill is 

defined as a spill taking place between November 1 and May 31, in other words, the trajectories 

would be launched during this time period. For a winter spill, we have only considered the full 360 

day period. The OSRA model estimates that 4% or fewer of the trajectories launched during this time 

period would contact Wrangel Island or Kolyuchin Island within 360 days. The OSRA model 

estimates that 5% or fewer of the trajectories would contact any section of the Russian coastline in 

360 days with the following exceptions: LA1 (6%), LA4 (12%), and LA9 (32%). 

For the U. S. side of the Chukchi Sea, 6% or fewer of the trajectories from any LA would contact the 

Pt. Barrow/ Plover Islands area within 360 days. For the Chukchi Sea spring lead system, fewer than 

6% of the trajectories would contact the spring lead system over 360 days with the following 

exceptions: LA10 (7-10%), LA11 (3-12%), LA12 (1-14%). For the Beaufort Sea spring lead system, 

fewer than 5% of trajectories from any LA would contact the lead system ERAs. For the Beaufort Sea 

near shore ice ERAs, fewer than 1% of trajectories would contact these ERAs. For the Harrison Bay/ 

Colville Delta ERA, <0.5% of trajectories would contact this ERA except from LA8 where 1% of 

trajectories would contact some part of the Harrison Bay/ Colville Delta ERA. The OSRA model 

estimates <0.5% of trajectories originating from any LA would contact ERAs 8, 33, 34, 43, 44, 71, or 

72. 

Over 360 days, fewer than 2% of trajectories would contact any portion of the Russian Chukchi Sea 

coastline with the following exceptions: LA1 (6%), LA4 (12%), LA9 (32%) and LA10 5%. Over 360 

days, fewer than 5% of trajectories would contact any portion of the U. S. Chukchi Sea coastline with 

the following exceptions: LA4 (8%), LA5 (12%), LA10 (28%), LA11 (21%), LA12 (20%), and 

LA13 (9%). Over 360 days, fewer than 5% of trajectories would contact any portion of the U. S. 

Beaufort Sea coastline with the following exceptions: LA7 (6%), LA8 (9%), LA12 (6%), and LA13 

(10%). 

Conclusion 

In the event of a VLOS in this scenario, most of the contact between oil and polar bear habitat would 

occur on the U.S. side of the Chukchi Sea. The majority of the CBS stock is believed to den and come 

ashore on the Russian side of the Chukchi Sea, particularly at Wrangel Island. The majority of the 

SBS stock of polar bears come ashore and den further eastward in the Beaufort Sea. However there is 

a large area of overlap between the CBS stock and the SBS stock out on the sea ice in the 

northeastern portion of the Chukchi Sea. Both stocks are believed to be in decline. If a VLOS were to 

occur and if it resulted in the loss of large numbers of polar bears, particularly adult breeding age 

females, this would have a significant impact on the SBS and/or CBS stocks of polar bears. Contact 

with oil on the U.S. side of the Chukchi Sea would be most likely to occur along the U.S. Chukchi 

Sea coastline or the U.S. Chukchi Sea barrier islands. In the event of a VLOS, key habitats to protect 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 215

for polar bears would include the barrier islands and shoreline. The largest percentages of trajectories 

contacting sensitive habitats originate from the launch areas nearest to shore, LAs 9-13 (Appendix B, 

Figure B-10). Therefore the most protection to resources is afforded by the broadest coastal deferral, 

Alternative III. This alternative offers the most protection to nearshore resources, spring lead systems 

and spring polynyas because it decreases the percentage of trajectories that would contact these 

resource areas. It also affords more time prior to contact for clean up workers to effect as much clean 

up as is possible before the oil begins to contact nearshore resources. 

IV.E.9. Marine and Coastal Birds 

A very large oil spill (VLOS) could affect large numbers of marine and coastal birds due to the fact 

that they spend so much time on the surface of offshore and nearshore waters. Direct contact is the 

primary way that oil could kill birds in part due to its toxicity to individuals and their prey. The 

biology and status of marine and coastal birds are described in Section III.B.5 of the 193 EIS, and as 

further supplemented in this SEIS. 

Effects of a VLOS on marine and coastal birds are discussed below for each of the five phases of the 

hypothetical scenario. The greatest potential for effects on many species of marine and coastal birds 

occurs during Phase 2 (Offshore Oil). Onshore contact in Phase 3 would primarily affect many 

shorebird species and affect nearshore habitats. In all cases, long-term recovery is likely, but most 

species would require more than three generations and access to unaffected/restored habitats for this 

to occur. 

Phase 1 (Initial Event) 

At Phase 1, the potential impact producing factors with relevance to marine and coastal birds could 

include an explosion and fire from a drilling structure. This phase does not include the release of oil 

(Phase 2). Few birds would be in the immediate vicinity of a drilling structure during an initial event; 

therefore, few adverse effects on marine and coastal birds are anticipated. 

Phase 2 (Offshore Oil) 

At Phase 2, direct exposure to oil and gas is the critical impact producing factor affecting marine and 

coastal birds. Oil in the Chukchi Sea would be a serious threat to seabirds because of its properties of 

forming a thin, liquid layer on the water surface. Marine and coastal bird deaths due to oil spills arise 

from exposure from wetting and loss of thermoregulatory ability, loss of buoyancy, or from matted 

plumage, inability to fly or forage, ingestion and inhalation of vapors (Section IV.C.1.g(3)(g) of 

USDOI, MMS 2007a). Species are categorized and discussed below according to their level of 

potential for substantial effects. 

Birds with a Higher Potential for Substantial Effects 

Seabirds and waterfowl are most vulnerable to oil spills because they spend the majority of their time 

on the sea surface and often aggregate in dense flocks. 

Murres. Murres forage over a wide area of the Chukchi Sea during the breeding season, but are most 

concentrated near the breeding colonies at Cape Lisburne and Cape Thompson. In the late fall, 

juveniles and their male parents are floating flightless at sea during their at-sea rearing period. 

Attendant males are completely flightless at molt during the same period. The greatest source of 

potential impacts to common and thick-billed murres occurs from a hypothetical VLOS contacting 

nearshore waters at breeding colonies and to adult males and juvenile murres during the pelagic 

flightless period. 

The potential effects of a hypothetical VLOS are greater with murres than most other marine and 

coastal bird species because a spill could impact discrete colonies, namely those at Cape Lisburne and 

Cape Thompson. Foraging adults could be killed if contacted by oil and would not make it back to 
BOEMRE Sale 193 Revised Draft SEIS 

216 CHAPTER IV. Environmental Consequences 

the colony to incubate the egg or provision their chick. Adults may return to the nest only to cover 

the egg or chick in oil carried on their feathers. The abundance of prey items could be reduced or 

contaminated with oil, resulting in impacts to murres, even if they are not directly exposed to oil. 

Murres also may incur sublethal effects and either die at a later date or fail to breed in future years 

due to immuno-suppression or reduced fitness. All sex- and age-classes of murres could be affected. 

Hundreds of thousands of murres occur at the Cape Lisburne and Cape Thompson colonies. Oil 

contacting murres at or near the colonies has the potential to kill a majority of the birds there. Given 

that murres are long-lived birds with low reproductive rates, recovery from mortality associated with 

an oil spill would likely take more than three generations to occur. Abundance at colonies could be 

reduced for 15 years or longer. 

Juvenile murres and attendant males are particularly vulnerable while they are flightless and unable to 

rapidly move out of the area affected by a VLOS in the open sea. The core of the late-season molting 

area is in an offshore area of the southern Chukchi Sea, north of the Bering Strait. Oil contacting 

molting murres in this molting area could kill many murres. The adverse population impacts from oil 

contacting the molting area when juveniles and adult males were present would be somewhat less 

than those at the breeding colonies, because breeding females would not be in the pelagic molting 

area; but it is possible that a large percentage of the hatching-year cohort could be lost as well as their 

attendant male parents. 

Puffins. Puffins forage over a wide area of the Chukchi Sea during the breeding season and cover a 

much larger area later in summer. Most post-breeding puffins are located near Cape Lisburne in 

September. 

The tufted puffin is an obligate cliff nester. Foraging adults could be killed if contacted by oil and 

may not make it back to the colony to incubate the egg or provision their chicks. Adults may return 

to the nest only to cover the eggs or chicks in oil carried on their feathers. The abundance of prey 

items could be reduced or contaminated with oil, resulting in impacts to puffins, even if they are not 

directly exposed to oil. Puffins also may incur sublethal effects and either succumb at a later date or 

fail to breed in future years due to immuno-suppression or reduced fitness. 

Given that tufted puffins are long-lived birds with low reproductive rates, effects of a spill could 

reduce abundance at colonies for several years. All sex and age classes of puffins could be affected. 

The potential effects of a very large oil spill are greater with (less abundant) tufted puffins than 

horned puffins, because a spill could impact discrete colonies at Cape Thompson and Cape Lisburne. 

Recovery from mortality associated with the hypothetical VLOS likely would take more than three 

generations to occur. Abundance at cliff colonies could be reduced for 15 years or longer. 

A very large oil spill could also affect widely scattered horned puffin colonies located along barrier 

islands along the Chukchi Sea coast. Horned puffins can breed on suitable beach habitat on islands 

near shore by digging burrows or hiding under large pieces of driftwood or debris. If oil were to 

move to waters very near these colonies, nesting birds could be contacted and die. Given the 

distribution of these colonies, population recovery could occur from surrounding colonies once oiled 

beach habitats are restored, but this could take as long as 15 years depending on the extent of contact. 

Short-tailed Shearwaters and Auklets. Short-tailed shearwaters and auklets are considered 

together, because they occur in similar numbers, and both forage on patchily distributed zooplankton 

in pelagic waters of the Chukchi Sea. 

The non-uniform distribution of these species could favor their survival during an oil spill or lead to 

extensive mortality. Short-tailed shearwaters number between 20 and 30 million birds in the northern 

hemisphere and are widespread (but patchily distributed) within the Chukchi Sea. Flocks of 

shearwaters could number in the tens of thousands and several resting or foraging flocks could be 

contacted and killed by spilled oil. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 217

Auklets could number over 100,000, depending on seasonal intrusions of Bering Sea water that 

increases zooplankton availability in the south-central Chukchi Sea. Flocks of auklets could number 

in the tens of thousands and large foraging flocks could be contacted and killed by spilled oil. As a 

consequence, as many as 100,000 auklets and/or 100,000 shearwaters could be affected by a VLOS, 

especially if the spill covered a large area and contacted large groups of birds. The abundance of prey 

items could be reduced or contaminated with oil, resulting in impacts to shearwaters and auklets, even 

if they are not directly exposed to oil. This would be an adverse impact to the regional population, 

but recovery would likely occur in fewer than three generations because these populations are robust 

and widespread, and nest outside of the Chukchi Sea. 

Kittlitz’s Murrelet. The Kittlitz’s murrelet occurs in relatively limited numbers in the U.S. Chukchi 

Sea off the North Slope (Day, Gall, and Pritchard, 2011). A large majority of Kittlitz’s murrelets in 

the eastern Chukchi Sea could be killed if oil were to contact them in coastal areas. This species is 

widespread in low numbers throughout Alaska and birds offshore of the North Slope are at the outer 

range of the species distribution. Recovery would depend on dispersal from other areas, a time period 

that could exceed three generations. 

Black Guillemot. These birds usually are closely associated with the ice edge. Impacts to black 

guillemots could be extensive if a spill occurred when the ice edge was in close proximity to the spill 

location or if nearshore habitats are contacted. Foraging adults could be killed if contacted by oil and 

may not make it back to the colony to incubate the eggs or provision their chicks. Oiled adults may 

return to the nest only to cover the eggs or chicks in oil carried on their feathers. The abundance of 

prey items could be reduced or contaminated with oil, resulting in impacts to black guillemots, even if 

they are not directly exposed to oil. Black guillemots also may incur sublethal effects and either die 

at a later date or fail to breed in future years due to immuno-suppression or reduced fitness. 

The population of black guillemots in the Chukchi is not very large but appears to be widely 

dispersed. Specific breeding colonies on barrier islands could experience extensive mortality, but 

recovery from surrounding colonies would be expected once oiled habitats had recovered, which 

depends on the extent of contact. 

Loons. Loons using the Chukchi Sea typically migrate close to shore until they are south of Cape 

Lisburne, when they travel over pelagic waters on their migration to wintering areas. Loons using 

nearshore areas could be affected by oil contact in nearshore waters along the coast during the open 

water season. A hypothetical VLOS could affect nearshore areas used by nonbreeding loons or, later 

in the open-water season, loon broods. Depending on the spill timing, trajectory analysis, and 

locations of offshore loons, a large proportion of any sex-age class could experience extensive 

mortality. Yellow-billed loons in the Chukchi Sea are at particular risk due to their low numbers and 

low reproductive rate. Extensive mortality of certain sex-age classes could contribute to immediate or 

gradual population-level impacts, including the large-scale loss of the yellow-billed and other loons 

on the Arctic Slope. 

Spectacled and Steller’s Eiders. Spectacled and Steller’s eiders must stage offshore in the spring if 

their breeding habitats are unavailable. Spring leads are open water areas used by spectacled and 

Steller’s eiders during the spring (April – June). The eiders then move to the tundra to nest. 

Most post-breeding spectacled and Steller’s eiders move to the offshore. Some spectacled eiders stage 

offshore near Barrow in the Plover Islands. Steller’s eiders make little use of this area because their 

abundance is small and their distribution is limited. Spectacled and Steller’s eiders migrate west to 

the Ledyard Bay Critical Habitat Unit (LBCHU; Figure 1). Critical habitat is a special designation 

under the Endangered Species Act that represents an area especially important to the persistence and 

recovery of a listed species. The LBCHU is especially important to spectacled eiders that molt there 

in dense flocks from July to November. Steller’s eiders continue south and west of the LBCHU to 

different molting areas. Any oil entering the LBCHU has some potential to contact a dense flock of 
BOEMRE Sale 193 Revised Draft SEIS 

218 CHAPTER IV. Environmental Consequences 

molting spectacled eiders, possibly including the late season aggregation of the North Slope’s 

successful breeding females and their broods. This level of mortality likely could not be recovered 

within three generations, even if the eider populations otherwise remain stable. 

Long-tailed Duck. Long-tailed ducks could suffer direct or indirect mortality, if they are contacted 

by oil or inhale vapors. The abundance of prey items could be reduced or contaminated with oil, 

resulting in impacts to long-tailed ducks even if they are not directly exposed to oil. Long-tailed 

ducks also may incur sublethal effects and either die at a later date or fail to breed in future years due 

to immuno-suppression or reduced fitness. 

Long-tailed ducks could experience extensive mortality if a very large oil spill contacted important 

duck habitats, including Peard Bay and Kasegaluk Lagoon. As many as 7,000 long-tailed ducks can 

occur at one time in Peard Bay late in the open-water season. If spilled oil were to enter Peard Bay 

and contact these birds, the entire flock could be killed. Similarly, as many as 9,000 long-tailed ducks 

can occur at one time in Kasegaluk Lagoon during the open water season. If spilled oil were to enter 

Kasegaluk Lagoon and contact these birds, the entire flock could be killed. Recovery of the regional 

population from mortality of more than 7,000 and/or 9,000 long-tailed ducks would not likely occur 

within three generations. 

Common Eider. Common eiders molt near several locations along the Alaska Chukchi Sea coast, 

including Point Lay, Icy Cape, and Cape Lisburne. Common eiders could suffer direct or indirect 

mortality, if they are contacted by oil or inhale vapors. The abundance of prey items could be 

reduced or contaminated with oil, resulting in impacts to common eiders even if they are not directly 

exposed to oil. Common eiders also may incur sublethal effects and either die later or fail to breed in 

future years due to immuno-suppression or reduced fitness. As with other eiders, the common eider 

probably molts in locations having high-density prey items. 

Several hundred common eiders breeding on offshore barrier islands of the Arctic Coastal Plain could 

experience extensive mortality if contacted in nearshore waters. Recovery from the larger population 

would be expected to occur in fewer than three generations (once oiled habitats had recovered) if the 

population trend continued to be stable. 

Impacts to common eiders could be extensive, especially from oil contacting Kasegaluk Lagoon or 

Peard Bay. As many as 4,000 common eiders can occur at one time in Peard Bay late in the openwater season. If spilled oil were to enter Peard Bay and contact these birds, the entire flock could be 

killed. Similarly, as many as 2,000 common eiders can occur at one time in Kasegaluk Lagoon during 

the open water season. If spilled oil were to enter Kasegaluk Lagoon and contact these birds, the 

entire flock could be killed. Recovery of the regional population from mortality of more than 2,000 

and/or 4,000 common eiders would not likely occur within three generations. 

King Eider. Impacts to king eiders would be similar to common eiders in the Chukchi Sea, except 

that king eiders molt at locations in the Bering Sea. King eiders tend to occur farther offshore in 

greater concentrations of broken ice. King eiders would be contacted more quickly by an oil spill 

originating offshore than birds closer to shore. King eiders have been observed in Peard Bay and are 

less abundant than common eiders. The effects of oil exposure would be similar to common eiders, 

but the number of birds affected likely would be less in Peard Bay and Kasegaluk Lagoon. 

Although reduced from population levels of the mid-1970s, the king eider population in the nearby 

Beaufort Sea remains relatively large and has a positive long-term (14 year) growth rate. Hundreds of 

king eiders could be killed. Recovery from the larger population would be expected to occur in fewer 

than three generations (once oiled habitats had recovered), if the long-term population trend 

continued. 

Black-Legged Kittiwake. Impacts to black-legged kittiwakes could be extensive and in many ways 

similar to shearwaters and auklets. However, kittiwakes in pelagic waters may be at less of a risk if 
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CHAPTER IV. Environmental Consequences 219

they are more widely distributed than shearwaters and auklets, in which case a VLOS would be less 

likely to affect a large proportion of the kittiwakes in the Chukchi Sea. Impacts to kittiwakes at Cape 

Thompson and Cape Lisburne likely would be similar to other seabirds nesting there. A large 

proportion of the entire nesting population (~48,000 birds) could be killed if oil were to contact them 

in nearshore waters around these colonies. It would likely take more than three generations for the 

regional population to recover from this level of mortality because recolonization by birds from more 

southern colonies is expected once oiled habitats had recovered. 

Pacific Brant. Pacific brant could be affected by an oil spill reaching Kasegaluk Lagoon, an 

important molting area. Other important molting areas include Peard Bay and Ledyard Bay. 

Brant use Kasegaluk Lagoon as a stopover location during postbreeding migration from late June 

through August. As much as 45% of the estimated Pacific Flyway population can be located in 

Kasegaluk Lagoon at any one time. Under a hypothetical very large oil spill scenario, a very large oil 

spill could contact brant in Kasegaluk Lagoon during the May-October open-water period. Impacts 

could range from direct mortality, if brant were present during a spill or indirect mortality, if they 

used the lagoon long after a spill but ingested oil while foraging or had less foraging habitat available. 

Impacts to habitat in Kasegaluk Lagoon or other molting areas could persist for a number of years and 

continue to affect brant for a long time after the spill. The loss of as much as 45% of the Pacific 

Flyway population of brant could occur if oil contacted these geese in nearshore waters. Recovery 

from this level of mortality would take more than three generations to occur. 

Phalaropes. Phalaropes are most abundant in the Chukchi Sea during the post-nesting period in late 

summer and fall. Phalaropes use habitat within a few meters of shore, especially Peard Bay and 

Kasegaluk Lagoon, and also pelagic areas where they forage on patchy concentrations of 

zooplankton. Phalaropes were one of the key species groups of shorebirds which utilized Kasegaluk 

Lagoon and Peard Bay, where they stage or stopover in nearshore marine and lacustrine waters. A 

VLOS could contact and kill phalaropes using Peard Bay and Kasegaluk Lagoon. In addition to 

direct mortality from contact with oil, phalaropes could be affected by ingesting contaminated prey or 

by decreased prey concentrations. If oil contaminated or decreased prey species, phalaropes could be 

affected long after the oil spill reached important habitat areas. 

Given the high variability in shorebird abundance at migration stopover sites, a VLOS could affect 

either very few or almost every phalarope using an area, depending on when the spill occurred. 

Migrating flocks often number in the hundreds of birds. If several flocks were contacted by spilled 

oil, mortality of at least several hundred phalaropes could occur. Phalarope populations appear stable. 

The loss of hundreds of phalaropes would be considered an adverse but not significant impact, and 

population recovery would likely occur in fewer than three generations (once oiled habitats had 

recovered) if the population trend continued to be stable. If this magnitude of mortality were 

exceeded, then a significant adverse impact would occur and population recovery would likely take 

much longer. 

Lesser Snow Goose. There are very few lesser snow geese nesting in Alaska. This species nests on 

an island in the Kukpowruk River delta (about 60 km south of Point Lay) in the southern portion of 

Kasegaluk Lagoon. If oil from a VLOS were to contact nearshore areas/channels adjacent to the 

nesting colony, most nesting birds there could be killed. This could eliminate one of two consistently 

occupied nesting colonies for lesser snow geese in the U.S. The loss of this breeding colony would 

require more than three generations to recover, increasing the importance and vulnerability of the 

lesser snow goose population at the remaining U.S. colony near Prudhoe Bay. 

Other Waterfowl and Shorebirds. Impacts on many species of waterfowl and shorebirds are 

anticipated to be relatively low, but there are some key areas of vulnerability where they could be at 

risk of effects from a very large oil spill. 
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220 CHAPTER IV. Environmental Consequences 

More than 4,000 greater white-fronted geese have been observed in Kasegaluk Lagoon. A VLOS 

entering Kasegaluk Lagoon during their period of occupancy could contact and kill them. A VLOS 

also could lead to ingestion of contaminated food resources or decrease the abundance of those food 

resources. A relatively small number of nesting tundra swans in Kasegaluk Lagoon could also be 

contacted and killed. 

Dunlins are another prominent species in Kasegaluk Lagoon and Peard Bay in late summer and fall. 

As with other species of shorebirds and waterfowl, a VLOS during periods of peak abundance could 

contact and kill large numbers of dunlins. Impacts to bar-tailed godwits, given their recent population 

declines, could be particularly important. 

Birds with a Lower Potential for Substantial Effects 

The birds discussed below spend less time in direct contact with water and, therefore, the potential for 

substantial effects is considerably lower than for seabirds and waterfowl above. 

Northern Fulmar. Most fulmars are present only in the southern portions of the Chukchi Sea for a 

few weeks at the end of summer. Spilled oil could contact and kill non-breeding fulmars as they 

spend most of their time foraging or resting on the sea surface. Given that few fulmars would be 

present in areas potentially affected by a VLOS, the likelihood of large-scale mortality and other 

impacts is minimal. Any mortality to the regional population is anticipated to be recovered within 

three generations. 

Gulls and Terns. Ross’s gulls and ivory gulls are ice-associated birds and breed well outside the 

Chukchi Sea. They are present for a short period while migrating through the Chukchi Sea to 

overwintering locations. Terns migrate through the Chukchi Sea but are rarely observed in pelagic 

waters. Large-scale mortality or other impacts to these species are less likely than many other species 

of marine and coastal birds, depending on the season. 

Jaegers. Jaegers are present throughout the Chukchi Sea, but are not known to occur in high 

concentrations. Spilled oil could contact and kill jaegers as they spend most of their time foraging or 

resting on the sea surface. The likelihood of large-scale mortality and other impacts to jaegers is 

minimal because they occur in low densities and few would be affected at any particular time or 

place. Any mortality to the regional population is anticipated to be recovered within three 

generations. 

Raptors. No raptors use open water areas of the Chukchi Sea. There are low numbers of a variety of 

vagrant raptors that could be attracted to dead or dying birds or floating carcasses that they could 

carry to shore. Anticipated impacts to raptors from a very large oil spill likely would be minimal, but 

low numbers of raptors may be killed if they were to feed on oiled carcasses and be affected by the oil 

themselves. 

Phase 3 (Onshore Contact) 

Shorebird “hot-spots” are temporary concentration areas, most often associated with large river deltas 

in the Beaufort Sea. While there are no large river deltas along the Chukchi Sea, these same 

migrating shorebirds must use coastal areas of the Chukchi Sea as they migrate west to wintering 

areas out of the Arctic. Large numbers of shorebirds could come into contact with spilled oil along 

shoreline areas and could be affected during the post-breeding period through oil exposure and 

subsequent hypothermia if they encounter oil on shorelines. They could also be indirectly affected by 

eating contaminated prey or through mortality in their invertebrate food sources. Such mortality could 

have population-level effects, because large numbers of shorebirds could be affected. 
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CHAPTER IV. Environmental Consequences 221

Phase 4 (Spill Response and Cleanup) 

Spill response activities could disturb and displace marine and coastal birds, which could have net 

beneficial effects by intentionally or unintentionally moving birds away from oiled areas. This 

displacement may move birds to unoiled areas, with negligible energetic costs, if these habitats were 

of similar quality. Marine and coastal birds could be harmed, however, if birds moved to inferior 

habitats where biological needs could not be met. Several species have specific nesting (e.g., islands, 

cliffs, low-gradient beaches) or foraging requirements (e.g., lagoons, passes between barrier islands) 

that could be altered by cleanup efforts. While the marine and coastal birds could physically relocate 

to other areas, those areas may be unsuitable and delay recovery. 

Phase 5 (Long-term Recovery) 

Long-term describes an impact producing factor that continues to produce effects in populations for 

more than 2 years. Many of the effects from direct contact of oil to most offshore and onshore areas 

have the potential to take more than three generations to recover. Similarly, indirect effects on large 

numbers of shorebirds, such as those to coastal sediments and invertebrates, could persist for 

extended periods. As these were previously described under more direct effects for Phases 2 and 3, 

they are not repeated here. 

Oil Spill Trajectory Analysis

Above we have addressed the potential impacts to marine and coastal bird species during each phase 

of the hypothetical scenario. We now use estimated oil spill trajectories provided by the OSRA model 

to consider the likelihood of such impacts occurring. 

This section describes the results estimated by the OSRA model of a hypothetical VLOS in the 

Chukchi Sea contacting specific Environmental Resource Areas (ERAs) that are important to marine 

and coastal birds. An ERA is a hypothetical polygon that represents a geographic area important to 

one or several bird species or species groups during a discrete amount of time. The ERA locations are 

incorporated by reference from LS 193 EIS (USDOI, MMS, 2007a) and are shown in Appendix B, 

Figures B-2–B-5. The ERAs important to marine and coastal birds are summarized in Appendix A, 

Table A.1-13 of the Sale 193 FEIS. The vulnerability of an ERA is based on the seasonal use patterns 

of marine and coastal birds using the area (Appendix A, Table A.1-12, USDOI, MMS 2007a). 

The following paragraphs present the results (expressed as a percentage of trajectories contacting) 

estimated by the OSRA model of a hypothetical very large spill contacting habitats that are important 

to marine and coastal birds. Given the wide variety of bird species that use the U.S. Chukchi Sea area 

and factoring in continuous changes in prey abundance and other biotic and abiotic factors that affect 

bird distribution, it is possible that large aggregations of some bird species could be contacted by a 

VLOS. For instance, short-tailed shearwaters and some auklet species occur during the summer 

throughout the Chukchi Sea area, but the hypothetical VLOS could contact large numbers of these 

birds or none at all, depending on the location of the spill and location of the birds at the time of the 

spill. 

Summer Spill 

Under a hypothetical very large oil spill scenario for summer, the OSRA model estimates that ≥1% of 

spill trajectories from any individual LA could contact ERAs important to birds within 60 days 

(Appendix B, Table B-2). 

Most post-breeding spectacled and Steller’s eiders move offshore and then migrate west to the 

Ledyard Bay Critical Habitat Unit (LBCHU). The LBCHU (ERA 10) is especially important to 

spectacled eiders that molt there in dense flocks from July to November. Steller’s eiders continue 

south and west of the LBCHU to different molting areas. The OSRA model estimates that 38% and 

22% of trajectories from a hypothetical VLOS originating from LA10 or LA11, respectively, could 
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222 CHAPTER IV. Environmental Consequences 

contact spectacled eiders molting in the LBCHU (ERA 10) during the summer within the 60 and 360 

day periods. The OSRA LA and the ERA are in close proximity to or overlap each other. 

Many pre- and post-breeding shorebirds and waterfowl stage at Kasegaluk Lagoon, while other bird 

species breed or molt in or near the lagoon. The highest percentages of trajectories from a 

hypothetical VLOS that could contact Kasegaluk Lagoon (ERA 1) were 16% and 14% from LAs 11 

and 10, respectively, within 60 and 360 days. 

Waterfowl and shorebirds use Peard Bay, especially in the ice-free season, to breed, molt, and forage 

during migration. The highest percentage of trajectories from a hypothetical VLOS contacting Peard 

Bay (ERA 64) over a period of 60 days were 23% and 15% from LAs 13 and 12, respectively. The 

highest percentage of trajectories from a hypothetical very large spill contacting Peard Bay (ERA 64) 

during a 360 day period were 25% and 18% from LAs 13 and 12, respectively. 

Environmental Resource Area 15 is adjacent to the murre breeding colonies near Cape Lisburne. This 

ERA also applies to other seabirds breeding at Cape Lisburne including black-legged kittiwakes, 

puffins, and much smaller numbers of glaucous gulls and pelagic cormorants. Similar species are 

located at colonies near Cape Thompson (ERA 14). The highest percentages of trajectories from a 

hypothetical VLOS contacting ERA 15 were 22% and 19% from LAs 9 and 10, respectively. The 

highest percentage of trajectories from a VLOS contacting ERA 14 was 16% from LA9 within 60 and 

360 days. Spilled oil contacting these ERAs is assumed to contact all birds using these areas during 

the May-October period. 

The OSRA model estimates that 9% and 8% of trajectories from LA8 or LA13, respectively, would 

contact spectacled eiders and other seabirds staging offshore Barrow in the Plover Islands (ERA 2) 

within 60 days during summer. Within 360 days the above values increase to 13% and 10%, 

respectively. 

The Chukchi Sea spring lead system (ERAs 19-23) is used by marine and coastal birds as they move 

east to breeding areas or stage offshore if breeding habitats were unavailable. As the hypothetical 

VLOS would originate during the open water season (post-July 15), the spring lead system, by 

definition, would not exist or be available for contact within 60 days following a well control 

incident. The same situation exists for the Beaufort Sea spring lead system (ERAs 24-34). Within 

360 days, however, ≤4% of trajectories from a VLOS are estimated to contact the Chukchi Sea spring 

lead system and ≤6% are estimated to contact the Beaufort Sea spring lead system. 

Murres forage over a wide area of the Chukchi Sea during the breeding season and cover a much 

larger area later in the summer and fall when juveniles are floating flightless at sea during their at-sea 

rearing period. Attendant male murres also are flightless while molting during this period. The core 

of this area is represented as ERA 18. The highest percentage of trajectories from a hypothetical 

VLOS that could contact ERA 18 were about 42%, 19% and 16% from LAs 9, 10 and 4, respectively, 

within 60 and 360 days. 

Winter Spill 

The OSRA model estimates that <16% of trajectories from a VLOS starting at LA1-LA13 could 

contact habitats (ERAs) that are important to marine and coastal birds (Appendix B, Table B-16). The 

OSRA model estimates that 16% and 10% of trajectories from a hypothetical VLOS originating from 

LA10 or LA11, respectively, could contact spectacled eiders molting in the LBCHU (ERA 10) during 

the winter within 360 days. 

Many sea ducks must stage offshore in the spring if their breeding habitats are unavailable. 

Environmental resource areas 19-23 make up the Chukchi Sea spring lead system (April-June) used 

by eiders and other sea ducks during spring, and the highest percentages of trajectories from a 

hypothetical VLOS contacting these ERAs are 14% and 12% from LA12 and LA11, respectively 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 223

during the winter 360 day assessment period. The percentage of trajectories estimated to contact these 

ERAs is highest because the launch areas and the ERAs are in close proximity to or overlap each 

other. A VLOS from the other LAs all are estimated to have percentages of trajectories <10% of 

contacting the spring lead systems of the Chukchi Sea (ERAs 19-23) and Beaufort Sea (ERAs 24-34). 

The OSRA estimates ≤6% of trajectories from a hypothetical VLOS originating in any of the LAs 

could contact sea ducks staging offshore Barrow in the Plover Islands (ERA 2) for a winter 360 day 

analysis period. Steller’s eiders make little use of ERA 2. 

Kasegaluk Lagoon and Peard Bay are important areas for marine and coastal birds during open water 

in summer and fall, but if these sites were contacted by oil after November 1, the oil would likely 

over-winter and there would likely be effects on the habitat and the marine and coastal birds as they 

return in spring and begin to forage and breed in these areas. Up to 8% of trajectories from a 

hypothetical VLOS from any of the LAs could contact Peard Bay (ERA 64) or 11% for Kasegaluk 

Lagoon (ERA 1) within 360 days, during winter. 

Trajectories from a hypothetical VLOS during winter, within 360 days had an estimated ≤1% contact 

with the pelagic murre molting area (ERA 18) from any LA. 

Conclusion 

A VLOS has the greatest potential for affecting large numbers of birds in part due to its toxicity to 

individuals and their prey and the amount of time these birds spend on the surface of marine and 

coastal waters. Under a hypothetical VLOS scenario, marine and coastal birds in key areas or at key 

times could experience a variety of negative effects from petroleum exposure and habitat loss. Key 

areas evaluated included: 

 Kasegaluk Lagoon 

 Ledyard Bay 

 Peard Bay 

 barrier islands 

 the spring open-water lead systems 

 Cape Lisburne 

 Cape Thompson 

All of the areas above provide important nesting, molting, or migration habitat to a variety of 

seabirds, waterfowl, and shorebirds. The Ledyard Bay Critical Habitat Unit is especially important to 

spectacled eiders that molt there in dense flocks from July to November. 

A VLOS during periods of peak use could affect large numbers of marine and coastal birds, including 

listed eiders, loons, seabirds, and waterfowl. As a typical example, up to 45% of the estimated 

Pacific Flyway population of Pacific brant could be affected, if an oil spill reaches Kasegaluk 

Lagoon. Effects could range from direct mortality of approximately 60,000 brant to sublethal effects 

on an equal or smaller number of brant. The loss of up to 45% of the Pacific Flyway population 

would have conspicuous population-level effects. The situation with brant is similar to a wide variety 

of waterfowl and shorebirds that use similar areas of the Chukchi Sea. 

A hypothetical VLOS could impact large numbers of murres, puffins, and kittiwakes at the Cape 

Lisburne and Cape Thompson colonies. The magnitude of potential mortality could result in 

significant adverse impacts to the colonies. Large-scale mortality could occur to migrating or molting 

concentrations of marine and coastal birds, including adult male and juvenile murres in the late 

summer molting area. Mortality from a hypothetical VLOS could result in population-level effects 

for most marine and coastal bird species that would take more than three generations to recover. 
BOEMRE Sale 193 Revised Draft SEIS 

224 CHAPTER IV. Environmental Consequences 

Large-scale mortality could occur with respect to pelagic distributions of auklets and shearwaters 

during the open-water period. 

As a group, the Launch Areas (specifically LAs 8-13) affected by the deferral corridors contemplated 

in Alternatives III and IV tend to exhibit higher percentages of spill trajectories contacting sensitive 

nearshore and coastal habitats along the Chukchi Sea. These alternatives may offer protection to 

nearshore resources, spring lead systems and spring polynyas by decreasing the percentage of 

trajectories that would contact these resource areas. In this sense, the most protection to nearshore 

and coastal birds is afforded by the broadest coastal deferral, Alternative III. Deferrals may also 

afford more time for spill response and cleanup prior to a spill contacting nearshore resources. These 

benefits would not be expected to accrue to pelagic species of birds. 

IV.E.10. Ice Seals 

A VLOS is hypothesized to occur following a series of operational failures in a scenario described in 

Section IV.D. This analysis of the VLOS scenario is divided into five phases representing the Initial 

Event (Phase 1), Offshore Oil (Phase 2), Onshore Contact (Phase 3), Spill Response and Clean-up 

(Phase 4), and Long Term Recovery (Phase 5). The following analysis addresses each phase in 

sequence. Phases 2 and 3 exhibit the greatest potential for large-scale adverse effects on many 

species of ice seals. A VLOS would affect bearded, ringed, spotted, and ribbon seals to varying 

degrees in offshore areas, particularly if ice and therefore appreciable numbers of seals are present. 

Indirect adverse effects are less likely as ice seals are capable of ridding their bodies of accumulated 

hydrocarbons via renal and biliary mechanisms, mostly within 7 days (Engelhardt, 1983). Onshore 

contact is only expected to affect spotted seals in very localized areas, since spotted seals select only a 

few locations along the Chukchi and Beaufort coasts for haulouts. In all cases, each species is 

expected to recover from any decline in abundance and/or change in distribution within three 

generations or less. 

Phase 1 (Initial Event) 

The initial event is a well-control incident that could include an explosion, fire, sinking of the drill 

rig, and redistribution of sediment and drilling wastes in the local area. This phase does not include 

the release of oil to offshore waters (Phase 2), contact with shore (Phase 3) or spill response and 

cleanup (Phase 4). In the proposed Sale 193 area, ringed, bearded, and spotted seals were the most 

common seal species observed by marine mammal observers during drilling operations (Brueggeman 

et al. 1992), seismic surveys (Funk et al. 2010; Blees et al. 2010), marine mammal surveys 

(Brueggeman, 2010), and shallow hazard surveys (Brueggeman 2009). Ribbon seals were observed 

least of all, and existing survey data rarely note their presence. Impacts to all species of seals 

potentially present in the vicinity of the initial event are discussed below, with species-specific 

differences noted as appropriate. 

Explosion. An explosion at the drill site could cause direct impacts (auditory, injury, or death) to any 

seals in the immediate vicinity. Southall et al. (2007) determined the injury criteria for pinnipeds for 

aerial single pulsed noise events such as explosions was 149 dB re: 20 μPa (Sound Pressure Level) 

and 144 dB re: (20 μPa)2-s (Sound Exposure Level). Pulsed noise levels exceeding these thresholds 

may elicit Temporary Threshold Shift (TTS) or Permanent Threshold Shift (PTS) in any seals within 

the noise radius stated above. At least one study has demonstrated that other physiological damages, 

including permanent organ damage, could occur in seals within close proximity to intense explosions 

(Hill 1978). Ultimately the amount of pressure and noise produced by an explosion would determine 

the extent of any danger zones for seals in the area. Such pressure and noise levels are highly 

variable, depending on a host of factors characterizing an explosion. 

Because very few seals are expected to occur in close proximity to exploration drilling in the Chukchi 

Sea, there should be little or no physiological damage to ice seals in the immediate area. However the 
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CHAPTER IV. Environmental Consequences 225

risks of inducing TTS and PTS in seals would likely extend beyond 60 m from a drilling unit. Based 

on density estimates produced by NMFS (Allen and Angliss 2010, 2011; Cameron et al. 2009; Kelly 

et al. 2010) and marine mammal surveys (Funk et al. 2010; Blees et al. 2010; Brueggeman et al. 1992, 

2009, 2010), only a few seals, likely less than five, could reasonably be expected to be affected by a 

large explosion anywhere in the Lease Area. Any resulting losses in the local seal populations would 

not lead to population level effects. 

Fire. Fire from an intial exploration drilling unit explosion is very unlikely to affect any seals, as 

very few are expected to be in the immediate vicinity. 

Sinking drill rig. Sinking of a drilling unit would have no adverse effects on any ice seals in the 

area. 

Sediment redistribution. Phase 1 could indirectly affect bearded seals by introducing and 

redistributing drilling muds and sediments into benthic feeding areas. Sediments and metals released 

into the ocean would precipitate out of the water column, mostly within a few hundred meters of a 

drilling rig. The deposition of these additional sediments onto the sea floor would likely bury 

individuals from some sessile benthic species, killing them (see Section IV.E.4, Lower Trophic Level 

Organisms). Because marine worms, echinoderms, and molluscs are important in the bearded seal 

diet (Dehn et al. 2007), bearded seals would be unable to forage on patches of the sea floor that have 

recently been buried under sediments or may ingest small quantities of contaminants. Blanchard, 

Nichols, and Parris (2010) found little difference in macrofaunal community structure between 

historic drill sites and the surrounding environment in the Chukchi Sea indicating such effects would 

be short-term. While some prey items may die as a result of being buried under sediments and 

tailings, lowering the locations suitability for benthic feeders such as bearded seals, the site should 

eventually reach a state similar to that of surrounding areas (Blanchard, et al., 2008, 2009). 

Phase 2 (Offshore Oil) 

Ice seals would be exposed to hydrocarbons in offshore areas during a hypothetical very large oil 

spill. Oil in the Chukchi Sea could cause short-term physiological effects and also constitute a threat 

to seals if long-term exposure occurs. Additional information about potential impacts to seals is 

available in Section IV.C.1.h(4) of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Contamination. The vulnerability of individual ice seal species to contacting crude oil is largely a 

function of their seasonal use of different areas. Some coastal use areas, polynyas, and lead systems 

are the most likely areas for relatively larger numbers of seals to come in contact with spilled oil. 

These are all aggregation areas for different species of seals at different times of the year. Major 

distinctions in distribution are noted in the subsections below. 

Spotted seals are known to aggregate in coastal areas during summer months, mostly in Kasegaluk 

Lagoon, and the areas between Kotzebue and Wales, Alaska. However they also occur in small 

numbers in Smith Bay, Peard Bay, Dease Inlet, and the Colville River Delta, Alaska. During the 

summers and open water season, ringed and bearded seals mostly associate with areas of sea ice, 

where they occur in their highest numbers. In contrast ribbon seals are mostly found in the pelagic 

areas away from the coast and areas of sea ice during the open water period. As ice encroaches south 

in the fall, all of the ice seal species move south in tandem with the ice, eventually occupying the 

Bering Sea. However many ringed and some bearded seals remain in the Chukchi and Beaufort Seas 

during the winters by creating breathing holes, or using lead systems and polynyas for water access. 

During winter and spring ringed seals prefer areas of shorefast ice, while bearded seals utilize lead 

and polynya areas of fragmented pack ice away from the areas of shorefast ice. 

Ice seals have the ability to purge their bodies of hydrocarbons through renal and biliary pathways. 

Although they can get lesions on their eyes and some internal organs from contacting crude oil, 

studies have indicated that many of the physiological effects self-correct if the duration of exposure is 
BOEMRE Sale 193 Revised Draft SEIS 

226 CHAPTER IV. Environmental Consequences 

not too great (Engelhardt, Geraci, and Smith, 1977; Engelhardt,1982, 1983, 1985; Smith and Geraci 

1975; Geraci and Smith 1976b, 1976c; St. Aubin 1990). However Spraker et al. (1994) observed 

lesions in the thalamus of harbor seal brains after they were oiled. 

While seals may experience short-term physiological impacts from exposure to an oil spill as 

described in the Sale 193 FEIS, Section IV.C.1.h(4) (USDOI, MMS, 2007a), Engelhardt (1983) states 

that exposure studies in ringed seals reveals they have a great capability to excrete accumulated 

hydrocarbons via renal and biliary excretion mechanisms, clearing blood and most other tissues of the 

residues within 7 days. In harbor seals (Phoca vitulina), a somewhat similar species, an investigation 

revealed that there were no significant quantities of oil in the tissues (liver, blubber, kidney and 

skeletal muscles) of harbor seals exposed to the EVOS (Bence and Burns 1995), and that the cause of 

the decreasing trend in harbor seal numbers since EVOS (4.6% per year) is complicated because seal 

populations were declining prior to the spill (Frost et al. 1999). A further analysis of harbor seal 

population trends and movements in Prince William Sound concluded harbor seals moved away from 

some oiled haulouts during the EVOS (Hoover-Miller et al. 2001) and that the original estimate of 

300+ harbor seal mortalities may have been overstated. 

Loss of Access to Food. A very serious repercussion of a VLOS may be the loss of fishes and 

invertebrates from local populations over an area as was described in Section IV.E.5 and Section 

IV.E.4, particularly Arctic and saffron cod, arthropods, mollusks, and other invertebrates. Adult 

ringed, spotted, and ribbon seals mostly rely on fishes for the majority of their diets, although young 

seals may consume large numbers of arthropods like euphausids and copepods. Bearded seals feed 

on mollusks, polychaetes and arthropods to a large degree, as a part of their very broad diet. The loss 

of any of these food sources in an area could have far-reaching effects that may last for multiple 

years, providing a smaller quantitative and qualitative food base for high level predators such as seals. 

The consequences of such a loss in the prey base would be reduced productivity in seal populations 

using an area, or even a short-term loss of ice seals from an area. However the constituents in crude 

oil do weather and break down over time, and weather, ocean currents, and temperature act to 

disperse oil slicks. Many, if not most, marine organisms produce very large quantities of offspring 

that are often dispersed by ocean currents. Consequently the loss of biota from an area exposed to 

crude oil should be replenished within a few years, in light of the high reproductive rates, and 

mobility of marine organisms, and the influx of younger organisms via ocean currents. Though issues 

continue to exist with the after-effects of the DWH event in the Gulf of Mexico, the sea floor in that 

area was about 5,000 feet below the ocean surface as opposed to the Sale 193 area where water depths 

are generally measured in the tens of meters. Deeper waters such as those found in the Gulf of 

Mexico typically move very slowly as opposed to shallower waters in the Chukchi Sea, which tend to 

be more dynamic. Effects to seals from loss of access to food might persist in the Chukchi Sea for 

multiple seasons or years after a VLOS. 

Phase 3 (Onshore Contact) 

The only seal species likely to be affected by spills contacting coastlines would be spotted seals. 

Bearded, ringed, and ribbon seals spend their lives on or around sea ice and rarely if ever come ashore 

in coastal areas. 

Contact with Oil. The effects of seals contacting crude oil were described in Phase 2, and on page 

IV-156 of the Sale 193 FEIS (MMS, 2007). 

Contamination. The effects of oil contamination on spotted seals are the same as described in Phase 

2. However abrasive sediments and sands may scrub oil from the coats of some seals lessening the 

amount and duration of contamination that individual seals experience. 

Loss of Access to Habitat. A VLOS that contacts the shoreline would not necessarily affect the 

foraging success of seals since they feed in the water. However, a spill that contacts the shoreline, 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 227

and remains spread over large areas of water could adversely affect foraging success for spotted seal 

species. Such effects might last across season and perhaps a few years. 

Phase 4 (Spill Response and Cleanup) 

Spill response activities could disturb and displace seals from affected marine and coastal areas. 

Negative short term impacts from disturbance would be outweighed by beneficial effects from 

intentionally or unintentionally hazing seals away from oiled areas. 

The effects of vessel and aircraft traffic associated with an oil spill response and cleanup may 

displace seals to a very minor degree. Such effects have been observed in numerous ship and airbased surveys in the Chukchi and Beaufort Seas over the years (Blees et al., 2010; Brewer et al., 

1993; Brueggeman et al. 1991, 2009, 2010; Funk et al., 2010; Treacy et al. 1996). Some activities 

such as in-situ burning, animal rescue, the use of skimmers and booms, drilling relief wells, etc. could 

have additive effects, most likely displacing seals to an even greater degree. Marine mammal 

observers would be used, but a few seals are likely to be temporarily frightened from the area since an 

MMO cannot account for all the marine mammals in the area, particularly the ones that are 

submerged. However it is also likely any seals exposed to a VLOS will be able to detect the oil, at 

least through olfaction, and attempt to leave the area on their own. This is particularly true if their 

prey base is adversely affected quantitatively. The use of dispersants are unlikely to have any 

immediate effects on seals in an area exposed to a VLOS event, however there may be some adverse 

consequences to using certain types of dispersants which may affect the food web, and the long-term 

effects of dispersant use may extend beyond the proposal area. 

Cleanup activities such as beach cleaning may be performed with a high degree of success using 

newer technologies such as ionic solutions (Hogshead, Evangelos, Williams, et al., 2010; Painter, 

2011). However, other activities such as spill cleanup under ice or in areas of broken ice may be 

more problematic. The effects of these activities on seals could vary, depending upon the presence of 

seals in an area, pre-existing stress levels, etc. 

To the extent that hazing seals from oiled areas could preclude more severe impacts, Phase 4 of the 

hypothetical VLOS event would provide a net benefit to seals. 

Phase 5 (Long-term Recovery) 

Long-term is defined as affecting populations for more than 2 years. The immediate effects of shortterm oiling are not expected to persist beyond a few months. What would be more marked would be 

the effects from long-term oil exposure, which could be lethal. If seals are able to successfully detect 

and avoid crude oil, as has been suggested by some experts (Geraci and St. Aubin, 1988), there 

should be few if any individuals suffering from long-term exposure to the slick from a VLOS. 

However, if ice seals lack appropriate oil detection capabilities, many individuals might die from 

contact with a VLOS. The exact effects of a VLOS on seals will be a function of variables such as 

timing, duration, persistence, location, size and components of the spill, as well as ocean currents, 

wind, weathering, sea ice, etc. Depending on the variables and species affected, and based on an 

estimated presence of seals derived from available surveys, tens to several thousand individual seals 

could be affected or killed from the effects of contact with a VLOS. Expanded analysis of VLOS 

contact is provided in subsections below. 

For spotted, bearded, and ringed seals the loss of thousands of individuals could be recovered within 

three generations. Within the context of annual mortality in the seal populations, these numbers 

would represent but a fraction of the seals sustainably harvested each year, and in the case of bearded 

and ringed seals, an even smaller fraction than what is killed and eaten by polar bears annually. For 

example, in the Canadian High Arctic a population of approximately 1,800 polar bears consumes an 

estimated 77,400 ringed seals annually (Stirling and Øritsland 1995). By dividing these values 

(Population polar bear / Ringed Seals consumed annual) we are able to identify a rough coefficient 
BOEMRE Sale 193 Revised Draft SEIS 

228 CHAPTER IV. Environmental Consequences 

(0.0232) that could be used to provide a similar estimate of the minimum number of ringed seals 

consumed annually by polar bears in the Southern Beaufort Sea (SBS) (=64,500) and in the Chukchi 

Bering Sea (CBS) (=86,000) when divided into polar bear population estimates. This rudimentary 

model assumes equal consumption ratios of bearded and ringed seals by polar bears in the Canadian 

and American Arctic, and does not account for differences in consumption of walrus, spotted and 

ribbon seal, and scavenged subsistence kills of bowhead whales and cetacean carcasses. Nonetheless 

the simple model still indicates that a hypothetical loss of even 5,000 ringed seals would constitute an 

immediate loss of about 3.3% of the ringed seals consumed by polar bears in the combined CBS and 

SBS polar bear populations. The ongoing losses of ringed and bearded seals to polar bear predation 

and subsistence harvests are believed to be naturally sustainable. The loss of several thousand seals 

via a VLOS event could also be viewed as captured mortality from natural sources, and is likely to 

self-correct within one or two seasons. 

Oil Spill Trajectory Analysis 

A VLOS could contact offshore and nearshore areas where seals may be present. The probability of 

contact depends on the location, timing, and magnitude of the spill. The OSRA model uses 13 launch 

areas (LAs) to model the origin of spill trajectories. The launch areas (LAs) are found in Appendix 

B, Figure B-10). 

The drilling season is typically July 15 through October 31 in the Chukchi Sea. This time period is 

typically when any spills from drilling would occur. The lack of sea ice during this period permits the 

safe operation of offshore drilling platforms. In the unlikely event of a well blowout, BOEMRE has 

determined from 39 to 74 days would be required for another drill vessel to transit to the site and drill 

a relief well. 

Within 60 days for a summer spill the estimated discontinuous area contacted is between 245,800 and 

364,100 km2 and within 360 days 264,500 to 450,400 km2 (Appendix B, Table B-5). Winter spills 

are more restricted in area with 60-day spills covering a discontinuous area contacted of 162,200 to 

385,600 km2, and within 360 days 368,400 to 507,200 km2 (Appendix B, Table B-6). Such 

patchiness in a long duration spill may allow some seals to at least partially avoid or reduce contact 

with the oil slick, reducing the overall effects on some individuals. 

A very large oil spill continuing after October 31 is treated as a winter spill. Since the hypothetical 

oil spill could continue after October 31 and/or melt out of ice during the following spring, potential 

trajectories are also assessed over an assessment period of 360 days. 

In the event of a VLOS not all of the hydrocarbons are discharged at once, as often occurs with 

marine accidents such as the Exxon Valdez oil spill in Prince William Sound, Alaska. Instead they 

flow into the ocean at rates that decrease over time. For the briefest spill period BOEMRE estimates 

that a spill could persist on the surface of the water for up to three weeks, and so a 60 day period of 

potential contact was analyzed. However if a spill were to occur late in the open water season, the 

liquid hydrocarbons may freeze into the sea ice, and could remain overwinter without any extensive 

amount of weathering. If this were to happen quantities of unweathered oil could end up being 

transported to different areas in the Chukchi and Beaufort Seas and be released in the spring. To 

address concerns such as this BOEMRE has also analyzed a spill window of 360 days. 

This section describes the results estimated by the OSRA model of a hypothetical very large oil spill 

in the Chukchi Sea contacting specific Environmental Resource Areas (ERAs) that are important to 

ice seals. An Environmental Resource Area (ERA) noted in this section is a polygon used to 

represent an area important to one or more seal species at some stage in their life cycle. During 

winter bearded and ringed seals are the only species expected to be present in the area and their 

primary winter habitats include polynyas, lead systems, and shorefast or pack ice for ringed or 

bearded seals respectively. During the summer (open-water) season ringed, ribbon, and bearded seals 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 229

may be found swimming in open water, though their numbers increase with proximity to areas of sea 

ice. Spotted seals are seasonal visitors to the Beaufort and Chukchi seas, and mostly occupy 

nearshore areas, bays, and lagoon systems where they periodically haul out, sometimes in large 

numbers. As stated earlier, ribbon seals are mostly pelagic, and tend to occupy the southern and 

western Chukchi Sea to a higher degree than the proposal areas. With the exception of hauled out 

spotted seals, other ice seals do not tend to be gregarious for social reasons as much as to exploit 

limited resources such as available polynyas and lead systems. 

ERAs indicating lead systems, and major concentration are incorporated by reference from Sale 193 

FEIS and shown in Appendix B, Figures B-2 to B-5, while polynya systems are depicted in Figure 

III.A-14 of the Sale 193 FEIS. The likelihood of any species being affected by a very large oil spill 

will be determined by a number of factors including: seasonality occurrence of a species’; spill 

avoidance abilities of a species; presence; distribution; habitat use; diet; timing of a spill; spill 

constituents; spill magnitude; spill duration; and a species ability to persist in a contaminated area. 

Bearded and ringed seals occur in the Chukchi and Beaufort Seas year-round, although a very large 

proportion of their populations winter south in the Bering Sea ice areas. In contrast ribbon seals 

mostly summer in the northern Bering Sea and in the southern Chukchi Sea, where little ice is persists 

during the open water season. Many spotted seals winter in the Bering Sea, however large 

aggregations (100’s and 1000’s) may be found in Kasegaluk lagoon, Avak Inlet, and between 

Kotzebue and Wales on the Seward Peninsula coast, while lower concentrations (10’s) occur in 

Admiralty, Smith, Kugrua and Peard Bays; and the Colville River Delta. 

The following paragraphs present the results (expressed as a percentage of trajectories contacting) 

estimated by the OSRA model of a hypothetical very large spill contacting habitats that are important 

to seal species. For example a very large winter spill from any launch area could hardly be expected 

to directly affect spotted seals within 60 days since they migrate south in late October-November. 

While they could come into contact with spilled oil by June or July of the following year, since it 

would be within 360 days of the spill date, by that time most of the hazardous components of a spill 

will have weathered away. Thus the timing of a spill most likely to affect spotted seals would be one 

that occurred during the early to mid summer, using the 60 day trajectory. 

The OSRA model estimates spill trajectories originating from any individual LA which may have a 

≥1% probability of contacting Environmental Resource Areas (ERA’s) or Land Segments (LS) with 

importance to seals within 60 days (Tables B-7, B-9, B-15 and B-18), and 360 days (Tables B-8, B10, B-16, and B-19). Due to differences in summer habitat use between the different seal species in 

the analysis area, bearded, ringed, ribbon, and spotted seals will be analyzed independently. Because 

ice seals may be present in affected areas year-round, this analysis considers the 60 and 360 day time 

periods for trajectories during summer and winter, unless otherwise noted. To focus on significant 

impacts (or elevated potential for significant impacts), only a percentage of trajectories contacting 

≥5% are discussed. 

Bearded Seals 

Bearded seal presence during the open water season is correlated with the presence of sea ice. 

Consequently, they are less common in the southern Chukchi Sea and around coastal areas during the 

summer period, yet more common near the ice front and in areas of drifting sea ice, particularly in the 

northern portion of the analysis area. Since they forage for benthic species, bearded seals must 

associate with relatively shallow waters over the continental shelf. For this reason, bearded seal 

densities tend to be higher in the sourthern Chukchi Sea early in the spring, and decrease as the open 

water season progresses. Though the Chukchi Sea has a large continental shelf area, the shelf in the 

Beaufort Sea tends to be narrow and ultimately the water depths suitable for prolonged bearded seal 

occupancy may determine the presence and densitites of bearded seals. Consequently, in some years 

bearded seals in the Beaufort Sea may forage farther from the ice front than those in the Chukchi Sea. 
BOEMRE Sale 193 Revised Draft SEIS 

230 CHAPTER IV. Environmental Consequences 

The sub-population of resident bearded seals in the Beaufort Sea is estimated at around 3,150 as 

compared to the estimated 27,000 residing year-round in the Chukchi Sea (Cameron et al. 2009), 

though both resident populations are considered to be part of the Beringian Distinct Population 

Segment (DPS) of bearded seals. 

A LS analysis is pointless for bearded seals considering their strong association with sea ice, however 

during winter months their presence is strongly linked to polynyas, areas of broken ice, and lead 

systems where they have immediate access to water and food resources. During the summer bearded 

seals do not tend to aggregate, spending much of their time foraging at sea. Throughout the year 

bearded seals avoid nearshore areas including areas of shorefast ice. 

Summer within 60 Days. Higher densities of bearded seals occur in open water near areas of sea 

ice, and spills are most likely to affect them anywhere in the open water. However the shallow waters 

of shoals make them particularly productive from the perspective of a benthos-feeding bearded seal. 

Consequently one may expect somewhat larger densities of bearded seals in the vicinity of Hanna 

(ERA 56) and Herald shoals. LAs 2, 3, 6, 7, 8, 11, 12, or 13 had 14, 22, 40, 40, 15, 19, 56, or 27 

percent of trajectories (respectively) contacting ERA 56 in the vicinity of Hanna Shoal (Appendix B, 

B-1). However any spills in the open water could very likely affect some bearded seals since they are 

somewhat ubiquitous in the Chukchi Sea and to a much lesser degree the Beaufort Sea. 

Summer within 360 Days. If a VLOS were to occur, freeze into the ice and melt out up to 360 days 

from the release date, the OSRA model estimates that the Herald Shoal polynya has a 7, 22, 10, or 6 

percent of trajectories contacting LAs 1, 4, 5, or 10. LAs 1, 2, 3, 5, 6, 7, 8, 11, 12, or 13 would 

respectively have 10, 23, 50, 10, 29, 34, 23, 12, 21, or 19% of trajectories contacting Hanna Shoal. 

LAs 7 or 8 also have 6 or 5% of their respective trajectories contacting Beaufort Lead System 7, 

although <5% of trajectories contact the remaining spring lead systems. 

Winter within 60 Days. The OSRA model estimates 7 or 8% of trajectories from LA10 contact 

ERA 20 or 21, respectively. Likewise, 5 or 9% of trajectories from LA10 contact ERA’s 21 or 22, 

and 10% of trajectories from LA12 contact ERA 22. All of these ERAs plus ERAs 19 and 23 

constitute the Chukchi Spring Lead System where many bearded seals will aggregate during the 

winter season. Similarly the Herald Shoal polynya system had 8 and 18% trajectories contacting 

from LAs 1 and 4. The Hanna Shoal polynya has 10, 26, 64, 6, 21, 43, 45, 25, 11, 22, 19, or 25 

percent of trajectories from LAs 1, 2, 3, 4, 5, 6, 7, 8, 10, 11, 12, or 13, respectively. These lead and 

polynya systems are the only known locations where bearded seals concentrate during winter and any 

spill that occurs in one of these areas could have marked effects on any seals using them. Such 

effects may be much higher than what would be expected in open water or during the summer. 

However, if a spill made its way into a lead or polynya system, any remaining volatile compounds 

would begin weathering out of the slick, albeit at a slower rate than would occur during a summer 

spill. The oil weathering models estimates that approximately 30% of oil from a slick would remain 

from a 60,000 bbl per day summer spill after 30 days, and 48% would remain from a winter (meltout) 

spill after 30 days (Appendix B, Tables B-3 and B-4). Consequently, at least half of the oil in any of 

the leads or polynyas would quickly weathered out of the slick and the ensuing effects on bearded 

seals might be moderated to one degree or another. 

Winter within 360 Days. The OSRA model estimates, the Hanna Shoal polynya has 15, 33, 68, 

10,29, 51, 54, 38, 19, 33, 33, or 38% of trajectories contacting from LAs 1, 2, 3, 4, 5, 6, 7, 8, 10, 11, 

12, or 13 respectively. The Herald Shoal polynya system would have an 8 or 19 percent of 

trajectories contact from LAs 1 or 4, while ERA 45. 

Ringed Seals 

As with bearded seals, ringed seals have a strong association with sea ice. However unlike bearded 

seals, ringed seals overwinter in areas of shorefast ice, particularly where heaves and irregularities 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 231

create icy hummocks that can protect their lairs from polar bear predation. During summer, ringed 

seals associate with sea ice in the open waters and so may occur in the open ocean where they forage 

on fishes. It is assumed that their presence and densities in any given area will depend upon the food 

stocks in a local area, as well as the presence or absence of sea ice. Consequently LSs are not 

analyzed for ringed seals for a 60 day summer spill. Polynya and lead systems will be analyzed for 

the 360 day summer, 60 day winter, or 360 day winter time periods. 

Summer within 60 Days. The 60 day summer VLOS analysis for ringed seals is the same as what 

was analyzed for bearded seals. Please consult summer 60-day analysis for bearded seals for greater 

detail. 

Summer within 360 Days. Ringed seals prefer areas of shorefast ice, mostly foregoing areas of pack 

ice. However they frequently use polynyas surrounded by stable pack ice, such as occurs at Hanna 

and Herald Shoals during the winter. The spring lead systems in the Beaufort and Chukchi Seas are 

also important to ringed seals since it allows them to forage for fishes and comfortably rest on an icy 

platform if needed. The percent of spill trajectories contacting ringed seals in Hanna and Herald 

Shoals, and around any existing lead systems are the same as what was described for bearded seals 

using the same habitat. 

Winter within 60 Day. The percentage of trajectories contacting ringed seal habitat within 60 days 

are the same as those for bearded seals with an exception. The preferred habitat of overwintering 

ringed seals is shorefast ice where they can maintain breathing holes, subnivean dens, and whelp on a 

stable medium. Consequently, the vast majority of ringed seals will not be in any of the Launch 

Areas (LAs) or in the open ocean during winter. Instead, they will be in the nearshore zone. Using 

the grouped land segments for the Beaufort and Chukchi coastlines, the percentage of trajectories 

contacting the Siberian coast is 8% from LA9. For the United States Chukchi Sea coast the 

percentage of trajectories contacting are 17, 9, or 7% for LAs 10, 11, or 12 (Appendix B, Table B19). The OSRA model estimates <5% of the trajectories from any of the LAs would contact the 

Beaufort Sea coast. 

Winter within 360 Day. A winter VLOS within 360 days would have the same percentages of 

trajectories contacting polynyas and lead systems for ringed seals as it did for bearded seals. 

Considering the winter habitat use of ringed seals, there is a 6, 12, 32, or 5% of trajectories contacting 

the Russian Chukchi coast from LAs 1, 4, 9, or 10 respectively. The OSRA model estimates 8, 12, 5, 

28, 21, 20, or 9 % of trajectories from LAs 4, 5, 6, 10, 11, 12, or 13 would contact the United States 

Chukchi Sea coast, and 6, 9, 6, or 10 percent of trajectories contact the United States Beaufort from 

LA7, 8, 12, or 13 (Appendix B, B-20). 

Ribbon Seals 

During the summer ribbon seals have been observed in very, very low numbers during Chukchi Sea 

marine mammal surveys (Funk et al., 2010; Blees et al., 2010; Brueggeman et al., 1991, 2009, 2010). 

Ribbon seals spend most of their lives in the open ocean, only relying on the ice front during early 

spring to briefly whelp, and molt before returning to the water for the remainder of the year. In the 

Chukchi Sea most ribbon seals are found in the southern and western regions, sometimes being 

observed in the eastern and east-central Chukchi Sea. Occasionally, a ribbon seal is observed in the 

vicinity of Barrow, Alaska, although these sightings are believed to be quite rare. Whelping chiefly 

occurs in the Bering, and perhaps in a few areas of the southern Chukchi Sea. Consequently, they 

would not be at risk from the proposed action. Any ribbon seals that could be affected by a VLOS 

would be in the open water and in extremely low densities, and they are not known to associate with 

any particular ERAs or LSs. At most, no more than a few tens to several hundred ribbon seals could 

be affected by a hydrocarbon release from any of the LAs in the proposal area. If a VLOS were to 

occur, BOEMRE expects a fraction of the ribbon seals would be killed, while the remainder would 

probably recover within a few days. Such numbers would not affect the persistence of a local 
BOEMRE Sale 193 Revised Draft SEIS 

232 CHAPTER IV. Environmental Consequences 

population or the regional stock of ribbon seals, though recovery might last from 1 to 3 years 

depending upon the number of individuals lost from the population. 

Spotted Seals 

Spotted seals are summer visitors to the Chukchi Sea and to a much lesser extent, the Beaufort Sea. 

Their primary haulout sites in the Chukchi Sea include Kasegaluk Lagoon, and the areas around 

Kotzebue Sound. Haulout sites in the Beaufort Sea are very small by comparison, hosting 

populations numbering into the 10’s. The known Beaufort haulouts include Dease Inlet/Admiralty 

Bay, Smith Bay, and the eastern edge of the Colville River Delta. In the following analyses the 

appropriate ERAs and are analyzed to estimate the percentage of trajectories contacting spotted seal 

habitat in the proposal area. During the Arctic summer spotted seals are not as strongly associated 

with ice as are bearded and ringed seals. 

As with bearded, ringed, and ribbon seals, any VLOS in open water conditions is likely to contact 

some individual spotted seals; however, slicks would weather and disperse over time. The VLOS 

analyzed in the OSRA could be expected to contact hundreds or perhaps even a few thousand spotted 

seals in the Chukchi Sea, or some 10’s of seals in the Beaufort Sea. The largest aggregation of 

spotted seals that could be oiled occurs in Kasegaluk Lagoon between Icy Cape and Wainwright, 

where a few thousand seals haul out during the summer. 

Summer within 60 Days. The percentage of trajectories contacting spotted seals in the open water 

are similar to what was described for bearded, ringed, and ribbon seals, however coastal areas are 

more vulnerable for spotted seals since they are the only ice seal species in the Chukchi and Beaufort 

Seas that regularly use shore-based haulouts. Kasegaluk Lagoon has a 14, 16, or 5 percent of 

trajectories contacting from LAs 10, 11, or 12 respectively. All other known haulout sites have <5% 

of trajectories contacting from any of the LAs. 

Summer within 360 Days. As with the summer 60-day time period, a 360-day time period would 

have a 14, 16, or 5 percent of trajectories contacting Kasegaluk Lagoon. However, there would also 

be a 6, 13, 12, 18, or 25 percent of trajectories contacting Peard Bay from LAs 6, 7, 8, 12, or 13, and a 

5 percent of trajectories contacting Kugrua Bay from LA12. 

Winter within 360 Days. The OSRA estimates LAs 4, 5, 10, or 11 have a 5, 6, 11, or 8 percent of 

trajectories contacting Kasegaluk Lagoon (Appendix B, Table B-16). All other LAs have <5% 

trajectories contacting spotted seal haulout areas and are not discussed further. 

Conclusion 

In the event of a VLOS, ice seals could be adversely affected to varying degrees depending on habitat 

use, densities, season, and various spill characteristics. 

Spotted seals are the only phocid species in the analysis area that habitually use shore-based haulouts. 

Their principle haulout locations that could be affected by a VLOS, ranked from largest to smallest, 

are Kasegaluk Lagoon, Kugrua Bay, Dease Inlet/Admiralty Bay, Smith Bay, and the Colville River 

Delta. Kasegaluk Lagoon is the largest haulout location that could be affected, and is several times 

larger than all of the others combined. Although spotted seals may forage for fishes in the open 

ocean, their presence is not known to be associated with the ice front. Consequently, their presence is 

associated with haulout areas and nearshore areas with open water. 

In contrast ribbon seals are the most pelagic seal species in the area, remaining in the open ocean for 

most of the year except for spring whelping and molting in the Bering and southern Chukchi Seas. 

Based on their very low presence in marine mammal surveys, BOEMRE concludes that they occur 

only in very low numbers spread across the Chukchi Sea, and are virtually absent from the Beaufort 

Sea. Consequently ribbon seal populations are not expected to be affected by a VLOS from any of 

the OSRA Launch Areas. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 233

Both bearded and ringed seals closely associate with sea ice throughout the year, very rarely, if ever, 

coming ashore. Both species prefer to forage in proximity to the southern ice edge during the 

summer months, although some may be found in the open ocean away from areas of sea ice. Bearded 

seals feed on benthic organisms on the relatively shallow Chukchi continental shelf, while ringed 

seals forage for fishes and some invertebrates in the water column. These differences in food 

selection and foraging behavior help determine the presence or absence of each of these species in an 

area. Bearded seals are essentially restricted to areas over the continental shelf and the ice front 

where they can reach the seafloor to feed on benthic organisms. Ringed seals may be found under 

areas of solid ice as well as in the ice front where they predate fishes such as Arctic and saffron cod. 

Presently there are no areas identified as important ringed, bearded, or ribbon seal habitat during the 

summer months. However, during the winter, conditions change drastically with the southward 

advance of sea ice, when only bearded and ringed seals persist in the Chukchi and Beaufort Seas. 

During winter, bearded seals loosely congregate around polynyas, and lead systems, generally 

avoiding areas of shorefast ice. Ringed seals however, select shorefast ice zones as their primary 

habitat where they survive by making and maintaining breathing holes through the ice and by 

constructing subnivean lairs, particularly under pressure ridges where they are somewhat protected 

from predators. If lead systems or polynyas occur near the shorefast zone, ringed seals may often 

maintain a presence in proximity to the lead or polynya, however because of their site fidelity and 

need for stable ice, they are strongly linked with stable shorefast ice. Any VLOS reaching a polynya 

or lead system could therefore have serious effects on local ringed and bearded seal sub-populations, 

potentially oiling or even killing hundreds to thousands of bearded and/or ringed seals. 

Potential effects of a VLOS event on fishes and invertebrates are analyzed in greater detail in other 

resource sections (Sections IV.E.4 and IV.E.5). Because ice seals rely on these organisms for food, 

any significant impacts on fishes or invertebrates would have serious consequences to seal 

populations. A massive die off of prey species would most likely cause seals to leave the area to seek 

food elsewhere. While such movements would entail some energetic cost, it is unlikely many seals 

would immediately starve to death. However displaced seals would compete with seals elsewhere for 

the limited food resources, perhaps lowering the overall fitness of a local population, or even 

contributing to the loss of population segments through malnutrition. Consequently a VLOS has the 

potential to affect large numbers of seals in part due to the effects their prey and the local food-web. 

Mortality from a hypothetical VLOS could result in temporary population-level effects for bearded, 

ringed, and spotted seals, and to a much lesser degree ribbon seals due to their scarcity in the analysis 

area. 

If Alternative IV is selected, portions of LA8–LA13 would be deferred, and if Alternative III is 

selected larger portions of LA8–LA13 would not be available for oil and gas exploration and 

development under Sale 193. As these LAs generally exhibit a higher percentage of trajectories 

contacing nearshore areas, deferring portions of these areas can reduce the potential for impacts on 

coastal habitats and the species that use them, like spotted seals. Depending on the season, 

Alternative III or IV could also reduce percentages of trajectories contacting areas important to 

bearded and ringed seals, such as Hannah Shoal, polynyas and spring lead systems, and (in the case of 

ringed seals) shorefast ice. The larger deferral associated with Alternative III has greater potential to 

reduce nearshore impacts as compared with Alternative IV. It is more difficult to correlate any 

benefits to ribbon seals from either deferral corridor. 

IV.E.11. Pacific Walrus 

A very large oil spill (VLOS) could affect Pacific walrus at sea, on sea ice, or at coastal haulouts. 

Effects could result from direct contact with oil, inhalation or exposure to toxic fumes from the oil 

(such as polycyclic aromatic hydrocarbons or PAHs), ingestion of oil or contaminated prey, habitat 

loss, or prey loss. Additional effects could occur during clean up and well control work. These 
BOEMRE Sale 193 Revised Draft SEIS 

234 CHAPTER IV. Environmental Consequences 

impacts could include inhalation or exposure to toxic fumes from clean up products, disturbance at 

important on ice or terrestrial haulout sites, and destruction of prey species. 

The impacts that occur during each phase of a blowout and subsequent clean up are discussed below. 

The most direct impacts would occur as a result of Phases 2 and 3, the oil spilled offshore and 

onshore. The most recent estimate of the Pacific walrus population suggests a minimum of 129,000 

walrus (Speckman et al, 2011). Some researchers believe that the population may be in decline based 

on age structure and productivity information (GarlichMiller, Quakenbush and Bromaghin, 2006). 

The Pacific walrus is listed as a candidate for threatened status under the Endangered Species Act due 

to the continuing loss of sea ice habitat caused by climate change (76 FR 7634 [Feb 10, 2011]). With 

a population in decline, any loss of large numbers of walruses, walrus habitat, or prey species would 

exacerbate that decline. Recovery would not occur unless the population begins to rebound from 

other factors that may be limiting population productivity or growth. 

Phase 1 (Initial Event) 

The initial phase could include a large explosion of natural gas and a fire. The rig may or may not be 

disabled or sink at that point. The impact producing factors that might effect walrus would be the 

explosion itself (depending upon the size of the explosion and their proximity to it) and the smoke 

and debris resulting from the fire. Walrus are very sensitive to disturbance and are unlikely to remain 

in the vicinity of an active drilling operation, especially during the open water season when ice is not 

present. If walrus were in close enough proximity to be able to hear the explosion, they may be 

frightened into a panic and leave the area. During stampedes from coastal or ice floe haulouts, calves 

and smaller walrus are the most vulnerable to injury. Falling ash and debris could also haze walrus 

away from the area. If the explosion occurs at the sea floor, benthic invertebrates may be destroyed in 

the area affected by the explosion or the sunken platform. This area would then be unavailable as a 

feeding area for walrus until it is recolonized by invertebrate species. 

Phase 2 (Offshore Oil Spill) 

Walrus could be directly and indirectly affected by an offshore oil spill. Exposure to oil or associated 

fumes could cause respiratory distress and inflammation of mucous membranes and eyes, leading to 

damage such as abrasions and ulcerations. Walrus, which have large protruding eyes, would be 

particularly vulnerable. Walrus rely primarily on a thick layer of blubber for insulation and therefore 

are less likely than fur bearers to suffer from hypothermia as a result of oiling. However, they may be 

more likely to suffer skin inflammation and ulcers as a result of oil exposure. Studies have shown that 

while marine mammals such as walrus are not usually killed by surface contact with oil, ingestion of 

oil or oil contaminated prey items can cause tissue changes (Kooyman, Gentry and McAlister, 1976). 

Ringed and Bearded seals have the ability to metabolize small amounts of hydrocarbons so that such 

tissue damage is temporary unless the exposure is chronic over time (Kooyman, Gentry and 

McAlister, 1976). Although similar studies have not been done with walrus, their physiology is 

consistent with that of other Arctic seals. If walrus share this ability, some short term adverse impacts 

may be mitigated. Chronic exposure may still result in lethal effects or long term sub-lethal effects 

that reduce fitness. 

Walrus at haulouts have been shown to be very sensitive to smells. In at least one case, walrus 

abandoned a beach apparently in response to a strong scent of perfume (ADFG unpublished data). 

Walrus may avoid oil or oiled ice due to the smell, or may remain in the area in spite of the presence 

of oil. Studies on other seal species have indicated that seals intent on feeding will not avoid an area 

due to oil or oil sheens (Geraci and St. Aubin, 1990). Oil may impede the ability to dive by increasing 

buoyancy, which would in turn increase the energy expenditures of feeding, particularly for younger, 

smaller walrus. The VLOS scenario analyzes a light weight oil: 35° API. In general, lighter oils 

dissipate more quickly through evaporation, dissolution and dispersion. For comparison, the oil 

spilled in the Exxon Valdez spill was a medium weight oil with 27° API. Oil, especially heavy oils 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 235

and weathered tarry oil, may impede swimming and diving by adhering to the walrus hide and 

reducing the ability of the animal to move its flippers efficiently. Sand, gravel or other debris may 

adhere to the oiled skin further impeding locomotion and impacting the walrus’ ability to use their 

vibrissae to locate prey items along the sea floor. 

Walrus primarily feed on benthic invertebrates, such as clams and marine worms. Benthic 

invertebrates that come into contact with the spill would ingest hydrocarbons from water, sediments 

and food. Invertebrates could concentrate contaminants because they metabolize hydrocarbons 

poorly. Long-term or chronic oil ingestion may result in kidney damage, liver damage, or ulcers in 

the digestive tracts of walrus. Depending upon the level of impacts to benthic invertebrates, walrus 

could be forced to travel farther to forage, resulting in increased energetic costs and perhaps increased 

competition among walrus for food sources. 

Phase 3 (Onshore Contact) 

Depending upon the location of the spill site and other factors, oil could contact shore within 10 days 

of the initial event. Walrus could come into contact with oil at coastal haulouts. Regardless of 

whether contact occurred at sea, on ice or on land, the results to the physical health of the walrus 

would be the same as those listed under Phase 2. If walrus avoid coastal areas that have been fouled 

by oil, they may be excluded from important coastal resting areas once the sea ice retreats off of the 

continental shelf in late summer. Walrus cannot remain at sea indefinitely; they must haul out to rest 

and regain body heat. Calves and young walrus are more restricted in the amount of time that they can 

spend at sea, and are unable to swim as far or for as long as adult walrus. 

Phase 4 (Spill Response and Clean Up Activities) 

Spill response and clean up activities would involve large numbers of boats of various sizes, 

skimmers, airplanes, and helicopters. In-situ burning and corralling oil with boom material, or 

booming off sensitive nearshore habitats may occur. Although the USCG has not previously 

approved the use of dispersants in the Arctic, their use is foreseeable. Dispersants could be ingested 

by benthic invertebrates, and have impacts similar to oil if ingested by walrus. Depending upon the 

type of chemical dispersant used, dispersants could also cause direct impacts to walrus by irritating 

eyes, mucous membranes, or respiratory systems. 

In the initial aftermath of a spill, activity would be concentrated in the immediate area of the spilled 

oil. Walrus would likely avoid the area due to the large amount of noise and activity, which may 

reduce the likelihood that they would be oiled or be exposed to PAHs which tend to evaporate 

relatively quickly (within a few days, unless frozen into ice). Gas (primarily methane and ethane) 

would quickly dissipate into the atmosphere at the spill site and walrus are not likely to be exposed to 

gas in the event of an explosion and spill. Immediate responses, in addition to seeking to control the 

well and stop the flow of oil, may include attempts to cap the flow or repair the rupture. In-situ 

burning has been shown to be very effective with freshly spilled oil, but the oil becomes more 

difficult to ignite as it ages and the aromatic hydrocarbons burn or evaporate. In-situ burning would 

release soot and other pollutants into the air, but it is unlikely that walrus would remain in the vicinity 

of such activity or be exposed to enough smoke and soot to suffer respiratory effects. 

As the spill response continues, the oil (and thus the response) will become spread out over a larger 

area. The amount of oil being discharged daily would decrease as the pressure remaining in the well 

decreases. BOEMRE has estimated that the flow of oil would decrease from a high of 60,000 

bbls/day to just over 20,000 bbls/day over the 74 day spill duration analyzed in this VLOS scenario. 

Depending upon the location of the spill site and the time of the spill, BOEMRE estimates that a 

discontinuous area of 162,200 square kilometers (km2) to 547,600 km2 would be contacted by oil. As 

the spill continues, clean up efforts would likely focus on the spill site, villages and areas deemed to 

be critically important to fish or wildlife. If the spill begins early in the open water drilling season 
BOEMRE Sale 193 Revised Draft SEIS 

236 CHAPTER IV. Environmental Consequences 

(mid-July), then the longer that the spill goes on, the more likely it becomes that walrus will 

encounter oil and/ or disturbance from clean up efforts. In recent years, walrus have retreated to 

coastal haulouts in September due to a lack of sea ice cover as a resting platform. If the spill occurs 

toward the end of the open water drilling season (late October) walrus may already be moving 

southward out of the Chukchi Sea and may be less likely to be impacted by oil or clean up efforts 

during that season (USGS, unpublished tagging data). 

Even after the flow of oil has been stopped, responders would continue cleaning any remaining oil 

that can be located. Clean up efforts could focus on oiled shoreline, and hot washing methods or 

dispersants could be used. The coastlines being cleaned would be unavailable to walrus for resting. 

Dispersants may cause skin irritations, respiratory impacts or impacts to sensitive tissues around the 

eyes, nose, or mouth. This process may be continued the year following the spill. Oil frozen in ice 

over winter would melt out in the spring through brine channels and into leads and polynyas. 

Skimmers and other methods may be used to try to capture this remaining oil the spring/summer 

following the spill. This could lead to additional disturbance to walrus in the ice pack, as well as 

exposure to oil when the walrus return in the spring. At that time of year, the females are calving and 

the calves may be especially sensitive to the effects of oil or disturbance. High rates of spontaneous 

abortions have been reported for some other marine mammal species after a spill, though it is unclear 

whether this is related to the spill itself or stress related to clean up activities or is an unrelated event 

(Geraci and St. Aubin 1990; and Kooyman, Gentry and McAlister 1976). 

Phase 5 (Long Term Recovery) 

After cleanup efforts have ceased, the remaining oil will continue to weather and be subject to 

microbial degradation. This process is likely to be very slow in Arctic waters. Oil that has been 

suspended in the water column or in the sediment may continue to be ingested by the benthic 

organisms that walrus prey upon. Walrus may continue to be exposed to hydrocarbons through their 

prey, which may lead to reduced fitness over time. 

Damage assessment studies will occur as a part of the natural resource damage assessment process 

(NRDA). Depending upon the types of studies conducted, some may lead to increased disturbance of 

walrus by adding additional boat, plane, and shoreline traffic to the Chukchi Sea. 

Oil Spill Trajectory Analysis 

A VLOS could contact offshore or onshore areas where walrus may be present. The degree of 

contact with oil would depend upon the location, timing, and magnitude of the spill. The OSRA 

model divides the 193 lease sale area into 13 launch areas (LAs) to model the spill trajectories from 

different sources of origin. The LAs are described in Appendix B, Figure B-10. In many instances, 

the differences between launch areas are less important than the magnitude of the spill given the large 

area that a VLOS could encompass. 

The drilling season in the Chukchi Sea is the open water season, typically between July 15 and 

October 31. The VLOS scenario estimates for the purpose of analysis a spill duration of up to 74 

days. Spilled oil could remain on the water surface for up to 3 weeks. A spill beginning early in the 

open water season and stopped within 39 days would, therefore, remain on the water surface for 60 

days. A spill which started late in the open water season or was not stopped for 74 days would likely 

freeze into the ice and persist over winter, melting out in the spring. The BOEMRE therefore 

analyzed a summer spill that persists for 60 days and 360 days, and a winter spill that persists for 360 

days. 

This section describes the results estimated by the Oil Spill Risk Analysis model (OSRA model) of a 

hypothetical very large oil spill in the Chukchi Sea contacting specific Environmental Resource Areas 

(ERAs), Land Segments (LSs) or Grouped Land Segments (GLSs) where walrus are likely to be 

found. An ERA is a polygon that represents a geographic area during a specific time period. The ERA 
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CHAPTER IV. Environmental Consequences 237

locations are incorporated from the Sale 193 FEIS (USDOI, MMS, 2007a) and found in Appendix B, 

Figures B-1 to B-4. The ERAs are summarized in Appendix A, Tables A.1-13 through A.1-15 of the 

Sale 193 FEIS. The vulnerability of an ERA is based on the seasonal use patterns of walrus 

(Appendix A, Table A.1-12, USDOI, MMS 2007a). LSs and GLSs are sections of the coastline and 

are not seasonal. For this analysis, we do not consider the effectiveness of clean up methods. We 

make the assumption that if oil contacts the coastline, the oil will remain there until it breaks down 

via natural processes. 

In the Sale 193 FEIS, the OSRA analysis focused on terrestrial walrus haulout locations at Cape 

Lisburne, on Wrangel Island, on Kolyuchin Island and along the Russian coastline of the Chukchi 

Sea. Since that time, walrus have begun hauling out in large numbers along the U.S. side of the 

Chukchi Sea coast as well. We also have additional information about at sea distribution from 

tagging studies and surveys. We have incorporated ERAs from the Sale 193 FEIS that were not used 

in relation to walrus at that time to capture this new information about where walrus may come into 

contact with oil. At large terrestrial haulouts, there are usually many walrus in the nearshore waters 

in the vicinity of the haulout. Where possible, we have used ERAs rather than land segments as a 

proxy for the terrestrial haulouts so that both the onshore and offshore components of the walrus 

associated with the haulout are represented. Although as many as 15,000 walrus have been recorded 

hauling out on the U.S. side of the Chukchi Sea in recent years; the largest walrus haulouts are still 

primarily on the Russian side of the Chukchi Sea, where haulouts of over 100,000 walrus may occur. 

Walrus enter the Chukchi Sea in the spring time when the sea ice retreats, and return to the Bering 

Sea in late fall when the Chukchi Sea freezes. Where possible, we have used ERAs with a year round 

vulnerability (Jan-Dec) even though we recognize that walrus won’t be present in the Chukchi Sea in 

December through late February. In the event that oil was to contact these ERAs in December 

through February, it would freeze into the ice and snow over winter and remain frozen in the ice until 

spring. The oil would then melt out of the thawing ice in the spring just as the walrus are returning to 

the area. Oil spreads under sea ice and adheres to the rough bottom of the sea ice, filling in 

depressions in the sea ice. In calm conditions, oil spreads beneath the surface of the sea ice. How 

much it spreads before becoming encapsulated in the ice depends upon the viscosity of the oil, and 

surface tension forces. In rough seas, oil may be pushed up on top of the ice, or broken up into 

droplets in the water column. Currents may also spread the oil below the surface of the ice or in open 

water. Emulsions of oil mixed with water will also freeze into the ice where they will remain until the 

spring melt season. In one experiment, oil released under first year ice in the Beaufort Sea became 

encapsulated in the ice and remained in place until spring (Fingas and Hollebone, 2003). 

Summer Spills (June 1 – October 31) 

The following information is summarized from Tables B-7, B-8, B-11, and B-12. A summer spill is 

defined as a spill taking place during the open water season between June 1 and October 31. The 

following discussion uses the geographic description and the corresponding ERA number can be 

found in Table 16. The OSRA model estimates that 2% or fewer of the trajectories launched during 

this time period would contact Wrangel Island or Kolyuchin Island within 60 days or within 360 days 

from LAs 1-13. The OSRA model estimates that 4% or fewer of the trajectories would contact any 

section of the Russian coastline in 60 days with one exception—12% of the trajectories from LA9 

would contact some section of the Russian coastline, though not necessarily where walrus may be. 

Over 360 days, the percentage of trajectories that would contact some section of the Russian coastline 

is 6% or fewer, again with the exception of LA9 where the percentage of trajectories contacting the 

coastline would be 19%. 

On the U.S. side of the Chukchi Sea, results are more variable. The percentage of trajectories 

contacting the Pt. Barrow/Plover Islands area within 60 days is 2% or less from all launch areas 

except LA8 (9%) and LA13 (8%). Within 360 days, the percentage of trajectories contacting this 
BOEMRE Sale 193 Revised Draft SEIS 

238 CHAPTER IV. Environmental Consequences 

Table 16. Walrus habitat areas analyzed in the VLOS OSRA analysis. 

ERA or 

GLS Geographic Description Period of Vulnerability 

Figure in 

Appendix B

ERA 39 South of Pt Lay to Icy Cape Jan–Dec Figure B-2 

ERA 40 Icy Cape to Peard Bay including Wainwright Jan–Dec Figure B-2 

 ERA 2 Pt Barrow, Plover Islands area May–Oct Figure B-2 

ERA 59 Kolyuchin Island May–Nov Figure B-2 

ERA 11 Wrangel Island with 12 mile buffer Jan–Dec Figure B-2 

ERA 46 Herald Shoal polynya area Jan–Dec Figure B-2 

ERA 48 Hanna Shoal polynya area Jan–Dec Figure B-2 

ERA 20 Southern portion of Chukchi spring lead system April–June Figure B-3 

ERA 21 middle portion of Chukchi spring lead system April–June Figure B-3 

ERA 22 Northern portion of Chukchi spring lead system April–June Figure B-3 

ERA 15 Cape Lisburne area May–October Figure B-4 

GLS 95 Russian coastline, LSs 1-39 Jan–Dec Figure B-5 

area is 2% or fewer from all LAs except LA7 (6%), LA8 (13%) and LA13 (10%). For the Cape 

Lisburne area, 4% or fewer trajectories contact the area within 60 days with the exception of LA 9 

(22%) and LA10 (19%). No additional trajectories would contact the coast between 60 and 360 days. 

For the Chukchi Sea spring lead system, 3% or fewer of the trajectories would contact the spring lead 

system within 60 days. Within 360 days, 4% or fewer trajectories will contact the spring lead system. 

The highest percentage of trajectories contacting the spring lead system is from LAs 10, 11 and 12. 

Of the ERAs considered in the summer analysis for walrus, the most vulnerable areas in the event of a 

VLOS are the Point Lay and Point Wainwright subsistence areas and the Hanna and Herald Shoal 

polynyas. For the Point Lay subsistence area, the percentage of trajectories contacting the ERA 

within 60 days is 5% or fewer for all LAs except LA10 (18%) and LA11 (16%). Within 360 days the 

only additional contact would be an additional 1% if the VLOS were to originate in LA10. For the 

Wainwright subsistence area ERA, the percentage of trajectories contacting within 60 days is fewer 

than 5% for all LAs except LA5 (8%), LA10 (9%), LA11 (23%), LA12 (27%) and LA13 (7%). Over 

360 days, the percentage of trajectories contacting the ERA is 5% or fewer from all LAs except LA5 

(9%), LA6 (6%), LA10 (10%), LA11 (25%), LA12 (29%), and LA13 (9%). For the Herald Shoal 

polynya, the percentage of trajectories contacting the ERA within 60 days is 5% or fewer for most 

LAs, the exceptions are LA1 (7%), LA4 (21%), LA5 (9%), and LA10 (6%). No additional 

trajectories would contact the ERAs between 60 and 360 days except an additional 1% from LA4 or 

LA5. For the Hanna Shoal polynya ERA, only LAs 4, 9 and 10 have 5% or fewer trajectories 

contacting this ERA within 60 days. A VLOS originating in LA1 or LA8 would have 7% of the 

trajectories contacting the Hanna Shoal polynya ERA within 60 days; the rest are as follows: LA2 

(15%), LA3 (18%), LA5 and LA7 (17%), LA6 (47%), LA11 (20%), LA12 (15%), and LA13 (8%). 

Between 60 and 360 days, an additional 1-5% of trajectories (depending upon LA) would contact the 

Hanna Shoal polynya ERA. 

Winter Spills (November 1 – May 31) 

The following information is summarized from Tables B-16, B-19, and B-20. A winter spill is 

defined as a spill taking place between November 1 and May 31, in other words, the trajectories 

would be launched during this time period. For a winter spill, we have only considered the full 360 

day period. The OSRA model estimates that 4% or fewer of the trajectories launched during this time 

period would contact Wrangel Island or Kolyuchin Island within 360 days. The OSRA model 

estimates that 5% or fewer of the trajectories would contact any section of the Russian coastline in 

360 days with the following exceptions: LA1 (6%), LA4 (12%), and LA9 (32%). 

For the U.S. side of the Chukchi Sea, 6% or fewer of the trajectories from any LA would contact the 

Pt. Barrow/ Plover Islands area within 360 days. For the Cape Lisburne ERA, 5% or fewer of the 

trajectories from any LA would contact this ERA within 360 days. For the Chukchi Sea spring lead 

system, fewer than 6% of the trajectories would contact the spring lead system over 360 days with the 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 239

following exceptions: LA10 (7-10%), LA11 (3-12%), LA12 (1-14%). For the Point Lay area ERA, 

fewer than 3% of trajectories would contact the ERA with the following exceptions: LA4 (6%), LA5 

(7%), LA10 (25%), and LA11 (13%). For the Wainwright area ERA, fewer than 3% of trajectories 

would contact the ERA with the following exceptions: LA4 (7%), LA5 (10%), LA10 (18%), LA11 

(19%), and LA12 (20%). For the Herald Shoal polynya ERA, 4% or fewer trajectories would contact 

this ERA over 360 days with the following exceptions: LA1 (8%), and LA4 (19%). The Hanna Shoal 

ERA has the highest percentage of trajectories contacting it of the ERAs considered here. For LA9, 

3% of trajectories would contact this ERA. For LAs 1-4 and LA8, 11-20% of trajectories would 

contact the Hanna Shoal ERA. For LAs 7, 10 and 13, 23-28% of trajectories would contact Hanna 

Shoal. For LAs 5, 6, 11, and 12, 35-54% of trajectories would contact the Hanna Shoal ERA. 

Conclusion 

In the event of a VLOS, the OSRA model estimates most of the contact between oil and walrus 

habitat would occur on the U.S. side of the Chukchi Sea, while the bulk of the walrus population 

hauls out on the Russian side of the Chukchi Sea. Contact with oil on the U.S. side of the Chukchi 

Sea would be most likely to occur at Herald or Hanna shoals, or at coastal haulouts near Wainwright 

or Pt. Lay. Walrus are less vulnerable to injury from contact than are furred seals, but more likely to 

be subjected to long term chronic ingestion of hydrocarbons from eating benthic prey than are seals 

that eat fish. In the event of a VLOS, key habitats to protect for walrus would include the Herald and 

Hanna Shoal polynyas and the Wainwright and Pt. Lay areas. Significant impacts to the walrus 

population would be most likely to occur if large scale contamination of prey and habitat persisted for 

years. 

As illustrated in the analysis above, hypothetical spills launched from LAs 10, 11 and 12 generally 

exhibit the highest potential for contact with the Hanna Shoal polynya, the Chukchi Sea spring lead 

system, and the Wainwright and Pt. Lay areas. LAs 8 and 13 are associated with slightly higher 

potential for contact with the Pt. Barrow, Plover Islands area. Deferring portions of LA9 could reduce 

the potential for VLOS contact with sections of the Russian coastline. By deferring these areas from 

leasing, the corridors in Alternative IV and (to a greater extent) Alternative III could reduce the 

potential for impacts to walrus and walrus habitats. The Pacific walrus population is currently 

estimated at a minimum of 129,000. If a VLOS were to occur and to contact large portions of habitat 

inhabited by walrus, calves of the year would most likely be at risk. 

IV.E.12. Terrestrial Mammals 

A VLOS is hypothesized to occur following a series of operational failures. Analysis of the 

hypothetical VLOS scenario described in Section IV.D.2 is divided into five phases: the Initial Event 

(Phase 1), Offshore Oil (Phase 2), Onshore Contact (Phase 3), Spill Response and Clean-up (Phase 4), 

and Long Term Recovery (Phase 5). These phases and the types of impacts that could occur during 

each are discussed sequentially. A discussion of the percent oil spill trajectories contacting various 

areas important to terrestrial mammals is then provided. 

A VLOS in the Chukchi Sea could negatively affect terrestrial mammals in the region. The greatest 

potential for large-scale effects on several species of terrestrial mammals occurs during Phase 3, when 

spilled oil may contact Land Segments (LSs) that are used by mammal species including caribou, 

grizzly bears, muskox, and various furbearer species. With the exception of caribou, terrestrial 

mammals do not aggregate in coastal areas in numbers sufficient to permit population level effects to 

occur from oiling. 

Phase 1 (Initial Event) 

The initial event is a well-control incident and blowout that could lead to an explosion, fire, sinking 

drill rig, and the redistribution of sediment and drilling wastes in the local area. This Phase does not 

include the release of oil (Phase 2) or spill response/cleanup (Phase 4). The proposal area in the 
BOEMRE Sale 193 Revised Draft SEIS 

240 CHAPTER IV. Environmental Consequences 

Chukchi Sea is too far offshore for any Phase 1 events to be detected by terrestrial mammals. While 

some smoke could be produced by a fire, there should be no deleterious effects on terrestrial 

mammals, since particulate matter will disperse into the atmosphere around a drilling rig. 

Phase 2 (Offshore Oil) 

Terrestrial mammals by definition use onshore areas to a greater extent than offshore areas. 

However, some terrestrial mammals use sea ice to hunt and scavenge during winter. Consequently, 

they could be exposed to offshore oil at certain times of the year. Grizzly bears are known to venture 

out onto the sea ice during spring to predate seals (Doupé et al. 2007; Taylor 1995; Struzik 2003; 

Lindsay 2009; Doupé 2005; Wolkow 2005). Arctic foxes range far over the shorefast and pack-ice 

scavenging polar bear kills, and hunting when they can. Wolverines do not travel as far onto the ice 

as Arctic foxes, but are known to hunt ringed seals in some areas. As described in Section 

IV.C.1.i(4)(d) of the Sale 193 FEIS, terrestrial mammals may experience physiological effects from 

ingesting oiled food items, oiling of their fur, and ingesting oil via grooming. The most likely means 

for a terrestrial mammal to contact spilled oil in the offshore environment involves ingesting 

contaminated meat from a kill/carcass, or through accidentally getting their fur oiled. While they are 

good swimmers, the Arctic waters are probably too cold for grizzly bears, foxes, or wolverines to 

regularly swim for any significant amount of time during winter, although Arctic foxes will swim 

between barrier islands during the summer. Caribou are unlikely to ingest oiled vegetation since they 

are very selective feeders (Kuropat and Bryant 1980), however grizzly bears and scavengers may not 

be particular with regard to their foods. If salmon runs were contaminated, the effects may affect 

multiple grizzly bears. A VLOS in the Chukchi Sea may be a threat to these species if long-term 

exposure occurs, if they ingest significant quantities of oil, or if their fur becomes oiled and 

compromises its insulating capacity. 

Phase 3 (Onshore Contact) 

Caribou, muskoxen, grizzly bears, and furbearers could be affected by spills contacting coastlines; 

however, any actual chance of animals contacting oil from a VLOS would be a function of animal 

numbers, densities, the season, the size of the oiled area, etc. As described in Section IV.C.1.i (4)(d) 

of the Sale 193 FEIS (USDOI, MMS, 2007a), terrestrial mammals may experience physiological 

effects from exposure to an oil spill through oiling of their fur and ingesting oiled food items. 

A VLOS in the Chukchi Sea may be a threat to terrestrial mammal species if long-term exposure 

occurs, they ingest significant quantities of oil, or if their fur becomes oiled and compromises its 

insulating capacity. The greatest risk of contact would most likely come from ingesting oil through 

contaminated food items, or grooming oiled fur. Caribou are unlikely to ingest oiled vegetation since 

they are very selective feeders (Kuropat and Bryant, 1980); however, grizzly bears and scavengers 

may not be particular with regard to their foods. If salmon runs were contaminated or otherwise 

affected as described in Section IV.E.5, multiple grizzly bears may be affected. If caribou in insect 

relief areas become oiled, there is a chance that they could ingest some oil when grooming 

themselves; however, crude oil is a very noxious substance, and caribou may be more likely to rub it 

off on vegetation or land features, rather than licking it from their fur. 

Contact with Oil 

The effects of terrestrial mammals contacting crude oil were described in Phase 2, and on page IV176 of the Sale 193 FEIS (USDOI, MMS, 2007a). 

Contamination 

The two primary routes of oil contamination for terrestrial mammals are ingestion and oiling of fur. 

Because the Arctic is a very cold environment, terrestrial mammals rely on dense coats of fur for 

warmth. While some species such as the grizzly can put on extensive amounts of body fat and 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 241

hibernate to overwinter, others such as Arctic foxes and wolverines do not, and so remain active yearround. Caribou and muskox put on some body fat before winter, but only after grazing on vegetation 

for an entire summer and into the fall. If the fur of most species of terrestrial mammals were to 

become oiled they might attempt to rub the oil off onto another medium such as soils, rocks, or 

vegetation, or they could attempt to lick themselves clean. If the latter were to occur, these animals 

might ingest quantities of oil or hydrocarbons sufficient to cause permanent injury or death. Likewise 

it has been hypothesized that terrestrial mammals might accidentally ingest oil while grazing on 

vegetation that has been oiled or, in the case of predators, by consuming an oiled carcass. Section 

IV.C.1.i(4)(d) of the Sale 193 FEIS (USDOI, MMS, 2007a) analyzes and summarizes the effects of 

an oil spill on terrestrial mammals in greater detail. 

Loss of Access to Food 

A VLOS event should not affect the availability of forage for herbivores such as caribou or muskox, 

since they can readily travel a short distance to an un-oiled patch of vegetation. The risk is greatest 

with grizzly bears and other predators, since passing up a contaminated carcass or kill could have 

serious implications for their nutritional status at a critically important time. A decrease in nutritional 

status could have subsequent repercussions on overall fitness and ability to survive in the harsh 

environment, especially when there is no guarantee another similar food would be available in the 

near future. 

Loss of Access 

Unless large numbers of marine mammals, birds, and fishes are killed by a VLOS, there should be no 

immediate change in access to additional carcasses and other food for terrestrial mammals. However, 

any adverse impact to salmon stocks could have effects on the ability of grizzly bears, wolves, etc. to 

secure sufficient food permitting their continued survival. The loss of salmon runs could also have 

long-term effects on streamside vegetation such as willows and graminoids by limiting or removing 

annual nutrient surge into an otherwise nutrient-poor system. The consequences of the loss of a 

seasonal nutrient input into a community could then affect the quality, and perhaps quantity, of the 

forage base for species such as muskoxen and caribou. 

Phase 4 (Spill Response and Cleanup) 

Spill response activities could disturb and displace marine and coastal areas, which could act to 

displace terrestrial mammals away from an oiled area. 

The effects of vessel and aircraft traffic associated with an oil spill response and cleanup may startle 

caribou, muskoxen, grizzlies, or wolves as described in the Sale 193 FEIS (USDOI, MMS, 2007a), 

Sections IV.C.1.i(4)(d)(2)b) and IV.C.1.i(3). Some activities such as in-situ burning, animal rescue, 

etc. could have additive effects, most likely displacing animals to a slightly greater degree. However, 

it is also likely bears and scavenger animals could be disturbed while feeding on carcasses, potentially 

creating unwanted bear-human conflicts. Cleanup activities such as beach cleaning may be 

performed with a high degree of success using newer technologies (Painter, 2011). However other 

activities such as spill cleanup under ice or in areas of broken ice may be more problematic. The 

effects of these activities on terrestrial mammals would vary, depending upon the extent of coastal 

area exposed to hydrocarbon contaminants, scale and timing of the spill response, and pre-existing 

stress levels (insect relief period, nutritional status, etc.). 

Phase 5 (Long-term Recovery) 

Long-term is defined as an effect that continues in populations for more than 2 years. The immediate 

effects of short-term oiling are not expected to persist beyond a few months. If anadromous fish 

stocks are heavily affected there could be associated effects on bears and wolves that may rely on 

salmon as part of their annual food budget. Long-term effects could include the removal of annual 
BOEMRE Sale 193 Revised Draft SEIS 

242 CHAPTER IV. Environmental Consequences 

nutrient inputs in the rivers and streams supporting several mammal species and riparian vegetation, 

and over time it could have effects on other ecological communities. Even if several thousand 

caribou were immediately killed as a result of a VLOS those numbers would most likely be 

replenished within one year or two on the outside. Muskox do not frequent most coastal areas and so 

should not be at risk from a very large spill event, while predators such as grizzly bears, wolves, 

foxes, etc. normally occur in very small numbers that would not result in population level effects 

lasting beyond a year or two. 

Oil Spill Trajectory Analysis 

Grizzlies, furbearers, caribou and muskoxen would only be affected at very specific land segments 

during the summer, open-water season or by consuming oiled food items in the coastal zone in the 

event of a spill. As described in Section IV.C.1.i(4)(d) of the USDOI, MMS (2007a), terrestrial 

mammals may experience physiological effects from exposure to an oil spill through oiling of their 

fur, and ingesting oiled food items. A VLOS in the Chukchi Sea may be a threat to these species if 

long-term exposure occurs, if they ingest significant quantities of oil, or if their fur becomes oiled, 

compromising its insulative abilities. The greatest risk of contact would most likely come from 

ingesting oil through contaminated food items, or grooming oiled fur. 

Within 60 days for a summer spill the estimated discontinuous area contacted is between 245,800 and 

364,100 km2 and within 360 days 264,500 to 450,400 km2 (Appendix B, Table B-5). Winter spills 

are more restricted in area within 60 days covering a discontinuous area contacted of 162,200 to 

385,600 km2, and within 360 days 368,400 to 507,200 km2 (Appendix B, Table B-6). Such 

patchiness in a spill would likely affect the quantity of oil that reaches shore, and the number of 

animals that may be contaminated, due to uneven levels of habitat use along the Chukchi and 

Beaufort Sea coastlines. 

A very large spill could contact offshore and nearshore areas terrestrial mammals may frequent. The 

percentage of trajectories contacting the resouce would depend on the location, timing, and magnitude 

of the spill, ocean currents, weathering, and other factors. The OSRA model uses 13 launch areas 

(LAs) to model the origination of spill trajectories. The LAs are described in Appendix B, Figure B10. A VLOS continuing after 31 October is treated as a winter spill. Oil could still be released during 

this period, so 360 days is the most conservative assessment period for this hypothetical situation. 

The drilling season is typically July 15 through October 31 in the Chukchi Sea. This time period is 

typically when any spills from drilling would occur. In the unlikely event of a well blowout leading 

to a VLOS, BOEMRE has determined from 39 to 74 days would be required for another drilling unit 

to transit to the site and drill a relief well. 

In the event of this VLOS not all of the hydrocarbons are discharged at once, unlike what occurs with 

marine accidents such as the Exxon Valdez Oil Spill in Prince William Sound, Alaska. Instead they 

flow into the ocean at rates that decrease over time. For the briefest spill period BOEMRE estimates 

that a spill could persist on the surface of the water for up to three weeks, and so a 60-day period of 

potential contact was analyzed. However if a spill were to occur late in the open water season, the 

liquid hydrocarbons may freeze into the sea ice, and remain overwinter without any extensive amount 

of weathering. If this were to happen quantities of un-weathered oil could end up being transported to 

different areas in the Chukchi and Beaufort Seas and be released in the spring. To address concerns 

such as this BOEMRE has also analyzed a 360-day period. The environments of the Chukchi and 

Beaufort Seas are such that an effective oil spill response is likely under favorable conditions. 

However periods of bad weather and/or too much sea ice could hamper or prevent an effective oil 

spill response, particularly if the spill lasted into winter. An approved OSRP would be required for 

all drilling activities prior to issuance of a permit by BOEMRE. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 243

This section describes the results estimated by the OSRA model of a hypothetical very large oil spill 

in the Chukchi Sea contacting specific LSs that have importance to terrestrial mammals. During 

winter caribou and muskoxen will be inland at their wintering areas, and grizzly bears will be 

hibernating. However in the early spring grizzly bears are known to move out onto the ice, killing 

and feeding on ringed seal pups. Furbearers such as Arctic foxes, wolverines, etc. are also known to 

travel extensively on the ice in some areas, feeding on marine mammal carcasses, and any individuals 

that they can kill. 

The following paragraphs present the results (expressed as a percentage of trajectories contacting) 

estimated by the OSRA model of a hypothetical very large spill contacting habitats that are important 

to terrestrial mammal species. For example a very large spill during winter from any launch area 

could hardly be expected to directly affect caribou within 60 days since they migrate inland to winter 

habitat. However they could come into contact with spilled oil by June or July of the following year, 

since it would be within 360 days of the spill date, though by that time most of the hazardous 

components of a spill will have weathered away. 

The OSRA model estimates from any individual LA which may have a ≥1% of trajectories contacting 

Land Segments (LS) with importance to terrestrial mammals within 60 days (Tables B-1, B-9,, B-15 

and B-18), and 360 days (Tables B-2, B-10, B-16, and B-19). Due to differences in summer habitat 

use between the different species in the analysis area, each species will be analyzed independently. 

Wolves, foxes, wolverines, etc. are addressed under the heading furbearers, while the remainder of 

the species are addressed at the species level. These analyses consider the 60 and 360-day time 

periods for a very large oil spill spills occurring during summer, and the winter unless otherwise 

noted. To focus on significant impacts (or elevated potential for significant impacts), only 

percentages of trajectories ≥ 5% are discussed. 

Caribou 

Caribou from the WAH, CAH, PCH, and TCH calve on the Arctic Coastal Plain (ACP) a short 

distance from the coasts in the relatively flat coastal plain. The ACP is riddled with shallow lakes, 

ponds, streams, and puddles, all of which create ideal breeding habitat for hordes of mosquitoes, 

which have been known to force caribou onto barrier islands, to coastal areas, or into the surf in an 

effort to gain relief from their torment. During the peak insect harassment season (July to mid 

August) caribou seek insect relief along coastlines and river deltas, barrier islands, mudflats, lake 

margins, gravel bars, snow and aufeis fields, and on windy mountain slopes and ridges. Most caribou 

visit insect relief areas along the coasts although sizable portions of the PCH move into the Brooks 

Range foothills during summer for insect relief, and by early August most of the PCH is scattered into 

the Brooks Range and into Canada. The primary land segments where insect relief most frequently 

occurs include LS 62-71 (WAH), 82-83 (TCH), 95-103 (CAH), and 103-109 (CAH & PCH). 

A very large oil spill remaining in the offshore area should have no identifiable effects on caribou. 

For the onshore contact phase none of the land segments identified as insect relief areas have ≥5% 

trajectories contacting within 60 and 360 days summer or winter. 

Muskox 

The muskox population in northeastern Alaska, including ANWR, has been decreasing for several 

years partially due to predation by grizzly bears. Muskoxen also occur in coastal areas from Prudhoe 

Bay to the Seward Peninsula, though they do not seek insect relief as do caribou. It is highly unlikely 

any muskox would come into contact with a VLOS since their primary summer habitat is composed 

of riparian areas, and willow thickets or windswept uplands with easy access to quality forage plants 

during winter and spring. During winter and spring calving they prefer windswept upland areas that 

provide easy access to quality forage species. Although some individuals may be seen on the coasts, 
BOEMRE Sale 193 Revised Draft SEIS 

244 CHAPTER IV. Environmental Consequences 

or on barrier islands, such occurrences are atypical and infrequent. LSs that have been identified as 

important coastal habitat areas for muskox include LSs 59-61. 

A very large oil spill remaining in the offshore area should have no identifiable effects on muskox. 

For the onshore contact phase none of the land segments identified important to muskox have ≥5% 

trajectories contacting within 60 and 360 days summer or winter. 

Grizzly Bear 

The highest densities of grizzly bears in the analysis area occur in the mountains and foothills of the 

Brooks Range, but some individuals occur in coastal areas, particularly around salmon spawning 

streams. Coastal concentrations may be found when salmon runs occur in the Pitmegea and other 

rivers (LSs 67-68), and when marine mammal carcasses that wash ashore between Cape Seppings and 

Cape Thompson (LSs 61-64) and between Cape Lisburne and Kasegaluk Lagoon (LSs 65-75). The 

fact that grizzly bears hibernate makes them highly unlikely to contact oil from a VLOS during within 

60 days during winter, however after they emerge from their dens in April and May they may wander 

out onto shorefast sea ice to predate ringed seals as has been reported in Canada (Doupé et al., 2007; 

Struzik, 2003; Taylor, 1993) and could come into contact with spilled oil. 

Still, a VLOS remaining in the offshore area should have no identifiable effects on the grizzly bears 

population. 

For the onshore contact phase none of the land segments identified important to grizzlies have ≥ 5% 

trajectories contacting within 60 and 360 days summer. 

Winter within 60 Days. During the period covered by a 60 day winter spill, grizzly bears will be 

hibernating inland from the coasts in sites that provide safe, dry conditions. An oil spill trajectory 

analysis for this period is not provided. 

Winter within 360 Days. During winter within 360 days LS 73 has ≥ 5% of trajectories from LA1-

LA13. The OSRA model estimates a 8, 10, 7, 7, 12, 14, 6, or 5% trajectories contacting ERAs 19 to 

23 (Chukchi Spring Lead System) within 360 days from LAs 5, 10, 11, 12, or 13 (Table B-16, 

Appendix B). This Chukchi spring lead system would only factor into the trajectory analysis for 

grizzly bears if a bear were foraging for seals on the ice in the early spring, and came into contact 

with oil, or ingested oil from a kill or carcass. 

Furbearers 

Wolves spend most of their lives in Arctic foothills, not normally inhabiting the Arctic coastal areas. 

Red foxes exhibit a similar preference for hills and upland areas over wetter coastal areas, although 

some have been known to den in dry areas around the coast. Arctic foxes show habitat preferences 

for drier areas near the coast and commonly go out onto the shorefast and pack ice to scavenge and 

sometimes hunt for their food. They are known to kill ringed seal pups if they can get to them, 

however well placed and constructed subnivean lairs make predation activities on seal pups difficult. 

Wolverines range widely and can be found anywhere on the Arctic coast throughout the year, and in 

the winter they may even venture onto ice to hunt or scavenge. Wolves and red foxes should not be 

affected in any way by a VLOS due to their habitat restrictions; however, Arctic foxes are ubiquitous 

on sea ice and the coastal areas of the Chukchi and Beaufort Seas. If a VLOS were to occur a number 

of Arctic foxes could become oiled, which may compromise the thermal characteristics of their fur, 

perhaps leading to hypothermia and/or death. Wolverines could also come into contact with a VLOS, 

particularly during winter, however wolverines require very large areas for their home ranges, and are 

quite unlikely to come into contact with a VLOS at any time of the year, particularly in numbers 

resulting in population level effects. Considering the dispersed populations and diverse habitat 

preferences of Arctic foxes and wolverines, along with their propensity to travel great distances, their 

analyses will focus on Grouped Land Segments (GLSs) rather than LS’s, and include the 60-day time 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 245

period for a VLOS. Arctic foxes are very common in Alaska, and could be expected on areas of sea 

ice that may be contaced by a spill. In contrast wolverines are scarce and solitary by nature and are 

unlikely to come into contact with spilled oil. It would be pointless to analyze ERA’s for Arctic foxes 

or wolverines because of the ubiquitous distribution of Arctic foxes or the scarcity of wolverines. 

Any spills during the VLOS winter 60-day could affect polynya areas, lead systems, shear zones, and 

other areas of biological importance to Arctic foxes and wolverines, most likely oiling or killing a few 

Arctic foxes. Considering the reproductive capabilities of Arctic foxes, any such losses should not 

have detectable population level effects, and any losses would probably be replaced within one year. 

No more than one or two wolverines should be affected by a winter VLOS lasting 60 days. While 

wolverines venture out onto ice in some areas, they are not known to travel far onto the pack-ice or to 

wander, as do Arctic foxes. Wolverines maintain well established territories occupying large spatial 

areas making occurrences of more than one wolverine highly unlikely, and consequently very few 

wolverines should be affected by a VLOS event. 

A very large oil spill remaining in the offshore area should have no identifiable effects on furbears. 

The percentage of trajectories contacting furbearer resouces onshore are summarized as follows: 

Summer within 60 Days. The OSRA model estimates 12% of trajectories from LA9 contact the 

Russian Chukchi Coast, and 14 and 15 percent of trajectories from LAs 8 and 13, respectively contact 

any portion of the U.S. Beaufort Coast (Appendix B, B-11). The U.S. Chukchi Coast has 5, 9, 6, 5, 9, 

24, 26, 26, or 17 percent of trajectories contacting from LAs 4, 5, 6, 8, 9, 10, 11, 12, or 13 

respectively. 

Summer within 360 Days. The OSRA Model estimates 6, 6, 19, or 6% trajectories contacting 

Russian Chukchi Coast from LAs 4, 8, 9, or 10. A spill from LAs 4, 5, 6, 7, 8, 9, 10, 11, 12, or 13 

would have a corresponding 6, 11, 8, 9, 9, 9, 25, 28, 31, or 20% trajectories contacting any point on 

the U.S. Chukchi Coast (Appendix B, B-12). The U.S. Beaufort Coast would have a 7, 20 or 19% 

chance of being contacted by a VLOS from LAs 7, 8, or 13 respectively.Winter 60-Day: 

Winter within 60 Days. The OSRA Model estimates 8% of the trajectories from LA9 contact the 

Russian Chukchi Coast, while the U.S. Beaufort Coast has ≤5% of trajectories contacting. The 

OSRA model estimates LAs 10, 11, and 12 have a 17, 9, and 7 percent of trajectories contacting the 

U.S. Chukchi Coast. Winter 360-Day: 

Winter within 360 Days. The U.S. Chukchi Coast has 8, 12, 5, 28, 21, 20, or 9 percent of 

trajectories contacting from LAs 4, 5, 6, 10, 11, 12, or 13 respectively. LA 1 has 6 percent of 

trajectories contacting the Russian Coast, and LAs 4, 9, and 10 have a corresponding 12, 32, or 5 

percent of trajectories contacting the Russian coast. The United States Beaufort Coast has 6, 9, and 

10 percent of trajectories contacting LAs 7, 8, 12, or 13 (Appendix B: Figure B-10 and Table B-20). 

Conclusion 

Terrestrial mammals should not be significantly affected by a VLOS event. Caribou are the only 

species occurring onshore in the proposal area that might be affected in numbers greater than 1,000; 

however, this level of impact is unlikely. If a worst case scenario was to occur and several thousand 

caribou were to succumb to the effects of oil contamination, the herd sizes are sufficient to recover 

from losses within one and no more than two years. Grizzly bears in the Alaskan Arctic require 

extremely large home ranges to meet their needs. Consequently a VLOS is unlikely to involve more 

than a few bears at most. If those bears were to die as a result of consuming an oiled marine mammal 

carcass, contaminated salmon, or through grooming oiled fur, their home ranges could be reoccupied 

by other bears within that same season, and the population recovery would most likely occur within a 

year or two. 
BOEMRE Sale 193 Revised Draft SEIS 

246 CHAPTER IV. Environmental Consequences 

Effects on local muskox populations should also be small since they do not occur in large numbers, 

spending much of their time inland and away from the coast. The effects on furbearers such as foxes, 

wolves and wolverines would also be short-term since they either produce large litters (foxes), or 

occur in very low densities (wolverines, wolves). Any losses to fox populations would quickly be 

replenished, while the low population density and large home-ranges of wolverines and wolves would 

act to prevent more than a very few individuals from being exposed to a VLOS. 

The presence of oil spill cleanup crews and the associated oil spill response activity (aircraft, landing 

craft, nearshore boats, etc.) should effectively haze most terrestrial mammal species from 

contaminated areas or sites. By unintentionally disturbing the animals, responders may provide a 

positive benefit by forcing those animals away from the spill and potential contamination. 

If Alternative IV is selected, portions of LA’s 8–13 would be deffered, and if Alternative III is 

selected larger portions of LA’s 8–3 would not be available for lease under Sale 193. As the above 

analysis demonstrates, hypothetical spills emanating LASs 8–13 exhibit a comparatively higher 

potential for contact with nearshore and onshore areas used by terrestrial mammals. Should portions 

of these LAs be deferred from leasing, the consequences to terrestrial mammals would be smaller 

chances of spills originating in the affected LAs, and smaller probabilities of spills contacting 

shorefast ice, LSs and some ERAs. The larger deferral associated with Alternative III has greater 

potential to reduce impacts as compared with Alternative IV. A slightly larger potential for impacts 

would occur under Alternative I. 

IV.E.13. Vegetation and Wetlands 

Contamination of coastal vegetation and wetlands would likely occur during a VLOS and associated 

cleanup efforts. The potential for spilled oil to contact vegetation and wetland environments is 

influenced by timing of a VLOS, the seasonal effects of currents and subsequent advection of oil, 

timing and duration of oil spill, presence or absence of fast or pack ice, and general weather patterns 

(wind and storm events). The Chukchi Sea shoreline is characterized by small tides and moderate 

winds of the region (Sale 193 FEIS Section III.A.), creating a low potential for spilled oil to reach 

beyond the intertidal area. Seasonal storm events could force oil into upper shoreline areas and inside 

delta areas (Reimnitz and Maurer, 1979). Placement of booms around sheltered embayments and 

streams where diadromous and marine fish species congregate could prevent loss of fish, their habitat, 

and benthic communities that support their ecosystems. The occurrence of shore fast ice along the 

coastline of the Chukchi Sea prevents the growth of aquatic macrophytes in many littoral areas. 

Phase 1 (Initial Event) 

There are no potential impacts to vegetation and wetlands from the initial blowout event. 

Phase 2 (Offshore Oil) 

There are no potential impacts to vegetation and wetlands from contact to oil in offshore areas. 

Phase 3 (Onshore Contact) 

At Phase 3, direct exposure to oil is an impact producing factor that can affect vegetation and 

wetlands. The potential of oil from a VLOS contacting the coastal vegetation and wetlands would be 

dependent upon timing of a VLOS, the seasonal effects of currents and subsequent advection of oil, 

timing and duration of oil spill, presence or absence of fast or pack ice, and general weather patterns 

(wind and storm events). The amount of impact would be a function of the size of the oiled area and 

the duration of the VLOS. 

Oil stranded on beaches may occur only on the surface, or it could penetrate into subsurface layers. 

Permeable substrates, generally associated with larger sand grain sizes, and holes created by infauna 

could increase oil penetration, especially that of light oils and petroleum products. Penetration into 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 247

coarse-grained sand beaches may occur at a depth of 25 cm (5 in) (Pezeshki, et al., 2000). Light oils 

may penetrate peat shores; however, peat resists penetration by heavy oils (NOAA, 2000). Although 

any residual oil that could remain following cleanup might be largely removed in highly exposed 

locations through wave action, oil could remain in the shallow subsurface for extended periods of 

time. In some locations, oil might become buried by new sand or gravel deposition. Natural 

degradation and persistence of oil on beaches are influenced by the type of oil spilled, amount 

present, sand grain size, degree of penetration into the subsurface, exposure to weathering action of 

waves, and sand movement onto and off shore. Although petroleum-degrading microbial 

communities are present, biodegradation along Arctic coastlines would likely be slow (Price, Owens 

and Sergy, 2002; Braddock, Lindstrom and Price, 2003) and is limited to only a few months per year. 

Spilled oil could persist for many years, with continued effects on potential recovery of infaunal 

communities (USDOI, MMS, 2003). On sheltered beaches, heavy oiling left for long periods could 

form an asphalt pavement relatively resistant to weathering (Hayes et al., 1992; 1993). Lagoon 

shorelines include low-energy beaches where spilled oil would likely persist for many years. Spilled 

oil may persist for extended periods on peat shores; however, if cleaned up, it would be expected to 

persist for less than a decade (Owens and Michel, 2003). If the spill reached shoreline areas, the 

probability of adverse impacts on the tundra and marshes would depend on wind and wave 

conditions. Due to the low tidal range typical in such environments, stranded oil would be subject to 

low rates of abrasion and dispersal by littoral processes. 

Oil deposition above the level of normal wave activity would occur, if the spill takes place during 

spring tides or during storm surges. In such case, oil stranded in emergent vegetation is expected to 

persist for long periods due to the low rates of dispersion and degradation. Impacts would include the 

destruction of emergent vegetation, if the oil slick sinks into the root system (Jin, et al., 2002). 

Impacts to wetlands from a VLOS oil slick in the vicinity of the coast during a storm surge could 

result in injury or mortality of vegetation and invertebrates in or on the substrate. Other effects of 

spills could include a change in plant community composition or the displacement of sensitive species 

by more tolerant species. Impacts to soil microbial communities might result in long term wetland 

effects, and wetland recovery would likely be slowed. 

Various factors influence the extent of impacts to wetlands. Impacts would depend on site-specific 

factors at the location and time of the spill. The degree of impacts are related to the oil type and 

degree of weathering, the quantity of the spill (lightly or heavily oiled substrates), duration of 

exposure, season, plant species, percentage of plant surface oiled, substrate type, soil moisture level, 

and oil penetration into the soil (Hayes et al., 1992; Hoff, 1995; NOAA, 1994; Pezeshki, Hester, Lin, 

et al., 2000). Higher mortality and poorer recovery of vegetation generally result from spills of lighter 

petroleum products (such as diesel fuel), heavy deposits of oil, spills during the growing season, 

contact with sensitive plant species, completely oiled plants, and deep penetration of oil and 

accumulation in substrates. Vegetation regrowth and recovery are generally better where oil spills 

occur in flooded areas or on saturated soils, than on unsaturated soils (BLM, 2002). Coastal wetlands 

in sheltered areas (such as embayments and lagoons) and that are not exposed to strong water 

circulation or wave activity, would be expected to retain oil longer with longer-lasting effects on biota 

(Culbertson, Valiela, Pickart, et al., 2008). 

Phase 4 (Spill Response and Cleanup) 

Spill cleanup operations might adversely impact coastal beaches if the removal of contaminated 

substrates affects beach stability and results in accelerated shoreline erosion. Vehicular and foot 

traffic during cleanup could mix surface oil into the subsurface, where it would likely persist for a 

longer time. Manual cleanup rather than use of heavy equipment would minimize the amount of 

substrate removed due to effects of motorized vehicles on fragile tundra soils. Skimming, booming, 

in-situ burning, and other spill response and cleanup operations can be effective means of preventing 

offshore oil spills from reaching coastal wetlands and other vegetation. However, spill response 
BOEMRE Sale 193 Revised Draft SEIS 

248 CHAPTER IV. Environmental Consequences 

activities could also disturb, trample, or otherwise damage these resources through the transportation 

and use of equipment. The effect would be similar to the temporary impacts associated with pipeline 

construction, shorebase construction, and vessel traffic. These temporary losses of vegetative 

resources would be minimized through appropriate spill response planning and protocols. 

Phase 5 (Long-term Recovery) 

Long-term is defined as an effect that affects populations for more than 2 years. Long term effects are 

possible for coastal areas due to severity of the VLOS and OSRA projections. Storm surges are a 

concern. In 1970, Reimnitz and Maurer (1979) observed the effects of tidal surges from a major storm 

event that inundated low-lying tundra and delta regions on the Beaufort Sea shoreline, leaving debris 

lines from flotsam as far as 5,000 m (16,500 ft) inland. A storm of equal or greater magnitude could 

force weathered oil far inward and leave residue over wide areas of tundra and river shores. In such 

cases, full recovery of wetlands, including invertebrate communities, may require more than 10 years 

depending on site and spill characteristics (Culbertson, et al., 2008). Oil could remain in some 

wetland substrates for decades, even if it was cleaned from the surface. Heavy deposits of oil in 

sheltered areas of coastal wetlands or in the supratidal zone could form asphalt pavements resistant to 

degradation (Culbertson, et al., 2008). 

Oil Spill Trajectory Analysis 

The following paragraphs present the results (expressed as a percent of trajectories contacting) 

estimated by the OSRA model of a hypothetical very large oil spill contacting coastal areas. The 

probability of an oil spill contacting the coastal areas would depend on the location, timing, and 

magnitude of the spill, ocean currents, weathering, etc. The OSRA model uses 13 launch areas (LAs) 

to model the origination of spill trajectories (Appendix B, Figure B-10). The Chukchi Sea summer 

season (open-water season) lasts from 15 July to October 31, and is when any drilling related spills 

would occur. In the unlikely event of a well blowout, BOEMRE has determined from 39 to 74 days 

would be required for another drillship to transit to the site and drill a relief well. In the event of a 

VLOS not all of the hydrocarbons are discharged at once. They flow into the ocean at rates that 

decrease over time. For the briefest spill period BOEMRE assumed that a spill has a 3 week discharge 

window, and so a 60 day period of potential contact was analyzed. However if a spill were to occur 

late in the open water season, the liquid hydrocarbons may freeze into the sea ice, and remain 

overwinter without any extensive amount of weathering. If this were to happen un-weathered oil 

could be transported to non-spill zone areas in the Chukchi and Beaufort Seas and be released in the 

spring. To address concerns such as this BOEMRE has also analyzed a spill window of 360 days. A 

VLOS continuing after 31 October is treated as a winter spill. Oil could still be released during this 

period, so 360-days is the most conservative assessment period for this hypothetical situation. 

As explained above, most segments of Chukchi Sea lack vegetation and are summarized here as 

coastal barrens. The coastal barrens include the following 13 shorelines types (Table A.1-8 of the Sale 

193 FEIS): exposed rocky shore; exposed solid man-made structures; exposed wave-cut platforms in 

bedrock, mud or clay; fine to medium-grained sand beaches; tundra cliffs; coarse grained sand 

beaches, mixed sand and gravel beaches; gravel beaches; exposed tidal flats; sheltered rocky shore 

and sheltered scarps in bedrock, mud or clay; sheltered solid man-made structures; peat shorelines; 

sheltered tidal flats; and other unranked shores. Due to the physical components of coastal barrens, 

lack of fauna and flora, and the presence of underlying permafrost, oil spill slicks may be cleaned 

more effectively in these areas. The predominance of shore fast ice along these shorelines precludes 

most vegetation and benthic fauna from establishing themselves on the coastal barrens. 

This analysis focuses on coastal areas featuring more valuable vegetation and wetland communities: 

sheltered vegetated low banks (9B) and salt/brackish water marshes (10A). These communities 

contribute more to the higher trophic-levels and are a higher source of nutrients to the surrounding 

waters than the coastal barrens because they include vegetation and animal life. They are included in 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 249

Table A.1-8 of the Sale 193 FEIS are the two remaining shoreline types for OSRA analysis. These 

two types are only considered in the application of the OSRA at Land Segments (LSs) where either 

one comprised 5% or more sheltered vegetated low banks and salt/brackish water marshes of the 

coastal area are considered in the for each LE. 

Sheltered Vegetated Low Banks 

LSs featuring 5% or more sheltered vegetated low banks include: Kuchaurak and Kuchiak Creek 

LS70 (9%); Kukpowruk River, Noakok, Sitkok Point LS71 (7%); Kokolik River, Point Lay, 

Siksrikpak Point LS72 (19%); Tungaich Point, Tungak Creek LS73 (8%); Kasegaluk Lagoon, Solivik 

Island, Utukok River LS74 (9%); Akeonik, Icy Cape LS5 (18%); Avak Inlet, Tunalik River LS76 

(7%); Nivat Point, Nokotlek Point LS77 (9%); and Point Belcher, Wainwright, Wainwright Inlet 

LS79 (11%). For summer spills, the OSRA model estimates that within 60 days, 1% of the spill 

trajectories from LA 4 would contact LS74 and LS75. One percent is also the estimated percent 

trajectories starting at LA5 would contact LSs 73-75 and LS76. An estimated <1-4% of trajectories 

applies to the following: LA 10, with regard to LSs 70-75, 77, and 79; LA 11 iwith regard to LSs 71-

77 and 79; and LA 12, with regard to LSs 74-77 and 79. Within 360 days the OSRA model estimates 

that 1-2% of the spill trajectories starting at the following LAs would contact the indicated LSs: LA4 

with regard to LS73-75; LA5 with regard to LS73-75, and LS77; and LAs 5-8 with regard to LS79. 

For winter spills, the OSRA model estimates that within 60 days, 1-4% of the spill trajectories 

starting at LA10 would contact LS70-75. This estimate also applies for LA11 with regard to LSs 72-

75 and LS79, as well as to LA12 with regard to LS79. 

Salt/Brackish Water Marshes 

The only LS with coastal area of 5% or more salt/brackish water marshes that could be impacted by 

the VLOS is Kuchaurak and Kuchiak Creek (LS 70), 10% of which is comprised of these resources. 

For all hypothetical spill (summer and winter, 60 days and 360 days), the OSRA model estimates that 

1% of spill trajectories starting at LA10 would contact LS70. 

Conclusion 

Potential impacts from spills would be expected to occur from the direct effects of oil on coastal 

vegetation and wetlands. Shoreline and inundated areas of vegetation lost to the effects of a VLOS 

would recover slowly, providing an opportunity for accelerated erosion during recovery time. Tundra 

and marsh areas would be affected if the onshore contact is concurrent with a storm-surge. Oil 

contamination could persist for 10 years or more during which time the oil in the sediments could be 

slowly released back into the environment as a result of erosion or exposure of oiled sediments and 

soils. Response and clean-up efforts have the potential to cause negative effects by exposing shoreline 

areas to anthropogenic disturbance. Overall, the effects of oil exposure on vegetation and wetlands 

could take 2-10 years for recovery, depending on severity and duration of a VLOS. 

The selection of Alternative III or IV (coastwise corridor deferrals), which removes parts of LAs 8-13 

from the Lease Sale area, could reduce the chance of a VLOs from contaminating nearshore, 

estuarine, intertidal, and riverine waters. The larger deferral associated with Alternative III has greater 

potential to reduce onshore and nearshore impacts as compared with Alternative IV. The effects of 

degradation of offshore water quality would not be reduced under either Alternative III or IV. 

IV.E.14. Economy 

This section discusses the phase by phase effects of the potential impacts on the economy from a 

hypothetical VLOS. This section focuses on the impacts to jobs, personal income, revenues, and 

potential future economic activity. Each phase is evaluated according to the impact producing factors 

described in the hypothetical scenario that could affect the economy. The highest potential for 

impacts to the economy would occur during Phase 4, when thousands of spill response and cleanup 
BOEMRE Sale 193 Revised Draft SEIS 

250 CHAPTER IV. Environmental Consequences 

workers would be employed. Revenues to the North Slope Borough, State of Alaska, and the Federal 

government could also be affected by a VLOS event. 

Phase 1 (Initial Event) 

In Phase 1, the potential impact producing factors with relevance to the economy include explosion 

and fire. Once the explosion is reported, response equipment and workers will be mobilized and sent 

to the site of explosion to address a fire. There could also be economic impacts from 

psychological/social distress from news and images of the event. Employment and personal income 

levels will be moderate during this initial phase. 

Phase 2 (Offshore Oil) 

In Phase 2, the relevant impact producing factors for the economy include contact with oil, 

contamination, and loss of access. There could be increasing space/use conflicts for access to and use 

of shipping lanes, open water space, open air space, and dock/port space. Employment and personal 

income would begin to rapidly increase during the continuing release of an oil spill in offshore waters 

as response workers and equipment continued to mobilize and first responders began offshore cleanup 

operations. The numbers of cleanup workers and response vessels in Phase 2 would depend on the 

spatial extent of the thin liquid layer of oil on the water surface. The effects of spill response and 

cleanup activities on the economy are described in greater detail within Phase 4. 

Phase 3 (Onshore Oil) 

The important impact producing factors for the economy in Phase 3 include contact with oil, 

contamination, and loss of access from increased space/use conflicts from water traffic as well as 

dock space. The numbers of workers and onshore infrastructure would begin to substantially increase 

during this phase as more workers are needed for onshore cleanup operations. The effects of spill 

response and cleanup activities on the economy are described in greater detail within Phase 4. 

Phase 4 (Spill Response and Cleanup) 

Potential impact producing factors in Phase 4 that will generate substantial economic effects include 

vessels, aircraft, in-situ burning, animal rescue, dispersants, skimmers, booming, beach cleaning, 

drilling of relief well, and bioremediation. Employment and personal income will reach peak levels 

during Phase 4. In this phase, thousands of workers would be employed for response and cleanup 

operations in offshore Federal and State waters, as well as onshore Federal, State, and private lands. 

Additional housing and infrastructure may be needed to support the influx of a large amount of 

workers for spill cleanup, generating additional property tax revenues for the NSB. 

The discussion of employment for oil spill response is based on the most relevant historical 

experience of a spill in Alaskan waters, the EVOS of 1989. That spill was 240,000 bbl. It generated 

enormous employment of up to 10,000 workers directly doing cleanup work in relatively remote 

locations. Smaller numbers of cleanup workers returned in the warmer months of each year 

following 1989 until 1992. During the EVOS, numerous local residents quit their jobs to work on the 

cleanup at often significantly higher wages. This generated a sudden and significant inflation in the 

local economy (Cohen, 1993). Similar effects on the NSB would be mitigated due to the likelihood 

that cleanup activities, including administrative personnel and spill-cleanup workers, would likely be 

located in existing enclave-support facilities, though local residents leaving their jobs to work on the 

cleanup could create labor shortages in the local economy. Additional housing and infrastructure 

could be needed to support the influx of a large amount of workers for spill cleanup, with extra ships 

staged offshore likely needed to house spill response workers and infrastructure. The NSB would 

presumably receive property tax revenues from any additional onshore infrastructure put in place to 

support clean up efforts. We assume that additional infrastructure built onshore would also be an 

enclave. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 251

In the event of a 2.2 MMbbl oil spill, the number of workers employed to clean it up would depend 

on several factors. These include the procedures called for in the OSRP, how well-prepared with 

equipment and training the entities responsible for cleanup were, how efficiently the cleanup was 

executed, and how well coordination of the cleanup was executed among numerous responsible 

entities. If a very large oil spill of 2.2 MMbbl occurred it would generate several thousand direct, 

indirect, and induced jobs and millions of dollars in personal income associated with oil spill response 

and cleanup. The number of workers would likely be much larger than the number of workers who 

cleaned up the EVOS. For further detail on the spill response and cleanup components of the VLOS 

scenario, see Section IV.D.2. Any potential moratoria subsequent to a hypothetical VLOS would have 

a negative effect on jobs, income, and revenues generated by other potential future production on 

State and Federal lands and waters. 

The number of vessels and responders would increase exponentially as the spill continued, peaking in 

Phase 4. See section IV.D.2 has assumptions on number of staging locations, vessels, workers, and 

booming teams involved in response. For a discussion on how seasonal conditions could affect 

response and cleanup activities, see Section IV.D.2. the assumption is that while employment during 

winter cleanup and response would be less than employment for summer cleanup and response 

operations, the overall short run employment effect would be substantial. 

Revenue impacts on the NSB from a potential very large oil spill would be in the form of property tax 

revenues from any new infrastructure built to house the influx of workers and infrastructure. If TAPS 

throughout is reduced because of the oil spill, either through a moratoria or space-use conflicts with 

producing fields, direct revenues accruing to the State would be adversely affected, as would indirect 

revenues associated with full pipeline enhanced value from North Slope production. Any other 

displaced or lost production from Federal offshore or onshore leases would reduce revenues the 

Federal government receives through oil and gas production. Potential space/use conflicts or a 

moratorium could also delay permitting for other exploration and production activities that would 

generate economic activity through employment, personal income, and revenues. Loss of access from 

congested shipping routes and crowded ports could have a short term affect on Alaska economic 

output as delivery of goods and services could be reduced. 

Phase 5 (Long-term Recovery) 

In Phase 5, the impact producing factors with relevance to the economy are unavailability of 

environmental resources, contamination, perception of contamination (tainting), co-opting of human 

resources, and psychological distress. Each of these impact producing factors has the potential to have 

long term economic impacts in the form of employment, personal income, and revenues. In Phase 5, 

response and cleanup employment will begin declining from peak levels. 

A VLOS event could displace future economic activity that currently does not exist or is relatively 

minor in the Arctic. A VLOS could have substantial effects on jobs and revenues associated with any 

future commercial or recreational fishing taking place in the area, either from pollution of the fishing 

resource or closure of fishing grounds, and potential space/use conflicts between fisherman and 

response and cleanup operations. A VLOS could have similar adverse impacts on jobs and revenues 

generated by potential tourism and marine shipping in the region. 

A VLOS event would also result in a Natural Resource Damage Assessment (NRDA). The National 

Ocean and Atmospheric Administration (NOAA) conducts NRDA’s through a process that includes 

determination of the injuries from a spill, quantification of those injuries, and then restoration 

planning. For a description of the approaches and methods NOAA uses to identify and value injuries 

to natural resource services that have been damaged from an event like a VLOS, please refer to 

NOAA’s Damage Assessment, Remediation, and Restoration Program 

(http://darrp.noaa.gov/about/index.html). The result of the NRDA process could be substantial 

revenue impacts as the population of interest is compensated for a range of natural resource service 
BOEMRE Sale 193 Revised Draft SEIS 

252 CHAPTER IV. Environmental Consequences 

values damaged by the hypothetical VLOS and could come at a high cost to the responsible parties. 

For example, after the EVOS, Exxon paid Federal and State governments $900 million for civil 

claims, and an additional $125 million in restitution and fines under a separate settlement for Federal 

criminal charges. 

Oil Spill Trajectory Analysis

Above we have addressed the potential impacts to the economy during each phase of a VLOS event. 

In terms of oil spill impacts, the trajectory analysis for economic impacts is not expected to be 

different for a VLOS regardless of which launch area it emanates from or the percentage of spill 

trajectories contacting particular environmental resource areas. Future potential economic activities 

that are contacted would depend on where those activities are taking place; estimating where highly 

speculative future economic activity that does not exist now could take place during the time frame of 

the hypothetical scenario is beyond the scope of this analysis. 

Conclusion 

A hVLOS event of 2.2 MMbbl would generate several thousand direct, indirect, and induced jobs, 

and millions of dollars in personal income associated with oil spill response and cleanup in the short 

run. The effects would be significant in the short term. The expectation is that employment of 

cleanup workers to increase rapidly during Phase 2 and Phase 3, and to peak during Phase 4. 

Revenue impacts from a VLOS event include additional property tax revenues accruing to NSB from 

any additional onshore oil spill response infrastructure, and any potential decline in Federal, State, 

and local government revenues from displacement of other oil and gas production. A VLOS could 

also have significant adverse impacts on economic activity that does not currently take place in the 

area but could exist in the future, such as commercial fishing, recreational fishing, tourism, and 

increased Arctic marine shipping. The above impacts would occur to the same extent under each 

action alternative. 

IV.E.15. Subsistence Harvest Patterns 

A very large oil spill (VLOS) could affect subsistence-harvest patterns through altering the overall 

subsistence round due to: (1) displacement, (2) undesirability for use from contamination or perceived 

tainting, (3) reduced numbers due to species deflection from oil or anthropogenic noise during 

remediation efforts, or their pursuit becoming more difficult because of increased hunter effort, and 

(4) increased risk or cost of the subsistence effort due to having to travel further distances to harvest 

species. Direct contact of oil with barrier islands and coastal shorelines would create toxic 

environments for resources and traditional subsistence harvests in these areas. The effects on 

subsistence resources are provided in the discussions in the previous sections. The Sale 193 FEIS 

includes broader discussion of the types of impacts that could occur to subsistence-harvest patterns, 

and provides background information for the assessment below. 

A VLOS in winter could affect polar bear hunting and sealing. Bird hunting, sealing, whaling, and the 

ocean netting of fish could be affected by a spill during the open-water season. Disturbance could 

extend the subsistence hunt in terms of miles to be covered, making more frequent and longer trips 

necessary to harvest enough resources in a harvest season. The loss of waterfowl populations to oil 

spills would cause harvest disruptions in the spring that would be significant to subsistence hunters 

who regard the spring waterfowl hunt to be of primary importance. In the event of a VLOS contacting 

and extensively oiling habitats, the presence of hundreds of humans, boats, and aircraft would result 

in anthropogenic noise that would likely displace subsistence species and alter or reduce subsistencehunter access to subsistence species in traditional harvest areas. 

Negative effects on specific subsistence species, as well as to the more general patterns of subsistence 

resource use, persisted in Prince William Sound for several years after the EVOS and the subsequent 

cleanup effort. In the Chukchi Sea region, marine mammals are the most important subsistence 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 253

resource, both culturally as well as in terms of food. The bowhead whale hunt could be disrupted, as 

could the hunts for beluga whale, bearded seal, and other marine mammals generally. Impacts would 

be intensified should entrained oil contaminate ice leads and surrounding shoreline. Although there 

has been little harvest of walrus in Wainwright and Point Lay in the past few years, future harvest 

could be disrupted. Animals could be directly oiled, or oil could become part of the ice floes they use 

on their northern migration. Such animals may be considered undesirable and more difficult to hunt 

because of the physical conditions. Animals are also likely to be “spooked” or wary, either because of 

the spill itself or from the “hazing” of marine mammals, which is a standard spill-response technique 

to encourage them to leave the area affected by a spill. There has been little experience with under-ice 

or broken-ice oil spills, and local residents have little confidence in industry’s current capability to 

successfully clean them up. While the concern most typically is phrased in terms of the potential 

effects of oil spills on whales and whaling, it can be generalized to a concern for marine mammals 

and ocean resources in general. Marine mammals and fishes typically comprise 60% of a coastal 

community’s diet. It is often stated in public testimony that “The sea is my garden.” A VLOS could 

affect migrating anadromous fishes in the river deltas, as well as species that use oiled coastal and 

nearshore habitat, such as breeding caribou and nesting birds (see Sections IV.E.5, Fish Resources; 

IV.E.12, Terrestrial Mammals; and IV.E.9, Marine and Coastal Birds, respectively). 

Other effects from potential oil spills, such as food tainting and cleanup disturbance could occur after 

a spill event. An oil spill affecting any part of the migration route of the bowhead whale could taint 

this resource that is culturally pivotal to the subsistence lifestyle. Even if whales were available for 

the spring and fall hunts, tainting concerns could leave bowheads less desirable and alter or stop the 

subsistence hunt. Communities unaffected by a potential spill would share bowhead whale products 

with impacted villages, and the harvesting, sharing, and processing of other resources should 

continue. Concerns about tainting would apply also to polar bears and seals and could cause potential 

short-term but serious adverse effects on some bird populations. A potential loss of a small number of 

polar bears would reduce their local availability to subsistence users. Oil-spill-cleanup activities could 

produce additional effects on subsistence activities, potentially causing displacement of subsistence 

resources and subsistence hunters. 

Although the VLOS would originate within the Chukchi Sea Planning Area, indirect impacts might 

be felt by communities remote from the sale area and far removed from the spill. Essentially, 

concerns about subsistence harvests and subsistence food consumption would be shared by all 

Inupiaq and Yup’ik Eskimo communities in the Chukchi and Bering seas adjacent to the migratory 

corridor used by whales and other migrating species, as well as subsistence users on the Russian 

Arctic coast of the Chukchi Sea. Concerns about contaminated subsistence resources in these 

communities seriously could curtail traditional practices for harvesting, sharing, and processing 

important subsistence species because all communities would share concerns over the safety of 

subsistence foods and whale food products and the health of the whale stock. 

In the Chukchi Sea the active-ice, or ice-flaw, zone is an important habitat for marine mammals such 

as bowhead and beluga whales, walruses, seals, and other marine mammals. Seals, walruses, and 

beluga whales would be most vulnerable to a spill contacting this zone; polar bears would be most 

vulnerable to spills contacting the flaw zone or the coast. The most noticeable effects of potential oil 

spills from offshore oil activities would be through contamination of seals, walruses, and polar bears, 

with lesser effects on beluga whales (USDOI, MMS, 2007a). For more information on potential 

impacts from a VLOS to these species, see Sections IV.E.10 Ice Seals; IV.E.11 Pacific Walrus; 

IV.E.8 Polar Bear; and IV.E.7 Cetaceans. 

Very large oil spills could affect subsistence patterns by reducing populations of subsistence species, 

contaminating subsistence species or their habitats, or rendering resources unfit to eat. These effects 

could reduce the amount of subsistence foods harvested, cause changes in traditional diets, increase 

risks and wear and tear on equipment if users were required to travel farther to obtain subsistence 
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254 CHAPTER IV. Environmental Consequences 

resources, and cause social stress due to the reduction or loss of preferred foods harvested in the 

traditional fashion (USDOI BLM and MMS, 2003; USDOI, BLM, 2004a, 2005, 2006; USDOI, 

MMS, 1987b, 1990b, 1998a, 2001, 2003a, 2004, 2006a,b,d). 

Effects of a VLOS on subsistence-harvest patterns are discussed below for each of the five phases of 

the hypothetical scenario. The greatest potential for effects on subsistence resources and practices 

occurs during Phase 3 (Onshore Contact) and 4 (Spill Response and Cleanup). In all cases, long-term 

recovery of resources and practices is likely, and harvesting, sharing, and processing of subsistence 

resources would continue but would be hampered to the degree these resources were contaminated. 

Tainting concerns in communities nearest the spill or contacted coastlines could seriously curtail 

traditional practices for harvesting, sharing, and processing resources and threaten pivotal practices of 

traditional Native culture. In the case of long term or extended contamination, harvests would cease 

until such time as local subsistence hunters perceived resources as safe. Any losses of resources could 

be significant to the local harvest by subsistence-dependant communities. Just as with the Exxon 

Valdez oil spill, the instantaneous nature and the magnitude of the event would not permit 

opportunistic “stocking up” of available resources (USDOI, MMS, 2007a, 2008a). 

Phase 1 (Initial Event) 

Direct impacts on subsistence resources would likely be quite localized in the initial phases of the 

blowout event. However, indirect impacts to substance-harvest patterns from news and images of the 

event would likely be traumatic to subsistence harvesters throughout the Chukchi Sea region, and 

would likely produce increased stress and anxiety over the safety and availability of resources and 

harvest areas. Fears about reduced or contaminated resources, contaminated habitats and harvest 

areas, reductions in the ability to harvest traditional foods, and general food safety could all cause 

additive social stress (USDOI, MMS, 2007a, 2008a). 

Phase 2 (Offshore Oil) 

In this phase, offshore resources could come into direct contact with spilled oil, and pollution 

stemming from an oil spill may contaminate environmental resources, habitat, and food sources. The 

presence of oil and the initial response to the spill event could prevent or disrupt access to and use of 

affected areas. If offshore oil directly contacted migrating or resident marine mammals and 

compromised traditional harvest areas by persisting there, subsistence practices, particularly bowhead 

whaling, would be seriously curtailed due to the same issues concerning contamination discussed in 

Phase 1, as well as creating serious reductions in access to traditional nearshore harvest areas. 

Seabirds and waterfowl would be most vulnerable to this phase of a VLOS because they spend the 

majority of their time on the sea surface and often aggregate in dense flocks. Marine mammals such 

as ice seals, bearded seal, walrus and polar bear would either not be in the area or, in the case of 

walrus, would be unlikely to remain in the vicinity of an active drilling operation (see Sections 

IV.E.8, IV.E.10, and IV.E.11). 

Effects of a VLOS on key subsistence species during Phase 2 are discussed below. 

Bowhead Whales. In the event of aVLOS, the probability of oil contacting whales is likely to be 

considerably less than the probability of oil contacting bowhead habitat and traditional harvest areas. 

The number of whales contacting spilled oil would depend on the location, size, timing, and duration 

of the spill and the whales’ ability or inclination to avoid contact. If oil got into leads or ice-free areas 

frequented by migrating bowheads, some portion of the population could be exposed to spilled oil. 

Prolonged exposure to freshly spilled oil could kill some whales. Whales travelling under the ice or 

feeding near the bottom could also experience contamination. A recent study establishing that 

bowhead whales have olfactory bulbs and can smell when they breathe tends to substantiate TEK 

regarding this species’ ability to smell and avoid areas where oil is present. For more information on 

potential impacts to bowheads from a VLOS, refer to Section IV.E.6. 
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CHAPTER IV. Environmental Consequences 255

There are, in some years and in some locations, relatively large aggregations of feeding bowhead 

whales within potentially affected areas. If a large amount of fresh oil contacted a significant portion 

of such an aggregation, effects potentially could be greater than typically would be assumed. We 

cannot rule out population-level effects if a large number of females and newborn or very young 

calves were contacted by a large amount of fresh crude oil. Traditional practices for harvesting, 

sharing, and processing subsistence resources could be seriously curtailed in the short term, if there 

are concerns over the tainting of bowhead whales or their feeding areas from an oil spill. 

Barrow elder Thomas Brower, Sr., observed an oil spill from a U.S. Navy vessel in the Plover Islands 

east of Barrow in 1944 (Brower, 1944 as cited in NSB, Commission on History and Culture, 1980) 

where about 25,000 gallons were spilled. According to Brower: 

...for four (4) years after that oil spill, the whales made a wide detour out to sea from these islands. 

Those Native families could no longer hunt whales during these years at that location.” 

Although this spill event reveals that species can experience recovery from an oil spill in the Arctic 

after 4 years without cleanup, the event is remembered more importantly as a time of devastation and 

deprivation by those who directly witnessed the effects of the spill or those who were told of the 

event by witnesses. Not only were whales absent for 4 years following the spill, but other resources 

were absent or occurred in reduced numbers. The people of Barrow who remember the spill consider 

it evidence that even a relatively small oil spill in a defined area can have lasting effects on 

subsistence resources and harvests. 

Thomas Brower, Sr. also stated that: 

In the cold, Arctic water, the oil formed a mass several inches thick on top of the water. Both sides of 

the barrier islands in that area(the Plover Islands) became covered with oil. That first year, I saw a 

solid mass of oil six (6) to ten (10) inches thick surrounding the islands. On the seaward side of the 

islands, a mass of thick oil extended out sixty (60) feet from the islands, and the oil slick went much 

further offshore than that. I observed how seals and birds who swam in the water would be blinded and 

suffocated by contact with the oil. It took approximately four (4) years for the oil to finally disappear. 

(Brower as cited in NSB, Commission on History and Culture, 1980) (USDOI, MMS, 2007a) 

Beluga Whales, Seals and Walrus. The effects from a VLOS on beluga whales, seals, and walrus 

would occur from: (1) oiling of skin and fur; (2) inhaling hydrocarbon vapors; (3) ingesting oilcontaminated prey; (5) losing food sources; and (6) temporary displacement from some feeding areas. 

Additional discussion of potential impacts to these marine mammals is provided in Section IV.E.10. 

In general, any VLOS in nearshore marine waters could cause injury or death to these sea mammals, 

potentially cause them to move off of their normal course, and make them unavailable for the 

subsistence harvest. 

A VLOS contacting nearshore areas near Point Lay would disrupt the beluga migration and deprive 

the community of its primary subsistence hunt. There are, in some years and in some locations, 

relatively large aggregations of feeding and molting beluga whales within the planning area. If a large 

amount of fresh oil contacted a significant portion of such an aggregation, effects could be greater 

than typically assumed. Population-level effects cannot be ruled out if a large number of females and 

newborn or very young calves were contacted by a large amount of fresh crude oil (USDOI, MMS, 

2007a). Analysis of potential VLOS impacts on these species is provided in Section IV.E.7 

Cetaceans, Section IV.E.10 Ice Seals, and IV.E.11 Pacific Walrus 

Polar Bears. If a VLOS occurred, significant impacts to polar bears could result, particularly if areas 

in and around polar bear aggregations were oiled. This is because the biological potential for polar 

bears to recover from any perturbation is low due to their low reproductive rate and rapid loss of sea 

ice habitat due to global climate change. Analysis of potential VLOS impacts to Polar Bears is 

provided in Section IV.E.8. 
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256 CHAPTER IV. Environmental Consequences 

Birds. The direct and indirect effects on marine and coastal birds from contact with oil are analyzed 

in greater detail in Section IV.E.9. Many bird species important to subsistence in the Chukchi Sea 

region are associated with nearshore and coastal areas, or both. Impacts to subsistence caused by 

oiling of birds during the offshore spill phase are presented within the Phase 3 discussion of onshore 

contact, below. 

Phase 3 (Onshore Contact) 

In this phase the more profound impacts to subsistence resources and practices would occur: (1) 

onshore resources and coastal harvest areas could come into direct contact with spilled oil; (2) 

pollution stemming from a VLOS contaminate subsistence resources and their habitats and food 

sources, subsistence harvest areas, and seriously curtail use of traditional food sources because of 

actual and perceived contamination. In addition, the presence of oil would prevent or disrupt access to 

and use of traditional subsistence harvest areas. For subsistence practices to fully recover, access to 

recovered/restored harvest areas would be necessary. 

Effects of a VLOS on key subsistence species during Phase 3 are discussed below. 

Walrus and Polar Bears. For walrus, an oil spill impacting coastal haulout areas could have a 

significant impact on walrus populations; the same would be true if oil contacted denning polar bears. 

Oil-spill effects could cause injury or death to these sea mammals, potentially cause them to alter 

normal behaviors, and make them unavailable for the subsistence harvest (see Sections IV.E.11 and 

IV.E.8 for analysis of potential impacts on these species). 

Caribou and Other Terrestrial Mammals. Terrestrial mammals would be affected by a VLOS to 

the extent they reside in coastal habitats and feed near contaminated shorelines. Caribou can frequent 

barrier islands and shallow coastal waters during periods of heavy insect harassment and could 

become oiled and/or eat contaminated vegetation, although more likely animals would be deflected 

from contaminated areas by spill cleanup activity. During late winter- early spring, caribou move out 

on to the ice and lick sea ice for the salt and would be exposed to oil if a spill contaminates the ice. If 

a VLOS occurred during the open-water season or during winter and melted out of the ice during 

spring, caribou frequenting coastal habitats would be directly contaminated by the spill along the 

beaches and in shallow waters during periods of insect-pest-escape activities. Caribou that become 

oiled are not likely to suffer the loss of thermoinsulation through fur contamination although toxic oil 

would be absorbed through the skin and also would be inhaled. Significant weight loss and aspiration 

pneumonia leading to death are possible adverse effects of oil ingestion in caribou. Caribou that 

become oiled by contact with a spill in coastal waters could die from toxic hydrocarbon inhalation 

and absorption through the skin. Similar effects would be expected for muskoxen. Grizzly bears 

depend on coastal streams, beaches, mudflats, and river mouths during the summer and fall for 

catching fish and finding carrion. If a VLOS contaminates beaches and tidal flats along the Chukchi 

Sea coast, some grizzly bears and Arctic foxes are likely to ingest contaminated food, such as oiled 

birds, seals, and other carrion. Such ingestion could result in the loss of bears and foxes through 

kidney failure and other complications. Small numbers of grizzly bears and Arctic foxes could be lost 

through ingestion of contaminated prey or carrion (USDOI, MMS, 2007a) (see Section IV.E.12 for 

analysis of potential impacts on these species). 

Fish. A VLOS impacting intertidal or estuarine spawning and rearing habitats used by capelin or 

other fishes potentially could result in significant adverse impacts to some local breeding populations. 

Recovery to former status by dispersal from nearby population segments would require more than 

three generations. Anadromous fish can be particularly impacted if oil reaches mouths and deltas of 

anadromous streams and rivers. Table 7 within Section IV.E.5 provides more detailed information on 

anadromous waters in the region, and the species that they support. Depending on the timing, extent, 
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CHAPTER IV. Environmental Consequences 257

and persistence of a VLOS, some distinct runs of pink and chum salmon could be eliminated. 

Recovery from this significant adverse impact would only occur as strays from other populations 

colonized the streams after the oiled habitats recovered. These local fish stocks would not be 

available for subsistence harvests for many years. 

Birds. As described in Section IV.E.9, the greatest potential for substantial adverse impacts from a 

VLOS on marine and coastal birds would come in important coastal bird habitats. These areas are 

Kasegaluk Lagoon, Peard Bay, the barrier islands, the spring open-water lead system, and the seabirdnesting colonies at Cape Lisburne and Cape Thompson. Oil spills have the greatest potential for 

affecting large numbers of birds in part due to toxicity to individuals and their prey and the 

difficulties involved in cleaning up spills in remote areas, given the wide variety of possible ice 

conditions. A VLOS could impact large number of murres, puffins, and kittiwakes at the Cape 

Lisburne and Cape Thompson colonies. The magnitude of potential mortality could result in 

significant adverse impacts to the colonies. Similarly, large-scale mortality could occur to pelagic 

distributions of auklets and shearwaters during the open-water period and male and juvenile murres in 

the late summer. Kasegaluk Lagoon, Peard Bay, colonies at Cape Thompson and Cape Lisburne, the 

open-water Spring-Lead System, and barrier islands provide important nesting, molting, and 

migration habitat to a variety of waterfowl and shorebirds. Spills during periods of peak use could 

affect large numbers of birds. Up to 45% of the estimated Pacific Flyway population of Pacific brant 

could be affected if an oil spill reached Kasegaluk Lagoon. Effects could range from direct mortality 

of approximately 60,000 brant to sublethal effects on an equal or smaller number of brant. The loss of 

up to 45% of the Pacific Flyway population would have conspicuous population-level effects. The 

situation with brant is similar to a wide variety of waterfowl and shorebirds that use similar areas of 

the Chukchi Sea. The loss of waterfowl populations to oil spills would cause harvest disruptions that 

would be significant to subsistence hunters who regard the spring waterfowl hunt to be of primary 

importance. 

Subsistence Practices. A VLOS could affect subsistence patterns by reducing populations or 

availability of subsistence species, contaminating subsistence species or their habitats, producing 

tainting concerns in resources, and rendering resources as unfit to eat. These effects would reduce the 

amount of subsistence foods harvested, result in changes in traditional diets, and increase risks and 

wear and tear on equipment as users would be forced to travel farther to obtain subsistence resources. 

Marine mammals are the most important subsistence resource, both conceptually and as food, for 

these regions. The bowhead whale hunt could be disrupted, as could the beluga harvest and the more 

general and longer hunt for walruses. Animals could be directly oiled, or oil could contaminate the 

icefloes they use on their northern migration. Contaminated animals would be considered undesirable 

and could be more difficult to hunt because of the physical conditions. Animals could be “spooked” 

and wary, either because of the spill itself or of the “hazing” of marine mammals, which is a standard 

spill-response technique used to encourage them to leave the area affected by a spill. There has been 

little experience with under-ice or broken-ice oil spills, and local residents have little confidence in 

industry’s current capability to successfully clean up a spill of this type in a timely manner (USDOI, 

MMS, 2007a). 

In addition to impacts to subsistence-resource populations, a VLOS could produce tainting and 

cleanup disturbance. An oil spill affecting any part of the migration route of the bowhead whale and 

other marine mammals could taint a resource that is culturally pivotal to the subsistence lifestyle. 

Even if whales were available for the spring and fall hunts, tainting concerns would make bowheads 

less desirable and alter or stop the subsistence hunt. Communities unaffected by a potential spill 

would share bowhead whale products with impacted villages, and the harvesting, sharing, and 

processing of uncontaminated resources would continue (USDOI, MMS, 2007a). 

While the greatest tainting concern is most typically expressed as it relates to potential oil-spill effects 

whales and whaling, it is also a more generalized concern for marine mammals and ocean resources. 
BOEMRE Sale 193 Revised Draft SEIS 

258 CHAPTER IV. Environmental Consequences 

Marine mammals and fish typically comprise 60% of a coastal community’s diet, it is frequently 

stated in public testimony that “The sea is my garden.” A VLOS could impact migrating anadromous 

fish in the river deltas, as well as species that use (potentially oiled) coastal and nearshore habitats, 

such as nesting birds and breeding caribou. Concerns about tainting also would apply to walrus, 

bearded seal, other seals and polar bears and would cause serious adverse effects on some bird 

populations. A potential loss of a small number of polar bears would reduce their local availability to 

subsistence users. Waterfowl, fish, and marine mammals could be fouled, contaminated, or killed. A 

VLOS would be toxic immediately to fish and could contaminate them for years, even in apparently 

cleaned habitats. Waterfowl and marine mammal populations could be affected by the death of 

animals from hypothermia caused by oiling, reactions to toxic components of spilled oil, and gastric 

distress resulting from attempts to clean themselves. In addition, scavengers feeding on their remains, 

such as foxes and bears, also could be harmed (USDOI, MMS, 2007a). 

Oil-spill-cleanup activities would produce additional effects on subsistence activities, potentially 

causing displacement of subsistence resources and subsistence hunters. Even if, in some cases, 

biological effects on subsistence resources did not affect species' distributions or populations, 

disturbance could extend the subsistence hunt in terms of miles to be covered, making more frequent 

and longer trips necessary to harvest enough resources in a harvest season. Major negative impacts to 

specific subsistence species, as well as to the more general patterns of subsistence-resource use, 

persisted in Prince William Sound for several years after the Exxon Valdez oil spill event and the 

subsequent cleanup effort. 

A spill originating within the Chukchi Sea region would produce indirect impacts felt by communities 

remote from the sale area and far removed from the spill. Essentially, these same concerns about the 

integrity of subsistence resources, subsistence harvests, and subsistence food consumption would be 

shared by all Inupiat and Yup’ik Eskimo communities in the Chukchi Sea Region and would include 

indigenous people on the Russian Chukchi Sea coast adjacent to the migratory corridor used by 

whales and other migrating species including salmon stocks breeding in the Bering Sea region 

(USDOI, MMS, 2007a). 

There is also concern that the International Whaling Commission, which sets the quota for the Inupiat 

subsistence harvest of bowhead whales, would reduce the harvest quota following a major oil spill to 

ensure that overall population mortality did not increase. Such a move would have profound cultural 

and nutritional impacts on whaling communities. 

Tainting concerns could seriously curtail the harvesting, sharing, and processing of subsistence 

resources, and these practices would be hampered to the degree these resources were contaminated. 

All areas directly oiled, areas to some extent surrounding them, and areas used for staging and 

transportation corridors for oil-spill response would not be used by subsistence hunters for some time 

following a spill. Oil contamination of beaches would have a profound impact on whaling because, 

even if bowhead whales were not contaminated, Inupiat subsistence whalers would not be able to 

bring them ashore and butcher them on a contaminated shoreline. In the case of extreme 

contamination, harvests could cease until such time as resources were perceived as safe by local 

subsistence hunters. Because all communities would share concerns over the safety of these 

subsistence foods and the health of the whale stock, social stress would occur from the reduction or 

loss of preferred foods harvested in the traditional fashion and threaten a pivotal element of 

indigenous Alaska culture. The duration of avoidance by subsistence users would vary depending on 

the volume of the spill, the persistence of oil in the environment, the degree of impact on resources, 

the time necessary for recovery, and the confidence in assurances that resources were safe to eat. 

Such oil-spill effects would be considered significant (USDOI, MMS, 2007a). 

Russian Arctic Chukchi Sea Coastal Communities. Depending on the location and trajectory of the 

hypothetical VLOS, coastal communities on the Russian side of the Chukchi Sea could also 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 259

experience adverse impacts to their subsistence-harvest patters. Potentially, important coastal lagoons 

and nearshore subsistence-harvest areas for beluga, gray and bowhead whales, walrus, seals, fish, and 

birds could be contacted in the event of a VLOS. Intensive industrialization, massive immigration, 

forced acculturation, and the collapse of Soviet economic and employment supports have taken a 

huge toll on the indigenous peoples of the region. These conditions have, ironically and out of 

necessity, brought coastal Native peoples closer to nature and turned them again toward their 

traditional reliance on hunting and fishing of marine resources, and their traditional diet of marine 

mammals, fish, marine invertebrates, and other locally harvested resources such as small game. In 

some cases, population and industrial declines have lead to lower anthropogenic pressures on 

ecosystems, but more often these conditions have increased poaching levels due to increased 

unemployment and the lack of adequate food supplies. Effects from a VLOS could exacerbate 

existing stresses on local resource populations and the local hunt, causing significant impacts to 

indigenous coastal communities (Newell, 2004; Nuttall, 2005). 

Phase 4 (Spill Response and Cleanup) 

In this phase the more profound impacts to subsistence resources and practices would occur from 

noise disturbances, habitat alteration, and the real and perceived contamination from: (1) vessels 

supporting response and cleanup efforts; (2) aircraft supporting response and cleanup efforts; (3) 

relief well drilling, (4) in-situ burning of spilled oil; (5) the hazing and capture of wildlife; (6) 

dispersant use; (7) bioremediation; and, (8) beaching cleaning. In addition, manpower reallocations 

could seriously threaten traditional subsistence practices. Spill cleanup would provide an opportunity 

for local high paying spill cleanup wage work and would likely displace many local hunters and 

equipment from traditional subsistence harvest pursuits. Cleanup for a very large onshore oil spill 

could disrupt subsistence-harvest activities for at least an entire season from oil-spill employment for 

oil-spill response and cleanup. Effects of a VLOS on key subsistence species and harvest practices are 

discussed below (USDOI, MMS, 2007a). 

Disturbance to bowhead and beluga whales, seals, polar bears, caribou, fishes, and birds potentially 

would increase from oil-spill-cleanup activities. Offshore, skimmers, workboats, barges, aircraft 

overflights, relief well drilling activities and in-situ burning during cleanup could cause whales to 

temporarily alter their swimming direction. Such displacement could cause some animals, including 

seals in ice-covered or broken-ice conditions, to avoid areas where they are normally harvested or to 

become more wary and difficult to harvest. Nearshore, workers and boats, and onshore, workers, 

support vehicles, heavy equipment, and the intentional hazing and capture of animals could disturb 

coastal resource habitat, displace subsistence species, alter or reduce subsistence hunter access to 

these species, and alter or extend the normal subsistence hunt. Overall, oil-spill-cleanup activities, far 

from providing mitigation, more likely should be viewed as an additional impact, potentially causing 

displacement of subsistence resources and subsistence hunters (see Impact Assessment, Inc., 1998). 

Please also refer to Section IV.E.7, Cetaceans. 

Effects of a VLOS on key subsistence species during Phase 4 are discussed below. 

Bowhead Whales. There are no described observations concerning the level of disturbance on 

bowhead whales from cleanup activities although the presence of offshore skimmers, workboats, 

barges, aircraft overflights, and in-situ burning during cleanup are expected to cause whales to 

temporarily alter their swimming direction and cause temporary displacement. Oil-spill-response 

activities that included active attempts to move whales away from oiled areas would cause short-term 

changes in local distribution and abundance. In the case of a winter spill, few, if any, bowhead whales 

would be present and that action of ice in the lead system would reduce the amount of volatile 

hydrocarbons inhaled by bowheads (USDOI, MMS, 2002; USDOI, MMS, 2003a). 

Beluga Whales, Walrus and Other Marine Mammals. In the case of a VLOS in winter, when few 

important subsistence marine mammal resources would be present, cleanup measures would tend to 
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260 CHAPTER IV. Environmental Consequences 

reduce potential before migrating whales and other marine mammal species return to the area during 

breakup and the open-water season. Ringed seals are common during the winter, but they are not 

harvested by local subsistence hunters during this period. It is possible that cleanup operations could 

displace some ringed seals from maternity dens during the winter, resulting in the some seal pup 

losses. If a VLOS occurred, contacted, and extensively oiled coastal habitats during the open-water 

season, the presence of cleanup personnel, boats, and aircraft operating in the cleanup area is 

expected to displace beluga whales, seals, and walruses and to contribute to increased stress and 

reduced pup survival of ringed seals, if operations occur during the spring and as long thereafter as 

cleanup efforts continue (Impact Assessment, Inc., 1998; USDOI, MMS, 2003a, USDOI, BLM 

2004a, b). 

Polar Bears. If a VLOS occurred, contacted, and extensively oiled coastal habitats, the presence of 

cleanup personnel, boats, and aircraft operating in the cleanup area is expected to displace polar 

bears. It is possible that cleanup operations could displace some bears from maternity dens during the 

winter, resulting in the loss of some bear cubs. These effects would occur for the duration of cleanup. 

Cleanup efforts would include the removal of all oiled animal carcasses to prevent polar bears from 

scavenging them. Aircraft hazing of wildlife away from the spill would reduce the chances of polar 

bears entering coastal waters where there is an oil slick (Impact Assessment, Inc., 1998; USDOI, 

MMS, 2003a, USDOI, BLM, 2004a, b). 

Caribou and Other Terrestrial Mammals. If aVLOS contacted, and extensively oiled coastal 

habitats containing herds or bands of caribou during the insect season, the presence of cleanup 

personnel, boats, and aircraft operating in the area of cleanup activities is expected to cause 

displacement of some caribou in the oiled areas and could seriously stress the herd, resulting in 

increased mortality or decreased productivity. For most spills, control and cleanup operations at the 

spill site would frighten animals away from the spill and prevent them from grazing on oiled 

vegetation. These effects would occur for the duration of cleanup operations and are not expected to 

significantly affect caribou herd movements or foraging activities. Cleanup also would disturb some 

muskoxen, grizzly bears, and Arctic foxes (USDOI, BLM, 2006; USDOI, MMS, 2003a). 

Fish. Oil-spill-cleanup activities in open water or in broken ice are not expected to adversely affect 

fish populations utilized for subsistence. Onshore cleanup is likely to add little to the toxic oil contact 

impacts to fish resources described above (USDOI, MMS, 2003a). 

Birds. Spill response activities could disturb and displace marine and coastal birds, which could have 

net beneficial effects by intentionally or unintentionally moving birds away from oiled areas. This 

displacement may move birds to unoiled areas, with negligible energetic costs, if these habitats were 

of similar quality. Marine and coastal birds could be harmed, however, if birds moved to inferior 

habitats where biological needs could not be met. Several species have specific nesting (e.g., islands, 

cliffs, low-gradient beaches) or foraging requirements (e.g., lagoons, passes between barrier islands) 

that could be altered by clean-up efforts. While the marine and coastal birds could physically relocate 

to other areas, those areas may be unsuitable and delay recovery. 

Subsistence Practices. Spill-cleanup strategies potentially would reduce the amount of spilled oil in 

the environment and tend to mitigate spill-contamination effects, especially in the case of a winter 

spill when few important subsistence resources would be present and cleanup is likely to be fairly 

effective. Disturbance to bowhead and beluga whales, seals, walruses, caribou, fish, birds, and polar 

bears would increase from oil-spill cleanup activities for spills occurring during breakup or the openwater season. Offshore, skimmers, workboats, barges, aircraft overflights, and in-situ burning during 

cleanup could cause whales to temporarily alter their swimming direction. Such displacement would 

cause some animals, including seals in ice-covered or broken-ice conditions, to avoid areas where 

they are normally harvested or to become more wary and difficult to harvest. Cleanup disturbance 

would affect polar bears within about 1 mile of the activity. People and boats offshore and people, 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 261

support vehicles, and heavy equipment onshore, as well as the intentional hazing and capture of 

animals would disturb coastal resource habitat, displace subsistence species, alter or reduce 

subsistence-hunter access to these species, and alter or extend the normal subsistence hunt. Deflection 

of resources, resulting from the combination of a VLOS and spill-response activities, would persist 

beyond the timeframe of a single season, perhaps lasting several years (USDOI, MMS, 2007a). 

Subsistence hunting also would be impacted by any spill that required the local knowledge, 

experience, and vessels of local whaling captains. Diverting effort and equipment to oil-spill cleanup 

would adversely impact the subsistence whale hunt (and other harvesting activities, as well). Far from 

providing mitigation, oil spill-cleanup activities more likely should be viewed as an additional impact, 

potentially causing displacement of the subsistence hunt, subsistence resources, and subsistence 

hunters. The overall result would be a major effect on subsistence harvests and subsistence users, who 

would suffer impacts on their nutritional and cultural well-being. Impacts subsistence harvests and 

subsistence users would be significant as they would likely persist for more than a single harvest 

season (Impact Assessment, Inc., 1998; USDOI, MMS, 2003a, USDOI, BLM, 2004a, b). 

Phase 5 (Long-term Recovery) 

In this phase the impacts to subsistence resources and practices would occur from: (1) the 

unavailability of (or increased difficulty in utilizing) environmental resources; (2) longer term 

contamination from pollution stemming from the oil spill; (3) the perception that resources are 

contaminated altering use patterns; (4) the co-opting of human resources such as manpower, 

equipment, and other resources required to study long-term impacts and facilitate recovery would be 

unavailable for other purposes; and (5) psychological and social distress, stemming from long-term 

impacts from a VLOS. Effects of a VLOS on key subsistence species and harvest practices are 

discussed below. 

In the long-term recovery phase, longer term subsistence impacts would transform into near-term 

sociocultural impacts and their disaggregation would be difficult. Nevertheless, many observations 

can be posited, based on long-term recovery research done after the Exxon Valdez oil spill. Longterm subsistence impacts from a VLOS and its cleanup would be any perceived chronic disruption of 

the bowhead whale harvest and any actual or perceived tainting of the whale meat anywhere during 

the bowhead whale inmigration, summer feeding, and outmigration. Adverse subsistence effects that 

would be in evidence in the recovery period would include long-term disruptions in harvest patterns 

that could lead to a breakdown of kinship networks and sharing patterns and increased social stress in 

the community (USDOI, MMS, 2007a). 

Participation in oil-spill cleanup would be such a disruption. Cleanup participation, as local residents 

did in the Exxon Valdez oil spill in 1989, could cause residents to: (1) not participate in subsistence 

activities; (2) have a surplus of cash to spend on material goods as well as drugs and alcohol; and (3) 

not seek or continue employment in other jobs in the community (as oil-spill-cleanup wages are 

higher than average). Indications are that the sudden, dramatic increase in income earned from 

working on cleaning up the Exxon Valdez spill and being unable to pursue subsistence harvests 

because of the spill caused a tremendous amount of social upheaval. This was revealed by reported 

increases in depression, violence, and substance abuse (Picou et al., 1992; Cohen, 1993; Picou and 

Gill, 1993; Fall, 1992; Impact Assessment, Inc., 1990c; Fall and Utermohle, 1995; Human Relations 

Area Files, Inc., 1994a, b, c). 

Multiyear disruptions of subsistence-harvest patterns, especially to the bowhead whale, a pivotal 

subsistence resource to the Inupiat culture, could disrupt sharing networks, subsistence-task groups, 

and crew structures and would cause disruptions of the central Inupiat cultural value: subsistence as a 

way of life. These disruptions also could cause a breakdown in sharing patterns, family ties, and the 

community's sense of well-being and could damage sharing linkages with other communities. Other 

effects might be a decreasing emphasis on subsistence as a livelihood, with an increased emphasis on 
BOEMRE Sale 193 Revised Draft SEIS 

262 CHAPTER IV. Environmental Consequences 

wage employment, individualism, and entrepreneurism. If a VLOS occurred, employment for oil-spill 

response and cleanup could disrupt subsistence-harvest activities for at least two harvest seasons. If a 

VLOS adversely impacted traditional-use areas, subsistence users would have to travel farther to 

harvest uncontaminated resources, which would result in higher effects on sociocultural patterns for a 

much longer time than the actual period that subsistence resources would be measurably 

contaminated. In general, a decline in the certainty about the safety of subsistence foods, potential 

displacement of subsistence resources and hunters, and changes in sharing and visiting could lead to a 

loss of community solidarity, and extra-regional efforts to acquire subsistence foods would by 

necessity be undertaken, likely taxing the resources of other subsistence regions (USDOI, MMS, 

2007a, 2008a). 

Research of the long-term effects of the Exxon Valdez oil spill in 1989 (Fall et al., 2001; Impact 

Assessment, Inc., 2001) indicates the following effects may be realized from a VLOS on communities 

whose cultural survival is tied to the traditional use of food: (1) communities highly dependent on 

subsistence (“wild”) foods are most vulnerable to the effects from an oil spill. In these communities, 

self-identities and family life are organized to a larger extent around seasonal harvest distribution and 

use of foods; (3) the lingering presence of oil in the environment leads to continuing avoidance of 

subsistence-harvest resources; (4) the short-term depression of subsistence-food harvests and uses did 

not lead to long-term sociocultural losses, such as loss of cultural knowledge, skills, or values within 

families; (5) the organization of the subsistence sector was not eroded by the spill; and (6) concerns 

over contamination of subsistence resources persists, and confidence in the benefits in eating natural 

foods was eroded. 

An overall study on 21 Alaskan communities concluded that impacts from the EVOS on subsistence 

use and the social and cultural system that subsistence activities support persist to this day (Fall and 

Utermohle, 1995; Impact Assessment, Inc., 1998; Field et al., 1999; USDOI, MMS, 2003a; USDOI, 

BLM and MMS, 2003). Impacts in the first year following the spill included dramatic declines in 

harvest levels, reduced diversity of resources used, reduced sharing, and disruption in opportunity for 

young people to participate and learn the cultural values associated with subsistence. Fear of 

contamination of food resources was identified as a major factor in these reductions. In the following 

3 years, harvest levels, sharing, and subsistence involvement rebounded, although not uniformly 

across and among communities. Ten years after the spill, the authors conclude that subsistence uses 

largely had recovered to previous levels, but that some long-term changes remained, notably in fish 

species making up a larger portion of total subsistence, with marine mammals, marine invertebrates 

and birds making up a smaller part than before the spill. Resource scarcity was cited as main the 

reason for changes rather than fear of contamination that was cited just after the spill. Hunters also 

reported that additional effort was required to achieve desired harvest levels because some resources 

were more scarce (Fall and Utermohle, 1999). 

After aVLOS, it is expected that considerable stress and anxiety would occur over the loss of 

subsistence resources, contamination of habitat and subsistence resources, fear of the health effects of 

eating contaminated wild foods, fear of changes to harvest regulations (i.e., quotas), and the need to 

depend on the knowledge of others about environmental contamination (Fall 1992, McMullen 1993). 

Individuals and communities would be increasingly stressed during the time it would take to modify 

subsistence-harvest patterns by selectively changing harvest areas (if such areas were even available) 

and there would be increased costs and risks associated with travel and hunting in unfamiliar areas. 

Associated cultural activities, such as the organization of subsistence activities among kinship groups 

and the relationships among those who customarily process and share subsistence harvests, would 

also be modified or would decline (USDOI, BLM, 2008). 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 263

Oil Spill Trajectory Analysis 

Above we have addressed the potential impacts to subsistence resources and harvests during each 

phase of the hypothetical scenario. We now use estimated results (expressed as percentage of 

trajectories contacting) provided by the OSRA model to consider whether such impacts could occur. 

This section describes the results estimated by the OSRA model of a hypothetical very large oil spill 

in the Chukchi Sea contacting specific Environmental Resource Areas (ERAs) and Land Segments 

(LSs) that are important for subsistence resource concentrations or important as traditional harvest 

areas. An ERA is a hypothetical polygon that represents a geographic area important to subsistence 

resource species' use or subsistence harvests within a specific season. The ERA locations are 

incorporated from Appendix A of the Sale 193 FEIS (USDOI, MMS 2007a) and shown in Appendix 

B, Figures B-1 to B-4. The ERAs important to subsistence-harvest patterns are summarized in 

Appendix A, Table A.1-15 of the Sale 193 FEIS. The vulnerability of an ERA is based on the 

seasonal use patterns of subsistence resources or the seasonal of subsistence harvesters using the area 

(Appendix A, Table A.1-12, USDOI, MMS 2007a). 

The following discussion presents the results (expressed as a percentage of trajectories contacting) 

estimated by the OSRA model of a hypothetical very large spill contacting ERAs and LS habitats that 

are important for subsistence resources and harvests. Given the numbers of resources and the large 

nearshore marine harvest areas of the Chukchi Sea subsistence-dependent coastal communities of 

Barrow, Wainwright, Point Lay and Point Hope, as well as those on the Russian Chukotkan coast, it 

is likely that many of these areas would be contacted by a very large spill. The hypothetical very 

large spill could contact many of these areas and avoid others entirely, depending on the location of 

the spill and location of the ERA or a specific LS at the time of the spill. 

Oil-spill contact in winter could affect polar bear hunting and sealing. During the open-water season, 

a VLOS could affect bird hunting, sealing, and whaling, as well as netting of fish in the ocean. 

For each community below, the following paragraphs discuss summer results located in Appendix B, 

Tables B-7, B-8, B-9, B-10, B-13 and B-14 in the first paragraph and then winter results located in 

Appendix B, Tables B-15, B-16, B-17, B-18, B-21and B-22 in the second paragraph. Maps showing 

the ERA, LS and BS locations discussed are located in Appendix B; ERAs (Figures B-2 to B-5), LSs 

(Figures B-6 to B-8), and BSs (Figure B-1). 

Barrow. For a summer spill, the OSRA model estimates <0.5% of spill trajectories from LA1-LA13 

contacting ERA 41 (Barrow Chukchi Sea whaling and subsistence area) within 60 days, and <0.5-1% 

trajectories contact from LA1-LA13 within 360 days; for ERA 42 (Barrow Beaufort Sea whaling and 

subsistence) there is <0.5-12% trajectories contacting within 60 days, and <0.5-14% trajectories 

contacting from LA1-LA13 within 360 days. The LSs 82 (Skull Cliff), 83 (Nulavik), 84, (Walakpa 

River), 85 (Elson Lagoon), 86 (Dease Inlet), 87 (Kurgorak Bay), 88 (Cape Simpson), 89 (Smith Bay) 

and 90 (Drew Point/Kolovik) have <0.5-11% trajectories contacting from LA1-LA13 within 60 days 

and a <0.5-13% trajectories within 360 days (LS 90 is <0.5%). 

Winter-trajectory percentages generally are higher. Within 60 days, they range from <0.5-5% starting 

at LA1-LA13 for ERA 41 (ERA 42 is <0.5%), and <0.5-6% for both ERA’s over a 360-day period 

starting from LA1-LA13. Land Segments 82-85 have a <0.5-3% trajectories contacting within 60 

days from LA1-LA13; LSs 82-88 have a <0.5-7% trajectories contacting within 360 days from LA1-

LA13. 

Wainwright. For a summer spill, the OSRA model estimates <0.5-27% trajectories starting at LA4-

LA13 contact Wainwright’s subsistence ERA 40 within 60 days and 1-29% trajectories contact from 

LA1-LA13 within 360 days. Land Segments 76 (Avak Inlet/Tunalik River), 77 (Nivat Point/Nokotlek 

Point), 78 (Point Collie/Sigeakruk Point), 79 (Point Belcher/Wainwright), 80 (Eluksingiak 
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264 CHAPTER IV. Environmental Consequences 

Point/Kugrua Bay), and 81 (Peard Bay/Point Franklin) have <0.5-6% trajectories contacting from 

LA11-LA13 within 60 days and 360 days. 

In winter, percentage of trajectories contacting, range from <0.5-14% from LA4-LA13 for ERA 40, 

and 1-20% within 360 days from LA1-LA13. The LSs 78-80 have <0.5-2% trajectories contacting 

within 60 days from LA12 (LS 81 has values <0.5%). Land Segments 76-80 have a <0.5-4% 

trajectories contacting within 360 days from LA4-L13. 

Point Lay. For a summer spill, the OSRA model estimates <0.5-16% trajectories from LA4-LA13 

contact Point Lay’s subsistence ERA 39 within 60 days and <0.5-19% trajectories contacting from 

LA4-LA13 within 360 days. Land Segments 70 (Kuchaurak/Kuchiak Creek), 71 (Kukpowruk 

River/Sitkok Point), 72 (Point Lay/Siksrikpak Point), 73 (Tungaich Point/Tungak Creek), 74 

(Kasegaluk Lagoon/Solivik Island), and 75 (Akeonik, Icy Cape) have <0.5-4% trajectories contacting 

from LA4-LA12 within 60 and 360 days. 

In winter, contact percentages within 60 days, range from <0.5-20% trajectories from LA4-LA11 for 

ERA 39, and <0.5-25% within 360 days from LA1-LA12. Land Segments 71-75 have <0.5-4% 

trajectories contacting within 60 days from LA4-LA11. Land Segments 70-75 have <0.5-5% 

trajectories contacting within 360 days from LA4-LA12. 

Point Hope. For a summer spill, the OSRA model estimates <0.5-8% trajectories from LA4-LA11 

contact Point Hope’s subsistence ERA 38 within 60 days, and <0.5-8% trajectories contacting from 

LA4-LA11 over a 360-day period. Land Segments 63 (Asikpak Lagoon/Cape Seppings), 64 (Kukpuk 

River/Point Hope), 65 (Buckland/Cape Lisburne), and 66 (Ayugatak Lagoon) have <0.5-3% 

trajectories contacting from trajectories from LA4-LA11 within 60 and 360 days (LS 62, Atosik 

Lagoon/Kuropak Creek, has values <0.5%). 

In winter, the only contact percentages for ERA 38 greater than 0.5% within 60 and 360 days are 1-

2% from LA9-LA10. Point Hope LSs 62-64 and 66 all have a <0.5% trajectories contacting within 60 

days from LA1-LA13 with LS 60 having 1% trajectories contacting. Land Segments 64 and 65 have a 

1% trajectories contacting within 360 days from LA9. Within 360 days, LSs 62, 63, and 66 all have 

<0.5% trajectories contacting. 

Kivalina. For a summer spill, the OSRA model estimates <0.5 trajectories from LA1-LA13 contact 

Kivalina subsistence ERA 13 within 60 and 360 days. Land Segments 58 (Cape Krusenstern/Kasik 

Lagoon), 59 (Ipiavik Lagoon/Omikviorok River), 60 (Kivalina/Wulik River), 61 (Cape 

Seppings/Pusaluk Lagoon), and 62 (Atosik Lagoon/Kuropak Creek) have <0.5% trajectories 

contacting from LA1-LA13 within 60 and 360 days. 

In winter, contact percentages within 60 and 360 days are <0.5% for ERA 13 and LSs 58-62 from 

LA1-LA13. 

Kotzebue and Vicinity. For a summer spill, the OSRA model estimates a <0.5% of trajectories from 

LA1-LA13 contact Kotzebue and vicinity subsistence ERAs 13 and 5 within 60 and 360 days. Land 

Segments 47 (Kitluk River/West Fork Espenberg River), 48 (Cape Espenberg/Espenberg River), 49 

(Kungealoruk Creek/Pish River), 50 (Clifford Point/Sullivan Bluffs), 51 (Cape Deceit/Toawlevic 

Point), 52 (Motherwood Point/Willow Bay), 53 (Kiwalik/MudCreek), 54 (Baldwin Peninsula/Lewis 

Rich Channel), 55 (Cape Blossom/Pipe Spit), 56 (Kinuk Island/Noatak River), 57 (Aukulak 

Lagoon/Sheshalik Spit), and 58 (Cape Krusenstern/Krusenstern Lagoon) all have a <0.5% trajectories 

contacting from LA1-LA13 within 60 and 360 days. 

In winter, contact percentages within 60 and 360 days are <0.5% for ERAs 13 and 5 and LSs 47-58 

from LA1-. 

Shishmaref. For a summer spill, the OSRA model estimates a <0.5% chance of trajectories from 

LA1-LA13 contacting Shishmaref subsistence ERA 5 within 60 and 360 days. Land Segments 40 
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CHAPTER IV. Environmental Consequences 265

(Ah-Gude-Le-Rock/Mint River), 41 (Ikpek/Yankee River), 42 (Arctic Lagoon/Nuluk River), 43 

(Sarichef Island/Shishmaref Airport), 44 (Cape Lowenstern/Shishmaref), 45 (Shishmaref 

Inlet/Cowpack Inlet), 46 (Cowpack Inlet/White Fish Lake), 47 (Kitluk River/West Fork Espenberg 

River), 48 (Cape Espenberg/Espenberg River) have <0.5% trajectories contacting from trajectories 

from LA1-LA13 within 60 days and 360 days. 

In winter, contact percentages within 60 and 360 days are <0.5% for ERA 5 and LSs 40-48 from 

LA1-LA13. 

Wales. For a summer spill, the OSRA model estimates <0.5% of trajectories from LA1-LA13 contact 

Wales subsistence ERA 5 within 60 and 360 days. Land Segments 40 (Ah-Gude-Le-Rock/Mint 

River), 41 (Ikpek/Yankee River), and 42 (Arctic Lagoon/Nuluk River) have <0.5% trajectories 

contacting from LA1-LA13 within 60 days and 360 days. There are 1% trajectories contacting 

Boundary Segment 2 (WesternEastern Bering Strait) from LA 9 within 60 and 360 days. 

In winter, contact percentages within 60 and 360 days are <0.5% for ERA 5 and LSs 40-42 from 

LA1-LA13. During winter, there are 1% trajectories contacting Boundary Segment 2 (Western Bering 

Strait) from LA 9 within 60 and 360 days. 

Russian Arctic Chukchi Sea Coastal Communities. For a summer spill, the OSRA model estimates 

<0.5-7% trajectories from LA4-LA10 within 60 and 360 days contact the Enermino/Neshkan/Alyatki 

marine mammal harvest ERA 3. The OSRA model estimates 1-3% of trajectories from LA9-LA10 

within 60 and 360 days contact the Naukan/Uelen/Inchoun/Chegitun marine mammal harvest ERA 4. 

In winter, the OSRA model estimates <0.5-% of trajectories from LA1-LA11 contacting the 

Enermino/Neshkan/Alyatki marine mammal harvest ERA 3 within 60 and 360 days. The OSRA 

model estimates 5% of trajectories from LA9 contacting the Naukan/Uelen/Inchoun/Chegitun marine 

mammal harvest ERA 4 within 60 and 360 days. 

Land Segments 7 (Kosa Bruch), 8 (Klark/Mys Uering), and 9 (Nasha/Bukhta Rodzhers) are potential 

harvest areas for the community of Ushakovskoe on Wrangel Island (pop. estimated 8). Land 

Segments 7, 8 and 9 have <0.5% trajectories contacting during summer and winter from LA1-LA13 

within 60 days. Land Segment 8 has 1% of trajectories contacting from LA8 and LA 13 within 360 

days. During winter, LSs 7 and 8 have 1% of trajectories contacting within 360 days from LA1 and 

LA 2. 

Land Segments 14 (Innukay/Mys Veuman), 15 (Laguna Adtaynung/Lagina Uvargina), and 16 (Mys 

Emmatagen/Uvargin) are potential harvest areas for the community of Billings (pop. 272). During 

summer and winter,trajectory percentages within the 60 and 360days are <0.5% from LA1-LA13. 

Land Segments 18 (Mys Enmykay/Laguna Rypil’khin), 19 (Laguna Kuepil’khin/Leningradskii), 20 

(Kuekvun’/Tynupytku), and 21 (Laguna Kinmanyakicha/Val’korkey) are potential harvest areas for 

the communities of Leningradskii (pop. 835), Pil’gyn (pop. unknown), and Polyarny (pop. unknown). 

During summer and winter, contact percentages within the 60 and 360 days are <0.5% from LA1-

LA13. 

Land Segments 21, 22 (Ekiatan’/Rypkarpi), and 23 (Emuem/Tenkergin) are potential harvest areas 

for the communities of Rypkarpi (pop. 915) and Cape Shmidt (pop. 717). In summer and winter, 

contact percentages within the 60 and 360days are <0.5% from LA1-LA13. 

Land Segments 26 (Ekugvaam/Pil’khin), 27 (Laguna Nut/Rigol’), 28 (Kamynga/Laguna Vankarema), 

and 29 (Akanatkhyrgyn/Vel’may) are potential harvest areas for the communities of Rigol’ (pop. 

unknown) and Vankarem (pop. 186). During summer and winter, contact percentages for LSs 26, 28, 

and 29 within the 60days are <0.5% for all LAs. Land Segment 27 has 1% of trajectories contacting 

within 60 days in summer from LA4 and LA9. Within 360 days, LSs 26-29 have 1% of trajectories 

contacting from LA4, LA8 and LA9. In winter, Land Segment 27 has 1% trajectories contacting from 
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266 CHAPTER IV. Environmental Consequences 

LA4 and LA9; within 360 days, LSs 26-29 have 1% of trajectories contacting from LA1, LA4 and 

LA9. 

Land Segments 29, 30 (Laguna Kunergin/Laguna Pyngopil’khin), and 31 (Alyatki/Kolyuchin Bay) 

are potential harvest areas for the community of Nutpel’men (pop. 155). In summer, the percentage of 

trajectories contacting for LSs 29-31 within 60 days are <0.5% for all LAs. Within 360 days summer, 

LSs 29-31 have 1% of trajectories contacting LA9. In winter, contact percentages for LSs 29 and 30 

within 60 days are <0.5% for all LAs and LS 32 has 1% trajectories contacting from LA9. Within 360 

days, LSs 29-31 have 1-2% of trajectories contacting from LA4 and LA9. 

Land Segments 30, 31, 32 (Mys Dzhenretlen/Lit’khekay-Polar Station), and 33 (Neskan/Mys Neskan) 

are potential harvest areas for the communities of Alyatki (seasonal camp?) and Neshkan (pop. 628). 

In summer contact percentages for LSs 30 and 31 within 60 days are <0.5%. LSs 32 and 33 for the 

60-day period have a 1% trajectories contacting from LA9. Within 360 days, LSs 30-33 have 1-2% of 

trajectories contacting during summer from LA9 and LA10. In winter, contact percentages for LSs 31 

and 33 within the 60-day period are <0.5%. LSs 30 and 32 have a 1% trajectories contacting for 

winter trajectories from LA9. Within 360 days, LSs 30-33 have a 1-3% trajectories contacting from 

LA 4 and LA10. 

Land Segments 34 (Emelin/Tepken), 35 (Enurmino/Mys Neten), and 36 (Mys Chechan/Mys Serditse 

Kamen) are potential harvest areas for the community of Enurmino (pop. 304). In summer, LSs 34-36 

have 1-2% trajectories contacting from trajectories originating from LA9 within the 60-day period. 

Within 360 days, LSs 34-36 have a 1-3% trajectories contacting from trajectories originating from 

LA9 and LA10. In winter, contact percentages for LSs 34-36 range from 1-2% within 60 days from 

LA9. Within 360 days, LSs 34-36 have a 1-5% trajectories contacting for winter trajectories from 

LA4, LA 9, and LA10. 

Land Segments 36, 37 (Chevgtun/Mys Volnistyy), and 38 (Enmytagyn/Mys Unikin) are potential 

harvest areas for the community of Chegitun (seasonal camp?). Land Segments 36-38 have 1–2 

percent of trajectories contacting from LA9 within 60 and 360 days during summer. In winter 1 

percent of trajectories contacting LSs 36 and 37 from LA9 within 60 days; contact percentages for LS 

38 are<0.5%. Within 360 days, LSs 36-38 have 2–4 percent of trajectories contacting from LA 9. 

Land Segments 37, 38, and 39 (Cape Dezhnev/Mys Uelen) are potential harvest areas for the 

communities of Inchoun (pop. 362), Uelen (pop. 678), and Naukan (pop. 359). Land Segments 37-39 

have 1-2% of trajectories contacting from LA9 within 60 days during summer. Within 360 days, LSs 

37-39 have 1-2% of trajectories contacting from LA9. In winter there is 1% trajectories contacting LS 

37 from LA9 within 60 days; contact percentages for LSs 38 and 39 are <0.5% within 60 days during 

winter. Within 360 days, LSs 37-39 have 1–3 percent of trajectories contacting from LA9. 

The potential for bowhead whales to be contacted directly from trajectories originating from a VLOS 

is relatively small except in areas off Point Lay and Wainwright, but the potential trajectories 

contacting to whale habitat, whale migration corridors, and subsistence-whaling areas in the Chukchi 

Sea (both Russian and American waters) is considerably greater. Bowheaad whales may or may not 

be perceived as being contaminated, and the desire for bowhead whales may outweigh the concerns 

about contamination. Onshore areas and terrestrial subsistence resources for Point Lay and 

Wainwright have a high potential for trajectory contact. 

Conclusion 

If a VLOS occurred and affected any part of the bowhead whale’s migration route, it could taint this 

culturally important resource. Any actual or perceived disruption of the bowhead whale harvest from 

oil spills and any actual or perceived impacts anywhere during the bowhead’s spring migration, 

summer feeding, and fall migration could disrupt the bowhead hunt for an entire season even though 

whales still would be available. In fact, even if whales were available for the spring and fall seasons, 
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CHAPTER IV. Environmental Consequences 267

traditional cultural concerns of tainting could make bowheads less desirable and alter or stop the 

subsistence harvest in Barrow, Wainwright, Point Lay, and Point Hope, and the beluga whale hunt in 

Point Lay for at least two seasons. Concerns over the safety of subsistence foods could persist for 

many years past any actual harvest disruption. This would be a significant adverse effect. In terms of 

other species, this same concern also would extend to walrus, seals, polar bears, fish, and birds. 

A spill originating within the Chukchi Sea region could produce indirect impacts felt by communities 

remote from the sale area and far removed from the spill. Essentially, concerns about subsistence 

harvests and subsistence food consumption would be shared by all Inupiat and Yup’ik Eskimo 

communities in the Chukchi (including indigenous people on the Russian Chukchi Sea coast) and 

Bering seas adjacent to the migratory corridor used by whales and other migrating species. Major 

impacts are expected from a VLOS when contamination of the shoreline, tainting concerns, cleanup 

disturbance, and disruption of subsistence practices are factored together (USDOI, MMS, 2009). 

In considering lease sale alternatives, it is noted that LAs 8–13 generally exhibit higher percentages 

of spill contacting important subsistence areas along the U.S. Chukchi Sea coast. Deferring portions 

of LAs 8–13 (as proposed under Alternative IV and, to a greater extent, Alternative III) could in a 

sense slightly reduce the potential for VLOS-related impacts to subsistence activities in this region by 

decreasing the percentage of trajectories that would contact many important subsistence areas. 

IV.E.16. Sociocultural Systems 

Impacts from a VLOS would be expected to adversely impact sociocultural systems to the extent they 

adversely impacted subsistence harvests and practices. Sociocultural impacts of oil spills are of at 

least two types. The first is the result of direct effects on resources that are used in some way by local 

residents (i.e., subsistence, tourism, recreation, and elements of quality of life). The second is the 

impact of spill-cleanup efforts, in terms of short-term increases in population and economic 

opportunities, as well as increased demand on community services and increased stress to local 

communities (USDOI, MMS, 2007a). Potential VLOS effects on subsistence resources and practices 

were discussed in Section IV.E.14. 

Effects on the sociocultural systems of local communities could be caused by disturbance from small 

changes in population and employment, periodic interference with subsistence-harvest patterns from 

oil spills and oil-spill cleanup, and stress due to fears of a potential spill and the disruptions it would 

cause. If there are concerns over the tainting of bowhead whales and other marine mammals from an 

oil spill, traditional practices for harvesting, sharing, and processing subsistence resources could be 

seriously curtailed in the short term, and overall effects from these sources could be expected to 

displace ongoing sociocultural systems (USDOI, MMS, 2007a). 

Phase 1 (Initial Event) 

In this phase, pre-existing stress created by fears of a large spill would be triggered. Stress from this 

general fear can be broken down into particular fears: (1) being inundated during cleanup with 

outsiders who will disrupt local cultural continuity; (2) the damage that spills will do to the present 

and future natural environment; (3) the drawn out nature of oil-spill litigation; (4) the contamination 

of subsistence foods; (5) the lack of local resources to mobilize for advocacy and activism with 

regional, State, and Federal agencies; (6) the lack of personal and professional time (capacity) to 

interact with regional, State, and Federal agencies; (7) retracing the steps and the extensive public 

effort (and the frustrations involved) taken to oppose offshore development; (8) responding 

repeatedly to questions and information requests posed by researchers and regional, State, and Federal 

outreach staff; and (9) having to employ and work with lawyers to draft litigation in attempts to stop 

proposed development (USDOI, MMS, 2007a). 
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268 CHAPTER IV. Environmental Consequences 

Phase 2 (Offshore Oil) 

The sociocultural impacts for this phase would blend with and closely resemble those described in 

Phase 1. Additional stresses produced at this phase would include fears about cleanup response 

capabilities or their lack. An ADF&G social-effects survey administered by the Division of 

Subsistence Management in 1994 in Nuiqsut included questions on effects from OCS development. 

About 60% of the respondents did not believe a small oil spill could be contained or cleaned up, and 

80% did not believe a large oil spill could be contained or cleaned up (Fall and Utermohle, 1995; 

Impact Assessment, Inc., 1998; Field et al., 1999; USDOI, MMS, 2003a; USDOI, BLM and MMS, 

2003). 

If offshore subsistence-harvest areas were impacted by the spill and Federal and State response 

agencies imposed area closures, subsistence harvests could be curtailed or cease completely in these 

areas and consequent sociocultural system impacts would be expected. Stress and fear would persist 

long term and would be a factor over a much larger area than just the locally impacted area. 

Phase 3 (Onshore Contact) 

Disruption of subsistence harvest resources from a VLOS would have predictable and significant 

consequences and would affect all aspects of sociocultural resources—social organization, cultural 

values, and institutional organization (Luton, 1985). The primary effect would be the depletion of 

each Native family’s stored foods and the spectre of harvesting less preferred resources. Concerns 

over tainting would create a reluctance to consume suspect resources. The harvest of less-preferred 

resources is more time, labor, and equipment intensive. See the discussion of subsistence resource 

tainting concerns discussed in Section IV.E.14. 

A VLOS would result in the contamination of subsistence resources and would be a threat to the 

health and lifestyle of the affected communities. If a VLOS affected a traditional-use area, then 

subsistence users would have to travel farther to harvest uncontaminated resources, which would 

result in high effects on sociocultural patterns for a much longer time than the period that subsistence 

resources would be measurably contaminated (USDOI, BLM, 2005). 

Phase 4 (Spill Response and Cleanup) 

Oil-spill employment (response and cleanup) could disrupt subsistence-harvest activities for at least 

an entire harvest season (and likely longer) and disrupt some sociocultural systems, and could further 

displace these systems, although cleanup activities alone are generally not sufficient alone to cause 

displacement. Spill cleanup would generate thousands of jobs and the sudden employment increases 

offered by wage work as spill cleanup workers could have sudden and severe effects, including 

inflation and displacement of Native residents from their normal subsistence-harvest activities. 

Cleanup is unlikely to add population to the communities because administrators and workers would 

likely live in separate enclaves, but cleanup employment of local Inupiat could alter normal 

subsistence practices and put stresses on local village infrastructures by drawing local workers away 

from village service jobs. Oil-spill-cleanup activities should be viewed as an additional impact, 

causing displacement of subsistence resources and subsistence hunters and employment disruptions 

(see Impact Assessment, Inc., 1998; USDOI, BLM, 2005). 

Phase 5 (Long-term Recovery) 

A VLOS can lead to a disruption of the kinship networks (i.e., social organization), which in turn 

could lead to a decreased emphasis on the importance of the family, cooperation, and sharing. 

Multiyear disruptions of subsistence-harvest patterns, especially to the bowhead whale (an important 

species to the Inupiat culture), could disrupt sharing networks, subsistence-task groups, and crew 

structures and could cause disruptions of the central Inupiat cultural value: subsistence as a way of 

life. These disruptions also could cause a breakdown in sharing patterns, family ties, and the 
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CHAPTER IV. Environmental Consequences 269

community's sense of well-being and could damage sharing linkages with other communities. Other 

effects might be a decreasing emphasis on subsistence as a livelihood, with an increased emphasis on 

wage employment, individualism, and entrepreneurism. Effects on the sociocultural system, such as 

increased drug and alcohol abuse, breakdown in family ties, and a weakening of social well-being, 

could lead to additional stresses on the health and social services available. Effects on the 

sociocultural systems described above would be expected to persist for many years and likely much 

longer, placing additional stress on the sociocultural systems with trends toward displacement of 

existing institutions (USDOI, MMS, 2007a, 2008a). 

Social organization effects would be very pronounced. Social well-being would be affected as risk, 

safety, and health concerns would increase as the work of harvesting became more intensive, 

increasing the likelihood of equipment breakdowns and accidents among harvesters. Increased 

demands would be placed on the networks in which each household participates, as available 

resources were redistributed according to need. If scarcity continued, greater requests would be made, 

first to nearby communities and then to those beyond (Fairbanks, Anchorage, and other cities inside 

and outside Alaska). These requests, in turn, would accelerate the depletion of the resources of the 

contributing networks. Employment and income effects could be realized as cash was expended to 

maintain equipment and purchase food at local stores to make up for the shortfall in harvested foods. 

Lines of credit would be stretched. Workforce changes and demographic changes could occur through 

consolidation of households to save money, placement of dependents with relatives beyond the 

village, and outmigration of wage earners in search of employment. These could further deplete the 

pool of available subsistence producers and would affect the structure of households and reduce the 

stability of families and communities (USDOI, BLM, 2008a). 

Stress to subsistence and sharing could affect the very central core values of the Inupiat culture. The 

inability of the community’s leaders—the subsistence providers—to fulfill their roles would have 

negative effects on community stability. Over time, if knowledge holders or recipients are removed 

from the community, spiritual teaching and knowledge transfer that takes place as part of the hunt 

would be diminished. The loss of equipment and property used in subsistence harvests and the 

foreclosure of use of the materials in objects of cultural expression and trade, an important source of 

supplemental income to approximately one in five households, could also result. Individuals and 

communities would be increasingly stressed during the time it would take to modify subsistenceharvest patterns by selectively changing harvest areas (if such areas were even available) and there 

would be increased costs and risks associated with travel and hunting in unfamiliar areas. Associated 

cultural activities, such as the organization of subsistence activities among kinship groups and the 

relationships among those who customarily process and share subsistence harvests, would also be 

modified or would decline (USDOI, BLM, 2008). 

Institutional organizations would be affected as requests for temporary assistance from various public 

and private institutions would likely increase. As cash was diverted to meet the increased costs of 

food, other expenses such as utilities might go unpaid. Demands for corrective actions by 

organizational institutions are likely to increase, with institutions working cooperatively to find 

solutions to the problem. However, if corrective action did not sufficiently address the effects, legal 

action and other forms of social action could increase eroding cooperation between institutions 

(USDOI, BLM, 2008). 

Research of the long-term effects of Exxon Valdez oil spill by Fall et al. (2001) and Impact 

Assessment, Inc. (2001) indicated the following effects likely to be realized from a VLOS: (1) 

communities highly dependent on subsistence (“wild”) foods would be most vulnerable to the effects 

from an oil spill (in these communities, self-identities and family life are organized to a larger extent 

around seasonal harvest distribution and use of foods, and cultural survival is tied to the traditional 

use of food); (2) both the level of distress and sense of loss would increase with proximity to the spill 

and the degree of oiling; (3) the lingering presence of oil in the environment would lead to continuing 
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270 CHAPTER IV. Environmental Consequences 

avoidance of subsistence-harvest resources; (4) the short-term depression of the subsistence-food 

harvest and food use would not necessarily lead to long-term sociocultural losses, such as loss of 

cultural knowledge, skills, or values within families. In fact, concerns about potential sociocultural 

effects led in many instances to intensification of economic and cultural revitalization as a social 

movement in communities; (5) during cleanup, the effort of village residents would be redirected 

from subsistence activities to wage-sector employment and redirected between cash/and noncash 

activities; (6) the traditional organization of the subsistence sector would not necessarily be eroded by 

the spill; (7) concern over contamination of subsistence resources would persist, and confidence in the 

benefits of eating natural foods would erode: (8) no major demographic changes would necessarily 

occur (apparent outmigration of residents did not take place in the case of the Exxon Valdez oil 

spill—there also was not a permanent immigration—and the surge of population with initiation of 

cleanup activities subsided with curtailment of those activities); and (9) the purchase of lands for 

conservation areas would cause losses to the Native Alaskans land base, while creating new 

opportunities for income and investment. These conditions indicate that a very large oil spill did 

cause chronic disruption for a period of time after the spill but that existing social patterns, although 

affected, were not displaced. That is, the social structure of villages, towns, and cities, while affected 

by a very large oil spill, continued and persisted in the aftermath of the spill (Picou et al., 1992; 

Cohen, 1993; Picou and Gill, 1993; Fall, 1992; Impact Assessment, Inc., 1990c; Fall and Utermohle, 

1995; Human Relations Area Files, Inc., 1994). 

The Impact Assessment, Inc. (2001) study added additional consideration of psychological and 

identity impacts from the spill. These authors emphasized that for Alaskan Natives, the early impacts 

of the spill were compounded by the sense of “fear” about resource safety and the “alienation” from 

culturally valued activities this caused. These authors also noted that continuing litigation contributes 

to continuing psychological impacts of the spill. While this report did not include new data from the 

10-year, postspill time period, some of the reported impacts would have been mitigated by the general 

recovery in subsistence harvest practices (USDOI, MMS, 2003a; USDOI, BLM and MMS, 2003). A 

study by Picou et al. (1992) showed that 18 months following the EVOS, residents of Cordova had 

experienced long-term negative social effects—disruption to work roles and increased personal stress. 

Additionally, they observed that work disruption was correlated with intrusive stress and fishermen 

experienced more work disruption than other occupations. It may be possible that other natural 

resource community activities such as participation in subsistence harvests may identify 

subpopulations more vulnerable to long-term negative social impacts (Picou et al., 1992). 

Another good source of information on spill effects is the Social Indicators Study of Alaskan Coastal 

Villages, Volume VI: Analysis of the Exxon Valdez Spill Area, 1988-1992 (Human Relations Area 

Files, Inc., 1994). The summary of findings section affirmed that immediately after the spill and 

continuing into early 1990, Native people decreased their harvests of wild resources and relied on 

preserved foods harvested before the spill. By winter 1991, the Natives’ normal harvesting activities 

had begun to resume, but the proportions of wild foods in their diets remained below those of 1989. 

The study also demonstrated in its analysis that non-Natives and Natives “define the environment and 

resources within the environment very differently. Commodity valuation takes precedence” for nonNatives and “instrumental use and cultural and spiritual valuation take precedence” for Native people 

(Human Relations Area Files, Inc., 1994). An overall study on 21 Alaskan communities concluded 

that impacts from the EVOS on subsistence use and the social and cultural system that subsistence 

activities support persisted (Fall and Utermohle, 1995; Impact Assessment, Inc., 1998; Field et al., 

1999; USDOI, MMS, 2003a, 2007a; USDOI, BLM and MMS, 2003). 

A VLOS in the Chukchi Sea would be expected to affect individuals and social systems in ways 

similar to the effects of the Exxon Valdez oil spill. As shown by that spill, some individuals found a 

new arena for pre-existing personal and political conflict, especially over the dispensation of money 

and contracts. In the smaller communities, clean-up work produced a redistribution of resources, 
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CHAPTER IV. Environmental Consequences 271

creating new schisms in the community and increasing social stresses. Many members of small 

communities were on the road to sobriety before the spill; after the spill, many people were drinking 

again, leading to the re-emergence of numerous alcohol-related problems (such as child abuse, 

domestic violence, and accidents). Institutional effects included additional burdens on local 

governments, the disruption of existing community plans and programs, strain on local officials, 

difficulty dealing with Exxon, community conflicts, disruptions of customary habits and patterns of 

behavior, emotional effects and stress-related disorders from confronting environmental degradation 

and death, and violation of community values (Endter-Wada, 1992). Post-spill stress resulted from the 

seeming loss of control over individual and institutional environments, as well as from secondary 

episodes such as litigation, which produced secrecy over information, uncertainty over outcomes, and 

community segmentation (Smythe, 1990). Attempts to mitigate social effects were often ineffective 

because of concerns over litigation, causing a reluctance to intervene out of fear that these actions 

might benefit adversaries in legal battles (Imapact Assessment, Inc., 1990b, 1998; Human Relations 

Area Files, Inc. 1994; ADF&G 1995). In response to spill hazards, there was a resurgence in 

traditional strategies for responding to resource shortages, which in traditional times, and following 

the spill, resulted in an increase in sharing, a renewal and strengthening of social connections with 

extended family members and friends, and a cooperative approach to subsistence activities within and 

between the most affected communities (USDOI, BLM, 2008). 

In general, “perceptions of risk” exist among local residents concerned about oil spills and manifest in 

fears and concerns for stakeholder cultural rights and resources. Considering the importance of social 

networks that are maintained through subsistence-harvest patterns and sociocultural systems, any type 

of disruption adds to cumulative change. The mere fact that, for example, certain members of the 

NSB engage in actively opposing offshore development cumulates social change. 

Oil Spill Trajectory Analysis 

Above we have addressed the potential impacts to sociocultural systems during each phase of the 

hypothetical scenario. Impacts on sociocultural systems are directly related to impacts on subsistenceharvest patterns (see Section IV.E.14, subsistence-harvest patterns). The oil spill trajectory analysis 

for subsistence resources and practices would therefore also apply here for sociocultural systems. 

Conclusion 

The effects of a VLOS on sociocultural systems could cause chronic disruption to sociocultural 

systems for a period of at least two years and likely longer with a tendency for additional stress on the 

sociocultural systems. Longer term disruptions to subsistence resources and practices would impact 

sharing networks, subsistence task groups, and crew structures, as well as cause disruptions of the 

central Inupiat cultural value: subsistence as a way of life (USDOI, MMS, 2007a). 

These disruptions could cause breakdowns in family ties, a community’s sense of well-being, and 

damage sharing linkages with other communities and could seriously curtail community activities and 

traditional practices for harvesting, sharing, and processing subsistence resources—a major impact on 

sociocultural systems. The effects of disruption to sociocultural systems would last beyond the period 

of oil-spill cleanup and could lapse into a chronic disruption of social organization, cultural values, 

and institutional organization with a tendency to displace existing social patterns. The 

accommodation response of Inupiat culture in itself to the impacts of a VLOS could represent major 

impacts to social systems (USDOI, MMS, 2003a, 2006a, 2007a; USDOI, BLM and MMS, 2003). 

Similar to Subsistence Harvest-Patterns, the potential for significant impacts could be reduced by 

implementing larger a larger deferral area under Alternative IV or, to a greater extent, Alternative III. 

IV.E.17. Archaeological Resources 

A VLOS and subsequent cleanup could impact the archaeological resources of the Chukchi Sea and 

coastline directly, indirectly, or both. Beached shipwrecks, shipwrecks in shallow waters, and coastal 
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272 CHAPTER IV. Environmental Consequences 

historic and prehistoric archeological sites could all be adversely affected. Protection of 

archaeological resources during an oil spill requires specific knowledge of the resource's location, 

condition, nature, and extent prior to impact. However, large portions of the coastline have not been 

systematically surveyed for archaeological sites. The sites that are known include those on or eligible 

for the National Register of Historic Places under the NHPA, sites also referred to as historic 

properties. 

Archaeological surveys and analyses are required in areas where potential archaeological resources 

are at risk from offshore operations. These efforts would be required prior to any exploration 

activities and, by extension, the events that constitute the VLOS scenario. Applicable requirements 

are specified by: 

 MMS Handbook 620.1H, Archaeological Resource Protection. 

 BOEMRE regulations (30 CFR 250.194; 30 CFR 250.211; 30 CFR 250.241; 30 CFR 

250.1007(a)(5); and 30 CFR 250.1010(c)). 

 ITL No. 16, Archaeological and Geological Hazards Reports and Surveys (Sec. II.B.3.C(3)). 

 MMS NTL No. 05-A03, Archaeological Survey and Evaluation for Exploration and 

Development Activities. 

 The National Historic Preservation Act of 1966 as amended. 

Archaeological resources, either onshore or offshore, will be identified before any activities are 

permitted, and they will be avoided or potential effects will be mitigated. 

After the Exxon Valdez spill, the Advisory Council on Historic Preservation declared that all 

archaeological sites were to be treated as if they were significant and eligible for the National 

Register of Historic Places (USDOI, MMS 2007a, 2009; USDOI BLM, 2008). This analysis assumes 

that significant effects occur whenever unique archaeological information is lost. 

Phase 1 (Initial Event) 

Onshore archaeological resources (prehistoric and historic sites) would not be immediately impacted 

during the initial phase of a very large oil spill because the distance of a blowout site from shore is at 

least 25 miles. However, a large blowout could impact submerged offshore archaeological resources 

within close vicinity. Such resources could be damaged by the high volume of escaping gas, buried 

by large amounts of dispersed sediments, crushed by the sinking of the rig or platform, destroyed 

during relief well drilling, or contaminated by hydrocarbons (USDOI, BOEMRE, 2011). The 

potential for impacts to any adjacent shipwrecks is high. 

Given the limited data related to historic ship losses and prehistoric paleo-landforms in the Chukchi 

Sea area, it is difficult to determine how many historic properties might be located in areas affected 

by the hypothetical VLOS scenario. However, the potential of a well being drilled close enough to 

damage or bury a known prehistoric or historic resource, such as a shipwreck, is low given measures 

required at the planning stages for exploration. Archaeological surveys are required prior to any 

exploration (and for that matter, development and production) activities to identify anomolies such as 

shipwrecks and other geomorphical features. In the past, BOEMRE has required surveys only on 

leases within blocks deemed to have a high potential for containing historic and/or prehistoric 

resources. Avoidance mitigation resulting from these surveys would further protect historic and 

prehistoric archaeological resources from the potential impacts of a catastrophic blowout (USDOI, 

BOEMRE, 2011). Additional surveys to identify the locations of archaeological resources in the 

Chukchi Sea region would prove valuable in assessing and protecting historic properties in the region. 

However, this information is not considered essential for a reasoned choice among lease sale 

alternatives for reasons explained in Section IV.C.16. Further, it would be infeasible at this time to 
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CHAPTER IV. Environmental Consequences 273

collect detailed information for all of the locations that could potentially be affected in the event of a 

VLOS. 

Phase 2 (Offshore Oil) 

There is a possibility that oil from a catastrophic blowout could come in contact with wooden 

shipwrecks and artifacts on the seafloor and accelerate their deterioration (USDOI, BOEMRE, 2011). 

A recent experimental study has suggested that, while the degradation of wood in terrestrial 

environments is initially retarded by contamination with crude oil, at later stages, the biodeterioration 

of wood was accelerated (Ejechi, 2003). Regardless of water depth, because oil is a hydrocarbon, 

heavy oiling could contaminate organic materials associated with archaeological sites, resulting in 

erroneous dates from standard radiometric dating techniques (e.g., 14C-dating). Interference with the 

accuracy of 14C-dating would result in the loss of valuable data necessary to understand and interpret 

the sites (USDOI, BOEMRE, 2011). 

Phase 3 (Onshore Contact) 

A very large oil spill would affect onshore archaeological sites the most. In the event of a VLOS 

scenario, it is estimated that 150 to 850 miles of discontinuous shoreline could be oiled to some 

degree. Onshore prehistoric and historic sites would be impacted to some extent if a high-volume spill 

reaches shore. Sites on barrier islands could suffer the heaviest impact. Oil contamination of 

shorelines from a very large oil spill is a potential direct impact that would affect archaeological site 

recognition. Crude oil also may contaminate organic material used in C14 dating and, although there 

are methods for cleaning contaminated C14 samples, greater expense is incurred (Dekin et al., 1993). 

It should be noted that other anthropogenic sources of hydrocarbons and other possible contaminants 

also exist, so caution should always be taken when analyzing radiocarbon samples from coastal 

Alaska (see Reger, McMahan, and Holmes, 1992; USDOI, MMS 2007a, 2009). Despite these risks, 

past events have shown that spilled oil itself has little direct effect on archaeological resources 

(Bittner, 1993). The most significant damage to archaeological sites could be related to cleanup and 

response efforts (USDOI, BOEMRE, 2011). 

Phase 4 (Spill Response and Cleanup) 

Various aspects of a VLOS response and cleanup have some potential to adversely affect 

archaeological resources. 

Offshore archaeological resources could be disturbed by vessel anchoring. However, ancillary 

damages from vessels associated with oil-spill response activities (e.g., anchoring) are unlikely due to 

the use of dynamically positioned vessels responding to a VLOS. If response and support vessels 

were to anchor near a deepwater blowout site, the potential to damage undiscovered vessels in the 

area would be high due to the required number and the size of anchors and the length of mooring 

chains needed to safely secure vessels. Additionally, multiple offshore vessel decontamination 

stations would likely be established in shallow water outside of ports or entrances to inland 

waterways, as seen for the DWH event. The anchoring of vessels could result in damage to both 

known and undiscovered archaeological sites; the potential to impact archaeological resources 

increases as the density of anchoring activities in these areas increases (USDOI, BOEMRE, 2011). 

It is possible that large quantities of subsea dispersants could be used during spill response. This 

could result in unintended effects from dispersed oil droplets settling to the seafloor. Though 

information on the actual impacts to submerged cultural resources is inconclusive at this time, oil 

settling to the seafloor could come in contact with archaeological resources. At present, there is no 

evidence of this having occurred at sites in the Gulf of Mexico potentially affected by the DWH event 

(USDOI, BOEMRE, 2011). 
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274 CHAPTER IV. Environmental Consequences 

The potential for damaging archaeological resources increases as the oil spill and related response 

activities progress landward. In shallower waters, most of the damage would be associated with oil 

cleanup and response activities. Hundreds of vessels would respond to a shallow-water blowout and 

would likely anchor, potentially damaging both known and undiscovered archaeological sites. 

Additional anchoring would be associated with offshore vessel decontamination stations, as described 

above. As the spill moves into the intertidal zone, the chance of direct contact between the oil and 

archaeological resources increases. As discussed above, this could result in increased degradation of 

wooden shipwrecks and artifacts (USDOI, BOEMRE, 2011). 

Onshore, oil-spill-cleanup activities in the event of a VLOS and any other activity that removes or 

disturbs soil and/or causes shallow permafrost to thaw have the potential to disturb archaeological 

resources. Because cultural resources are located at or near the ground surface, a spill that occurred 

during the summer would have a greater effect on these resources than a spill that occurred during the 

winter. Oil spilled during winter, however, could impact cultural resources if the warm oil melted the 

snow and permafrost and impacted the underlying cultural resources. While the contamination of the 

cultural resources would render some of the data recovery valueless, the clean-up procedures would 

create even greater impacts. Since cultural resources are nonrenewable, the effects could result in loss 

of site integrity (USDOI, MMS 2007a, 2009; USDOI, BLM, 2008). 

Any onshore activity (cleanup or otherwise) that brings development in contact with remote areas has 

the potential to expose archaeological resources to disturbance from construction or from vandalism. 

Historic sites, such as hunting, fishing, and whaling camps, or structures associated with settlements 

or the Distant Early Warning (DEW) Line (a system of radar stations) could be affected by increased 

cleanup activity in remote areas and increased vandalism. Prehistoric sites, though often not as visible 

as historic sites, also might be subjected to increased vandalism, as well (USDOI, MMS 2007a, 2009; 

USDOI BLM, 2008). 

Protection of an archaeological resource during an oil spill requires specific knowledge of the 

resource’s location, condition, nature, and extent prior to impact. Following the EVOS, Exxon 

developed and funded a Cultural Resource Program to ensure that potential effects on archaeological 

sites were minimized during shoreline treatment (Betts et al., 1991). This program involved a team of 

archaeologists who performed reconnaissance surveys of the affected beach segments, reviewed 

proposed oil-spill treatment, and monitored treatment. As a result of the coastline surveys, hundreds 

of archaeological sites were discovered, recorded, and verified. This resulted in the most 

comprehensive archaeological record of Alaska coastline ever documented (USDOI, MMS, 2007a, 

2009). 

However, large portions of the Alaska Region coastline have not been systematically surveyed for 

archaeological sites. While some response groups have compiled known archaeological site data in a 

form useful for mitigation during an emergency response (Wooley, Hillman, and O’Brien, 1997), 

these data have not been compiled for all areas of the Alaska Region. Subarea plans for the North 

Slope, Cook Inlet, and Prince William Sound reference procedures for addressing and mitigating 

potential impacts to archaeological resources should an oil spill occur. Interagency and regulatory 

aspects of oil spill archaeological site protection recently have been clarified. A programmatic 

agreement specifies the Federal On-Scene Coordinator’s role in protecting archaeological resources, 

the type of expertise needed for site protection, and the appropriate process for identifying and 

protecting archaeological sites during an emergency response. Under the agreement, the Federal OnScene Coordinator’s Historic Properties Specialist coordinates and directs the site identification and 

protection program, with consultation and cooperation of the Unified Command and other affected 

and interested parties (Alaska Regional Response Team, 1997, 2000; USDOI, MMS 2007a, 2009). 

Indeed the major source of potential impact from oil spills is the harm that could result from 

unmonitored shoreline cleanup activities. Cleanup activities could impact beached shipwrecks, or 
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CHAPTER IV. Environmental Consequences 275

shipwrecks in shallow waters, and coastal historic and prehistoric archaeological sites. Unmonitored 

booming, cleanup activities involving vehicle and foot traffic, mechanized cleanup involving heavy 

equipment, and high pressure washing on or near archaeological sites pose risks to archaeological 

resources. Exposure of undocumented sites increases the possibility of vandalism. Increased human 

presence and activity increases the potential for archaeological sites to be recognized, resulting in the 

site having a higher chance of being vandalized. The discovery and reporting of archaeological sites 

during cleanup activities also would result in their being documented and protected. Unauthorized 

collecting of artifacts by cleanup crew members also is a concern, albeit one that can be mitigated 

with effective training and supervision. As Bittner (1993) described in her summary of the 1989 

Exxon Valdez oil spill: “Damage assessment revealed no contamination of the sites by oil, but 

considerable damage resulted from vandalism associated with cleanup activities, and lesser amounts 

were caused by the cleanup process itself” (USDOI, MMS 2007a, 2009). 

A State University of New York at Binghamton study evaluated the extent of petrochemical 

contamination of archaeological sites as a result of the Exxon Valdez oil spill; it examined the effects 

of the spill on archaeological deposits and found that oil in the intertidal zone had not penetrated the 

subsoil, apparently due to hydrostatic pressure. Researchers concluded that the three main types of 

damage to archaeological deposits were oiling, vandalism, and erosion, but that fewer than 3% of the 

resources would suffer significant effects (Dekin et al., 1993; USDOI, MMS 2007a, 2009). Two 

studies of intertidal disturbance, the Exxon Valdez oil spill Cultural Resource Program and a paper on 

archaeological protection presented at the Atlanta meeting of the American Society for Testing and 

Materials, are in close agreement as to the effects of the spill on shoreline and intertidal resources. In 

the first study by Mobley et al. (1990), there were 1,000 archaeological sites in the area affected by 

the Exxon Valdez oil spill and about 24 of these, or 2.4%, were damaged (Mobley et al., 1990). In the 

second study (Wooley and Haggarty, 1993), a total of 609 sites were identified and of these, 14, or 

2.3%, were damaged. The findings of these two studies agree that less than 2.3%-2.4% of the sites in 

the area affected by the Exxon Valdez oil spill suffered damage. Although a number of sites in the 

EVOS area were vandalized during the 1989 cleanup season, the large number of Exxon and 

government agency archaeologists visible in the field may have lessened the amount of site vandalism 

that occurred (Mobley et al., 1990; USDOI, MMS 2007a, 2009). 

As a result of lessons learned from the EVOS, cultural resources were recognized as significant early 

on in the response to the DWH event, and archaeologists were embedded in Shoreline Cleanup 

Assessment Teams (SCAT) and consulted with cleanup crews. Historic preservation representatives 

were present at both the Joint Incident Command as well as each Area Command under the general 

oversight of the National Park Service to coordinate response efforts. Despite these efforts, some 

archaeological sites suffered damage from looting or from spill clean-up activities (USDOI, 

BOEMRE, 2011). Increased knowledge of archeological resource locations, coupled with increased 

levels of human activity in these areas, can lead to increased vandalism of sites. Various mitigation 

measures used to protect archaeological sites while cleaning up oil spills are avoidance (preferred), 

site consultation and inspection, onsite monitoring, site mapping, scientific collection of artifacts, and 

programs to make people aware of cultural resources (Haggarty et al., 1991; Wooley and Haggarty, 

1993; USDOI, MMS 2007a, 2009). 

Phase 5 (Long-term Recovery) 

Unlike biological resources that have the potential to recover, damage to archaeological resources 

from a very large oil spill and its cleanup activities would be irreversible, leading to the loss of 

important archaeological data needed for proper study and interpretation (USDOI, BOEMRE, 2011). 

Long-term effects of oiling on prehistoric and historic archaeological resources are poorly 

understood; however, oiling could alter the surrounding site dynamics and increase their degradation. 

In addition, onshore habitat degradation could lead to erosion, which would increase exposure to and 

subsidence of prehistoric and historic sites. 
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276 CHAPTER IV. Environmental Consequences 

Oil Spill Trajectory Analysis

It is difficult to prioritize any areas of the Chukchi Sea and coastline as more important for 

archaeological resources, because the locations of archaeological resources are largely unknown. 

However, the EVOS event demonstrated that potential impacts increase as coastal spill response and 

cleanup activities increase. A hypothetical spill which affects larger areas of the coastline may in this 

sense pose more potential for significant impacts to archaeological resources. In terms of oil spill 

impacts, the oil spill trajectory Land Segment analysis for subsistence-harvest patterns would apply 

here for archaeological resources (See Section IV.C.14, Subsistence-Harvest Patterns). 

Conclusion 

The greatest impacts on archaeological resources from a very large oil spill would be to onshore 

archaeological sites from oil-spill-cleanup activities. The potential for effects increases with oil-spill 

size and associated cleanup operations. Primary oil-spill impacts from cleanup activities would be 

expected on both prehistoric and historic archaeological sites. Following the Exxon Valdez oil spill, 

the greatest effects came from vandalism, because more people knew about the locations of the 

resources and were present at the sites. Offshore resources are at greatest risk from bottom-disturbing 

activities, notably anchoring and anchor dragging. 

Although it is not possible to predict the precise numbers or types of sites that would be affected, 

contact with archaeological sites would probably be unavoidable and the resulting loss of information 

would be irretrievable. The magnitude of the impact would depend on the significance and 

uniqueness of the information lost. It is difficult to draw a distinct correlation between the potential 

for archaeological impacts from a VLOS and the implementation of deferral corridors under various 

lease sale alternatives. Because impacts to archaeological resources would not vary under the 

different action alternatives, additional information about the location of currently unknown resources 

is not essential to a reasoned choice among lease sale alternatives. 

The most effective way to avoid adverse impacts from a VLOS would be to focus on effective 

surveying of potential exploration sites and the various mitigating measures used to protect 

archaeological sites while cleaning up oil spills. The latter category should include avoidance 

(preferred), site consultation and inspection, onsite monitoring, site mapping, scientific collection of 

artifacts, and programs to make people aware of cultural resources (Haggarty et al., 1991; USDOI, 

MMS 2007a, 2009). 

IV.E.18. Environmental Justice 

Any significant adverse impacts to subsistence resources and harvests or sociocultural systems from a 

VLOS would represent significant environmental justice impacts, i.e. disproportionate, high, adverse 

environmental and health effects on low-income, minority populations in the region. Alaskan Inupiat 

Natives, a recognized minority, are the predominant residents of Chukchi Sea coastal communities in 

the NSB and NWAB, the region potentially most affected by a VLOS. Eighty-three percent of the 

population of the NSB, and 87% of the NWAB are defined minority populations. 

Environmental Justice (EJ) is an initiative promoted by President Clinton’s February 11, 1994, 

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations 

and Low-Income Populations, and an accompanying Presidential memorandum. The Executive Order 

(EO) requires each Federal Agency to make the consideration of EJ part of its mission. Its intent is to 

promote fair treatment of people of all races, so no person or group of people shoulders a 

disproportionate share of the negative environmental effects from this country’s domestic and foreign 

programs. It focuses on minority and low-income people, but the USEPA defines EJ as the “equal 

treatment of all individuals, groups or communities regardless of race, ethnicity, or economic status 

from environmental hazards” (U.S. Department of Energy, 1997; USEPA, 2006). Specifically, the EO 

requires an evaluation as to whether the proposed project would have “disproportionately high 
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CHAPTER IV. Environmental Consequences 277

adverse human health and environmental effects...on minority populations and low income 

populations.” The EO also includes consideration of potential effects on Native subsistence activities. 

A pivotal part of any EJ analysis—as it directly relates to the EO’s charge to examine “human health 

and environmental effects...on minority populations and low income populations”—is a discussion of 

all human health factors that figure into the overall health and well being of indigenous populations 

on the North Slope and in the Northwest Arctic. A very large oil spill would exacerbate and magnify 

these factors that include: (1) existing regional health pathologies (increased diabetes, etc.); (2) social 

pathology (assault, alcohol and drug abuse, domestic violence, suicide, and homicide); (3) major 

employment fluctuations; (4) major changes in economic development; (5) stresses associated with 

sociocultural change (acculturation, an influx of oil-spill workers, increases in the economic standard 

of living, changes in education, etc.); and, (6) changes in environmental quality. Collectively these are 

described as the social determinants of health that encompass the array of socioeconomic and 

environmental factors (many of which have been studied individually with regard to health 

outcomes)—including social hierarchy, social exclusion, social support networks, income inequity, 

employment, educational opportunity, cultural integrity, food security, early childhood environment, 

and stress—and specific health diagnoses. For a more in-depth treatment of these factors, see Section 

III.C.1.p in the Sale 193 FEIS. 

Both on- and offshore oil and gas development has become a dominant socioeconomic force on the 

North Slope. Its direct and indirect influences through, for example, acculturative pressures, the influx 

of people from a different culture entering previously isolated Inupiat villages (e.g., teachers, CIP 

employees, oil workers); stress over perceived and actual threats to culture and subsistence; direct and 

indirect employment opportunities; and broad economic and infrastructure improvements. It is 

important to recognize that the potential from changes brought by the oil and gas development that 

this VLOS scenario assumes may create statewide, regional, and local (village-level) effects, as 

described above. Furthermore, it must be understood that effects on social determinants of health 

(SDH) may create concomitant positive and negative effects on health status. Local and regional SDH 

effects may be the most important to recognize because their recognition could lead to more effective 

strategies for mitigation (see, for example, Assai et al., 2006). For example, a local increase in 

employment may create both benefits through economic opportunity and adverse effects because of 

tensions between the imperative to provide for one’s family through subsistence activities and the 

pressure to be a successful wage earner. Mitigation could be targeted at efforts to devise flexible work 

schedules which allow participation in both activities. A very large oil spill event would impinge on 

and influence all the factors mentioned above. 

In the event of a VLOS, many of the aforementioned EJ impacts associated with routine oil and gas 

activities could intensify. Inupiat Natives are especially susceptible to negative impacts due to their 

reliance on subsistence foods. Subsistence resources and harvest practices, sociocultural systems, and 

human health could all be significantly affected. Potential effects would focus on the Inupiat 

communities of Barrow, Wainwright, Point Lay, Point Hope, and other subsistence communities, 

including those along the Russian Arctic Chukchi Sea coast. If a very large oil spill occurred and 

contaminated essential whaling areas, major effects could occur when impacts from contamination of 

the shoreline, tainting concerns, cleanup disturbance, and disruption of subsistence practices are 

factored together. In general, the central issue of effects on subsistence will be used as a proxy or 

construct for potential EJ impacts. 

The sociocultural impacts of a very large oil spill on Alaskan Native communities are interconnected 

with the subsistence lifestyle of these communities and would have consequent environmental justice 

impacts. Subsistence embodies the traditions of Alaskan Native culture with overlapping connections 

to other cultural, social, and economic institutions. In addition, some effects may be felt well beyond 

the villages, given the extensive subsistence-food-distribution networks that extend to members in 

other places. The damage to natural resources used for subsistence may result in a disruption of 
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278 CHAPTER IV. Environmental Consequences 

harvesting, processing, and sharing. Such damage can affect the essential connections between 

sociocultural factors of individual identity, social group, culture, and nature. Given the overarching 

importance of subsistence resources to the indigenous populations—all defined minority 

populations—any major impacts to subsistence resources that create attendant major impacts on 

Alaskan Native sociocultural systems would be expected to have consequent disproportionate, high 

adverse impacts on environmental justice. 

Possible oil-spill contamination of subsistence foods is a serious concern to Native health. 

Subsistence is the cornerstone of nutrition, culture, and social systems in NSB communities. A vital, 

productive subsistence way of life is strongly correlated with measures of overall well-being and 

psychosocial health in Arctic communities (Poppel et al., 2007; Hicks and Bjerregaard, 2006; 

Shepard and Rode, 1996). Impacts to the subsistence harvest, if severe enough, would also impact 

food security, nutritional status, and the risk of nutritionally based chronic medical problems such as 

high blood pressure, obesity, diabetes, and cardiovascular disease. The effects of contaminant-related 

health effects related to an oil spill are difficult to study. For example, exposure to benzene and other 

hazardous air pollutants (HAPs) near a spill could be high enough to increase the risk of rare cancers 

such as leukemia. However, because of the small population size in Chukchi Sea coastal villages, 

linking a change in incidence of such a cancer to an environmental exposure is statistically difficult. 

Nevertheless, for contaminants with well-characterized toxicological profiles such as benzene and 

specific PAHs, exposure is known to produce adverse health effects, and should be considered a 

major adverse health effect of a VLOS if individuals or communities are exposed (USDOI, MMS, 

2008a). 

Anyone dependent on subsistence resources could experience these effects to some degree, but they 

would be most prominent in Inupiat residents of the region where current data suggest that 

subsistence is a cornerstone of general wellbeing as well as physical health. 

Human health could be threatened because of the risk of consumption of contaminants in areas 

affected by oil spills. Risks can be reduced through timely warnings about spills, forecasts about 

which areas may be affected, and even evacuating people and avoiding marine and terrestrial foods 

that may be affected. Federal and State agencies with health-care responsibilities would have to 

sample the food sources and test for possible contamination. Interestingly, after the EVOS, testing of 

subsistence foods for hydrocarbon contamination (from 1989-1994) revealed very low concentrations 

of petroleum hydrocarbons in most subsistence foods. Based on these findings, the U.S. Food and 

Drug Administration (USFDA) concluded that eating food with such low levels of hydrocarbons 

posed no significant risk to human health (Hom et al., 1999). However, they recommended avoiding 

shellfish, which accumulates hydrocarbons. 

Whether subsistence users will use potentially tainted foods is entirely another question that involves 

cultural “confidence” in the purity of these foods. Based on surveys and findings in studies of the 

EVOS, Natives in affected communities largely avoided subsistence foods as long as the oil remained 

in the environment. Perceptions of food tainting and avoiding use of these foods remained (and 

remain today) in Native communities in Prince William Sound and the region after the EVOS, even 

when agency testing maintained that consumption posed no risk to human health (State of Alaska, 

Dept. of Fish and Game, 1995; Hom et al., 1999). Given the prominent and irreplaceable role of 

subsistence foods in local diets, it is apparent that both actual and perceived contamination can cause 

adverse impacts to EJ. 

The ability to assess and communicate the safety of subsistence resources following an oil spill is a 

continuing challenge to health and natural resource managers. After the EVOS, analytical testing and 

rigorous reporting procedures to get results out to local subsistence users were never completely 

convincing to most subsistence users about the safety of their food. Scientific conclusions often were 

not consistent with Native perceptions about environmental health. According to Peacock and Field 
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CHAPTER IV. Environmental Consequences 279

(1999), a discussion of subsistence-food issues must be cross-disciplinary, reflecting a spectrum of 

disciplines from toxicology, to marine biology, to cultural anthropology, to cross-cultural 

communication, to ultimately understanding disparate cultural definitions of risk perception itself. 

Any effective discussion of subsistence-resource contamination must understand the conflicting 

scientific paradigms of Western science and traditional knowledge in addition to the vocabulary of 

the social sciences in reference to observations throughout the collection, evaluation, and reporting 

process. True restoration of environmental damage, according to Picou and Gill (1996) “must include 

the reestablishment of a social equilibrium between the biophysical environment and the human 

community” (Field et al., 1999; Nighswander and Peacock, 1999; Fall et al., 1999). Since 1995, 

subsistence restoration resulting from the EVOS has improved by taking a more comprehensive 

approach by partnering with local communities and by linking scientific methodologies with 

traditional knowledge (Fall et al., 1999; Fall and Utermohle, 1999; USDOI, MMS, 2007a). 

Phase 1 (Initial Event) 

Given the location of a hypothetical blowout more than 25 miles or more from the shore, as well as 

the short duration of an ensuing fire, the initial event is not expected to impact land resources. No 

environmental justice impacts would directly result from these components of the scenario. On the 

other hand, pre-existing stress created by fears of a very large oil spill—now realized, in fact—would 

be triggered. Such stress could be interpreted to be a disproportionate impact on the local Inupiat 

population (see discussion on this point within Section IV.C.15, Sociocultural Systems). 

Indirect impacts from a spill originating within the Chukchi Sea region could be felt by communities 

remote from the sale area and far removed from the spill. Essentially, concerns about subsistence 

harvests and subsistence food consumption would be shared by all Inupiat and Yup’ik Eskimo 

communities in the Chukchi (including indigenous people on the Russian Chukchi Sea coast) and 

those portions of the Bering Sea adjacent to the migratory corridor used by whales and other 

migrating species. 

Phase 2 (Offshore Oil) 

Environmental justice impacts during this phase would blend with and closely resemble those 

described in Phase 1. Again, impacts described in the sociocultural systems discussion (see Section 

IV.C.15) are relevant here. If offshore subsistence-harvest areas were impacted by the spill, 

subsistence harvests could be curtailed or cease completely in these areas and consequent 

sociocultural and environmental justice impacts would be expected. A VLOS preventing traditional 

subsistence activities in the offshore waters of the Chukchi Sea would disproportionately impact the 

Alaskan Inupiat Natives, a defined minority population. 

Phase 3 (Onshore Contact) 

To the extent that a VLOS affected local subsistence resources and practices and sociocultural 

resources—social organization, cultural values, and institutional organization—consequent impacts 

on environmental justice would be expected. Further discussion of subsistence resource tainting 

concerns and potential impacts to sociocultural systems are discussed in sections IV.C.14 and 

IV.C.15, respectively. Contamination of subsistence resources poses a threat to the health and 

lifestyle of the affected communities. Consumption of contaminated resources would likely lead to 

increases in contaminant-related health problems such as cancer and neurodevelopmental delays. In 

the short term, these problems might be lessened by avoidance of contaminated resources, but chronic 

persistent low-level contamination many years after the spill could cause incremental increases in 

these problems (USDOI, BLM, 2008; USDOI, MMS, 2008a). If a VLOS occurred in or reached a 

traditional-use area, subsistence users would also have to travel farther to harvest uncontaminated 

resources. Alterations in harvest patterns could result in major effects on sociocultural patterns as 
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280 CHAPTER IV. Environmental Consequences 

well as increased safety risks during harvesting. The onshore contact phase thus poses the greatest 

potential for disproportionate, high adverse impacts on environmental justice. 

Phase 4 (Spill Response and Cleanup) 

A VLOS in the Chukchi Sea would trigger a wide-scale and protected spill response and cleanup 

effort. As illustrated by the EVOS, this Phase could implicate environmental justice considerations in 

several ways. Paid employment of local residents in cleanup efforts could curb participation in 

subsistence activities and alter normal subsistence practices. Given the urgency of cleanup efforts 

activities could also draw local workers away from village service jobs, which also tend to be lower 

paying. On the other hand, increased employment and income are generally associated with positive 

health outcomes. 

A rapid influx of nonresident personnel to or through a community is likely, and could lead to 

increased social and psychological problems. Adverse impacts could occur via social interactions and 

commerce-related factors such as the local economy and inflation. In general, the larger the spill, the 

more dramatic the expected changes as they related to social upheaval and implications for health 

(Human Relations Area Files, Inc., 1995; ADFG, 1995b; Impact Assessment, Inc., 1990c, 1998). The 

rapid influx of cash, the influx of nonresident workers to and through coastal communities, and shortterm and unstable employment increase the risk of infectious disease transmission, potentially 

compromising the efficacy of local prohibition laws in preventing adverse health effects from alcohol 

consumption, and could exacerbate social and psychological strain leading to maladaptive behavior, 

including violence and alcohol and drug abuse. The adverse health effects of insecure or unstable 

employment are similar to unemployment in many studies (Marmot and Wilkinson, 2004). 

Interference with subsistence seasonal activities would have implications for nutritional health and 

chronic diseases, such as diabetes. Such impacts could be in play as long as oil-spill response 

occurred and likely thereafter, and have lingering environmental justice impacts. 

The lack of any well established and extensive onshore infrastructure within the Chukchi Sea region 

could compromise the efficacy of response efforts, heightening and prolonging the impacts described 

above. Harsh weather conditions and movement of pack ice in the Chukchi Sea would present novel 

challenges for oil-spill cleanup which could increase the risk of public health problems resulting from 

exposure to contaminants and the perceived risks of subsistence resource contamination. Should 

Federal and State response agencies close affected areas to harvest, additional impacts to subsistence 

could occur. 

Phase 5 (Long-term Recovery) 

In the event of a very large oil spill, considerable stress and anxiety would occur over the loss of 

subsistence resources, contamination of habitat and subsistence resources, fear of the health effects of 

eating contaminated wild foods, fear of changes to harvest regulations (e.g., quotas), and the need to 

depend on the knowledge of others about environmental contamination (Fall 1992, McMullen 1993). 

Reductions in subsistence game populations, displacement of game, and fears of contamination could 

combine to substantially reduce subsistence game intake. If this occurred, the prevalence of diabetes 

and related metabolic disorders would be expected to increase substantially; increases in contaminantrelated health problems such as cancer and neurodevelopmental delays could also be expected. Food 

insecurity would increase markedly, and unless sharing networks and government programs were able 

to respond rapidly, hunger and potentially (though less likely) malnutrition could result (USDOI, 

BLM, 2008; USDOI, MMS, 2008a) 

Social pathology would likely increase, and, in parallel with increased social pathology and more 

difficult hunting conditions, injury rates and mortality could also increase. In the case of the Exxon 

Valdez oil spill, many members of small communities were on the road to sobriety before the spill; 

after the spill, some people began drinking again, leading to the re-emergence of numerous alcohol-
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 281

related problems (such as child abuse, domestic violence, and accidents). Institutional effects included 

additional burdens on local governments, disruption of existing community plans and programs, 

strain on local officials, difficulty dealing with Exxon, community conflict, disruptions of customary 

habits and patterns of behavior, emotional effects and stress-related disorders from confronting 

environmental degradation and death, and violation of community values (Endter-Wada, 1992). Postspill stress resulted from the seeming loss of control over individual and institutional environments, 

as well as from secondary episodes such as litigation, which produced secrecy over information, 

uncertainty over outcomes, and community segmentation (Smythe, 1990). Attempts to mitigate social 

effects were often ineffective because of concerns over litigation, causing a reluctance to intervene 

out of fear that these actions might benefit adversaries in legal battles (Imapct Assessment, Inc., 

1990a, 1998; Human Relations Area Files, Inc. 1994; ADFG 1995; USDOI, BLM, 2008; USDOI, 

MMS, 2008a). 

Impacts to the social determinants of health, possible after a very large oil spill, are some of the most 

serious adverse social products of such a catastrophic event. If, as in the Exxon Valdez oil spill, the 

disruption of sharing networks and increases in social pathology were extensive and persistent, 

substantial decreases in social capital could occur, with ramifications for not only psychosocial health 

but physical health as well (Ritchie and Gill, 2004; Marmot and Wilkinson 2004; USDOI, BLM, 

2008). 

Another primary environmental justice concern would relate to possible long-term health impacts to 

cleanup workers, a predominately minority population if local communities supplied cleanup 

personnel, and to possible disposal of oil-impacted solid waste in the region—a predominantly 

minority area. A very large oil spill in the region could also bring in large numbers of non-local 

minority workers for response and cleanup, adding an entirely new layer to environmental justice 

concerns in the region. With the DWH event, the racial composition of cleanup crews was so 

conspicuous that Ben Jealous, the president of the National Association for the Advancement of 

Colored People (NAACP), sent a public letter to BP Chief Operations Officer Tony Hayward on July 

9, 2010, demanding to know why African Americans were over-represented in “the most physically 

difficult, lowest paying jobs, with the most significant exposure to toxins” (NAACP, 2010). While 

regulations require the wearing of protective gear and only a small percentage of cleanup workers 

suffer immediate illness and injuries (CDC, 2010), exposure could have long-term health impacts 

such as increased rates of some types of cancer (Savitz and Engel, 2010; Kirkeleit et al., 2008). 

Therefore, a catastrophic spill could disproportionately affect onshore low income and minority 

cleanup workers (USDOI, BOEMRE, 2011). 

Oil Spill Trajectory Analysis 

Above we have addressed the potential impacts to environmental justice during each phase of the 

VLOS event. In terms of oil spill trajectory analysis, previous analysis within the subsistence 

resources and practices section again proves instructive. Impacts on subsistence-harvest patterns and 

sociocultural systems directly correlate with consequent impacts on environmental justice (See 

Section IV.C.14, Subsistence-Harvest Patterns and IV.C.15, Sociocultural Systems). The effects 

described in the Subsistence-Harvest Patterns and Sociocultural Systems section would be 

experienced primarily by the subsistence-dependent minority Inupiat population. 

Conclusion 

Environmental Justice impacts on Inupiat Natives could occur because of their reliance on subsistence 

foods, and oil-spill impacts would affect subsistence resources and harvest practices, sociocultural 

systems, and human health. Depending on the trajectory of the VLOS, the Inupiat communities of 

Barrow, Wainwright, Point Lay, and Point Hope, as well as the subsistence communities on the 

Russian Arctic Chukchi Sea coast, would all experience adverse impacts to varying degrees. 
BOEMRE Sale 193 Revised Draft SEIS 

282 CHAPTER IV. Environmental Consequences 

A very large oil spill would contaminate essential whaling areas and marine mammal harvest areas, 

and major effects would occur when impacts from contamination of the shoreline, tainting concerns, 

cleanup disturbance, and disruption of subsistence practices are factored together. In the event of a 

very large oil spill, many harvest areas and some subsistence resources would be unavailable for use. 

Some resource populations would suffer losses and, as a result of tainting, bowhead whales could be 

rendered unavailable for use. Whaling communities distant from and unaffected by potential spill 

effects are likely to share bowhead whale products with impacted villages. Harvesting, sharing, and 

processing of other subsistence resources should continue but would be hampered to the degree that 

these resources were contaminated. Traditional practices for harvesting, sharing, and processing 

subsistence resources could be seriously curtailed in the short-term, if there are concerns over the 

tainting of bowhead whales and other marine mammals from an oil spill. In this manner, EJ impacts 

could also spread to communities outside the Chukchi Sea. 

Public health impacts from a very large oil spill could be caused from contact with contaminants, 

which could occur mainly through inhalation, skin contact, or intake of contaminated subsistence 

foods; through reduced availability or acceptability of subsistence resources; through periodic 

interference with subsistence-harvest patterns from oil spills and oil-spill cleanup; and through stress 

due to fears of the long-term implications of a spill and the disruptions it would cause. 

Following the EVOS, communities experienced increases in post-traumatic stress disorder, 

depression, anxiety, and stress (Palinkas et al., 1993; Palinkas et al., 2004), decreased social 

interconnectedness (or social capital) (Ritchie and Gill, 2004), and decreased subsistence harvests of 

many resources that persist to this day (Fall and Utermohle, 1995; Impact Assessment, Inc., 1998; 

Field et al., 1999; USDOI, MMS, 2003a; USDOI, BLM and MMS, 2003). 

Selection of lease sale alternatives that incorporate deferral corridors along the Chukchi Sea could 

reduce the potential for drilling in areas closer to the Chukchi Sea shoreline. To the extent that 

hypothetical spills from areas within these deferral corridors exhibit higher percentages of trajectories 

contacting with shorelines or other areas important to subsistence harvest, selection of Alternative III 

or IV could slightly reduce the potential for VLOS impacts. Alternative III is most likely to reduce 

impacts because it incorporates the largest deferral area. As indicated in the Summary and 

Conclusion to the Subsistence-Harvest Patterns analysis, hypothetical spills emanating from LAs 10-

13 are generally more likely to contact important areas within the eastern Chuckchi Sea and portions 

of western Beaufort Sea. LA9 exhibits relative higher percentages of trajectories contacting Russian 

subsistence areas, as compared to the rest of the proposed lease sale area. 

In the event of aVLOS in the Chukchi Sea, the EJ-related impacts described above would produce 

disproportionate, high, adverse effects in the Inupiat subsistence-oriented communities of Barrow, 

Wainwright, Point Lay, and Point Hope and in Russian subsistence communities along the Chukchi 

Sea coastline. 

IV.E.19. Conclusion – Effects of a VLOS 

If it were to occur, a low-probability VLOS event could cause significant adverse environmental 

impacts to most of the examined environmental resources in the Chukchi Sea region. The majority of 

environmental resources are anticipated to recover over the long term. However, some vulnerable 

animal populations could suffer lasting, population-level impacts under certain circumstances. Longterm reductions in local animal populations would exacerbate disruptions to subsistence-harvest 

patterns and displacement of sociocultural systems. While intervention, response and cleanup efforts 

could mitigate spill volume and certain environmental effects, the significant and perhaps irrevocable 

adverse impacts associated with a VLOS event in the Chukchi Sea highlight the need for effective 

spill prevention. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER IV. Environmental Consequences 283

IV.F. Unavoidable Adverse Effects 

Below is a list of resource areas that could experience unavoidable adverse effects under all of the 

action alternatives, with notable types of impacts in parentheses: 

 water quality (various impacts associated with normal operations and potential discharges) 

 air quality (small, localized impacts via normal operations) 

 lower trophic level organisms (small, localized impacts via construction) 

 fish resources (disturbance and localized impacts to habitat) 

 Essential Fish Habitat (localized impacts from construction) 

 Threatened and Endangered marine mammals (noise and disturbance) 

 Threatened and Endangered marine and coastal birds (disturbance) 

 marine and coastal birds (disturbance) 

 other marine mammals (noise and disturbance) 

 terrestrial mammals (disturbance) 

 vegetation and wetlands (localized construction-related impacts) 

 subsistence-harvest patterns (disturbance) 

 sociocultural systems (various impacts from onshore and offshore infrastructure) 

 archaeological resources (ground and seafloor-disturbing activities) 

 land use plans and coastal management programs (construction) 

 environmental justice (noise and general disturbance) 

The natural gas development scenario would prolong oil and gas-related activities, extend the viable 

life of existing infrastructure, and build new facilities within previously disturbed areas. Overall, 

natural gas production and development would not pose any new types of impacts (short- or longterm) in addition to those posed by preceding oil activities. 

A VLOS is not considered in this section because it is extremely unlikely. Adverse effects from a 

VLOS are not considered unavoidable. 

IV.G. Relationship Between Local Short-Term Uses and 

Maintenance and Enhancement of Long-Term Productivity 

The Sale 193 FEIS found that oil exploration, development, and production activities would entail 

some potential for long-term impacts to nearly all resource areas. However, in each case the potential 

for impacts to long-term productivity is solely derived from the risk of a large-scale oil spill. The one 

exception to this trend was archaeological resources. The destruction of archaeological sites and/or 

unauthorized removal of artifacts could occur via normal oil exploration, development, and 

production activities, and would represent an inherently long-term loss. The potential for such 

impacts exists under each action alternative. 

In this SEIS, the natural gas development and production scenario does not involve a risk for a large 

oil spill. Nor does any component of the gas scenario pose new types of impacts that could adversely 

affect long-term productivity. None of the potential adverse impacts associated with the gas scenario 

(except of course for potential impacts to archaeological resources associated with ground and 

seafloor disturbance) would be permanent or persist past several generations. 

However, a low probability VLOS event could cause long-term impacts to a variety of resource areas, 

including several species of fish, cetaceans, and marine and coastal birds, as well as polar bears, ice 
BOEMRE Sale 193 Revised Draft SEIS 

284 CHAPTER IV. Environmental Consequences 

seals, walrus, subsistence harvest patterns, sociocultural systems, Environmental Justice and, again, 

archaeological resources. The potential for such impacts exists under each action alternative. 

IV.H. Irreversible and Irretrievable Commitment of Resources 

Irreversible and irretrievable commitment of resources refers to impacts or losses to resources that 

cannot be reversed or recovered. Holding an OCS lease sale and issuance of OCS leases do not 

constitute an irreversible and irretrievable commitment of resources. The OCSLA prescribes a fourstage process for the OCS program. This four-stage review process gives the Secretary of the Interior 

a “continuing opportunity for making informed adjustments” to ensure that all OCS oil-and-gas 

activities are conducted in an environmentally sound manner. In the first stage, BOEMRE prepares a 

5-year leasing program to identify the size, timing, and location of proposed lease sales and an EIS 

under NEPA. In the second stage, BOEMRE conducts the prelease process and sale-specific NEPA 

review. The third stage involves exploration of the leased tracts. Prior to any exploratory drilling, a 

lessee must submit an exploration plan (EP) to BOEMRE for review and approval. The EP must 

comply with the OCSLA, implementing regulations, lease provisions, and other Federal laws, and is 

subject to environmental review under NEPA. 

Irreversible and irretrievable effects could occur only as a result in exploration, development, and 

production activities. Each of these activities occur at a future stage of the OCS process and would 

require additional NEPA review that would identify any irreversible and irretrievable commitment of 

resources associated with the decision at hand. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER V. Cumulative Effects 285

CHAPTER V. Cumulative Effects 

V.A. Introduction 

The following subsections summarize the cumulative effects analysis from the Sale 193 FEIS, which 

is incorporated by reference. The analysis considers the potential effects of the proposed actions 

when they are added to past, present, and reasonably foreseeable activities. The summaries include a 

qualitative assessment of the incremental contribution of the Proposed Action to the overall 

cumulative effects on each resource. The incremental contribution to cumulative effects from natural 

gas development and production activities evaluated in this SEIS has been added to the cumulative 

impact summary for each resource. Cumulative impacts associated with the hypothetical VLOS 

scenario were discussed for each resource in Section IV.E, principally within Long-term Recovery 

subsections. For a more detailed discussion of the past, present, reasonably foreseeable, and 

speculative activities of the Chukchi Sea area, and the approach to the cumulative effects analysis, 

readers should reference Section V of the Sale 193 FEIS. There are no additional past, present, or 

reasonably foreseeable activities identified since the release of the Sale 193 FEIS in 2007 that would 

alter the analysis or conclusions therein. 

V.A.1. Structure of the Analysis 

The cumulative effects analysis in the Sale 193 FEIS comprised a 5-step process, which was 

maintained in analyzing natural gas development and production activities in this SEIS: 

1) Analysts identified the potential effects resulting from Sale 193 on the natural resources and human 

environment that may occur in the Chukchi Sea and the adjacent offshore and onshore areas. 

2) Analysts identified other past, present, and reasonably foreseeable future oil and gas development 

activity on the North Slope and adjacent offshore areas, and considered their effects on the natural 

resources and human environment potentially affected by Sale 193. Speculative activities were also 

identified and discussed. Our approach to identifying past, present, reasonably foreseeable, and 

speculative activities is further outlined below: 

 Past oil and gas activities development and production considered in the cumulative analysis 

were those that resulted in currently existing infrastructure. 

 Present oil and gas activities development and production considered in the cumulative 

analysis were those for which new facilities are under construction. 

 Reasonably foreseeable oil and gas activities considered in the cumulative analysis included 

exploration for undiscovered resources onshore and offshore that could occur during the next 

20 years, and development and production of discovered resources that are likely to occur in 

the next 20 years. Reasonably foreseeable activities include continued operation of the TAPS 

and tanker shipments of oil from Valdez, Alaska to markets in the Pacific Basin. 

 Speculative oil and gas activities are those activities that may occur beyond 20 years from the 

present time or not at all. 

3) Analysts considered effects from other actions on these same natural resources and human 

environments. We considered Federal OCS activities in the Beaufort and Chukchi Sea program areas 

as well as BLM’s continuing program of leasing in the NPR-A. It is reasonable to assume that 

exploration activities will continue in these Federal areas. There is no infrastructure in NPR-A at the 

present time, so a new large-diameter gathering line would have to be constructed from the Chukchi 

Sea coast to the Prudhoe Bay area. We considered the State of Alaska oil- and gas-leasing plans. The 

State develops 10-year leasing plans and publishes a schedule every other year. All of the North 

Slope and Beaufort Sea commercially producible crude oil is on State leases except for a portion of 

the Northstar field that is in the Federal OCS. Activities other than those associated with oil and gas 
BOEMRE Sale 193 Revised Draft SEIS 

286 CHAPTER V. Cumulative Effects 

that add to the environmental and sociocultural resources affected by the Proposed Action included 

sport and subsistence hunting and fishing, scientific surveys, and marine transportation. We did not 

attempt to estimate future military activities affecting this region. 

4) Analysts attempted to quantify effects by estimating the extent of the effects (for example, number 

of animals and habitat affected) and how long the effects would last (for example, population 

recovery time). 

5) Analysts weighed more heavily the activities that are more certain, closer in time, and closer 

geographically to the proposed lease sale to keep the cumulative-effects analysis concentrated on the 

effects that are in the Sale 193 area. 

Both the Sale 193 FEIS and the SEIS consider Arctic warming, which could contribute to cumulative 

effects through, among other things: 

 increased noise and disturbance related to increased shipping; 

 decreases in ice cover with the potential for resultant changes in prey-species concentrations 

and distribution with related changes in species distributions; changes in subsistence-hunting 

practices; and 

 northern expansion of species. 

It is possible that Arctic warming will contribute to other forms of cumulative effects as well. 

Moreover, it has been speculated that Arctic ecosystems could become weakened and animal 

populations depleted and more sensitive. Diminished habitat, food resources, or population levels 

could all contribute to negative cumulative effects on Arctic species. However, the extent to which 

such effects might occur and their incremental interaction with potential effects from Lease Sale 193 

activitiesdifficult to precisely forecast. BOEMRE’s cumulative effects analysis has concentrated on 

the reasonably foreseeable factors (including those associated with Arctic warming) identified in the 

steps above. 

The changes in incremental contributions to cumulative effects under Alternatives III and IV were not 

evaluated in the Sale 193 FEIS. The extended geographic scale and timeframe of the cumulative 

analysis reduces the sensitivity of this analysis and treatment of alternatives. Projecting future 

impacts on the resource further reduces the ability to detect a measurable change between the 

alternatives. Natural gas development and production activities would be largely identical under the 

action alternatives analyzed in the Sale 193 FEIS (Alternatives I, III, and IV). Differences in 

potential effects that may result from the deferral areas built into Alternatives II and IV are negligible. 

V.A.2. General Conclusions 

The bullets below summarize the general conclusions of the cumulative impacts analysis in the Sale 

193 FEIS. 

 Potential cumulative effects on the bowhead whale, subsistence, sociocultural systems, 

spectacled eider, polar bear, and caribou would be of primary concern and warrant continued 

close attention and effective mitigation practices. 

 The Chukchi Sea is a frontier area; therefore, impacts from Sale 193 would be the primary 

contributor to any OCS Program impacts. 

 We conclude that no significant cumulative impacts would result from routine activities 

associated the Proposed Action or alternatives. 

 In the event of a large offshore oil spill, biological resources may be present in the area but 

may not necessarily be contacted by the oil. If contacted by oil, significant adverse impacts 

could occur to biological resources and sociocultural systems. Some significant adverse 

impacts could occur to spectacled eiders, long-tailed ducks, common eiders, polar bears. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER V. Cumulative Effects 287

Most biological resources contacted by oil are expected to recover within two to three 

generations. 

 In the event of a large offshore oil spill, significant adverse impacts could occur to 

sociocultural systems. An oil spill could affect the availability of bowhead whales or other 

subsistence resources, or a resource might be considered tainted and unusable as a food 

source. 

 In the event of a large offshore oil spill, significant adverse Environmental Justice effects 

could occur in the Inupiat communities of Barrow, Wainwright, Point Hope, Point Lay, and 

Kivalina, within the North Slope Borough. If a large spill occurred and contaminated 

essential whaling areas, major effects could occur when impacts from contamination of the 

shoreline, tainting concerns, cleanup disturbance, and disruption of subsistence practices are 

factored together. Such impacts would be considered disproportionately high adverse effects 

on Alaska Natives. 

V.B. Analysis of Cumulative Effects 

Natural gas development (installation of a pipeline, to shore, expansion of platform and shore 

facilities, and construction of a pipeline across NPR-A) and production are expected to be similar to 

the same activities for the earlier oil development and production. Development and production are 

the later phases of activities that may occur as a result of Sale 193. The effects of the installation of a 

natural gas pipeline to shore would be the same as those from the installation of the oil pipeline to 

shore. The effects of expansion of the platform and shore facilities are expected to be less than the 

effects of the original installations and construction because of the small scope of activity. The 

effects related to construction of a natural gas pipeline across NPR-A are expected to be less than 

those for installation of the oil pipeline across NPR-A because the access road would already exist. 

Accordingly, the incremental contribution of natural gas production to cumulative effects would be 

considerably smaller than the incremental contribution of Sale 193 as analyzed in the Sale 193 FEIS. 

Moreover, leasing, exploration, and oil and gas development and production would represent only a 

small percentage of the foreseeable cumulative activities. The incremental contribution of Sale 193 

exploration, development, and production activities, including natural gas development and 

production, to overall cumulative effects would remain minor (in the absence of a large oil spill). 

Presentation of cumulative effects here follows the same organization as used in the Sale 193 FEIS, as 

well as Sections III and IV.C of this SEIS. Recent changes in ESA status do not result in changes to 

the organization of this section. Potential cumulative effects to the yellow-billed loon are evaluated in 

V.B.7, Marine and Coastal Birds. Potential cumulative effects to Pacific walrus, bearded seals and 

ringed seals are considered in V.B.8, Other Marine Mammals. 

V.B.1. Water Quality 

Current industrial impacts to water quality in the Chukchi Sea are minimal and degradation of the 

water quality is confined almost exclusively to external intrusions and naturally occurring processes. 

Future anthropogenic impacts to water quality would be caused primarily by discharge of pollution 

into the marine waters from point-source and nonpoint-source discharges. Polluted discharge from 

marine vessel traffic, especially from large vessels (such as large cruise ships), oil spills, and 

discharges from exploration, development, and production activities could cause degradation of the 

marine environment. 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

Activities from Sale 193 may cause small, localized increases in the concentrations of pollutants 

affecting water quality. These contaminants are temporary in nature, precipitating over a small period 

of time after the discharges cease. Effects on local water quality are expected to be low, while 
BOEMRE Sale 193 Revised Draft SEIS 

288 CHAPTER V. Cumulative Effects 

regional effects are expected to be very low. Sustained degradation of water quality to contamination 

levels above State and Federal criteria is unlikely. Compliant postlease activities do not pose a 

significant degree of risk to water quality. An accidental large oil spill would have possible 

significant impacts. The projected exploration and development from the Proposed Action would 

represent only a small percentage of the foreseeable cumulative activities; the contribution of the 

proposed action is not expected to change the level of overall cumulative effects. 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Effects of natural gas development and production would represent only a negligible increment to the 

effects from Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on water quality is expected to be negligible. 

V.B.2. Air Quality 

In the Alaska Arctic, Prudhoe Bay and Kuparuk River are the principal oil- and gas-producing fields. 

Air monitoring at a number of sites in the Kuparuk and Prudhoe Bay fields showed that 

concentrations of nitrogen dioxide, sulfur dioxide, and PM10 (particulate matter less than 10 

micrometers in diameter) are well within the National Ambient Air Quality Standards (NAAQS). 

BPXA’s air quality modeling for the Liberty Project indicated that emissions from the Prudhoe Bay 

and Kuparuk fields have very little effect on ambient concentrations elsewhere. The air quality 

modeling for Liberty indicated that maximum concentrations would occur within about 100-200 

meters from the facility boundary and would be considerably lower at 1 kilometer from the facility. 

Baseline air quality data has been collected recently in the vicinity of Wainwright and Point Lay (see 

for example, AECOM, Inc., 2009). It is likely that new development would be relatively scattered on 

the North Slope and, therefore, regional impacts would be small; higher, localized concentrations 

would occur in the immediate vicinity of production facilities. Based on this information, very little, 

if any, cumulative interaction between emissions from Sale 193 activities and other oil and gas 

facilities is expected. 

All activities in the Chukchi Sea, Beaufort Sea, and North Slope areas of Alaska in the past and 

occurring now have caused little deterioration in air quality, which remains better than required by 

national standards. Reasonably foreseeable North Slope area activities are not expected to change 

this. 

Arctic haze resulting from elevated concentrations of fine particulate matter occurs primarily in 

winter and spring. Most of these pollutants are attributed to combustion sources in Europe and Asia. 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

Emissions associated with routine program activities could cause small increases in onshore 

concentrations of some air pollutants. Emissions are not expected to exceed national or State air 

quality standards. In the event of a large oil spill, the concentrations of volatile organic compounds 

would increase rapidly near the spill site, but concentrations would dissipate rapidly and would be 

much reduced after the first day and there would be no major impacts. 

Sale 193 activities would represent only a small percentage of the existing North Slope activity. 

Production from Sale 193 is likely to offset declining production elsewhere. Emissions from Sale 193 

activities would have no significant cumulative effects on air quality. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER V. Cumulative Effects 289

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Effects of natural gas development and production would represent only a negligible increment to the 

effects from Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on air quality is expected to be negligible. 

V.B.3. Lower Trophic Level Organisms 

Climate change and decreases in the summer ice cover will probably have the greatest measurable 

effects on lower trophic level organisms in the Chukchi Sea. 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

Offshore production-platform construction, trench dredging, and pipeline burial are expected to affect 

some benthic organisms within 1 km for less than 1 year or season. The cumulative level of effect on 

lower trophic level organisms with standard mitigation would be locally moderate. Contributions 

resulting from the proposed action are not expected to change the overall cumulative effects on lower 

trophic level organisms. 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Effects of natural gas development and production would represent only a negligible increment to the 

effects from the Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on lower trophic level organisms is expected to be negligible. 

V.B.4. Fish Resources 

Subsistence fishing, coastal and maritime traffic, and any discharges from local communities have the 

potential to impact fish on a local level. There is no commercial fishing at this time (Arctic Fishery 

Management Plan, 2009) in the Sale 193 area and little recreational fishing. The environmental 

changes associated with Arctic climate change have the greatest potential to impact fish resources in 

the Chukchi Sea region. 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

Contributions resulting from the proposed action are not expected to change the overall cumulative 

effects on fish resources. 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Effects of natural gas development and production would represent only a negligible increment to the 

effects from the Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on fish resources is expected to be negligible. 

V.B.5. Essential Fish Habitat 

Subsistence fishing, coastal and maritime traffic, and discharges from local communities have the 

potential for local impacts on EFH. The environmental changes associated with Arctic climate 

change have the greatest potential to impact EFH in the Chukchi Sea region. 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

Contributions resulting from the proposed action are not expected to change the overall cumulative 

effects on EFH. 
BOEMRE Sale 193 Revised Draft SEIS 

290 CHAPTER V. Cumulative Effects 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Effects of natural gas development and production would represent only a negligible increment to the 

effects from the Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on EFH is expected to be negligible. 

V.B.6. Threatened and Endangered Species 

Threatened and Endangered Marine Mammals 

The following sources could contribute to potential cumulative effects on marine mammals found in 

the Chukchi Sea Planning Area: 

 subsistence hunting 

 activities related to offshore oil and gas exploration and development 

 marine vessel traffic 

 research activities 

 climate change 

 pollution and contaminants 

With respect to whales, available evidence indicates that subsistence hunting causes disturbance, 

changes in behavior, and sometimes temporary effects on habitat use, including migration paths 

(NMFS, 2003a). Whales avoid various industrial activities if the received sound levels associated 

with the activity are sufficiently strong (Richardson et al., 1995a; National Research Council, 2003a). 

Effects of a large oil spill in Federal or State waters would most likely result in non-lethal temporary 

or permanent effects on bowhead, fin, or humpback whales. It is unlikely, however, that the 

availability of food resources for whales would be affected. The main impacts of climate change 

would be related to habitat changes that might impact migratory routes and breeding, prey 

availability, or feeding grounds. 

Bowhead Whale 

The take of bowhead whales by indigenous hunters represents the largest known human-related cause 

of mortality in this population at the present time, and it is likely to remain so for the foreseeable 

future. The highly regulated subsistence take, while additive, is small and this population apparently 

has the capacity to absorb it and increase in abundance. Further, incidental take of bowhead whales 

as a result of commercial fishing, marine vessel traffic, and research activities has occurred only 

rarely. 

Available data indicates that noise and disturbance from oil and gas exploration and development 

activities since the mid-1970’s have had localized, short-term adverse effects, but no lasting 

population-level adverse effect on bowhead whales. There is no indication that human activities 

(other than historic commercial whaling) have caused long-term displacement in bowheads. 

Oil and gas exploration activities, especially during the 1990’s and early 2000’s, have been shaped by 

various mitigating measures and related requirements for monitoring. There are concerns about the 

effectiveness of mitigation measures being used in the Arctic (Expert Review Panel, 2010). 

Mitigation measures imposed through the MMPA authorizations process are designed to avoid Level 

A Harassment (injury), reduce the potential for population-level significant adverse effects on 

bowhead whales, and avoid an unmitigable adverse impact on their availability for subsistence 

purposes. Such mitigating measures, with monitoring requirements, were designed to, and probably 

did, reduce the impact on the whales and on potential impacts on whale availability to subsistence 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER V. Cumulative Effects 291

hunters. We assume future activities in Federal OCS waters will have similar levels of protective 

measures. 

Offshore exploration seismic surveys are likely to result in some incremental cumulative effects on 

bowhead whales by potentially excluding whales from feeding or resting areas and disruption of 

important associated biological behaviors. Analysis of the likely range of effects and the likelihood 

of exposures resulting in adverse behavioral effects supports a conclusion that the activities would 

result in no more than temporary adverse effects and less than stock-level effects. Seismic surveys, 

especially as mitigated under MMPA authorizations, are not expected to add significantly to the 

cumulative impacts on bowhead whales from past, present, and future activities. 

The ice-associated bowhead may be particularly susceptible to reductions or variation in sea ice cover 

associated with climate change (Kovacs et al., 2010). Potential impacts may result from an increase 

in vessel traffic, an increase in killer whale predation, changes to hunting dynamics, and other factors. 

Fin Whale 

Documented human-caused mortality of fin whales in the North Pacific since the cessation of 

commercial whaling is low. There is no evidence of subsistence take of fin whales in the Northeast 

Pacific (Angliss, DeMaster, and Lopez, 2001; Angliss and Lodge, 2002). Documented fishery 

interaction rates with fin whales are also low in the North Pacific. Reported instances of fin whale 

deaths due to vessel strikes are low. 

Humpback Whale 

Entrapment and entanglement in active fishing gear (O’Hara, Atkins, Ludicello, 1986) is the most 

frequently identified source of human-caused injury or mortality to humpback whales and it has been 

documented to have occurred in Alaska (von Zeigesar, 1984 cited in von Ziegesar, Miller, and 

Dahlheim, 1994). Angliss and Lodge (2003, p. 157) gives a total of 34 humpbacks from the Central 

North Pacific Stock classified as being involved in a human-related stranding or entanglement 

between 1997 and 2001. During the period 2003 to 2007 there were 86 reports of human-related 

mortalities or injuries of central North Pacific humpback whale; 54 incidents involved commercial 

fishing gear, and 23 of those incidents involved serious injuries or mortalities (Allen and Angliss, 

2010; Allen and Angliss, 2011). The Alaska Scientific Review Group (2001) stated that 32 

humpbacks were entangled in southeast Alaska in the previous five-year period. Noise and 

disturbance from whale-watching boats; industrial activities; and ships, boats, and aircraft are also 

causes of concern for humpback whales. Vessel collision is of concern as well. Perry, DeMaster, and 

Silber (1999b) summarized that humpbacks respond the most to moving sound sources (e.g., fishing 

vessels, low-flying aircraft) and the long-term displacement of humpbacks from Glacier Bay and 

parts of Hawaii may have occurred due to vessel-noise disturbance. Perry, DeMaster, and Silber 

(1999b) reported that continued development of coasts and oil exploitation and drilling may lead to 

humpbacks avoidance of areas. 

Polar Bear 

The main impacting factors of concern to polar bears (now listed as threatened under the ESA) are 

climate change, overharvest, and oil and fuel spills. Leads and polynas are important habitat for polar 

bears, especially during winter and spring, and increasing shipping traffic could disturb polar bears 

during these critical times (USDOI, FWS, 1995). Changes in the extent and concentration of sea ice 

are expected to have a significant impact on polar bears through alteration of the distribution, range, 

nutritional status, reproductive success, and ultimately the abundance and stock structure of polar 

bears (Post et al., 2009). 
BOEMRE Sale 193 Revised Draft SEIS 

292 CHAPTER V. Cumulative Effects 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

The Proposed Action is likely to result in a negligible contribution to effects on bowhead, fin, and 

humpback whales. There is the possibility of excluding whales from feeding or resting areas, and the 

possible disruption of important biological behaviors. The incremental contribution of the Proposed 

Action to cumulative effects on polar bears (now listed as threatened under the ESA) is expected to be 

minor, except for potential significant effects in the event of a large oil spill. 

Contribution of Natural Gas Development and Production to Cumulative Impacts 

Effects of natural gas development and production would represent only a small percentage of the 

effects from Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on ESA-listed marine mammals is expected to be negligible. 

Threatened and Endangered Birds 

The cumulative effects of the Proposed Action on threatened and endangered birds and designated 

critical habitat are evaluated in the Biological Evaluation prepared to meet responsibilities under the 

ESA. 

Cumulative effects on spectacled and Steller’s eiders and Kittlitz’s murrelets would be similar to 

those identified for other similar marine and coastal bird species (below), except that the significance 

thresholds are different. If spectacled and Steller's eider populations continue to decline, future losses 

would not be recovered within a generation and would be considered a significant impact. 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

The FWS BO concluded that 3 adult spectacled eiders and 1 adult Steller's eider may be incidentally 

taken through collisions with structures during activities authorized during leasing and exploration 

activities resulting from Sale 193. There is no authorized incidental take associated with oil spills as 

they are considered an unlawful activity. If spectacled and Steller's eider populations continue to 

decline, any spectacled and Steller's eider mortality associated with an oil spill would be a significant 

impact. 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Effects of natural gas development and production would represent only a small percentage of the 

effects from the Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on ESA-listed birds is expected to be negligible. 

V.B.7. Marine and Coastal Birds 

Subsistence hunting, coastwise and maritime traffic, and discharges from local communities have the 

potential for local impacts on marine and coastal birds. The environmental changes associated with 

Arctic climate change have the potential to impact marine and coastal birds in the Chukchi Sea 

region. 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

OCS seismic survey activities will not be allowed in the Ledyard Bay area after July 1 of each year 

and aircraft are required to remain 1,500 ft above the area or use designated routes during poor 

weather. Because of these measures, the cumulative effect of seismic exploration on marine and 

coastal birds probably would be minimal, particularly to birds staging or molting in the Ledyard Bay 

area. The cumulative effect of disturbance due to seafloor sampling and drilling platforms is 

expected to be minor. Construction of pipelines for offshore development would impact several 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER V. Cumulative Effects 293

hundreds of acres of bird molting and foraging habitat and would be a major, but short-term, impact 

that would result in the displacement of staging and molting birds from nearshore areas. 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Effects of natural gas development and production would represent only a small percentage of the 

effects from the Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on marine and coastal birds is expected to be negligible. 

V.B.8. Other Marine Mammals 

Increasing human activity, industrial development, oil and gas activities, and anthropogenic and 

natural contaminant levels in the Arctic may be affecting marine mammal populations (Quakenbush 

and Sheffield, 2006). Climate change is currently having a profound impact on many Arctic marine 

mammal populations, particularly ice-dependent pinnipeds. The primary impacts of climate change 

on cetaceans are the result of habitat changes (e.g. reductions in sea ice) that may impact prey 

location or availability. Changes in the extent and concentration of sea ice may alter the seasonal 

distributions, geographic ranges, patterns of migration, nutritional status, reproductive success, and 

ultimately the abundance and stock structure of some species (Tynan and DeMaster, 1997), resulting 

in significant impacts to some species. Some marine mammals may benefit from Arctic climate 

change. For example, sightings data of gray whale calves suggest that higher calf counts in the spring 

are associated with years of delayed onset of freezeup in the Chukchi Sea (Kovacs et al., 2010). 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

The incremental contribution of the Proposed Action to cumulative effects on marine mammals not 

listed under the ESA is expected to be minor, except for potential major effects in the event of a large 

oil spill. 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Effects of natural gas development and production would represent only a small percentage of the 

effects from the Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on marine mammals not listed under the ESA is expected to be negligible. 

V.B.9. Terrestrial Mammals 

Subsistence take, recreational hunting, and the environmental changes associated with Arctic climate 

change have the potential to impact terrestrial mammals to varying degrees. Industrial activities that 

could affect terrestrial mammals include: 

 Oil and gas development in NPR-A. 

 Road construction on the North Slope. 

 Coal development in the Brooks Range. 

 Expansion of Red Dog Mine. 

 Development of bornite mining in the Ambler Mining District. 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

The incremental contribution of the Proposed Action to cumulative effects on terrestrial mammals is 

expected to be negligible to minor. 
BOEMRE Sale 193 Revised Draft SEIS 

294 CHAPTER V. Cumulative Effects 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Effects of natural gas development and production would represent only a small percentage of the 

effects from Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on terrestrial mammals is expected to be negligible. 

V.B.10. Vegetation and Wetlands 

A 2001 evaluation of cumulative impacts on the North Slope indicates that impacts on vegetation at 

present include approximately 17,324 acres of tundra and floodplains covered due to gravel roads, 

gravel pads, and gravel mining (National Research Council, 2003b). Gravel roads and gravel pads 

represent more than 8,800 acres and gravel mines nearly 6,400 acres of the impacted area. The 

indirect effects associated with existing roads, roadside flooding, dust-killed tundra, and thermokarst 

were estimated to cover at least 10,500 acres (Nationa Resarch Council, 2003b). The total affected 

acreage is a small part of the Alaska coastal plain, and cumulative effects probably are not significant 

to the overall productivity of tundra plants. Impacts on vegetation could accumulate and persist, 

especially if the structures remain once industrial activity has ceased. Rehabilitation of gravel pads 

can result in the growth of grasses and sedges within 2 years after abandonment of the pads, but the 

natural growth of plant cover on abandoned gravel pads would be very low. Local additive effects of 

gravel pads and roads, borrow sites, and other infrastructure would be expected to persist decades 

after the oil fields are abandoned. 

Changes in vegetation from dust and snowdrift accumulation or the formation and draining of 

impoundments related to roads and gravel pads are not considered permanent. Typically, permafrostrelated geomorphic processes occurring in the North Slope create a constantly changing landscape 

that influences succession patterns in plant communities, so they are adapted to such frequent changes 

(see Section V.C.10 of the Sale 193 FEIS; USDOI, MMS, 2007a). 

In terms of acres of land affected, construction of onshore infrastructure would cause more than 99% 

of the effects. Cumulative effects of small oil spills and other discharges are expected to be localized. 

Small spills occurring on snow are expected to have few cumulative effects, as they are usually 

cleaned up immediately upon discovery and usually are successfully removed before reaching the 

vegetation root mat (see Section V.C.10 of the Sale 193 FEIS; USDOI, MMS, 2007a. 

The environmental changes associated with Arctic climate change have the greatest potential to 

impact vegetation and wetlands on the North Slope. 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

A large-diameter oil pipeline is assumed to be constructed from the Chukchi Sea coast across NPR-A. 

The overland oil pipeline(s) would be elevated above ground and pump stations would be needed at 

about 100-mi intervals. Assuming that the pipeline would create an eastward corridor of about 100 ft 

wide and 300 mi long, the area to be impacted would be approximately 1,470 hectares (3636 acres). 

This represents <1% of the area covered by vegetation and wetlands of the North Slope. A pump 

station is foreseen to be constructed on gravel pads at about 100 mi from each other along the pipeline 

corridor, for a likely maximum of three to four pump stations. The burial of vegetation under gravel 

pads could be considered a permanent loss (25 to 30 years) of the affected plant communities. 

Impacts to vegetation of Alaska’s North Slope from oil and gas exploration and development in the 

Chukchi Sea are expected to be a fraction of the total North Slope acreage. It is not expected that 

synergistic impacts to vegetation would occur by affecting additional acres, nor would any effects 

(whether beneficial or detrimental) occur to vegetation as a result of additional acres developed. 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER V. Cumulative Effects 295

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Effects of natural gas development and production would represent only a small percentage of the 

effects from Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on vegetation and wetlands is expected to be negligible. 

V.B.11. Economy 

Without the development of future onshore and offshore oil and gas development projects, the 

onshore and offshore oil industry in and near Prudhoe Bay is expected to decline, and the associated 

direct employment would also be expected to decline. Associated indirect employment in 

Southcentral Alaska, Fairbanks, and the NSB, and revenues to the Federal, State, and NSB 

governments would be expected to decline also. 

The Trans Alaska Pipeline System (TAPS) represents a tremendous capital investment. Additional 

onshore and offshore oil development and production is necessary to extend the useful life of TAPS. 

In January 8, 2003, the TAPS right-of-way was renewed for another 30 years by both State and 

Federal agencies. 

The northeast and northwest portions of the NPR-A are projected to generate considerable revenues 

in the future. Future revenues are also expected from continuing production at Prudhoe Bay and 

reasonably foreseeable Prudhoe Bay development. 

In the Sale 193 FEIS, cumulative oil and gas activities (past, present, and reasonable foreseeable 

development and production, both onshore and offshore, both State and Federal) are projected to 

generate annual revenues of $32 million to the NSB, $232 million to the State, and $1.1 billion to the 

Federal government. 

Cumulative gains in direct employment in the oil and gas industry would generate indirect and 

induced employment and associated personal income. Indirect and induced employment is generated 

by expenditures for goods and services used on the North Slope and spending by direct employees. 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

The Proposed Action is expected to have beneficial effects on the economies of the NSB, State of 

Alaska, and the Federal Government through the creation of direct, indirect, and induced employment 

and the generation of revenues. No royalties would flow to the State from Sale 193 oil production. 

Oil production from Sale 193 leases would contribute to extending the useful life of TAPS. 

The incremental contribution of the Proposed Action is expected to make a substantial incremental 

contribution to the NSB economy, a minor contribution to Alaska State economy, and a negligible 

contribution to National economy. 

Contribution of Gas Production to Cumulative Impacts 

Natural gas development and production would generate employment and revenues comparable to 

those generated by oil development and production resulting from Sale 193. No royalties would flow 

to the State from Sale 193 natural gas production. 

Natural gas from Sale 193 leases would contribute to extending the useful life of a large capacity 

North Slope gas pipeline to outside markets. 

Natural gas development and production is expected to have beneficial effects on the economy of the 

NSB, State of Alaska, and the Federal Government. The incremental contribution of natural gas 

development and production is expected to make a substantial incremental contribution to NSB 
BOEMRE Sale 193 Revised Draft SEIS 

296 CHAPTER V. Cumulative Effects 

economy, a minor contribution to Alaska State economy, and a negligible contribution to National 

economy. 

V.B.12. Subsistence-Harvest Patterns 

The NSB’s written scoping comments and recommendations on the BLM’s Northeast NPR-A IAP 

EIS in April 1997, articulated concerns about the cumulative impacts of all industrial and human 

activities on the North Slope and its residents. Consideration of these impacts must take into account 

industrial activities occurring offshore and at existing oil fields to the east; scientific research efforts; 

sport hunting and recreational uses of lands; and the enforcement of regulations governing the harvest 

of fish and wildlife resources by local residents (North Slope Borough, 1997; USDOI, MMS, 2003a). 

Onshore activities that could affect subsistence-harvest patterns include noise and traffic disturbance, 

disturbance from construction activities associated with ice roads, production facilities, pipelines, 

gravel mining, supply efforts, and potential oil spills. Adverse effects could include resource 

displacement; changes in hunter access to resources; increased competition; contamination levels in 

subsistence resources; harvest reductions; or increased effort, risk, and cost to hunters. Oil on the 

North Slope already has caused increased regulation of subsistence hunting, reduced access to 

hunting and fishing areas, altered habitat, and intensified competition from nonsubsistence hunters for 

fish and wildlife (Haynes and Pedersen, 1989; Pedersen et al., 2000; Miller, 2001). 

Access to subsistence resources and subsistence-hunting areas and the use of subsistence resources 

could change if cumulative noise and traffic disturbance reduces the availability of resources or alters 

distribution patterns. Subsistence-harvest activities could be disrupted occasionally by vessel and air 

traffic. If increased noise affected whales and caused them to deflect from their normal migration 

route, they could be displaced from traditional hunting areas, and the traditional bowhead whale 

harvest could be adversely affected by requiring boat crews to travel longer distances over extended 

periods for hunts. Because the bowhead whale harvest in all communities except Barrow tends to be 

quite small—one to two whales per year—noise disturbance from icebreakers and other vessels could 

cause this small harvest to become locally unavailable for an entire season. Increased air traffic and 

vessel activities in the Chukchi Sea could impact the beluga harvest by causing beluga whales to 

become locally unavailable for certain critical periods. Required protective mitigation is expected to 

reduce these noise disturbance impacts. 

Development of regional roads would have the potential to negatively affect wildlife and subsistence 

patterns through habitat fragmentation, increased access into wildlife habitats, increased disturbance 

impacts, increased potential for mortality (road kills), possible alteration of behavior or movement 

patterns of wildlife, increased competition for subsistence resources, and possibly an increase in 

tourist traffic and recreational use of the area. Increased access to terrestrial mammals could be 

associated with increases in hunting pressure and increases in competition for subsistence resources 

from both subsistence and nonsubsistence hunters. Increased harvest levels potentially could make 

game more scarce near roads. Reduced abundance and distribution of terrestrial mammals would be 

expected along the road corridor from hunting, trapping, recreation, and tourist traffic. As a result, 

subsistence hunts could take longer as hunters would have to travel farther from the road corridor to 

successfully reach game, or be forced to hunt in nontraditional areas. 

Because polar marine and terrestrial animal populations would be particularly vulnerable to changes 

in sea ice, snow cover, and alterations in habitat and food sources brought on by climate change, rapid 

and long-term impacts on subsistence resources (availability), subsistence-harvest practices (travel 

modes and conditions, traditional access routes, traditional seasons and harvest locations), and the 

traditional diet would be expected (IPCC, 2001b; National Research Council, 2003b; ACIA, 2004; 

Millennium Ecosystems Assessment, 2005; United Nations Environment Programme, 2005; 

Callaway, 2007). A study by Hovelsrud, McKenna and Huntington (2008) concluded that climate 

change was likely to change existing harvest patterns in way that would likely “decrease access to 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER V. Cumulative Effects 297

marine mammals and in ways that would increase risks and costs associated with hunting.” They 

predicted that less hunting was likely due to shifting marine mammal populations caused by changing 

sea ice conditions. This they believe would alter the “socioeconomic system of Arctic hunting 

communities.” They also see increased shipping and oil and gas activities as likely to increase 

pollution, noise, and ship strikes to whales. To them, the crucial concern is the development of an 

“extensive monitoring and analysis program” in order to disaggregate “local human causes from 

larger environmental changes” (Hovelsrud, McKenna, and Huntington, 2008). Later research by 

Ashjian et al. (2010), based on the collaboration of Western scientists and local whalers doing 

fieldwork off Barrow in 2005 and 2006, concluded that despite ongoing climate variability in the 

region, the area off Barrow continues to develop as a whale feeding area and the normal timing and 

arrival of bowheads off Barrow during their fall migration remains consistent. Thus, “the fall whale 

harvest by the Inupiat community of Barrow should be relatively resilient to climate change.” 

Nevertheless, the “whale harvest at Barrow could... be particularly vulnerable to anthropogenic 

activities such as ship traffic, oil development, or an oil spill.” 

Contribution of Sale 193 FEIS Alternative I to Cumulative Impacts 

Oil and gas development in the Chukchi Sea Planning Area could inhibit subsistence harvesters’ use 

of traditional harvest areas, which could reduce harvest success; increase the cost, effort, and risk 

involved with subsistence harvest; increase the and wear and tear on equipment used for harvesting 

subsistence foods; devalue elders’ knowledge of the traditional landscape; increase the importance of 

local knowledge of oil industry schedules and practices; and reduce the enjoyment of eating 

traditional foods (if harvests were to be reduced or if subsistence resources were perceived to be 

contaminated). The use of marine subsistence resources could change if oil development reduces 

availability or alters distribution patterns of subsistence species. The most serious concern to Inupiat 

subsistence users is that potential increases in noise from OCS development could disrupt the normal 

migration of bowhead whales, forcing subsistence whalers into longer hunts farther from shore. The 

communities of Barrow, Wainwright, Point Lay, Point Hope, and Kivalina would be potentially 

affected; Wainwright could be the most affected community because of potential impacts from shorebase-facility construction. 

A road associated with an oil-sales pipeline across NPR-A would provide new access to subsistencehunting areas and subsistence resources, and subsequent concerns about increased hunting pressure 

and increased competition for subsistence resources from both subsistence and nonsubsistence 

hunters. The pipeline across NPR-A could promote the development and expansion of the oil and gas 

development in NPR-A, and also possible hunter access restrictions, hunting area reductions, trespass 

issues, and disturbance and displacement of game. 

In the event that a large oil spill occurred and contaminated essential whaling areas, significant 

additive effects on subsistence-harvest could occur from contamination of the shoreline, tainting 

concerns (real or perceived effects on the quality of subsistence resources), cleanup disturbance, and 

disruption of subsistence practices. 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Natural gas development and production would represent only a small percentage of the effects of 

Sale 193. The incremental contribution of natural gas development and production to cumulative 

effects on subsistence-harvest practices is expected to be negligible. 

V.B.13. Sociocultural Systems 

It is important to note the difficulty in disaggregating the contribution of various factors to cumulative 

effects on the sociocultural systems of the North Slope communities. Many events (including 
BOEMRE Sale 193 Revised Draft SEIS 

298 CHAPTER V. Cumulative Effects 

ANCSA and ANILCA legislation, and the formation of the NSB, the AEWC, and other local and 

regional institutions) have combined with the area’s oil development to bring rapid social change to 

the area. On the regional level, cumulative effects from oil and gas development and other activities 

would have direct and indirect consequences on social organization, cultural practices and 

institutional organization but would not tend to displace social systems. 

Contribution of Alternative I to Cumulative Impacts 

The effects of Sale 193 on sociocultural systems are largely the same as overall cumulative effects, 

except that effects of onshore support facilities are likely to be focused in Wainwright. The Proposed 

Action would represent a small percentage of the foreseeable cumulative activities. 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Natural gas development and production would represent only a negligible increment to the effects 

from Sale 193. The incremental contribution of natural gas development and production to 

cumulative effects on sociocultural systems is expected to be negligible. 

V.B.14. Archaeological Resources 

The greatest cumulative effect on archaeological resources in the Chukchi Sea area is from natural 

processes such as ice gouging, bottom scour, thermokarst erosion, and shoreline erosion. Because the 

destructive effects of natural processes are cumulative, they have affected and will continue to affect 

archaeological resources in this area. 

In addition to Alternative I for Sale 193, other activities associated with this cumulative analysis that 

may affect archaeological resources in the Chukchi Sea include lease sales and activity in the 

Beaufort Sea and the NPR-A and State lands, State oil and gas fields, oil and gas transportation, 

noncrude carriers, and Federal activities. Cumulatively, these proposed projects likely would disturb 

the seafloor, but remote-sensing surveys made before approval of Federal or State lease actions would 

be expected to keep these effects low. Federal laws would preclude effects on most archaeological 

resources from these planned activities. 

Contribution of Alternative I to Cumulative Effects 

The incremental contribution of the Proposed Action to cumulative impacts on both prehistoric and 

historic archaeological resources should be negligible. Surface-disturbing activities that could 

damage archaeological sites would be mitigated by current State and Federal procedures, which 

require identification and mitigation of archaeological resources in the proposed project areas. 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Gas development and production would represent only a small percentage of the effects of Sale 193. 

The incremental contribution of natural gas development and production to cumulative effects on 

archaeological resources is expected to be negligible. 

V.B.15. Environmental Justice 

Activities on the North Slope and in the adjacent Chukchi and Beaufort seas may affect subsistence 

resources and harvest practices. Environmental justice-related effects on Inupiat Natives and the 

Inupiat communities of Barrow, Wainwright, Point Lay, and Point Hope could occur because of their 

reliance on subsistence foods. Onshore oil and gas development, especially potential road 

development within NPR-A and Alpine satellite field expansion, could impact subsistence resources 

and harvest practices. Subsistence resources, particularly caribou, could experience long-term 

disturbance and displacement effects, as well as functional loss of habitat and potential population 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER V. Cumulative Effects 299

reductions, causing subsistence hunters to alter traditional harvest practices by having to travel to 

unfamiliar areas. If this occurred, long-term displacement of ongoing social systems would be 

expected. Community activities and traditional practices for harvesting, sharing, and processing 

subsistence resources would be altered, and disproportionately high, adverse effects would be 

expected for the Inupiat communities of Barrow, Wainwright, Point Lay, and possibly Point Hope. 

Cumulative effects on human health would derive from impacts to subsistence, degradation of air and 

water quality, contaminants in subsistence foods, and sociocultural effects. Long-term climate 

change effects on marine and terrestrial ecosystems in the Arctic—affecting subsistence resources, 

traditional culture, and community infrastructure of subsistence-based indigenous communities in the 

NSB—would be a contributing factor to cumulative environmental justice-related impacts. Potential 

disproportionately high adverse effects on low-income, minority populations in the region are 

expected to be mitigated substantially, but not eliminated. 

Contribution of Alternative I to Cumulative Impacts 

In-place protective measures, stipulated measures for seismic-survey permits, and mitigation 

accompanying NMFS IHA authorizations are expected to mitigate effects. No unmitigable adverse 

effects on subsistence-harvest patterns, resources, or practices (or consequent effects on sociocultural 

systems) would occur as a result of noise and disturbance. Major effects are not expected from 

routine activities and operations; however, if a large oil spill occurred and contaminated essential 

whaling areas, major effects could occur when impacts from contamination of the shoreline, tainting 

concerns, cleanup disturbance, and disruption of subsistence practices are factored together. Only in 

the event of a large oil spill would disproportionately high and adverse effects be expected on 

Alaskan Natives. 

Section V.C.15 of the Sale 193 FEIS provides a discussion of the initiatives and studies that 

BOEMRE and other Federal, State, and NSB agencies have undertaken to address environmental 

justice issues on the North Slope. 

Contribution of Natural Gas Development and Production to Cumulative 

Impacts 

Gas development and production would represent only a small percentage of the effects of the Sale. 

The incremental contribution of natural gas development and production to cumulative effects for 

environmental justice issues would be expected to be negligible. 
BOEMRE Sale 193 Revised Draft SEIS 

300 CHAPTER VI. Consultation and Coordination 

CHAPTER VI. Consultation and Coordination 

VI.A. Development of the Proposed Action, DEIS, and FEIS. 

In 2002, the Secretary of the Interior issued the Final OCS Oil and Gas Leasing Program for 2002-

2007 (2002-2007 Five-Year Program). That document presented USDOI’s decision to consider 

annual “special-interest” sales in the Chukchi Sea/Hope Basin OCS Planning Areas. In response to 

the Call For Information and Nominations published in the Federal Register on February 9, 2005 (70 

FR 6903), industry nominated a substantial portion of the Chukchi Sea Planning Area. The prelease 

process and EIS could not be completed in time to allow the Sale during the 2002-2007 Five-Year 

Program, which expired on June 30, 2007. Chukchi Sale 193 was subsequently included in the 2007-

2012 Five-Year Program. 

Information on the prelease and NEPA processes for Sale 193 is in Sections I.D and VI of the Sale 

193 FEIS. Federal Register Notices, Scoping Report, Draft and Final Notices of Sale, and other 

information on Sale 193 is on the BOEMRE website at http://alaska.boemre.gov/cproject/ 

Chukchi193/Chukchiindex.htm. 

VI.B. Development of the SEIS 

On October 5, 2010, BOEMRE issued a Notice of Intent to Prepare a Supplemental Enviornmental 

Impact Statement (75 FR 61511). The availability of the Draft SEIS was announced on October 15, 

2010 (75 FR 63504) and a 45-day public review and comment period commenced. During this 

period, BOEMRE held six public hearings on the Draft SEIS and received more than 150,000 

comments. 

The BOEMRE took deliberate steps to announce the availability of the Draft SEIS, to disseminate the 

Draft SEIS, to meet with interested parties, and to publicize the series of meetings scheduled 

specifically for this process. These efforts included the following: 

 Publishing a Notice of Intent to Prepare the SEIS and a Notice of Availability in the Federal 

Register. 

 Updating the BOEMRE website and providing a link to the Draft SEIS. 

 Mailing hard copies of the Draft SEIS to Tribal and local governments, local libraries, and 

other parties who expressed interest in BOEMRE NEPA documents in the past. 

 Scheduling a series of meetings with both Tribal and local governments in five potentially 

affected villages, as well as Anchorage. 

 Placing large newspaper ads to appear in two editions each of the Arctic Sounder, Fairbanks 

News-Miner, and Anchorage Daily News. 

 Running public service messages on the two public radio stations serving the North Slope—

KBRW in Barrow and KOTZ in Kotzebue—and, providing the same messages to commercial 

radio station KBYR (which is heard in several communities of the North Slope). 

 Providing news media assignment editors with our community advisories and, thereby, the 

opportunity to follow up with additional announcements or stories. 

Public hearings on the Draft SEIS were held in the following communities on the dates indicated: 

Kotzebue (November 1, 2010), Point Hope (November 2, 2010), Point Lay (November 3, 2010), 

Wainwright (November 4, 2010), Barrow (November 5, 2010), and Anchorage (November 9, 2010). 

The BOEMRE also scheduled government-to-government meetings to meet the requirements of 

Executive Order 13175, Consultation and Coordination with Indian Tribal Governments. The 

BOEMRE representative met with the Native Villages of Kotzebue, Point Lay, Wainwright, and 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER VI. Consultation and Coordination 301

Barrow, and with the Inpupiat Community of the Arctic Slope. No government-to-government 

meeting was held with the Native Village of Point Hope because this Village had to cancel an initial 

meeting due to conflicts. The BOEMRE has offered through e-mail to reschedule the Native Village 

of Point Hope meeting by teleconference at the Village’s earliest convenience. It was later agreed that 

a government-to-government meeting would be held in Point Hope in June 2011. 

The BOEMRE also met with representatives from the North Slope Borough. 

On March 4, 2011, BOEMRE announced preparation of a Revised Draft SEIS to incorporate a VLOS 

analysis. Additional information on the impetus for this decision is provided in Chapter I. Additional 

information on the distinctions between a hypothetical VLOS model and Worst Case Discharge 

(WCD) values is provided in Section IV.D.2. 

The BOEMRE will follow a similar process by allowing a 45-day public and agency comment period 

and public hearings for this Revised Draft SEIS. 

VI.C. Consultation 

The BOEMRE has engaged in several consultation and coordination processes with other regulatory 

agencies in regard to proposed activities under Lease Sale 193. In terms of the NEPA process, 

NOAA served as a cooperating agency for the Sale 193 FEIS and has collaborated with BOEMRE 

while developing this Revised Draft SEIS. The subsections below provide a summary of how 

BOEMRE has satisfied or will satisfy its requirements under various Federal regulatory processes. 

VI.C.1. ESA Section 7 

A discussion on the ESA Section 7 consultation related to Sale 193 is provided in Section VI.D of the 

Sale 193 FEIS. 

Section 7(a)(2) of the ESA requires each Federal agency to ensure that any action that they authorize, 

fund, or carry out is not likely to jeopardize the continued existence of a listed species or result in the 

adverse modification of designated critical habitat. To satisfy its ESA obligations on proposed lease 

sales, BOEMRE consults with FWS and NMFS for listed species under each Service’s jurisdiction. 

For ESA consultation on proposed lease sales, BOEMRE specifically requests incremental Section 7 

consultation. Regulations at 50 CFR 402.14 (k) allow consultation on part of the entire action as long 

as that step does not violate Section 7(a)(2); there is a reasonable likelihood that the entire action will 

not violate Section 7(a)(2); and the agency continues consultation with respect to the entire action, 

obtaining a biological opinion for each step. Accordingly, at the lease-sale stage, BOEMRE consults 

on the early lease activities (seismic surveying, ancillary activities, and exploration drilling) to ensure 

that activities under any leases issued will not result in jeopardy to a listed species or cause adverse 

modification of designated critical habitat. The BOEMRE is required to reconsult for any proposed 

development and production activities. 

The BOEMRE’s predecessor agency, the MMS, prepared Biological Evaluations (BEs) that evaluated 

the types of activities contemplated under the Proposed Actions analyzed in the Sale 193 FEIS and 

this SEIS. In response to MMS requests to initiate formal consultation, both NMFS and FWS 

returned Biological Opinions analyzing potential oil and gas exploration, development, and 

production activities in the Chukchi Sea. Relevant NMFS BOs include the Arctic Regional BO of 

2006 and a 2008 BO for Oil and Gas Leasing and Exploration Activities in the Beaufort and Chukchi 

Seas. Applicable FWS BOs include the Oil and Gas Sale 193 BO from 2007 as well as the BO for 

Beaufort and Chukchi Sea Program Area Lease Sales completed in 2009. These documents, along 

with associated BEs and correspondence documents, are available at the BOEMRE website at 

http://alaska.boemre.gov/ref/Biological_opinions_evaluations.htm. As indicated in Table 17 (below), 

BOEMRE has consulted (or conferred) with the appropriate Service on the Proposed Action’s 

potential impacts to Endangered, Threatened, and Candidate species present within the affected area, 
BOEMRE Sale 193 Revised Draft SEIS 

302 CHAPTER VI. Consultation and Coordination 

as well as regarding potential impacts to designated Critical Habitat. Moreover, BOEMRE routinely 

reviews and updates its Section 7 obligations to remain in compliance with the ESA. 

Table 17. Consultation or conference with respect to potential impacts to Endangered, Threatened, and 

Candidate species present within the affected area. 

Species Listing 

Status 

Critical Habitat 

Designated 

(Yes/No) 

Completed 

Consultations / 

Conferences 

Additional 

Requirements for 

SEIS 

Bowhead 

Whale Endangered No NMFS ARBO 2006**** NMFS BCS BO 2008** None 

Humpback 

Whale Endangered No NMFS BCS BO 2008** None 

Fin Whale Endangered No NMFS BCS BO 2008** None 

Polar Bear Threatened Yes FWS BCS BO 2009* Additional 

consultation 

Spectacled 

Eider Threatened Yes 

FWS Sale 193 BO 

2007*** 

FWS BCS BO 2009 

None 

Steller’s Eider Threatened No 

FWS Sale 193 BO 

2007*** 

FWS BCS BO 2009* 

None 

Kittlitz’s 

Murrelet Candidate No 

FWS Sale 193 BO 

2007*** 

FWS BCS BO 2009* 

None 

Yellow-Billed 

Loon Candidate No FWS BCS BO 2009* None 

Walrus Candidate No None None 

Bearded Seal Proposed No None None 

Ringed Seal Proposed No None None 

* FWS BCS BO 2009 = Biological Opinion for Beaufort and Chukchi Sea Program Area Lease Sales and associated Seismic 

Surveys and Exploratory Drilling; Fish & Wildlife Service (September 3, 2009) 

**NMFS BCS BO 2008 = Biological Opinion for Oil and Gas Leasing and Exploration Activities in the Beaufort and Chukchi 

Seas, Alaska; and Authorizations of Small Takes Under the Marine Mammal Protection Act; National Marine Fisheries Service 

(July 17, 2008) 

*** FWS Sale 193 BO 2007 = Biological Opinion for Chukchi Sea Planning Area, Oil and Gas Lease Sale 193 and Associated 

Seismic Surveys and Exploratory Drilling; Fish & Wildlife Service (March 2007) 

**** NMFS ARBO 2006 = Biological Opinion for Oil & Gas Leasing & Exploration Activities in the U.S. Beaufort and Chukchi 

Seas, Alaska, Arctic Regional Biological Opinion; National Marine Fisheries Service (June 16, 2006) 

VI.C.2. Essential Fish Habitat Consultation 

The Magnuson-Stevens Act (as amended) requires Federal agencies to consult with NOAA Fisheries 

regarding actions that may advesely affect designated Essential Fish Habitat (EFH). In 2006, 

BOEMRE consulted with NMFS (which previously had responsibility for this program) regarding the 

potential effects on EFH for all five species of Pacific salmon. This process culminated in a 

document entitled “Chukchi Lease Sale 193 Essential Fish Habitat Consultation.” In August 2009, 

EFH was designated for Arctic cod, saffron Cod, and opilio crab. To address EFH consultation 

requirements for the upcoming decision to affirm, modify, or cancel Lease Sale 193, BOEMRE is 

preparing a separate EFH assessment to be delivered to NOAA Fisheries this summer (2011). Any 

conservation recommendations resulting from that consultation will be addressed in the Final SEIS. 

VI.C.3. Section 106 Consultation 

Section 106 of the National Historic Preservation Act (NHPA) requires Federal agencies to consult 

with the State Historic Preservation Officer (SHPO) regarding any undertaking with the potential to 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER VI. Consultation and Coordination 303

affect historic properties. On January 30, 2007, BOEMRE initiated Section 106 consultation with the 

Alaska State Historic Preservation Officer (SHPO) for the proposed Chukchi Sea Oil and Gas Lease 

Sale 193. The BOEMRE identified two historic resources (shipwrecks) in the Chukchi Sea Planning 

Area, and identified the specific lease blocks in which these shipwrecks were located (see Sale 193 

FEIS; USDOI, MMS, 2007a). At the time of the proposed lease-sale EIS, no bottom-disturbing 

activities were anticipated and BOEMRE requested SHPO's concurrence that proposed Lease Sale 

193 would have "no effect upon known offshore historic and/or prehistoric resources." Concurrence 

was received from SHPO on March 2, 2007. BOEMRE has subsequently consulted with the Alaska 

SHPO on two additional actions relevant to the Chukchi Sea Planning Area: the Arctic Multiple-Sale 

DEIS in 2008 and Shell’s ancillary activity notice for marine surveys in the Chukchi Sea in 2010. 

While no additional Section 106 consultation will be necessary for Sale 193 or this Supplemental EIS 

process, additional consultations will occur regarding exploration or development plans that may 

follow from this sale. 

VI.C.4. CZMA Consistency Review 

The Coastal Zone Management Act (CZMA) requires Federal agencies to insure that their activities 

are consistent to the maximum extent practicable with the enforceable policies of a State’s approved 

coastal management plan, including any enforeceable district policies. A Consistency Determination 

(CD) was sent to the State of Alaska in conjunction with the Proposed Notice of Sale in August 2007. 

The CD analyzed the consistency of Sale 193 with the Alaska Coastal Zone Management (CZM) 

program. The document evaluated potential effects from the sale action and from hypothetical 

exploration and development activities outlined in the FEIS analysis. The MMS found that the 

proposal was consistent to the maximum extent practicable with the state’s CZM program, including 

the enforceable policies of the North Slope Borough’s district plan. On October 30, 2007, the State of 

Alaska issued its final consistency decision concurring with our determination that the sale was 

consistent to the maximum extent practicable with the Alaska Coastal Management Program and the 

local district’s enforceable policies. 

VI.D. Authors, Reviewers, and Supporting Staff 

BOEMRE staff with a wide variety of expertise in appropriate scientific, economic, and sociocultural 

disciplines contributed to the development of the SEIS and the analysis herein. Representatives from 

NOAA, National Marine Fisheries Service and National Ocean Service offices also reviewed a draft 

document of the Revised Draft SEIS. Table 18 lists the primary individuals involved, their 

professional position, and their role in preparing and reviewing the SEIS. 

Table 18. List of the primary individuals contributing to development and analysis in the SEIS 

Name Professional Position Role in Preparation 

Tamara Arzt Environmental Protection 

Specialist 

Review: T&E species, other marine mammals, economy, 

subsistence, harvest patterns and resources, 

envsociocultural systems, environmental justice, NEPA 

Gene Augustine Interdisciplinary Biologist Review: Lower-trophic organisms; vegetation and 

wetlands 

Scott Blackburn Technical Writer/Editor Document review and preparation 

Christy Bohl Oil Spill Program Adminstrator Technical review: Oil Spill Program 

Jerry Brian Socioeconomic Specialist Analysis: economics 

Michael Burwell Socioeconomic Specialist Analysis: sociocultural, subsistence, archaeological, and 

environmental justice 
BOEMRE Sale 193 Revised Draft SEIS 

304 CHAPTER VI. Consultation and Coordination 

Name Professional Position Role in Preparation 

Megan Butterworth Biological Oceanographer 

Review: water quality, lower-trophic organisms, fish, 

Essential Fish Habitat, T&E species, other marine 

mammals 

Chris Campbell Sociocultural Specialist Review: Sociocultural and subsistence 

Mary Cody Wildlife Biologist Analysis: T&E species and marine mammal 

Chris Crews Wildlife Biologist Analysis: T&E species, marine mammal, terrestrial 

mammal 

Jim Craig, Ph.D. Geologist Natural gas scenario development 

Deborah Cranswick Chief, Environmental Analysis 

Section I 

Supervisory Project Lead; Natural gas scenario; NEPA 

review 

Jennifer Culbertson Biological Oceanographer Review: water quality, lower-trophic organisms, 

vegetation and wetlands 

Jeff Denton Wildlife Biologist Analysis: T&E species and marine mammals 

Nancy Deschu Fisheries Biologist Anlaysis: fish, EFH, water quality 

Dirk Herkhof Meteorologist Review: air quality 

Kelly Hite Environmental Protection 

Specialist 

Review: economy, subsistence harvest patterns and 

resources, sociocultural systems, environmental justice, 

NEPA 

Dan Holiday, Ph.D. Biological Oceanographer Analysis: lower-trophic organisms; vegetation and 

wetlands 

Tim Holder Sociocultural Specialist Arctic liaison 

Walter R. Johnson Oceanographer Review: Oil Spill Risk Analysis 

David Johnston Minerals Leasing Specialist Review: Leasing process 

Brian Jordan Federal Preservation Officer and 

Archaeologist Review: archaeological resources 

Jim Lima, Ph.D. Chief, Environmental Analysis 

Section II Review: NEPA 

Jefferey A. Loman Deputy Regional Director Regional management review 

Jim Lusher General Engineer Technical review; Drilling operations 

Matthew Lux Cartographic Specialist GIS map production 

Kyle Monkelien Petroleum Engineer Technical review; Drilling operations 

Hung Nguyen Emergency Oil Spill Response 

Coordinator Review: oil spill cleanup 

Robert Peterson Chief, Resource and Economic 

Analysis Section 

Review: Natural gas scenario and very large oil spill 

scenario 

Virginia Raps Meteorologist Analysis: climate and air quality 

Michael Routhier NEPA Coordinator Project Lead; NEPA review 

Mark Schroeder Wildlife Biologist Analysis: T&E species and marine and coastal birds 

Kirk Sherwood Geologist Technical review; hydrocarbon release scenario 

Kimberly Skrupky Marine Biologist Review: T&E species, other marine mammals 

Caryn Smith Oceanographer Analysis: sea ice, hydrocarbon release scenarios 
Sale 193 Revised Draft SEIS BOEMRE 

CHAPTER VI. Consultation and Coordination 305

Name Professional Position Role in Preparation 

Joe Talbott NEPA Coordinator Review: NEPA 

Dennis Thurston Geophysicist Analysis: archaeological 

Poojan B Tripathi Environmental Protection 

Specialist Review: vegetation and wetlands 

Sally Valdes Fisheries Biologist/Ecologist Review: lower-trophic organisms, fish, Essential Fish 

Habitat, terrestrial mammals 

James R Woehr Avian Biologist Review: marine and coastal birds 

Eric Wolvovsky Meteorologist Review; air quality 

Sharon Warren Program Analysis Officer Project Manager, policy coordination, and administrative 

record 

Representatives from the 

NOAA, National Marine 

Fisheries Service and 

National Ocean Science 

offices 

 Review of the draft document of the Revised Draft SEIS 
BOEMRE Sale 193 Revised Draft SEIS 

306 Literature Cited

Literature Cited 

ACIA. 2004. Impacts of a Warming Arctic: Arctic Climate Impact Assessment. Cambridge, UK: Cambridge 

University Press. 

ACIA. 2005. Arctic Climate Impact Assessment. Cambridge, UK: Cambridge University Press. Available at 

http://www.acia.uaf.edu/. 

Adcroft, Alistair, Hallberg, Robert, Dunne, John P., Samuels, Bonita L., Galt, J. A., Barker, Christopher H., and 

Payton, Debra. 2010. Simulations of underwater plumes of dissolved oil in the Gulf of Mexico. 

Geophys. Res. Lett. 37:18L18605. 

ADEC. 2011. Alaska’s Final 2010 Integrated Water Quality Monitoring and Assessment Report, July 15, 2010. 

State of Alaska Department of Environmental Conservation. Available at http://www.dec.state.ak.us/ 

water/. Accessed on April 8, 2011. 

ADEC. 2002. Sensitivity of Coastal Environments and Wildlife to Spilled Oil: Northwest Arctic Alaska. In: 

Northwest Arctic Subarea Plan. State of Alaska, Dept. of Environmental Conservation, Div. of Spill 

Prevention and Response. Available at http://dec.alaska.gov/spar/perp/plans/scp_nw.htm, and 

http://www.asgdc.state.ak.us/maps/cplans/subareas.html 

ADEC. 2005. Sensitivity of Coastal Environments and Wildlife to Spilled Oil: North Slope Alaska. In: North 

Slope Subarea Plan. State of Alaska, Dept. of Environmental Conservation, Div. of Spill Prevention 

and Response. http://dec.alaska.gov/spar/perp/plans/scp_ns.htm and http://www.asgdc.state.ak.us/ 

maps/cplans/subareas.html. 

ADEC. 2010. State Air Quality Control Program: Appendix III.K.3, Overview of Alaska and Air Quality 

(public review draft, October 7). Alaska Department of Environmental Conservation (ADEC). 

ADFG. 1995. Community Profile Database. Update to Volume 5, Arctic Region. Alaska Department of Fish 

and Game (ADFG), Division of Subsistence, Juneau, Alaska. 

ADFG. 1995. Summary and Conclusions. Vol. VI. An Investigation of the Sociocultural Consequences of Outer 

Continental Shelf Development in Alaska. OCS Study, MMS 95-0015. Technical Report No. 160 Vol. 

VI Summary and Conclusions. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

ADFG. 2009. ADF&G Reports Increase in Teshekpuk and Central and Arctic Caribou Herds. Press Release. 

Alaska Department of Fish and Game. Juneau, Alaska. Available at http://www.adfg.state.ak.us/news/ 

2009/4-13-09_nr.php (accessed on 31 Jan 2011). 

ADFG. 2010. Draft Final Report Satellite Tracking of Western Arctic Bowhead Whales. Alaska Dept. of Fish 

and Game, Juneau, AK for BOEMRE, MMS 01-05-CT39268, Anchorage AK. 63pp. 

ADFG. 2011. Anadromous Waters Catalog. Alaska Department of Fish and Game. Available at 

http://www.adfg.alaska.gov/sf/SARR/AWC/index.cfm?ADFG=main.overview. Accessed on April 4, 

2011. 

AECOM, Inc. 2009. Wainwright Near-term Ambient Air Quality Monitoring Program, First Quarter Data 

Report: November 2008 – January 2009. Document No.: 01865-104-3210. March, 2009. Prepared for: 

ConocoPhillips Alaska Inc.Wainwright AK. 

Ahmed, T., 2010, Reservoir Engineering Handbook: Fourth Edition, Elsevier, Gulf Professional Printing, 

Burlington MA and Kidlington, UK, 1,454 pp. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 307 

Ahrens, C. D. 2009. Meteorology Today: An Introduction to Weather, Climate, and the Environment. Ninth ed. 

Belmont, California: Brooks/Cole. 

Alaska Consultants, Inc., C.S. Courtnage, and S.R. Braund and Assocs. 1984. Barrow Arch Socioeconomic and 

Sociocultural Description. Technical Report 101. Anchorage, AK: USDOI, MMS, Alaska OCS 

Region, 641 pp. 

Alaska Regional Response Team. 1997. Cook Inlet Subarea Contingency Plan. Available at 

http://www.akrrt.org/CCI plan CItoc.shtml, 66 pp. 

Alaska Regional Response Team. 2000. Subarea Contingency Plans. Available at http://www.akrrt.org/ 

history.shtml. 

Alaska Shorebird Working Group. 2004. Alaska Shorebird Conservation Plan, 2nd ed., B.J. McCaffery and 

R.E. Gill, Coords. Anchorage, AK: ASWG, 68 pp. 

Allen, B. M., and R. P. Angliss. 2010. Alaska Marine Mammal Stock Assessments, 2009. U.S. Department 

of Commerce, NOAA Technical Memorandum NMFS-AFSC-206. 276 pp. 

Allen, B. M., and R. P. Angliss. 2011. Draft Alaska Marine Mammal Stock Assessments, 2010. U.S. 

Department of Commerce, NOAA Technical Memorandum NMFS-AFSC. 247 pp. 

AMAP. 2002. AMAP Assessment 2002: Persistent Organic Pollutants in the Arctic. Oslo, Norway: Arctic 

Monitoring and Assessment Programme; 2004. 309 pp. 

AMAP. 1997. Arctic Pollution Issues: A State of the Arctic Environment Report. Oslo, Norway: 1997. Arctic 

Monitoring and Assessment Programme. 188 pp. 

Amstrup, S. C., C. Gardner, K. C. Myers and F. W. Oehme. 1989. Ethylene glycol (antifreeze) poisoning in a 

free-ranging polar bear. Veterinary and Human Toxicology. 31:317-319. 

Amstrup, S.C., G.M. Durner, T.L. McDonald, and W. R. Johnson. 2006. Estimating potential effect of 

hypothetical oil spills on polar bears. USGS report final report for MMS, March 2006. Anchorage, 

AK: USGS, Alaska Science Center. 56 pp. 

Amstrup, S.C. 1995. Movements, Distribution, and Population Dynamics of Polar Bears in the Beaufort Sea. 

Ph.D Dissertation. Fairbanks, AK: University of Alaska, 299 pp. 

Amstrup, S.C. and C. Garner. 1994. Polar Bear Maternity Denning in the Beaufort Sea. Journal Wildlife 

Management 581:110. 

Amstrup, S.C. and D.P. DeMaster. 1988. Polar Bear. In: Selected Marine Mammals of Alaska: Species 

Accounts with Research and Management Recommendations, J.W. Lentfer, ed. Washington, DC: 

Marine Mammal Commission, pp. 39-56. 

Amstrup, S.C., G.M. Durner, I. Stirling, and T.L. McDonald. 2005. Allocating Harvest among Polar Bear 

Stocks in the Beaufort Sea. Arctic 58:247-259. 

Anderson, C.M. 2008. Email dated July 10, 2008: from Cheryl Anderson, USDOI, MMS, Herndon to Caryn 

Smith, USDOI, MMS, Alaska OCS Region. Subject: spill information. 

Anderson, Magnus and Jon Aars. 2008. Short-term behavioral response of polar bears (Ursus maritimus) to 

snowmobile disturbance. Polar Biology, 31:501-507. 
BOEMRE Sale 193 Revised Draft SEIS 

308 Literature Cited

Angerbjorn, A., B. Arvidson, E. Noren, and L. Strompren. 1991. The Effect of Winter Food on Reproduction in 

the Arctic Fox, Alopex lagopus: A Field Experiment. Journal of Animal Ecology 60:705-714. 

Angliss, R.P. and A.L. Lodge. 2002. Alaska Marine Mammal Stock Assessments, 2002. Final report. Seattle, 

WA: USDOC, NMFS, 193 pp. 

Angliss, R.P. and A.L. Lodge. 2003. Final 2003 Alaska Marine Mammal Stock Assessment. Juneau, AK: 

USDOC, NOAA, NMFS. 

Angliss, R.P. and R. Outlaw, eds. 2005. Draft Alaska Marine Mammal Stock Assessments 2005. Report SCCAMLR-XXIV. Seattle, WA: National Marine Mammal Lab., Alaska Fisheries Science Center. 

Angliss, R.P., and B.M Allen. 2009. Alaska Marine Mammal Stock Assessments, 2008. U.S. Dep. Commer., 

NOAA Tech. Memo. NMFS-AFSC-193, 258 p. Available at http://www.afsc.noaa.gov/ 

techmemos/nmfs-afsc-193.htm. 

Angliss, R.P., and R.B. Outlaw. 2007. Alaska Marine Mammal Stock Assessments, 2006. U.S. Dep. Commer., 

NOAA Tech. Memo. NMFS-AFSC-168, 244 pp. http://www.afsc.noaa.gov/techmemos/nmfs-afsc168.htm. 

Angliss, R.P., and R.B. Outlaw. 2008. Alaska Marine Mammal Stock Assessments, 2007. U.S. Dep. Commer., 

NOAA Tech. Memo. NMFS-AFSC-180, 252 pp. http://www.afsc.noaa.gov/techmemos/nmfs-afsc180.htm. 

Angliss, R.P., D.P. DeMaster, and A.L. Lopez. 2001. Alaska Marine Mammal Stock Assessments, 2001. 

Seattle, WA: USDOC, NOAA, NMFS, and AFSC. 203 pp. 

ARRT. 2010. The Alaska Federal and State Preparedness Plan for Response to Oil and Hazardous Substance 

Discharges and Releases, Alaska Regional Response Team., updated Jan 2010. http://dec.alaska.gov/ 

spar/perp/plans/uc.htm. 

Ashjian, C. J., S. R. Braund, R. G. Campbell, J. C. George, J, Kruse, W. Maslowski, S. E. Moore, C. R. 

Nicolson, S. R. Okkonen, B. F. Sherr, and Y. H. Spitz. 2010. Climate Variability, Oceanography, 

Bowhead Whale Distribution, and Inupiat Subsistence Whaling Near Barrow, Alaska. Arctic 63(2): 

179-194. 

Assai, M., S. Siddiqi, and S. Watts. 2006. Tackling Social Determinants of Health through Community-Based 

Initiatives. British Medical Journal 333:854-856. Downloaded from BMJ on 1/3/2007. 

Atlas, R. M.; P.D. Boehm, and J.A. Calder. 1981. Chemical and Biological Weathering of Oil, from the Amoco 

Cadiz Spillage, within the Littoral Zone. Estuarine, Coastal and Shelf Science 12589-608. 

Atlas, R. M.; A. Horowitz, and M. Busdosh. 1978. Prudhoe Crude Oil in Arctic Marine Ice, Water, Degradation 

and Interactions with Microbial and Benthic Communities. Journal of Fisheries Resource Board of 

Canada 35(5)585-590. 

Babaluk, J.A., J.D. Reist, J.D. Johnson, and L. Johnson. 2000. First Records of Sockeye Salmon (Oncorhynchus 

nerka) and Pink Salmon (O. gorbuscha) from Banks Island and Other Records of Pacific Salmon in 

Northwest Territories, Canada. Arctic 532:161-164. 

Bailey, A.M. 1948. Birds of Arctic Alaska. Popular Series No. 8. Denver, CO: Colorado Museum of Natural 

History, 317 pp. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 309 

Banks, A. N., W. G. Sanderson, B. Hughes, P. A. Cranswick, L. E. Smith, S. Whitehead, A. J. Musgrove, B. 

Haycock, and N. P. Fairney. 2008. The sea empress oil spill (Wales, UK): Effects on common scoter 

Melanitta nigra in Carmarthen bay and status ten years later. Marine Pollution Bulletin 56 (5) (5): 895-

902. 

Barber, W.E., R.L. Smith, and T.J. Weingartner. 1994. Fisheries Oceanography of the Northeast Chukchi Sea. 

Final Report. OCS Study MMS 93-0051. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

Barron, M. G. 2007. Sediment-associated phototoxicity to aquatic organisms. Human and Ecological Risk 

Assessment: An International Journal 13 (2): 317-21. 

Barron MG, MG Carls, R Heintz, and SD Rice. 2004. Evaluation of fish early life stage toxicity models of 

chronic embryonic exposures to complex polycyclic aromatic hydrocarbon mixtures. Toxicological 

Sciences 78: 60-67. 

Barron, M. G., M. G. Carls, J. W. Short, S. D. Rice, R. A. Heintz, M. Rau, and R. D. Giulio. 2005. Assessment 

of the phototoxicity of weathered alaska north slope crude oil to juvenile pink salmon. Chemosphere 

60 (1): 105-10. 

Barron, M. G., V. Vivian, S.H. Yee, and S.A. Diamond. 2008. Temporal and Sparial Variation in Solar 

Radiation and Photo-Enhanced Toxicity Risks of Spilled Oil in Prince William Sound, Alaska, USA. 

Environmental Toxicology and Chemistry pp. 727-736. 

Barry, T.W. 1968. Observations on Natural Mortality and Native Use of Eider Ducks along the Beaufort Sea 

Coast. Canadian Field-Naturalist 82:140-144. 

Barsdate, R. J., M. C. Miller, V. Alexander, J. R. Vestal, and J. E. Hobbie, 1980. Oil Spill Effects. Limnology 

of Tundra Ponds, Hobbie, J. Stroudberg, PA: Dowden, Hutchinson and Ross, pp. 388-406. 

Belchansky, G.I., D.C. Douglas, and N.G. Platonov. 2004. Duration of the Arctic Sea Ice Melt Season: 

Regional and Interannual Variability, 1979-2001. Journal of Climate 17:67-80. 

Belkin, I. M., P. C. Cornillon, and K. Sherman. 2009. Fronts in large marine ecosystems. Progress in 

Oceanography 81(1-4) (6): 223-36. 

Bellas, J. and P. Thor. 2007. Effects of selected PAHs on reproduction and survival of the calanoid copepod 

Acartia tonsa. DOI: 10.1007/s10646-007-0152-2. Ecotoxicology 16(6): 465-474. 

Belore, R. 2003. Large Wave Tank Dispersant Effectiveness Testing in Cold Water. Proceedings of the 2003 

International Oil Spill Conference, pp. 381-385. Washington, D.C: American Petroleum Institute. 

Available at http://www.boemre.gov/tarprojectcategories/ArcticOilSpillResponseResearch.htm. 

Belore, R. C., McHale, J., and Chapple, T. 1998. Oil Deposition Modelling for Surface Oil Well Blowouts. 

Proceedings of the Arctic Oilspill Program Technical Seminar, Ottawa, Ontario, Canada: Environment 

Canada. 

Bence, A.E. and W.A. Burns. 1995. Fingerprinting Hydrocarbons in the Biological Resources of the Exxon 

Valdez spill area. pp. 84-140. In: P.G. Wells, J.N. Butler and J.S. Hughes (eds.), Exxon Valdez oil 

spill: fate and effects in Alaskan waters, ASTM STP 1219. Philadelphia, PA: American Society for 

Testing and Materials,. 965 pp. 

Bengtson, J.L., L.M. Hiruki-Raring, M.A. Simpkins, and P.L. Boveng. 2005. Ringed and Bearded Seal 

Densities in the Eastern Chukchi Sea, 1999-2000. Polar Biology 28:833-845. 
BOEMRE Sale 193 Revised Draft SEIS 

310 Literature Cited

Benoit, D. , Y. Simard, J. Gagne, M. Geoffroy and L. Fortier. 2010. From polar night to midnight sun: 

photoperiod, seal predation and the diel vertical migrations of polar cod (Boreogadus saida) under 

landfast ice in the Arctic Ocean. Polar Biology 33: 1505-1520. 

Bent, A. C. 1987. Life Histories of North American waterfowl. New York, NY: Dover Publications, Inc. 

Bercha Group Inc. 2006. Alternative Oil Spill Occurrence Estimators and their Variability for the Chukchi Sea 

- Fault Tree Method. OCS Study MMS 2006-033. Anchorage, AK USDOI, MMS, Alaska OCS 

Region, unpaginated. 

Berchok, C., K. Stafford, D.K. Mellinger, S. Moore, J.C. George, and F. Brower. 2009. Passive acoustic 

monitoring in the western Beaufort Sea. 2009 Annual Report, Anchorage, AK: USDOI, MMS. 63 pp. 

Betts, R.C., C.B. Wooley, C.M. Mobley, J.D. Haggarty, and A. Crowell. 1991. Site Protection and Oil Spill 

Treatment at SEL-188, an Archaeological Site in Kenai Fjords National Park, Alaska. Anchorage, AK: 

Exxon Company, U.S.A, 79 pp. plus bibliography. 

Bice, K., Eil, A., Habib, B., Heijmans, P., Kopp, R., Nogues, J., Norcross, F., Sweitzer-Hamilton, M., & 

Whitworth, A. 2009. Black Carbon: A Review and Policy Recommendations. 80p. Princeton, NJ: 

Woodrow Wilson School of Public and International Affairs, Princeton University. Available at 

http://www.wws.princeton.edu/research/PWReports/F08/wws591e.pdf. 

Birtwell, I.K., and C.D. McAllister. 2002. Hydrocarbons and Their Effects on Aquatic Organisms in Relation to 

Offshore Oil and Gas Exploration and Oil Well Blowout Scenarios in British Columbia, 1985. Can. 

Tech. Rep. Fish. Aquat. Sci. 2391: 52pp. 

Bittner, J.E. 1993. Cultural Resources and the Exxon Valdez Oil Spill. In: Exxon Valdez Oil Spill Symposium, 

Program and Abstracts, B.Spies, L.J. Evans, B. Wright, M. Leonard, and C. Holba, eds. and comps., 

Anchorage, Ak., Feb. 2-5, 1992. Anchorage, AK: Exxon Valdez Oil Spill Trustee Council; UAA, 

University of Alaska Sea Grant College Program; and American Fisheries Society, Alaska Chapter, pp. 

13-15. 

Blanchard, A.L., H. Nichols, and C. Parris. 2010. 2008 Environmental Studies Program in the Chukchi Sea: 

Benthic Ecology of the Burger and Klondike Survey Areas. Annual report prepared for ConocoPhillips 

Alaska, Inc. and Shell Exploration & Production Company, Anchorage, Alaska. 72 pp. Institute of 

Marine Science, University of Alaska Fairbanks. Fairbanks, AK. 

Blanchard, A.L., C. Parris, and H. Nichols. 2010. 2009 Environmental Studies Program in the Chukchi Sea: 

Benthic Ecology of the Burger and Klondike Survey Areas. Annual report prepared for ConocoPhillips 

Alaska, Inc. and Shell Exploration & Production Company, Anchorage, Alaska. 94 pp. Institute of 

Marine Science, University of Alaska Fairbanks. Fairbanks, AK. 

Blees, M.K., K.G. Hartin, D.S. Ireland, and D. Hannay. (eds) 2010. Marine Mammal Monitoring and Mitigation 

During Open Water Seismic Exploration by Statoil USA E&P Inc. in the Chukchi Sea, AugustOctober 2010: 90-day Report. LGL Report P1119. Rep. from LGL Alaska Research Associates Inc., 

LGL Ltd., and JASCO Research Ltd. for Statoil USA E&P Inc., National Marine Fisheries Service, 

and U.S. Fish and Wildlife Service. 102 pp. + appendices. Anchorage, AK: USDOI, FWS. Available at 

http://www.nmfs.noaa.gov/pr/pdfs/permits/2010_statoil_90day_report.pdf. 

Bluhm, B.A. and R. Gradinger. 2008. Regional Variability in Food Availability for Arctic Marine Mammals. 

Ecological Applications 18(2):S77-S96. 

Bluhm, B. A., K. Iken, and R. Hopcroft. 2010. Observations and exploration of the Arctic's Canada basin and 

the Chukchi sea: The hidden ocean and RUSALCA expeditions. Deep Sea Research Part II: Topical 

Studies in Oceanography 57(1-2) (1): 1-4. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 311 

Bluhm, B. A., K. Iken, S. Mincks Hardyl, B. I. Sirenko, and B. A. Holladay. 2009. Community structure of 

epibenthic megafauna in the Chukchi Sea. DOI:10.3354/ab00198. Aquat. Biol. 7, 269-293. 

Bobra, A.M., W.Y. Shiu, D. Mackay, and R.H. Goodman. 1989. Acute toxicity of dispersed fresh and 

weathered crude oil and dispersants to Daphnia magna. doi:10.1016/0045-6535(89)90068-4. 

Chemosphere Volume 19(8–9): 1199-1222. 

Boehm, P. D. and Fiest, D. L. 1982. Subsurface Distributions of Petroleum from an Offshore Well Blowout. 

The Ixtoc I Blowout, Bay of Campeche. Environmental Science and Technology 162: 67-74. 

Boehm, P. D., D. L. Fiest, K. Hausknecht, J. Barbash, and G. Perry, 1982. Investigation of the Transport and 

Fate of Petroleum Hydrocarbons from the IXTOC-I Blowout in the Bay of Campeche--Sampling and 

Analytical Procedures. In: Energy and Environmental Chemistry, Keith, L. H.I. Ann Arbor, MI.: 

Ann Arbor Science, pp. 129–159. 

 Boertmann, D., A. Mosbech and P.Johansen. 1998. A review of biological resources in West Greenland 

sensitive to oil spills during winter. NERI Technical Report No. 246. Copenhagen, Denmark: Ministry 

of Environment and Energy, National Environmental Research Institute, Department of Arctic 

Environment. pp. 51-69. http://www2.dmu.dk/1_viden/2_publikationer/3_fagrapporter/ 

rapporter/FR246.pdf. 

Bonatto, S.L. and F.M. Salzano, 1997. A Single and Early Migration for the Peopling of the Americas 

Supported by Mitochondrial DNA Sequence Data. Proceedings of the National Academy of Sciences 

94: 1866–1871. 

Booth, J.A. 1984. The Epontic Algal Community of the Ice Edge Zone and Its Significance to the Davis Strait 

Ecosystem. Arctic Vol. 37, (3) 234-243. 

Booz, Allen and Hamilton, 1983, Evaluation of Alternatives for Transportation and Utilization of Alaska North 

Slope Gas, Summary Report. Prepared for the Alaska Task Force on Alternative Uses of North Slope 

Natural Gas, April 1983. Bethesda, MD: Booz, Allen & Hamilton Inc. 

Born, E.W, F.R. Riget, R. Dietz, D. Adriashek. 1999. Escape Responses of Hauled Out Ringed Seals (Phoca 

hispida) to Aircraft Disturbance. Polar Biology 21: 171-178. 

Boveng, P. L., J. L. Bengtson, T. W. Buckley, M. F. Cameron, S. P. Dahle, B. A. Megrey, J. E. Overland, and 

N. J. Williamson. 2008. Status review of the ribbon seal (Histriophoca fasciata). U.S. Dep. Commer., 

NOAA Tech. Memo. NMFS-AFSC-191, 115 pp. 

Boveng, P. L., J. L. Bengtson, T. W. Buckley, M. F. Cameron, S. P. Dahle, B. P. Kelly, B. A. Megrey, J. E. 

Overland, and N. J. Williamson. 2009. Status review of the spotted seal (Phoca largha). U.S. Dep. 

Commer., NOAA Tech. Memo. NMFS-AFSC-200, 153 pp. 

Burns, J.J., and S.J. Harbo, Jr. 1972. An aerial census of ringed seals, northern coast of Alaska. Arctic 

25(4):279-290. 

Brackney, A.W. and R.M. Platte. 1986. Habitat Use and Behavior of Molting Oldsquaw on the Coast of the 

Arctic National Wildlife Refuge, 1985. In: 1985 Update Report Baseline Study of the Fish, Wildlife, 

and their Habitats. Anchorage, AK: USDOI, FWS. 

Braddock. J. F., K. A. Gannon, and B. T. Rasley. 2004. Petroleum Hydrocarbon-Degrading Microbial 

Communities in Beaufort-Chukchi Sea Sediments,. OCS Study MMS 2004-061. Fairbanks, AK: 

University of Alaska Fairbanks, CMI and USDOI, MMS, Alaska OCS Region. 
BOEMRE Sale 193 Revised Draft SEIS 

312 Literature Cited

Braddock, J. F., J.E. Lindstrom, and R.C. Price. 2003. Weathering of a subarctic oil spill over 25 years: the 

Caribou-Poker Creeks Research Watershed experiment. Cold Regions Science and Technology, 

Volume 36 (1-3), 11-23. 

Braddock, J. F., J.E. Lindstrom, and R.C. Price. 2003. Weathering of a subarctic oil spill over 25 years: the 

Caribou-Poker Creeks Research Watershed experiment. Cold Regions Science and Technology 36 (1-

3): 11-23. 

Bradstreet, M.S.W. 1982. Occurrence, habitat use, and behavior of sea birds, marine mammals and arctic cod at 

the Pond Inlet ice edge. Arctic 35(1): 28-40. 

Bradstreet, M.S.W., and W.E. Cross. 1982. Trophic relationships at high Arctic ice edges. Arctic 35(1): 1-12. 

Bradstreet, M.S.W., K.J. Finley, A.D. Sekerak, W.B. Griffiths, C.R. Evans, M.F. Fabijan, and H.E. Stallard. 

1986. Aspects of the biology of Arctic cod (Boreogadus saida) and its importance in the arctic marine 

food chains. Can. Tech. Rep. Fish. Aquat. Sci. 1491: viii+193 pp. 

Braham, H.W. 1984. Distribution and Migration of Gray Whales in Alaska. In: The Gray Whale Eschrichtius 

robustus, M.L. Jones, S.L. Swartz, and S. Leatherwood, eds. Orlando, FL: Academic Press, 600 pp. 

Braham, H.W. and M.E. Dahlhiem. 1982. Killer Whales in Alaska Documented in the Platforms of 

Opportunity Program. Reports of the International Whaling Commission No. 32. Cambridge, UK: 

IWC, pp. 643-645. 

Braham, H.W., B.D. Krogman and G.M. Carroll. 1984. Bowhead and white whale migration, distribution, and 

abundance in the Bering, Chukchi, and Beaufort seas, 1975-78. NOAA Tech. Rep. NMFS SSRF-778. 

Washington, DC: USDOC, NOAA, NMFS. 39 p. Available at http://aquaticcommons.org/2054/, 

accessed 29 April 2011. 

Braithwaite, L. F. 1983. The effects of oil on the feeding mechanism of the bowhead whale. Anchorage, AK: 

USDOI, BLM and MMS, Alaska OCS Region, 45 pp. 

Brandvik, P., and L. Faksness. 2009. Weathering processes in Arctic oil spills: Meso-scale experiments with 

different ice conditions. Cold Regions Science and Technology 55(1) (1): 160-6. 

Brandvik, P.J., J.L. Myrhaug Resby, P. Daling, F. Lervik, and J. Fritt-Rasmussen. 2010. Meso-scale Weathering 

of Oil as a Function of Ice Conditions. Oil Properties, Dispersibility and In Situ Burnability of 

Weathered Oil as a Function of Time. SINTEF A15563. Trondheim, Norway: SINTEF. 

Bratton, G. R., C.B. Spainhour, W. Flory, M. Reed, and K. Jayko., 1993. Presence and Potential Effects of 

Contaminants. In: The Bowhead Whale, J.J. Burns, J. J. Montague and C. J. Cowles, eds. Special 

Publication of The Society for Marine Mammalogy, 2. Lawrence, KS: The Society for Marine 

Mammalogy, 701-744. 

Braund, S.R. and D.C. Burnham. 1984. Subsistence Economics and Marine Resource Use Patterns. In: The 

Barrow Arch Environment and Possible Consequences of Planned Offshore Oil and Gas Development. 

Proceedings of a Synthesis Meeting, J.C. Truett, ed. Girdwood, AK. Oct. 30-Nov. 1, 1984. 

Anchorage, AK: USDOI, MMS, Alaska OCS Region and USDOC, NOAA, OCSEAP. 

Brewer, K.D., M.L. Gallagher, P.R. Regos, P.E. Isert, and J.D. Hall. 1993. Kuvlum #1 Exploration Project Site 

Specific Monitoring Program: final report. Prepared for: ARCO Alaska Inc. 80 pp. Walnut Creek, CA: 

Coastal & Offshore Pacific Corporation. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 313 

British Petroleum. 2010. Statistical Review of World Energy. Historical Data workbook Oil Production – 

barrels (from 1965). Available at http://www.bp.com/productlanding.do?categoryId= 

6929&contentId=704462. 

Brodersen, C.. 1987. Rapid narcosis and delayed mortality in larvae of king crabs and kelp shrimp exposed to 

the water-soluble fraction of crude oil. Marine Environmental Research 22(3): 233-9. 

Brower, T.P. 1980. Qiniqtuagaksrat Utuqqanaat Inuuniagninisiqun: The Traditional Land Use Inventory for the 

Mid-Beaufort Sea. Vol. I. Barrow, AK. North Slope Borough. Commission on History and Culture. 

Brower, W.A., Jr., R.G. Baldwin, Jr., C.N. Williams, J.L. Wise, and L.D. Leslie. 1988. Climatic Atlas of the 

Outer Continental Shelf Waters and Coastal Regions of Alaska, Vol. I, Gulf of Alaska. Document ID: 

NAVAIR 50-1C-551; MMS 870011. Asheville, NC and Anchorage, AK: USDOD, NOCD; USDOI, 

MMS, Alaska OCS Region; and USDOC, NOAA, NOS, 530 pp. 

Brueggerman, J. 2009. 90-day report of the marine mammal monitoring program for the Conocphillips Alaska 

shallow hazards survey operqtions during the 2008 open water season in the Chukchi Sea. Canyon 

Creek Consulting LLC, 1147 21st Ave E, Seattle WA.;Prepared for ConocoPhillips Alaska, Inc. 42 pp. 

Brueggeman, J. 2010. Marine mammal surveys at the Klondike and Burger survey areas in the Chukchi Sea 

during the 2009 open water season. Seattle, WA. Canyon Creek Consulting LLC. 54 pp. 

Brueggeman, J. J., D. P. Volsen, R. A. Grotefendt, G. A. Green, J. J. Burns, and D. K. Ljungblad. 1991. 1990 

walrus monitoring program: the popcorn, burger, and crackerjack prospects in the Chukchi Sea. Report 

from EBASCO Environmental, Bellevue, WA, for Shell Western E&P Inc. and Chevron USA Inc. 

Houston, TX. Shell Western E&P Inc. 53 pp. 

Brueggeman, J. J., R.A. Grotefendt, M.A. Smultea, G.A. Green, R.A. Rowlett, C.C. Swanson, D.P. Volsen, 

C.E. Bowlby, C.I. Malme, R. Mlawski, and J.J. Burns. 1992. 1991 Marine Mammal Monitoring 

Program, Walruses and Polar Bears, Crackerjack and Diamond Prospects, Chukchi Sea. Shell Western 

E&P Inc. and Chevron USA, Inc. 109 pp plus appendices. 

Brueggeman, J., B. Watts, K. Lomac-Macnair, S. McFarland, P. Seiser, and A. Cyr. 2010. Marine Mammal 

Surveys at the Klondike and Burger Survey Areas in the Chukchi Sea during the 2009 Open Water 

Season (Draft). Report by Canyon Creek Consulting, LLC., Seattle, WA; for ConocoPhillips, Inc., 

Shell Exploration and Production Company, and Statoil USA E&P Inc., Anchorage AK: Shell 

Exploration and Production.55pp. Available at http://www-static.shell.com/static/usa/downloads/ 

2010/alaska/studies_canyon_creek_ch2_2009.pdf. 

Brueggeman, J., B. Watts, M. Wahl, P. Seiser, and A. Cyr. 2009. Marine Mammal Surveys at the Klondike and 

Burger Survey Areas in the Chukchi Sea during the 2008 Open Water Season. Report by Canyon 

Creek Consulting, LLC., Seattle, WA; for ConocoPhillips, Inc., Shell Exploration and Production 

Company, Anchorage AK: Shell Exploration and Production. 45pp. Available at 

http://www.alaska.boemre.gov/ref/ProjectHistory/2009_Chukchi_CPAI/2009_0900_mmsurvey.pdf. 

Brueggeman, J.J., A. Cyr, S. McFarland, I.M. Laursen, and K. Lomak-McNair. 2009. 90-Day Report of the 

Marine Mammal Monitoring Program for the ConocoPhillips Alaska Shallow Hazards Survey 

Operations during the 2008 Open Water Season in the Chukchi Sea. ConocoPhillips Alaska, Inc. 

Houston, TX: Shell Western E&P, Inc.49 pp. 

Brueggeman, J.J., D.P. Volsen, R.A. Grotefendt, G.A. Green, J.J. Burns, and D.K. Ljungblad. 1991. 1990 

Walrus Monitoring Program/The Popcorn, Burger and Crackerjack Prospects in the Chukchi Sea. 

Houston, TX: Shell Western E&P, Inc. 
BOEMRE Sale 193 Revised Draft SEIS 

314 Literature Cited

Brueggeman, J.J., G.A. Green, R.A. Grotefendt, M.A. Smultea, D.P. Volsen, R.A. Rowlett, C.C. Swanson, C.I. 

Malme, R. Mlawski, and J.J. Burns. 1992. Marine Mammal Monitoring Porgram (Seals and Whales) 

Crackerjack and Diamond Prospects Chukchi Sea. Rep. from EBASCO Environmental, Bellevue, WA, 

for Shell Western E&P Inc. and Chevron U.S.A. Inc. Houston, TX: Shell Western E&P, Inc. 62. pp. + 

App. 

Brusca, R. C., and G. J. Brusca. 2003. Invertebrates. Sunderland, MA: Sinauer Associates Incorporated. 

Burek, K.A., F. Gulland, and T.M. O’Hara. 2008. Effects of Climate Change on Arctic Marine Mammal Health. 

Ecological Applications 18(2) Supplement: S126-S134. 

Burger, A.E. and D.M. Fry. 1993. Effects of Oil Pollution on Seabirds in the Northeast Pacific. In: The Status, 

Ecology and Conservation of Marine Birds of the North Pacific, K. Vermeer, K.T. Briggs, K.H. 

Morgan, and D. Siegel-Causey, eds. CW66-124-1993E. Ottawa, Ont., Canada: Canadian Wildlife 

Service, pp. 254-263. 

Burgess R.M., R. Rose, P.W. Banyas, and B.E. Lawhead. 1993. Arctic Fox Studies in the Prudhoe Bay Unit 

and Adjacent Undeveloped Areas, 1992. Northern Alaska Research Studies. Anchorage, AK: BPXA, 

16 pp. 

Burgess, R.M. 2000. Arctic Fox. Chapter 8. In: The Natural History of an Arctic Oil Field Development and 

the Biota, J.C. Truett and S.R. Johnson, eds. San Diego, CA: Academic Press, Harcourt Science and 

Technology, pp. 159-178. 

Burgess, R.M. and P.W. Banyas. 1993. Inventory of Arctic Fox Dens in the Prudhoe Bay Region, 1992. 

Northern Alaska Research Studies. Anchorage, AK: BPXA, p. 89. 

Burgess, W.C. and C.R. Greene, Jr. 1999. Physical Acoustic Measurements. In: Marine Mammal and 

Acoustical Monitoring of Western Geophysical’s Open-Water Seismic Program in the Alaskan 

Beaufort Sea, 1998, LGL and Greeneridge, eds. LGL Report TA 2230-3. King City, Ont., Canada: 

LGL Ecological Reserarch Associates, Inc. 109 pp. 

Burns, J.J. 1981. Ribbon Seal-Phoca fasciata. In: Handbook of Marine Mammals, S.H. Ridgway and R.J. 

Harrison, eds. Vol. 2 Seals. New York: Academic Press, pp. 89-109. 

Burns, J.J., L.H. Shapiro, and F.H. Fay. 1981. Ice as Marine Mammal Habitat in the Bering Sea. In: The Eastern 

Bering Sea Shelf: Oceanography and Resources, D.W. Hood and J.A. Calder, eds. Vol. II. Juneau, 

AK: USDOC, NOAA, OMPA, and USDOI, BLM, pp. 781-797. 

Butler, J.N., B.F. Norris, and T.D. Sleeter. 1976. The Fate of Petroleum in the Open Ocean. In: Proceedings of 

the Symposium: Sources, Effects, and Sinks of Hydrocarbons in the Aquatic Environment, 

Washington, D.C., Aug. 9-11, 1976. Arlington, VA: American Institute of Biological Sciences, pp. 

287-297. 

Calbet, A., E. Saiz and C. Barata. 2006. Lethal and sublethal effects of naphthalene and 1,2-

dimethylnaphthalene on the marine copepod Paracartia grani. DOI: 10.1007/s00227-006-0468-0. 

Marine Biology Volume 151(1): 195-204. 

Calef, G., E. DeBock, and G. Lortie. 1976. The Reaction of Barren-Ground Caribou to Aircraft. Arctic 

29:201-212. 

Callaway, D. 2007. A Changing Climate: Consequences for Subsistence Communities. Alaska Park Science, 

Spring 2007. Anchorage, AK: USDOI, National Park Service. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 315 

Cameron, M.F., B. Fadely, K.E.W. Shelden, M.A. Simpkins, and L. Hiruki-Raring. 2009. Marine mammals of 

the Alaska region, p. 267-281. In: Our Living Oceans. Report on the status of U.S. living marine 

resources, 6th edition. NOAA Tech. Memo. NMFS-F/SPO-80. Seattle, WA: USDOC, NOAA, NMFS. 

Cameron, M.F., J.L. Bengtson, P.L. Boveng, J.K. Jansen, B.P. Kelly, S.P. Dahle, E.A. Logerwell, J.E. 

Overland, C.L. Sabine, G.T. Waring, and J.M. Wilder. 2010. Status Review of the Bearded Seal 

(Erignathus barbatus). USDOC, NOAA Tech. Memo. NMFS-AFSC-211. Seattle, WA: USDOC, 

NOAA, NMFS, Alaska Fisheries Science Center. 246 pp. Available at http://www.afsc.noaa.gov/ 

publications/AFSC-TM/NOAA-TM-AFSC-211.pdf. 

Cameron, R.D., D.J. Reed, J.R. Dau, and W.T. Smith. 1992. Redistribution of Calving Caribou in Response to 

Oil Field Development on the Arctic Slope of Alaska. Arctic 45(4):338-342. 

Cameron, R.D., W.T. Smith, R.G. White, and B. Griffith. 2005. Central Arctic Caribou and Petroleum 

Development: Distributional, Nutritional, and Reproductive Implications. Arctic 58:1-9. 

Camilli, R., C. M. Reddy, D. R. Yoerger, B. A. S. Van Mooy, M. V. Jakuba, J. C. Kinsey, C. P. McIntyre, S. P. 

Sylva, and J. V. Maloney. 2010. Tracking hydrocarbon plume transport and biodegradation at 

Deepwater Horizon. Science 330: 201-204 doi:10.1126/science.1195223 

Carls, M.G., R.A. Heintz, G.D. Marty, and S.D. Rice. 2005.Cytochrome P4501A Indunction in Oil-Exposed 

Pink Salmon Oncorhynchus gorbuscha Embryos Predicts Reduced Survival Potential. Marine Ecology 

Progress. Series 30(1):253-265. 

Caron, L.M.J. and T.G. Smith. 1990. Philopatry and Site Tenacity of Belugas, Delphinapterus leucas, Hunted 

by the Inuit at the Nastapoka Estuary, Eastern Hudson Bay. Can. Bull. Fish. Aquat. Sci. 22(4):69-79. 

Caselle, J. E., Love, M. S., Fusaro, C., and Schroeder, D. 2002. Trash or habitat? Fish assemblages on offshore 

oilfield seafloor debris in the Santa Barbara Channel, California. ICES Journal of Marine Science, 59: 

S258–S265. 

Center for Biological Diversity. 2008. Petition to List Three Seal Species Under the Endangered Species Act: 

Ringed Seal (Pusa hispida), Bearded Seal (Erignathus barbatus), and Spotted Seal (Phoca largha). 

139 pp. San Francisco, CA: Center for Biological Diversity, 

Centers for Disease Control and Prevention (CDC). 2010. NIOSH Report of BP illness and injury data (April 23 

– June 6, 2010). Available at http://www.cdc.gov/niosh/topics/oilspillresponse/ 

pdfs/NIOSHRept-PInjuryandIllnessDataApril23-June6.pdf. 

Chang, Wonjae, Whyte, Lyle, and Ghoshal, Subhasis. 2011. Comparison of the effects of variable site 

temperatures and constant incubation temperatures on the biodegradation of petroleum hydrocarbons 

in pilot-scale experiments with field-aged contaminated soils from a cold regions site. Chemosphere 

826:872-878. 

Christiansen, J.S., L.I. Karamushko and J. Nahrgang. 2010. Sub-lethal levesl of waterborne petroleum may 

depress routine metabolism in polar cod (Boreogadus saida). Polar Biology 33:1049-1055. 

Christiansen, J.S. and S.G.George, 1995. Contamination of food by crude oil affects food selection and growth 

performance, but not appetite, in an Arctic fish, the polar cod (Boreogadus saida). Polar Biology 

15(4):277-281. DOI: 10.1007/BF00239848. 

Circumpolar Arctic Vegetation Mapping Team. 2003. Map No. 1. Conservation of Arctic Flora and Fauna. 

Anchorage, AK: USDOI, FWS. 
BOEMRE Sale 193 Revised Draft SEIS 

316 Literature Cited

Clarke, J.T. and M.C. Ferguson. 2010. Large whale aerial surveys in the northeastern Chukchi Sea, 2008-2009, 

with review of 1982-1991 data. Unpublished, presented to the IWC Scientific Committee, June 2010. 

Clarke, J.T., M.C. Ferguson, C.L. Christman, S.I. grassia, A.A. Brower, and L.J. Morse. 2011. Chukchi 

Offshore Monitoring in Drilling Area (COMIDA) Distributrion and Relative Abundance of Marine 

Mammals: Aerial Surveys. Final Report. OCS Study BOEMRE 2011-006. Seattle, WA: USDOC, 

NOAA, NMFS, National Marine Mammal Laboratory, Alaska Fisheries Center. 

Clarke, J.T., S.E. Moore and D.K. Ljungblad. 1989. Observations on gray whale (Eschrichtius robustus) 

utilization patterns in the northeastern Chukchi Sea, July-October 1982-1987. Can. J. Zool. 

7(11):2646-2654 

Clarke, J.T., S.E. Moore, and M.M. Johnson. 1993. Observations on Beluga Fall Migration in the Alaskan 

Beaufort Sea, 198287, and Northeastern Chukchi Sea, 198291. Report of the International Whaling 

Commission 43. Cambridge, UK: IWC, pp. 387-396. 

Clough, N.K., A.C. Christiansen, and P.C. Patton, eds. 1987. Arctic National Wildlife Refuge, Alaska, Coastal 

Plain Resource Assessment - Report and Recommendation to the Congress of the United States and 

Final Legislative Environmental Impact Statement. Washington D.C: USDOI. 

Cohen, M.J. 1993. The Economic Impacts of the Exxon Valdez Oil Spill on Southcentral Alaska's Commercial 

Fishing Industry. In: Exxon Valdez Oil Spill Symposium Abstract Book, B. Spies, L.J. Evans, B. 

Wright, M. Leonard, and C. Holba, eds. and comps. Anchorage, Ak., Feb. 2–5, 1992. Anchorage, AK. 

Exxon Valdez Oil Spill Trustee Council; University of Alaska Sea Grant College Program; and 

American Fisheries Society, Alaska Chapter, pp. 227-230. 

Collins, J., J.T.E. Gilbert, Jr., R. King, J.E. Moore, and S.L. Zwicker. 1983. Oil and Gas Activity: Interaction 

with the Physical Environment. In Technical Environmental Guidelines for Offshore Oil and Gas 

Development, J.T.E. Gilbert, Jr., ed. Tulsa, OK: PennWell Books. 

COMIDA. 2009. Chukchi offshore monitoring in drilling area (COMIDA) aerial survey 2009. Annual report. 

27 pp. 

COMIDA. 2010. BWASP-COMIDA observation summaries, 1 July – 15 October 2010 observation maps 

.Unpublished maps: COMIDA provided to BOEMRE, October 20, 2010. 6pp. 

Comiso, J.C. 2006. Arctic Warming Signals from Satellite Observations. Weather 51(3): 70-76. 

Committee on Understanding Oil Spill Dispersants. 2005. Oil spill dispersants; efficacy and effects. 

Washington, DC: National Research Council. 

Conlan, K. and R.G. Kvitek. 2005. Recolonization of Soft-Sediment Ice Scours on an Exposed Arctic Coast. 

Marine Ecology Progress Series 286:21-42. 

Cooke, W.W. 1906. Distribution and Migration of North American Ducks, Geese, and Swans. Biological 

Survey Bulletin No. 26. Washington, DC: USDA. 

Coombs, S. and C.B. Braun. 2003. Information Processing by the Lateral Line System. In: Sensory Processing 

in Aquatic Environments, S.P. Collins and N.J. Marshall, eds. New York, NY: Springer-Verlag New 

York. 

Costello, M., M. Elliott, and R. Thiel., 2002. In: Fishes in Estuaries, M. Elliott and K. Hemingway, eds. Oxford, 

UK: Blackwell Science. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 317 

Couillard CM, K Lee, B Legare, and TL King. 2005. Effect of dispersant on the composition of the wateraccommodated fraction of crude oil and its toxicity to larval marine fish. Environmental Toxicology & 

Chemistry 24(6):1496-1504. 

Council on Environmental Quality (CEQ). 2010. Report Regarding the Minerals Management Service’s 

National Environmental Policy Act Policies, Practices, and Procedures, as the Relate to Outer 

Continental Shelf Oil and Gas Exploration and Development. Available at 

http://www.whitehouse.gov/sites/default/files/microsites/ceq/20100816-ceq-mms-ocs-nepa.pdf 

Cowardin, L., V. Carter, F. Golet, and E. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of 

the United States. Washington, DC: USDOI, FWS, Office of Biological Services. 

Craft, B.C., and Hawkins, M.F., 1959, Applied Petroleum Reservoir Engineering: Prentice Hall, Englewood 

Cliffs, NJ, 437 pp. 

Craig, P. and L. Haldorson. 1986. Pacific salmon in the North American Arctic. Arctic 39(1): 2-7. 

Craig, P.C. 1984. Fish Use of Coastal Waters of the Alaskan Beaufort Sea: A Review. Transactions of the 

American Fisheries Society 113:265-282. 

Craig, P.C. 1989. An Introduction to Amphidromous Fishes in the Alaskan Arctic, D.W. Norton, ed. Biological 

Papers 24. Fairbanks, AK: University of Alaska, Fairbanks, Institute of Arctic Biology, pp. 27-54. 

Craig, P.C. and L. Halderson. 1986. Pacific Salmon in the North American Arctic. Arctic 391:2-7. 

Craig, P.C., W.B. Griffiths, L. Haldorson, and H. McElderry. 1982. Ecological studies of arctic cod 

(Boreogadus saida) in Beaufort Sea coastal waters, Alaska. Canadian Journal of Fisheries and Aquatic 

Science 39: 395-406. 

Craig, P.C., W.B. Griffiths, L. Haldorson, and H. McElderry. 1985. Distributional patterns of fishes in an 

Alaskan arctic lagoon. Polar Biology 4(1): 9-18 

Crawford, R.E. 2003. Forage fish habitat distribution near the Alaskan coastal shelf areas of the Beaufort and 

Chukchi seas. Final Report for Contract 09-10-03 for the PWS Oil Spill Recovery Institute. Cordova, 

AK: Prince William Sound Science Center, Oil Spill Recovery Institute. 97 pp. 

Crawford, R.E. and J.K. Jorgenson. 1993. Schooling behavior of arctic cod (Boreogadus saida) in relation to 

drifting pack ice. Environmental Biology of Fishes 36: 345-357 

Crawford, R.E. and J.K. Jorgenson. 1996 Quantitative studies of arctic cod (Boreogadus saida) schools: 

important energy stores in the arctic food web. Arctic 49(2): 181-193. 

Cronin M.A., H.A. Whitlaw, and W.B. Ballard. 2000. Northern Alaska Oil Fields and Caribou. Wildlife 

Society Bulletin 284:919-922. 

Cross, W.E. 1982. Under-ice biota at the Pond Inlet ice edge and in adjacent fast ice areas during spring. Arctic 

35(1): 13-27. 

Culbertson, J.B., Valiela, I., Pickart, M., Peacock, E.E., & Reddy, C.M. (2008). Long-term consequences of 

residual petroleum on salt marsh grass. Journal of Applied Ecology 45 (4): 1284–1292. 

Dahlheim, M. E. and T. R. Loughlin. 1990. Effects of the Exxon Valdez on the distribution and abundance of 

humpback whales in Prince William Sound, Southeast Alaska, and the Kodiak archipelago. In: Exxon 

Valdez oil spill natural resource damage assessment. Unpublished report. NRDA Marine Mammals 

Study No. 1. Seattle, WA:USDOC, NOAA. 
BOEMRE Sale 193 Revised Draft SEIS 

318 Literature Cited

Dahlheim, M. E. and Matkin, C. O 1994. Assessment of Injuries to Prince William Sound Killer Whales . In: 

Exxon Valdez Oil Spill Symposium Abstract Book, B. Spies, L. G. Evans M. Leonard B. Wright and 

C. Holba, eds. and comps. Anchorage, Ak, Anchorage, AK: Exxon Valdez Oil Spill Trustee 

Council; University of Alaska Sea Grant College Program; and American Fisheries Society, Alaska 

Chapter, pp. 308-310. 

Damm, E., U. Schauer, B. Rudels, and C. Haas. 2007. Excess of bottom-released methane in an Arctic shelf sea 

polynya in winter. Continental Shelf Research 27:1692-1701. 

Darigo, N., O.K. Mason, and P.M Bowers, 2007, Review of Geological/Geophysical Data and Core Analysis to 

Determine Archaeological Potential of Buried Landforms, Beaufort Sea Shelf, Alaska. OCS Study 

MMS 2007-004. Anchorage, AK: USDOI, MMS, Alaska OCS Region 

Dau, C.P. and W.W. Larned. 2005. Aerial Population Survey of Common Eiders and Other Waterbirds in 

Nearshore Waters and Along Barrier Islands of the Arctic Coastal Plain of Alaska, 24-27 June 2005. 

Anchorage, AK: USDOI, FWS, Migratory Bird Management. 

Dau, J.R. and R.D. Cameron. 1986. Effects of a Road System on Caribou Distribution During Calving. 

Rangifer 1(Special Issue):95-101. 

Davis, A., L. J. Schafer and Z. G. Bell. 1960. The effects on human volunteers of exposure to air containing 

gasoline vapors. Archives of Human Health. 1:554-584. 

Davis, J.L., P. Valkenburg, and H.V. Reynolds. 1980. Population Dynamics of Alaska’s Western Arctic 

Caribou Herd. In: Proceedings of the Second International Reindeer/Caribou Symposium, E. Reimers, 

E. Gaare, and S. Skennsberg, eds. Roros, Norway. Trondheim, Norway: Direktorat for vilt og 

ferskvannsfisk. 

Day, R.H., A.E. Gall, and A.K. Prichard. 2011. The Status and Distribution of Kittlitz’s Murrelet 

(Brachyramophus brevirostris) in northern Alaska. Final Report. Prepared for the U.S. Fish and 

Wildlife Service, Fish and Wildlife Field Office, Fairbanks, AK by ABR, Inc, Environmental Research 

and Services, Fairbanks, Alaska. 39 pp. 

Day, R.H., K.J. Kuletz, and D.A. Nigro., 1999. Kittlitz's Murrlet Brachyramphus brevirostris. In: The Birds of 

North America. No. 435. Ithaca, NY: American Ornithologists’ Union, 28 pp. 

De Gouw, J.A., Middlebrook, A.M., Warneke, C., Ahmadov, R., and Atlas E.L. et al. 2011. Organic Aerosol 

Formation Downwind from the Deepwater Horizon Oil Spill. Science, vol. 331, pp. 1295 – 1299. doi: 

10.1126/science.1200320 

Dehn, L. A., G. G. Sheffield, E. H. Follmann, L. K. Duffy, D. L. Thomas and T. M. O’Hara. 2007 Feeding 

ecology of phocid seals and some walrus in the Alaskan and Canadian Arctic as determined by 

stomach contents and stable isotope analysis. Polar Biology 30:167-181. 

http://canhr.uaf.edu/Publications/Dehn.pdf 

Dehn, L.A., G.G. Sheffield, E.H. Follmann, L.K. Duffy, D.L. Thomas, and T.M. O'Hara. 2007. Feeding ecology 

of phocid seals and some walrus in the Alaskan and Canadian Arctic as determined by stomach 

contents and stable isotope analysis. Polar Biology 30:167-181. 

Dekin, A.A., Jr., M.S. Cassell, J.J. Ebert, E. Camilli, J.M. Kerley, M.R. Yarborough, P.A. Stahl, and B.L. 

Turcy. 1993. Exxon Valdez Oil Spill Archaeological Damage Assessment, Management Summary, 

Final Report. Juneau, AK: U.S. Dept. of Agriculture, Forest Service. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 319 

Delarue, J, Laurinolli, M. and Martin, B. 2009. Acoustic detections of fin whales in the Chukchi Sea. Arctic 

Acoustics Workshop, 18th Biennial Conference on the Biology of Marine Mammals, Quebec, QC. Oct 

2009 

Delarue, J, Yurk, H., and Martin, B. 2010. Killer whale acoustic detections in the Chukchi Sea: 

Delarue,L. M., M. Laurinolli, and B. Martin. 2009. Passive Acoustic Survey of Bowhead Whales in the 

Chukchi Sea. J. Acoust. Am. 125(4):2549-2549. 

Derocher A.E., O. Wiig, and G. Bangjord. 2000. Predation of Svalbard Reindeer by Polar Bears. Polar 

Biology 23:675-678. 

Derocher, A.E., N.J. Lunn, and I. Stirling. 2004. Polar Bears in a Warming Climate. Integrative and 

Comparative Biology 44:163-176. 

DFO. 2010. Advice relevant to the identification of critical habitat for the St. Lawrence beluga (Delphinapterus 

leucas). DFO Can. Sci. Advis. Sec., Sci. Advis. Rep. 2009/070. 

Dickens, D. 2011. Behavior of Oil Spills in Ice and Implications for Arctic Spill Response. Offshore 

Technology Conference, May 2–5, 2011. Houston, Texas. 

Dickins, D.G. and I. Buist. 1981. Oil and Gas Under Sea Ice. Report CV1, Prepared by Dome Petroleum Ltd. 

For Canadian Offshore Oil Spill Research Association (), Calgary, AB: . Vol. I and II, Calgary, 

Canada: COOSRA. 286 pp. 

Dickson, D.L., G. Balogh, and S. Hanlan. 2001. Tracking the Movement of King Eiders from Nesting Grounds 

on Banks Island, Northwest Territories to their Molting and Wintering Areas Using Satellite 

Telemetry. 2000/2001 Progress Report. Edmonton, Alb., Canada: Canadian Wildlife Service, 39 pp. 

Dickson, D.L., R.S. Suydam, and G. Balogh. 2000. Tracking the Movement of King Eiders from Nesting 

Grounds at Prudhoe Bay, Alaska to their Molting and Wintering Areas Using Satellite Telemetry. 

1999/2000 Progress Report. Edmonton, Alb., Canada: Canadian Wildlife Service, 37 pp. 

Diercks, A.R., et al. 2010. Characterization of subsurface polycyclic aromatic hydrocarbons at the Deepwater 

Horizon site. Geophys. Res. Lett., 37, L20602, doi:10.1029/2010GL045046. 

Discovery News. July 22, 2010. How Do Oil Skimmers Work? Available on the Discover News website at 

http://news.discovery.com/tech/how-do-oil-skimmers-work.html 

Divoky, G.J. 1983. The Pelagic and Nearshore Birds of the Alaskan Beaufort Sea. OCSEAP Final Reports of 

Principal Investigators, Vol. 23 (Oct. 1984). Anchorage, AK: USDOC, NOAA, and USDOI, MMS, pp. 

397-513. 

Divoky, G.J. 1984. The pelagic and nearshore birds of the Alaskan Beaufort Sea: biomass and trophics. P. 417-

437 in Barnes, P.W., D.M. Schell, and E. Reimnitz (eds.) The Alaskan Beaufort Sea, Ecosystems and 

Environments. Academic Press, Inc. Orlando, FL, 466 pp. 

Divoky, G.J. 1987. The Distribution and Abundance of Birds in the Eastern Chukchi Sea in Late Summer and 

Early Fall. Unpublished final report. Anchorage, AK: USDOC, NOAA, and USDOI, MMS, 96 pp. 

Doupé, J.P. 2005. Grizzlies Set to Invade the Arctic? EurekAlert. 3 pp. Available at http://www.eurekalert.org/ 

pub_releases/2005-03/nsae-gst030905.php accessed 10/5/2010. 
BOEMRE Sale 193 Revised Draft SEIS 

320 Literature Cited

Doupé, J.P., J.H. England, M. Furze, and D. Paetkau. 2007. Most Northerly Observation of a Grizzly Bear 

(Ursus arctos) in Canada: photographic and DNA evidence from Meliville Island, Northwest 

Territories. Arctic 60(3): 271-276. 

Duesterloh, S., J.W. Short, and M.G. Barron. 2002. Photoenhanced Toxicity of Weathered Alaska North Slope 

Crude Oil to the Calanoid Copepods Calanus marshallae and Metridia okhotensis. Environmental 

Science and Technology 3618:3953-3959 

Duesterloh, S., and T. C. Shirley. 2004. The role of copepods in the distribution of hydrocarbons: An 

experimental approach. Anchorage, AK: US Dept. of the Interior, Minerals Management Service, 

Dunton, K.H., E. Reimnitz, and S. Schonberg. 1982. An Arctic Kelp Community in the Alaskan Beaufort Sea. 

Arctic 35 (4): 465. 

Dunton, K.H., J.L. Goodall, S.V. Schonberg, and J.M. Grebmeier. In press. Multi-Decadal Synthesis of 

Benthic-Pelagic Coupling in the Western Arctic: Role of Cross-Shelf Advective Processes. Deep Sea 

Research. 

Dunton, K.H., J.L. Goodall, S.V. Schonberg, J.M. Grebmeier, and D.R. Maidment, 2005. Multidecadal 

Synthesis of Benthic–Pelagic Coupling in the Western Arctic: a Role of Cross-Shelf Advective 

Processes. Deep-Sea Research II 52, 3462–3477. 

Eberhardt, L.E., W.C. Hanson, J.L. Bengtson, R.A. Garrott, and E.E. Hanson. 1982. Arctic Fox Home Range 

Characteristics in an Oil-Development Area. Journal Wildlife Management 461:183-190. 

Elias, S., S. Short, and R.L. Phillips, 1992. Paleoecology of Late-Glacial Peats from the Bering Land Bridge, 

Chukchi Sea Shelf Region, Northwestern Alaska. Quaternary Research 38(3): 371-378. November 

1992. 

Elliott, M. 2002. Introduction. In: Fishes in Estuaries, M. Elliott and K. Hemingway, eds. Oxford: Blackwell 

Science, pp. 1-9. 

Endter-Wada, J. 1992. Social, Economic, and Subsistence Effects of the Exxon Valdez Oil Spill on the Kodiak 

Region. Pages 238-288 In Conference Proceedings, Alaska Outer Continental Shelf Region, Fourth 

Information Transfer Meeting, January 28-30, 1992, Anchorage, Alaska. Outer Continental Shelf 

Study MMS 92-0046. U.S. Department of Interior, Minerals Management Service, Alaska Outer 

Continental Shelf Region, Anchorage, Alaska. 

Engelhardt, F.R. 1982. Hydrocarbon metabolism and cortisol balance in oil-exposed ringed seals, Phoca 

hispida. Comp. Biochem. Physiol. 72C: 133-136. 

Engelhardt, F. R. 1983. Petroleum effects on marine mammals. Aquatic Toxicology 4:199-217. 

Engelhardt, F.R. 1985. Environmental Issues in the Arctic. POAC 85: The 8TH International Conference on 

Port and Ocean Engineering under Arctic Conditions. Danish Hydraulic Institute, Horsholm, Denmark. 

pp. 60-69. 

Engelhardt, F. R., J. R. Geraci, and T. G. Smith. 1977. Uptake and clearance of petroleum hydrocarbons in the 

ringed seal, Phoca hispida. Journal of the Fisheries Research Board of Canada 34:1143-1147. 

Etkin, D. S. Analysis of U.S. Oil Spillage. Washington, D.C.: API Publishing Services; 2009; Publication 356. 

Etkin, D.S., D.F. McCay, J. Michel. 2007. Review of the State of the Art on Modeling Interaction Between 

Spilled Oil and Shorelines for the Development of Algorithms for Oil Spill Risk Analysis Modeling. 

Herndon, VA USDOI, Minerals Management Service. OCS Study MMS 2007-063. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 321 

Evans, D., Walton, W., Baum, H., Mulholland, G., & Lawson, J. 1991. Smoke Emission from Burning Crude 

Oil. Artic and Marine Oilspill Program Technical Seminar. June 12-14, 1991, Vancouver, B.C. pp. 

421-449. 

Expert Review Panel. 2010. Expert panel review of monitoring and mitigation protocols in applications for 

incidental take authorizations related to oil and gas exploration, including seismic surveys in the 

Chukchi and Beaufort seas. Anchorage, AK. March 22–26, 2010. Open Water meeting. 25 pp. 

Faksness, Liv-Guri, Brandvik, Per Johan, Daae, Ragnhild L., Leirvik, Frode, and Borseth, Jan Fredrik, 2011. 

Large-scale oil-in-ice experiment in the Barents Sea: Monitoring of oil in water and MetOcean 

interactions. Marine Pollution Bulletin 62(5):976-984. Corrected Proof. 

Faksness, L.G. and P.J. Brandvik. 2008a. Distribution Of Water Soluble Components From Arctic Marine Oil 

Spills - A Combined Laboratory and Field Study. Cold Regions Science and Technology 54(2):97-10. 

Faksness, L.G. and P.J. Brandvik. 2008b. Distribution of Water Soluble Components from Oil Encapsulated in 

Arctic Sea Ice: Summary of Three Field Seasons. Cold Regions Science and Technology 54(2):106-

114. 

Fall, J.A. 1992. Changes in Subsistence Uses of Fish and Wildlife Resources in 15 Alaska Native Villages 

Following the Exxon Valdez Oil Spill. In: MMS-Alaska OCS Region, Fourth Information Transfer 

Meeting Conference Proceedings, Anchorage, Ak., May 1992. Anchorage, AK: USDOI, MMS, Alaska 

OCS Region, pp. 261-270. 

Fall, J.A. and C.J. Utermohle, eds. 1995. An Investigation of the Sociocultural Consequences of Outer 

Continental Shelf Development in Alaska. Vol. VI. Anchorage, AK: State of Alaska, Dept. of Fish and 

Game, Div. of Subsistence. 

Fall, J.A. and C.J. Utermohle. 1999. Subsistence Harvests and Uses in Eight Communities Ten Years After the 

Exxon Valdez Oil Spill. Technical Paper No. 252. Juneau, AK: ADF&G, Div. of Subsistence. 

Fall, J.A., L.J. Field, T.S. Nighswander, N. Peacock, and U. Varansi (eds.). 1999. Overview of Lessons Learned 

from the Exxon Valdez Oil Spill: A 10-Year Retrospective. In: Evaluating and Communicating 

Subsistence Seafood Safety in a Cross-Cultural Context. Pensacola, FL: SETAC Press. 

Fall, J.A., R. Miraglia, C. Simeone, C. Utermohle, and R. Wolfe. 2001. Long-term Consequences of the Exxon 

Valdez Oil Spill for Coastal Communities of Southcentral Alaska. OCS Study MMS 2001-032. 

Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

Farwell, C.; C.M. Reddy, E. Peacock, R.K. Nelson, L. Washburn, and D.L.Valentine. 2009. Weathering and the 

Fallout Plume of Heavy Oil from Strong Petroleum Seeps Near Coal Oil Point, CA. Environmental 

Science and Technology 43(10):3542–3548. 

Fay, F.H. 1974. The Role of Ice in the Ecology of Marine Mammals of the Bering Sea. In: Oceanography of 

the Bering Sea, D.W. Hood and E.J. Kelley, eds. Occasional Publication 2. Fairbanks, AK: Institute of 

Marine Science, pp. 383-389. 

Fay, F.H. 1981. Walrus Odobenus rosmarus (Linnaeus, 1758). In: Handbook of Marine Mammals, S.H. 

Ridgway and R.J.Harrison , eds. Vol. 1: The Walrus, Sea Lions, Fur Seals and Sea Otter. London: 

Academic Press, 235 pp. 

Fay, F.H. 1982. Ecology and Biology of the Pacific Walrus, Odobenus rosmarus divergens Illiger. North 

American Fauna 74:279. 

Fay, F.H. and J.J. Burns. 1988. Maximal Feeding Depths of Walruses. Arctic 413:239-240. 
BOEMRE Sale 193 Revised Draft SEIS 

322 Literature Cited

Fay, R. 2009. Soundscapes and the sense of hearing in fishes. Integ. Zool. 4(1): 26-32. 10.1111/j.1749-

4877.2008.00132.x. 

Fechhelm, R G and W.B. Griffiths. 2001. Status of Pacific Salmon in the Beaufort Sea, 2001. Anchorage, AK: 

LGL Alaska Research Assocs., Inc., 13 pp. 

Fechhelm, R.G., G.B. Buck, and M.R. Link. 2006. Year 24 of the Long-Term Monitoring of Nearshore 

Beaufort Sea Fishes in the Prudhoe Bay Region, 2006. Anchorage, AK: BP Exploration, Alaska, 82 

pp. 

Feder, H.M, S.C. Jewett, and A.L. Blanchard. 2007. Southeastern Chukchi Sea (Alaska) macrobenthos. 

DOI:l0.1007s00300·006·0180·z. Polar Biol. 15 pp. 

Feder, H.M., N.R. Foster, S.C. Jewett, T.J. Weingartner, and R. Baxter. 1994. Mollusks in the Northeastern 

Chukchi Sea. Arctic 47:145-163. 

Federal Aviation Administration. 2009. Port Columbus International Airport Final Environmental Impact 

Statement. 

Federal Register Notice. Vol. 76, No. 28, pages 7634-7679. Thursday, February 10, 2011. Endangered and 

Threatened Wildlife and Plants; 12-Month Finding on a Petition to List the Pacific Walrus as 

Endangered or Threatened; Proposed Rule. 

Federal Register, Vol. 73, No. 95, pages 28212-28303. Thursday, May 15, 2008. Endangered and Threatened 

Wildlife and Plants; Determination of Threatened Status for the Polar Bear (Ursus maritimus) 

Throughout Its Range; Final Rule 

Federal Register, Vol. 74, No. 249, pages 69139-69143. Wednesday, December 30, 2009. Marine Mammal 

Protection Act; Stock Assessment Report. 

Federal Register, Vol. 75, No. 234, pages 76086-76137. Tuesday, December 7, 2010. Endangered and 

Threatened Wildlife and Plants; Designation of Critical Habitat for the Polar Bear (Ursus maritimus) in 

the United States; Final Rule. 

Federal Register. 2005. Call for Information and Nominations. Outer Continental Shelf (OCS), Alaska Region, 

Chukchi Sea/Hope Basin and Norton Basin Planning Areas. Federal Register 70(26):6903. 

Federle, T.W., J.R. Vestal, G.R. Hater and M.C. Miller. 1979. Effects of Prudhoe Bay crude oil on primary 

production and zooplankton in arctic tundra thaw ponds. Marein Environmental Research 2(1): 3-18. 

Field, L.J., J.A. Fall, T.J. Nighswander, N. Peacock, and U. Varanasi, eds. 1999. Evaluating and 

Communicating Subsistence Seafood Safety in a Cross-Cultural Context. Pensacola, FL: SETAC 

Press, 338 pp. 

Fingas, M. 2000. The Basics of Oil Spill Cleanup. Lewis Publishers, Boca Raton, FL. 

Fingas, M., Ackerman F., Lambert, P., Li, K., Wang, Z., Mullin, J., Hannon, L., Wang, D., Steenkammer, A., 

Hiltabrand, R., Turpin, R., and Campagna, P. 1995. The Newfoundland offshore burn experiment: 

Further results of emissions measurement. In: Proceedings of the Eighteenth Arctic and Marine Oilspill 

Program Technical Seminar, Volume 2, June 14-16, 1995, Edmonton, Alberta, Canada, pp. 915-995. 

Fingas, M.F. and Hollebone, B.P. 2003. Review of Behaviour of Oil in Freezing Environments. Marine 

Pollution Bulletin. 47: 333–340. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 323 

Fox, A. and J. Madsen. 1997. Behavioural and Distributional Effects of Hunting Disturbance on Waterbirds in 

Europe: Implications of Refuge Design. Journal of Applied Ecology 34:1-13. 

Foy MG. 1982. Acute Lethal Toxicity of Prudhoe Bay Crude Oil and Corexit 9527 to Arctic Marine Fish and 

Invertebrates. Technology Development Report, Environment Canada, Ottawa, Ontario, Canada 

Froese, R. and D. Pauly. Editors. 2010. FishBase. World Wide Web electronic publication. www.fishbase.org, 

version (11/2010). 

Frost, K.J. and L.F. Lowry. 1983. Demersal Fishes and Invertebrates Trawled in the Northeastern Chukchi and 

Western Beaufort Seas, 1976-1977. NOAA Technical Report NMFS SSRF-764. Seattle, WA: 

USDOC, NOAA, NMFS, 22 pp. 

Frost, K.J. and L.F. Lowry. 1984. Ringed Seal Monitoring: Relationships of Distribution and Abundance to 

Habitat Attributes and Industrial Activities. OCS Study MMS 84-0210. Anchorage, AK: USDOI, 

MMS, Alaska OCS Region 

Frost, K.J. and L.F. Lowry. 1990. Distribution, Abundance, and Movements of Beluga Whales, Delphinapterus 

leucas, in Coastal Waters of Western Alaska. Can. Bull. Fish. and Aquat. Sci. 224:39-57. 

Frost, K.J., L.F. Lowry, and G. Carroll. 1993. Beluga Whale and Spotted Seal Use of a Coastal Lagoon System 

in the Northeastern Chukchi Sea. Arctic 461:8-16. 

Frost, K.J., L.F. Lowry, and J.M. Ver Hoef. 1999. Monitoring the Trend of Harbor Seals in Prince William 

Sound, Alaska, after the Exxon Valdez Oil Spill. Marine Mammal Science 15: 494-506. 

Frost, K.J., L.F. Lowry, G. Pendleton, and H.R. Nute. 2004. Factors Affecting the Observed Densities of 

Ringed Seals, Phoca hispida, in the Alaskan Beaufort Sea, 1996-99. Arctic 57:115-128. 

Frost, K.J., L.F. Lowry, J.R. Gilbert, and J.J. Burns. 1988. Ringed Seal Monitoring: Relationships of 

Distribution and Abundance to Habitat Attributes and Industrial Activities. OCS Study MMS 89-0026. 

Anchorage, AK: USDOC, NOAA, and USDOI, MMS, pp. 345-445. 

Fuller, A. S. and J.C. George. 1997. Evaluation of Subsistence Harvest Data from the North Slope Borough 

1993 Census for Eight North Slope Villages: for the Calendar Year 1992. Barrow, AK: North Slope 

Borough, Dept. of Wildlife Management. 

Funk, D.W., D.S. Ireland, R. Rodrigues, and W.R. Koski (eds.). 2010. Joint Monitoring Program in the Chukchi 

and Beaufort seas, open water seasons, 2006–2008. LGL Alaska Report P1050-2, Report from LGL 

Alaska Research Associates, Inc., LGL Ltd., Greeneridge Sciences, Inc., and JASCO Research , Ltd., 

for Shell Offshore, Inc. and Other Industry Contributors, and National Marine Fisheries Service, U.S. 

Fish and Wildlife Service. 506 p. plus Appendices. 

Funk., D.W., D.S. Ireland, R. Rodrigues, and W.R. Koski (eds.). 2011. Joint Monitoring Program in the 

Chukchi and Beaufort seas, open-water seasons, 2006–2009. LGL Alaska Report P1050-2, Report 

from LGL Alaska Research Associates, Inc., LGL Ltd., Greeneridge Sciences, Inc., and JASCO 

Applied Sciences, for Shell Offshore, Inc. and Other Industry Contributors, and National Marine 

Fisheries Service, U.S. Fish and Wildlife Service. 462 pp. plus Appendices. 

Gallaway, B.J. and R.G. Fechhelm. 2000. Anadromous and Amphidromous Fishes. In: The Natural History of 

an Arctic Oil Field: Development and the Biota, J.C. Truett and S.R. Johnson, eds. San Francisco, CA: 

Academic Press, pp. 349369. 

Garlich-Miller, J. 2006. Email dated Mar. 1, 2006, from Joel Garlich-Miller, FWS, Anchorage, to M. Burwell, 

MMS Alaska OCS Region; subject: walrus harvest numbers. 
BOEMRE Sale 193 Revised Draft SEIS 

324 Literature Cited

Garlich-Miller, J.L., Quakenbush, L.T., and Bromaghin, J.F. 2006. Trends in age Structure and Productivity of 

Pacific Walruses Harvested in the Bering Strait Region of Alaska, 1952–2002. Marine Mammal 

Science. 22(4):880-896. 

Garner, G.W. and P.E. Reynolds, eds. 1986. Arctic National Wildlife Refuge Coastal Plain Resource 

Assessment: Final Report: Baseline Study of the Fish, Wildlife and Their Habitats. Anchorage, AK: 

USDOI, FWS, Region 7, 695 pp. 

General Accounting Office (GAO). 1983. Issues Facing the Future Use of Alaska North Slope Natural Gas, 

GAO/REED-83-102. 145 pp. 

George, J. C., S. E. Moore and R. Suydam. 2007. Summary of Stock Structure Research on the BeringChukchi-Beaufort Seas Stock of Bowhead Whale (Balaena mysicetus) 2003-2007. Unpubl. report 

submitted to Int. Whal. Comm. (SC/59/BRG3. 15 pp. 

George, J.C. and R. Suydam. 1998. Observations of killer whale (Orcinus orca) predation in the northeastern 

Chukchi and western Beaufort seas. Mar. Mamm. Sci. 14: 330-332. 

George, J.C., J. She, R. Suydam, and C. Clark. 2004. Abundance and Population Trend (1978-2001) of Western 

Arctic Bowhead Whales Surveyed near Barrow, Alaska. Marine Mammal Science 20(4): 755-773. 

Geraci, J. R. 1988. Physiological and Toxic Effects on Cetaceans. In: Synthesis of Effects of Oil on Marine 

Mammals, J.R. Geraci and D.J. St. Aubin, eds. Washington, DC: USDOI, MMS 

Geraci, J. R., 1990. Physiologic and Toxic Effects on Cetaceans. In: Sea Mammals and Oil: Confronting the 

Risks, J.R. Geraci and D.J. St. Aubin, eds. San Diego, CA: Academic Press, Inc., and Harcourt Brace 

Jovanovich, pp. 167-197. 

Geraci, J. R., and T. G. Smith. 1976a. Behavior and pathophysiology of seals exposed to crude oil. Pages 447–

462 in Proceedings of the Symposium American University: Sources, Effects, and Sinks of 

Hydrocarbons in the Aquatic Environment, Washinton, D.C. The American Institute of Biological 

Sciences. 

Geraci, J. R., and T. G. Smith. 1976b. Direct and indirect effects of oil on ringed seals (Phoca hispida) of the 

Beaufort Sea. Journal of the Fisheries Research Board of Canada 33:1976–1984. 

Geraci, J. R., and T. G. Smith. 1976c. Behavior and pathophysiology of seals exposed to crude oil, p. 447-462. 

In Symposium on Sources, Effects, and Sinks of Hydrocarbons in the Aquatic Environment. 

American Institute of Biological Sciences. 

Geraci, J.R., and D.J. St. Aubin. 1988. Synthesis of Effects of Oil on Marine Mammals. Battelle Memorial 

Institute, Ventura, CA for USDOI, MMS, Atlantic OCS. OCS Study, MMS 88-0049. 142 pp. 

Geraci, J.R., and T.G. Smith. 1976d. Chapter 8: Consequences of Oil Fouling on Marine Mammals. In. Effects 

of Petroleum on Arctic and Subarctic Marine Environments and Organisms. pp. 399-410. 

Geraci, Joseph and David St. Aubin. 1990. Sea Mammals and Oil: Confronting the risks. Academic Press, Inc. 

San Diego, CA. 282pp. 

Gerdes, B., R. Brinkmeyer, G. Dieckmann, and E. Helmke. 2005. Influence of Crude Oil on Changes of 

Bacterial Communities in Arctic Sea-ice. FEMS Microbiology Ecology 53:129-139. 

GESMAP. 1995. The sea-surface microlayer and its role in global change. GESAMP Reports and Studies 59. 

76 p. Joint Group of Experts (IMO/FAO/Unesco-IOC/WMO/WHO/IAEA/UN/UNEP) on the 

Scientific Aspects of Marine Environmental Protection. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 325 

Gjøsteen, Janne K. Ø. and Løset, Sveinung. 2004. Laboratory experiments on oil spreading in broken ice. 

Cold Regions Science and Technology 382-3:103-116. 

Gleason, J. and K. Rode. 2009. Polar bear distribution and habitat association reflect long term changes in fall 

sea ice conditions in the Alskan Beaufort sea. Arctic, Vol. 62, NO.4(December 2009) pp. 405-417. 

Goebel, T., M.R. Waters, and D.H. O'Rourke, 2008. The Late Pleistocene dispersal of modern humans in the 

Americas. Science 319: 1497–1502. doi:10.1126/science.1153569. 

Goetz, K.T., D.J. Rugh, and J.A. Mocklin. 2009. Bowhead whale feeding study in the western Beaufort Sea. 

Section I: aerial surveys of bowhead whales in the vicinity of Barrow, August to September 2009. 

2009 Annual Report, Minerals Management Services, Anchorage, AK. 63 pp. 

Gosink, T.A., Pearson, J.G., Kelley, J.J., 1976. Gas Movement Through Sea Ice. Nature 263: 41–42. 

Gradinger, R. and B. Bluhm. 2004. In-situ observations on the distribution and behavior of amphipods and 

Arctic cod (Boreogadus saida) under the sea ice of the High Arctic Canada Basin. Polar Biology 27: 

595-603. 

Gradinger, R., B. A. Bluhm, R. R. Hopcroft, A. V. Gebruk, K. Kosobokova, B. Sirenko, and J. M. Wesławski. 

2010. Marine life in the Arctic. Life in the World's Oceans: Diversity, Distribution, and Abundance: 

183. 

Gradinger, R., B. Bluhm, and K. Iken. 2010. Arctic sea-ice ridges—Safe heavens for sea-ice fauna during 

periods of extreme ice melt? Deep Sea Research Part II: Topical Studies in Oceanography 57 (1-2) (1): 

86-95. Graham, M. and H.Hop. 1995. Aspects of Reproduction and Larval Biology of Arctic Cod 

(Boreogadus saida). Arctic 48 (2): 130–135 

Grahl-Nielsen, O. 1978. The Ekofisk Bravo Blowout: Petroleum Hydrocarbons in the Sea. In: The Proceedings 

of the Conference on Assessment of Ecological Impacts of Oil Spills, C.C. Bates, ed. Keystone, Colo., 

Jun. 14-17, 2005. Washington, DC: American Institute of Biological Sciences, pp. 476-487. 

Grantz, A., D.A. Dinter, E.R. Hill, R.E. Hunter, S.D. May, R.H. McMullin, and R.L. Phillips. 1982. Geological 

Framework, Hydrocarbon Potential and Environmental Conditions for Exploration and Development 

of Proposed Oil and Gas Lease Sale 87 in the Beaufort and Northeast Chukchi Seas. Open-File Report 

82-48. Menlo Park, CA: U.S. Geological Survey, 73 pp. 

Grebmeier, J. M., L. W. Cooper, H. M. Feder, and B. I. Sirenko. 2006. Ecosystem dynamics of the pacificinfluenced northern bering and Chukchi seas in the amerasian Arctic. Progress in Oceanography 71 (2-

4) (12): 331-61. 

Grebmeier, J. and K. Dunton. 2000. Benthic Processes in the Northern Bering/Chukchi Seas: Status and Global 

Change. In: Impacts of Change in Sea Ice and Other Environmental Parameters in the Arctic. Marine 

Mammal Workshop, Girdwood, AK., Feb. 15-17, 2000. Bethesda, MD: Marine Mammal Commission, 

pp. 61-71. 

Grebmeier, J.M., J.E. Overland, S.E. Moore, E.V. Farley, E.C. Carmack, L.W. Cooper, K.E. Frey, J.H. Helle, 

F.A. McLaughlin, and S.L. McNutt. 2006. A Major Ecosystem Shift in the Northern Bering Sea. 

Science 311:1461-1464. 

Green, D.R., B. Humphrey, and B. Fowler. 1982. Chemistry: 1. Field Sampling and Measurements. 1981 Study 

Results. Baffin Island Oil Spill (BIOS) Project Working Report 81-1. Edmonton, Alb., Canada: Baffin 

Island Oil Spill Project. 111 pp. 
BOEMRE Sale 193 Revised Draft SEIS 

326 Literature Cited

Gundlach, E.R., P.D. Boehem, M. Marchand, R.M. Atlas, D.M. Ward, and D.A. Wolfe. 1983. The Fate of 

Amoco Cadiz Oil. Science 221:122-129. 

Haggarty, J.C., C.B. Wooley, J.M. Erlandson, and A. Crowell. 1991. The 1990 Exxon Valdez Cultural Resource 

Program: Site Protection and Maritime Cultural Ecology in Prince William Sound and the Gulf of 

Alaska. Anchorage, AK: Exxon Company, USA. 

Haidvogel, D. B., K.S. Hedstrom, and J. Francis. 2001. Numerical Simulations of Atmosphere/Ocean/Sea Ice 

Interaction in the Arctic Ocean 1982-1996. OCS Study MMS 2001-069. Anchorage, AK: USDOI, 

MMS , 62 pp. 

Hanna, G.D. 1948. Animals and Tar Traps. Wasmann Journal of Biology 7(4): 133-139 

Hanna, G.D. 1963. Oil Seepages on the Arctic Coastal Plain, Alaska. Occasional Papers of the California 

Academy of Sciences 38: 18 pp. 

Hannay, D., Martin, B., Laurinolli, M. and Delarue, J. 2009. Chukchi Sea Acoustic Monitoring Program. In: 

Funk, D.W., Funk, D.S., Rodrigues, R., and Koski, W.R. (eds.). Joint monitoring program in the 

Chukchi and Beaufort seas, open water seasons 2006-2008. LGL Alaska Report P1050-1, Report from 

LGL Alaska Research Associates, Inc., LGL Ltd., Greenridge Sciences, Inc., and JASCO Research, 

Ltd., for Shell Offshore, Inc. and other industry contributors, and National Marine Fisheries Service, 

U.S. Fish and Wildlife Service. 288 pp. plus appendices. 

Hansen, D. J. 1985. The Potential Effects of Oil Spills and Other Chemical Pollutants on Marine Mammals 

Occurring in Alaskan Waters. OCS Report, MMS 85-0031. Anchorage, AK: USDOI, MMS, Alaska 

OCS Region, 22 pp. 

Hansen, H., D. Altin, S. F. Rørvik, I. Beathe Øverjordet, A. J. Olsen, and T. Nordtug. 2011. Comparative study 

on acute effects of water accommodated fractions of an artificially weathered crude oil on Calanus 

finmarchicus and Calanus glacialis (crustacea: Copepoda). Science of the Total Environment 409 (4) 

(1/15): 704-9. 

Harayama, S., Y. Kasai, and A. Hara. 2004. Microbial communities in oil-contaminated seawater. Current 

Opinion in Biotechnology 15 (3) (6): 205-14. 

Harcharek, R.C. 1995. North Slope Borough 1993/94 Economic Profile and Census Report. Vol. VII. Barrow, 

AK: North Slope Borough, Dept. of Planning and Community Services. 

Harding L. and J.A. Nagy. 1980. Responses of Grizzly Bears to Hydrocarbon Exploration on Richards Island, 

Northwest Territories, Canada. In: Bears-Their Biology and Management. Fourth International 

Conference Bears Resource and Management, Kalispell, Mont., Tonto Basin, AZ: Bear Biology 

Assoc., pp. 277-280. 

Harding, L.E. 1976. Den-Site Characteristics of Arctic Coastal Grizzly Bears (Ursus arctos) on Richards 

Island, Northwest Territories, Canada. Canadian Journal Zoology 54:1357-1363. 

Harvey, J. T. and M.E. Dahlheim., 1994. Cetaceans in Oil. In: Marine Mammals and the Exxon Valdez,T.R. 

Loughlin, ed. San Diego, CA: Academic Press, pp. 257-264. 

Harwood, J. and B. Wilson. 2001. The Implications of Developments on the Atlantic Frontier for Marine 

Mammals. Cont. Shelf Res. 218(10:1073-1093. 

Harwood, L.A. and I. Stirling. 1992. Distribution of Ringed Seals in the Southeastern Beaufort Sea during Late 

Summer. Can. J. Zool. 705:891-900. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 327 

Harwood, L.A., F. McLaughlin, R.M. Allen, J. Illasiak, Jr., and J. Alikamik. 2005. First-Ever Marine Mammal 

and Bird Observation in the Deep Canada Basin and Beaufort/Chukchi Seas: Expeditions during 2002. 

Polar Biology 283:250253. 

Harwood, L.A., J. Auld, A. Joynt and S.E. Moore. 2010. Distribution of bowhead whales in the SE Beaufort 

Sea during late summer, 2007-2009. DFO Can. Sci. Advis. Sec. Res. Doc. 2009/111. iv + 22 pp. 

Haskell, S.P., R.M. Nielson, W.B. Ballard, A. Cronin, and L. McDonald. 2006. Dynamic Responses of Calving 

Caribou to Oilfields in Northern Alaska. Arctic 59:179-190. 

Hatch, S.A., P.M. Meyers, D. M. Mulcahy, and D.C. Douglas. 2000. Seasonal Movements and Pelagic Habitat 

Use of Murres and Puffins Determined by Satellite Telemetry. Condor 102:145-154. 

Hayes, M., R. Hoff, J. Michel, D. Scholz, and G. Shigenaka. 1992. An Introduction to Coastal Habitats and 

Biological Resources for Oil Spill Response. Report No. HMRAD 92-4. USDOC/NOAA, Hazardous 

Materials Response and Assessment Division. 

Hayes, M., R. Hoff, J. Michel, D. Scholz, and G. Shigenaka. 1992. An Introduction to Coastal Habitats and 

Biological Resources for Oil Spill Response. Report No. HMRAD 92-4. USDOC/NOAA, Hazardous 

Materials Response and Assessment Division. 

Hayes, M.O., J. Michel, T.M. Montello, D.V. Aurand, A.M. Al-Mansi, A.H. Al-Moamen, T.C. Sauer and G.W. 

Thayer. 1993. Distribution and weathering of shoreline oil one year after the Gulf War oil spill. Marine 

Pollution Bulletin Volume 27, 1993, Pages 135-142. 

Haynes, T. and S. Pedersen. 1989. Development and Subsistence: Life After Oil. Alaska Fish and Game 

21(6):24-27. 

Hazard, K. 1988. Beluga Whale, Delphinapterus leucas. In: Selected Marine Mammals of Alaska: Species 

Accounts with Research and Management Recommendations, J.W. Lentfer, ed. Washington, DC: 

Marine Mammal Commission, 275 pp. 

Hazen, T. C., et al. 2010. Deep-sea oil plume enriches indigenous oil-degrading bacteria. Science 2010, 330, 

204–207. 

Health Canada. 2002. The Social Determinants of Health: An Overview of the Implications for Policy and the 

Role of the Health Sector. Accessed online at http://www.phac-aspc.gc.ca/ph-sp/phdd/pdf/ 

overview_implications/01_overview_e.pdf. 

Hemming, J.E. 1971. The Distribution and Movement Patterns of Caribou in Alaska. Federal Aid in Wildlife 

Restoration Project W-17-R. Wildlife Technical Bulletin No. 1. Juneau, AK: State of Alaska, Dept. 

of Fish and Game, 60 pp. 

Hicks, J. and P. Bjerregaard. 2006. The Transition from the Historical Inuit Suicide Pattern to the Present Inuit 

Suicide Pattern. Accessed online on Nov. 13, 2006, at http://www.inchr.org/Doc/April2006/Hickssuicide.pdf 

Highsmith, R. C., and K. O. Coyle. 1992. Productivity of Arctic Amphipods Relative to Gray Whale Energy 

Requirements. Marine Ecology Progress Seeries 83:141-150. 

Hill, S.H. 1978. A Guide to the Effects of Underwater Shock Waves on Arctic Marine Mammals and Fish. 

Institute of Ocean Sciences, Patricia Bay, Sidney, B.C. 50 pp. 

Hoff, R., 1995, Responding to Oil Spills in Coastal Marshes: The Fine Line between Help and Hinderance. 

HAZMAT Report 96-1. USDOC/NOAA, Hazardous Materials Response and Assessment Division. 
BOEMRE Sale 193 Revised Draft SEIS 

328 Literature Cited

Hogshead, C.G., M. Evangelos, P. Williams, A. Lupinsky, and P. Painter. 2010. Studies of Bitumen—Silica and 

Oil—Silica Interactions in Ionic Liquids. Energy Fuels 25:293–299. DOI:10.1021/ef10140k. 

Holland, P. 1997. Offshore Blowouts Causes and Control. Houston, TX: Gulf Publishing Company. 

Holland, M.M. 2006. The Transition to and Conditions of a Seasonally Ice-Free Arctic Ocean. In: 2006 Fall 

AGU Meeting, San Francisco, Calif., Dec. 10-15, 2006. San Francisco, CA: AGU. 

Hom, W., D.W. Brown, J.E. Stein, and U. Varanasi. 1999. Measuring the Exposure of Subsistence Fish and 

Marine Mammal Species to Aromatic Compounds following the Exxon Valdez Oil Spill. In: 

Evaluating and Communicating Subsistence Seafood Safety in a Cross-Cultural Context, L.J. Field and 

T. S. Nighswander N. Peacock and U. Varanasi J.A. Fall, eds. Pensacola, FL: SETAC Press. 

Hoover-Miller, A. A, K. R. Parker, and J. J. Burns. 2001. A reassessment of the impact of the Exxon Valdez oil 

spill on harbor seals (Phoca vitulina richardsi) in Prince William Sound. Marine Mammal Science. 

17(1): 111-135. 

Hopcroft, R., B. Bluhm, R. Gradinger, T. Whitledge, T. Weingartner, B. Norcross, and A. Springer. 2006. 

Arctic Ocean Synthesis: Analysis of Climate Change Impacts in the Chukchi and Beaufort Seas with 

Strategies for Future Research. Fairbanks, AK: University of Alaska, Fairbanks, Institute of Marine 

Science, 153 pp. 

Hopcroft, R., B. Bluhm, R. Gradinger, T. Whitledge, T. Weingartner, B. Norcross, and A. Springer. 2008. 

Arctic ocean synthesis: Analysis of climate change impacts in the Chukchi and beaufort seas with 

strategies for future research. Fairbanks, AK: University of Alaska, Fairbanks, Institute of Marine 

Science. 

Hopcroft, R., J. Questel, and C. Clarke-Hopcroft. 2010. Oceanographic assessment of the planktonic 

communities in the Klondike and Burger survey areas of the Chukchi sea; report for survey year 2009. 

Hopcroft, R., and K. N. Kosobokova. 2010. Distribution and egg production of pseudocalanus species in the 

Chukchi sea. Deep Sea Research Part II: Topical Studies in Oceanography 57 (1-2) (1): 49-56. 

Hopcroft, R.; Kosobokova, K.N.; Pinchuk, A.I. 2010. Zooplankton community patterns in the Chukchi sea 

during summer 2004. Deep Sea Research Part II: Topical Studies in Oceanography 57 (1-2) (1): 27-39. 

Hopkins, D., 1967 The Bering Land Bridge. Hopkins, D. ed. Stanford University Press, 512 pp. ISBN-10: 

0804702721, ISBN-13: 9780804702720 

Horejsi, B. 1981. Behavioral Response of Barren-Ground Caribou to a Moving Vehicle. Arctic 342:180-185. 

Hovelsrud, G.K., M. McKenna, and H.P. Huntington. 2008. Marine Mammal harvests and other interactions 

with humans. Ecological Applications 18(2) Supplement:S135-S147. 

Human Relations Area Files, Inc. 1994a. Social Indicators Study of Alaskan Coastal Villages, III. Analysis. J.G. 

Jorgensen, P.I. OCS Study MMS 93-0070. Anchorage, AK: USDOI, MMS, Alaska OCS Region, 520 

pp. 

Human Relations Area Files, Inc. 1994b. Social Indicators Study of Alaskan Coastal Villages V. Research 

Methodology for the Exxon Valdez Spill Area 1988-1992. OCS Study, MMS 93-0071. Anchorage, 

AK: USDOI, MMS, Alaska OCS Region. 

Human Relations Area Files, Inc. 1994c. Social Indicators Study of Alaskan Coastal Villages VI. Analysis of 

the Exxon Valdez Spill Area. OCS Study MMS 94-0064. Anchorage, AK: USDOI, MMS, Alaska 

OCS Region. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 329 

Hunter, M.L. 1996. Fundamentals of Conservation Biology. Cambridge, MA: Blackwell Science, 482 pp. 

Huntington, H.P. and L.T. Quakenbush. 2009. Traditional knowledge of bowhead migration patterns near 

Kaktovik and Barrow, Alaska. Report prepared for the Barrow and Kaktovic Whaling Captains 

Associations and Alaska EskimoWhaling Commission. 15 pp. Marine Fisheries Service, United States 

Fish and Wildlife Service. 488 pp plus Appendices. 

Huntington, H.P. and N.I. Mymrin. 1996. Traditional Ecological Knowledge of Beluga Whales. An 

Indigenous Knowledge Pilot Project in the Chukchi and Northern Bering Seas. Final Report. 

Anchorage, AK: Inuit Circumpolar Conference. 

Huntington, H.R. 1999. Traditional Knowledge of the Ecology of Beluga Whales (Delphinapterus leucas) in the 

Eastern Chukchi and Northern Bering Seas, Alaska. Arctic 531:49-61. 

Hurst, Rick J. and Nils Oritsland. 1982. Polar bear thermoregulation: effect of oil on the insulative properties of 

fur. J. Therm. Biology, vol. 7, pp 201-208. 

ICF, Incorporated, 1982, Alaska Natural Gas Development, An Economic Assessment of Marine Systems, final 

report, MA-RD-940-82082, 58 pp. and Appendices. 

Iken, K., B. Bluhm, and K. Dunton. 2010. Benthic food-web structure under differing water mass properties in 

the southern Chukchi Sea. Deep Sea Research Part II: Topical Studies in Oceanography 57 (1-2) (1): 

71-85. 

Impact Assessment, Inc. 1990a. Subsistence Resource Harvest Patterns: Nuiqsut. Special Report No. 8. 

Prepared for the U.S. Department of the Interior, Minerals Management Service, Alaska Outer 

Continental Shelf Region, Anchorage, Alaska. 

Impact Assessment, Inc. 1990b. Subsistence Resource Harvest Patterns: Kaktovik. Outer Continental Shelf 

Study, MMS 90-0039. Special Report 9. Prepared for the U.S. Department of Interior, Minerals 

Management Service, Alaska Outer Continental Shelf Region, Anchorage, Alaska. 

Impact Assessment, Inc. 1990c. Subsistence Resource Harvest Patterns: Kaktovik. OCS Study, MMS 90-0039. 

Special Report No. 9. Anchorage, AK: USDOI, MMS, Alaska OCS Region, Alaska Social and 

Economic Studies Program, 193 pp. 

Impact Assessment, Inc. 1998. Exxon Valdez Oil Spill, Cleanup, and Litigation: A Collection of Social Impacts 

Information and Analysis. Final report. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

Impact Assessment, Inc. 2001. Exxon Valdez Oil Spill, Cleanup and Litigation: A Collection of Social-Impact 

Information and Analysis. OCS Study, MMS 2001-058. Technical Report 161. Anchorage, AK: 

USDOI, MMS, Alaska OCS Region. 

Inslee, J. 2011. Personal communication. Comments on VLOS dated April 22, 2011. USDOC, NOAA to 

BOEMRE, Alaska OCS Region. 

International Whaling Commission. 2004a. Annex K. Report of the Standing Working Group on 

Environmental Concerns. Cambridge, UK: IWC. 

International Whaling Commission. 2004b. Report of the Scientific Committee. Cambridge, UK: IWC. 

International Whaling Commission. 2005a. Report of the Scientific Committee. Cambridge, UK: 

IWC. 

International Whaling Commission (IWC). 2005b. Annex F. Report of the Sub-Committee on Bowhead, Right 

and Gray Whales. Report 13:23. Cambridge, UK: IWC, 12 pp. 
BOEMRE Sale 193 Revised Draft SEIS 

330 Literature Cited

International Whaling Commission (IWC). 2005a. Report of the Scientific Committee. Cambridge, UK: IWC. 

International Whaling Commission (IWC). 2008. Report of the Scientific Committee. Eastern Canada-West 

Greenland bowhead whales. J. Cetacean Res. Manage. (Suppl.) 10:27-28. 

IPCC. 2001b. Climate Change 2001: The Scientific Basis. Geneva: IPCC. 

IPCC. 2007. Climate Change 2007: The Physical Science Basis. Contribution of Working Gourp I to the Fourth 

Assessment Report of the Intergovernmental Panel of Climate Change., S. Solomon, D Qin M. 

Manning Z. Chen M. Marquis K. B. Avery M. Tignor and H. L. Miller, eds. New York: Cambridge 

University Press, 996 pp. 

Ireland, D.S., D.W. Funk, R. Rodrigues, and W.R. Koski (eds). 2008. Joint monitoring program in the Chukchi 

and Beaufort Seas, July-November 2007. LGL Alaska Report P97-1, Report from LGL Alaska 

Research Associates, Inc., LGL Ltd., JASCO Research, Ltd, and Geeneridge Sciences, Inc. for Shell 

Offshore Inc.,ConocoPhillips Alaska, Inc., National Marine Fisheries Service, and United States Fish 

and Wildlife Service. 445 pp. plus Appendices. 

Ireland, D. S., W. R. Koski, T. A. Thomas, J. Beland, C. M. Reiser, D. W. Funk, and A. M. Crander. 2009. 

Updated distribution and relative abundance of cetaceans in the eastern Chukchi Sea in 2006-8. Report 

to the IWC SC/61/BRG4. 14 pp. 

Jackson, C. R. & Apel, J.R. Eds. 2004. Synthetic Aperture Radar Marine User’s Manual. U.S. Department of 

Commerce: Washington, D.C. Chapter 15: Mesoscale Storm Systems, authors K.S. Friedman, P.W. 

Vachon, & K. Katsaros. 

Jarvela, L.E., L.K. Thorsteinson, and M.J. Pelto. 1984. Oil and Gas Development and Related Issues. In: The 

Navarin Basin Environment and Possible Consequences of Offshore Oil and Gas Development, L.E. 

Jarvela, ed. Chapter 9. Juneau and Anchorage, AK: USDOC, NOAA, OCSEAP and USDOI, MMS, 

pp. 103-141. 

JASCO Research, Ltd for Shell Offshore Inc. and other industry contributors, and National 

Jay, C.V. and S. Hills. 2005. Movements of Walruses Radio-tagged in Bristol Bay, Alaska. Arctic 58:192-202. 

Jay, C.V., B.E. Ballachey, G.W. Garner, D.M. Mulcahy, and M. Arthur. 1996. Preliminary Research on 

Pacific Walrus to Evaluation Potential Effects by Disturbance of OCS-Related Oil and Gas Activities 

in the Chukchi Sea. Anchorage, AK: USGS, National Biological Service, 9 pp. 

Jiang, Z., Y. Huang, X. Xu, Y. Liao, L. S., Jingjing Liu, Q. Chen, and J. Zeng. 2010. Advance in the toxic 

effects of petroleum water accommodated fraction on marine plankton. Acta Ecologica Sinica 30 (1) 

(2): 8-15. 

Jingfors, K.T. 1982. Seasonal Activity Budgets and Movements of a Reintroduced Alaskan Muskox Herd. 

Journal Wildlife Management 462:344-350. 

Johansen, Ř. 2000. DeepBlow-A Lagrangian Plume Model for Deep Water Blowouts. Spill Science & 

Technology Bulletin 6 (2): 103-111. 

Johnson, D.R. and M.C. Todd. 1977. Summer Use of a Highway Crossing by Mountain Caribou. The 

Canadian Field-Naturalist 91(3):312-314. 

Johnson, S., D. Wiggins, and P. Wainwright. 1992. Use of Kasegaluk Lagoon, Chukchi Sea, Alaska, by Marine 

Birds and Mammals. Part II: Marine Birds. Herndon, VA: USDOI, MMS, 627 pp. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 331 

Johnson, S.R. and D.R. Herter. 1989. The Birds of the Beaufort Sea. Anchorage, AK: BPXA. 

Johnson, S.R., D.A. Wiggins, and P.F. Wainwright. 1992. Use of Kasegaluk Lagoon, Chukchi Sea, Alaska, by 

Marine Birds and Mammals, II: Marine Birds. Unpublished report. Herndon, VA: USDOI, MMS, pp. 

57-510. 

Johnson, S., K. Frost, and L. Lowry. 1996. Use of Kasegaluk Lagoon, Chukchi Sea, Alaska, by Marine Birds 

and Mammals, Part I: An Overview. Herndon, VA: USDOI, MMS, 627 pp. 

Johnson, S.R., K.J. Frost, and L.F. Lowry. 1992. Use of Kasegaluk Lagoon, Chukchi Sea, Alaska, by Marine 

Birds and Mammals, Volume I: An Overview. OCS Study MMS 92-0028. Anchorage, AK: USDOI, 

MMS, Alaska OCS Region, pp. 4-56. 

Joly, K., C. Nellemann, and I. Vistness. 2006. A Reevaluation of Caribou Distribution near an Oilfield Road on 

Alaska’s North Slope. Wildlife Society Bulletin 34:866-869. 

Jones, M.L. and S.L. Swartz. 1984. Demography and Phenology of Gray Whales and Evaluation of WhaleWatching Activities in Laguna San Ignacio, Baja California Sur, Mexico. In: The Gray Whale, M.L. 

Jones, S.L. Swartz, and S. Leatherwood, eds. New York: Academic Press, pp. 309-372. 

Jones, P.D. and A.Moberg. 2003. Hemispheric and Large-Scale Surface Air Temperature Variations: An 

Extensive Revision and an Update to 2001. Journal of Climate 16:206-223. 

Jonsson, H., Sundt, R.C., Aas, E., Sanni, S., 2010. The Arctic is no longer put on ice: evaluation of polar cod 

(Boreogadus saida) as a monitoring species of oil 

Jordan, R.E. and J.R. Payne. 1980. Fate and Weathering of Petroleum Spills in the Marine Environment: A 

Literature Review and Synopsis. Ann Arbor, MI: Ann Arbor Science Publishers, Inc., 174 pp. 

Joye, S.B., I.R. MacDonald, I. Leifer and V. Asper. 2011. Magnitude and oxidation potential of hydrocarbon 

gases released from the BP oil well blowout. Nature Geoscience: published online Feb. 13, 2011. 

doi:10.1038/ngeo1067. 

Khan, S., M. Martin, J. F. Payne, and A. D. Rahimtula. 1987. Embyotoxic Evaluation of a Prudoe Bay crude oil 

in rats. Toxicology Letters 38: 109-114. 

Karcher, M., Harms, I., Standring, W.J.F., Dowdall, M., Strand, P. 2010. On the Potential for Climate Change 

impacts on Marine Anthropogenic Radioactivity in the Arctic Regions. Marine Pollution Bulletin (60). 

Pp. 1151-1159. 

Kato, H. 1982. Food Habits of Largha Seal Pups in the Pack Ice Area. Scientific Report No. 34. Tokyo, Japan: 

Whales Research Institute, pp. 123-136. 

Kelly, B.P. 1988. Ringed Seal. In: Selected Marine Mammals of Alaska: Species Accounts with Research and 

Management Recommendations, J.W. Lentfer, ed. Washington, DC: Marine Mammal Commission, 

pp. 57-77. 

Kelly, B.P., J. L. Bengtson, P. L. Boveng, M. F. Cameron, S. P. Dahle, J. K. Jansen, E. A. Logerwell, J. E. 

Overland, C. L. Sabine, G. T. Waring, and J. M. Wilder 2010. Status review of the ringed seal (Phoca 

hispida). U.S. Dep. Commer., NOAA Tech. Memo. NMFS-AFSC-212. 250 pp. 

Kessler, J. D.; Valentine, D. L.; Redmond, M. C.; Du, M.; Chan,E. W.; Mendes, S. D.; Quiroz, E. W.; 

Villanueva, C. J.; Shusta, S. S.; Werra, L. M.; Yvon-Lewis, S.; Weber, T. C.. 2011. A persistent 

oxygen anomaly reveals the fate of spilled methane in the deep Gulf of Mexico. Science 331: 312-315 
BOEMRE Sale 193 Revised Draft SEIS 

332 Literature Cited

Khan RA and JF Payne. 2005. Influence of a crude oil dispersant, Corexit 9527, and dispersed oil on capelin 

(Mallotus villosus), Atlantic cod (Gadus morhus), longhorn sculpin (Myoxocephalus 

octodecemspinosus), and cunner (Tautogolabrus adspersus). Environmental Contamination & 

Toxicology 75(1): 50-56. 

Kiceniuk JW, WR Penrose, and WR Squires. 1978. Oil Spill Dispersants Cause Bradycardia in Marine Fish. 

Marine Pollution Bulletin 9(2): 42-45. 

King, J.G. 1970. The swans and geese of Alaska's Arctic Slope. Wildfowl Trust 21:11-17. Annual Report. 

Kinney, P.J., ed. 1985. Environmental Characterization and Biological Utilization of Peard Bay. OCS Study 

MMS 85-0102. Anchorage, AK: USDOC, NOAA, and USDOI, MMS, pp. 97-440. 

Klondike 1 well, 1989, Geochemistry data, steam-still analysis of whole oil, whole-oil chromatogram, and 

biomarker studies of saturates: Well Data files, Bureau of Ocean Energy Management Regulation and 

Enforcement, 3801 Centerpoint Drive, Anchorage, AK 99503. 

Kochnev, A.A. 2004. Warming of the Eastern Arctic and Present Status of the Pacific Walrus (Odobenus 

rosmarus divergens) Population. In: Marine Mammals of the Holarctic, V.M. Belkovich, ed. Moscow: 

KMK Scientific Press, 609 pp. 

Kochnev, A.A., V.M. Etylin, I. Kavry, E.B. Siv-Siv, and V. Tanko. 2003. Traditional Knowledge of Chukotka 

Native Peoples Regarding Polar Bear Habitat Use. Final Report. Anchorage, AK: USDOI, National 

Park Service, 165 pp. 

Konar, B. 2007. Recolonization of a High Latitude Hard Bottom Nearshore Community. Polar Biology 30:663-

667. 

Kooyman, G. L., R. L. Gentry and W. B. McAlister. 1976. Physiological Impact of Oil on Pinnipeds. USDOC, 

NMFS, Seattle, WA. 23 pp. 

Koski, W., J. Mocklin, A. Davis, j. Zeh, D. Rugh, J. C. George, and R. Suydam. 2008. Preliminary Estimates of 

2003-2004 Bering-Chukchi-Beaufort Bowhead Whales (Balaena mysticetus) Abundance from PhotoIdentification Data. Unpubl. report to Int. Whal. Comm. (SC/60/BRG18). 7 pp. 

Koski, W.R., J. Zeh, J. Mocklin, A.R. Davis, D.J. Rugh, J.C. George and R. Suydam. 2010. Abundance of 

Bering Chukchi-Beaufort bowhead whales (Balaena mysticetus) in 2004 Estimated from PhotoIdentification Data. J Cetacean Res. Manage. 11(2): 89-99. 

Kosobokova, K. N., and R. Hopcroft. 2010. Diversity and vertical distribution of mesozooplankton in the 

Arctic's Canada Basin. Deep Sea Research Part II: Topical Studies in Oceanography 57 (1-2) (1): 96-

110. 

Kosobokova, K.N., and R. Hopcroft, 2010. Diversity and vertical distribution of mesozooplankton in the 

Arctic's Canada Basin. Deep Sea Research Part II: Topical Studies in Oceanography 57 (1-2) (1): 96-

110. 

Kovacs, K.M., C. Lydersen, J.E. Overland, and S.E. Moore. 2010. Impacts of Changing Sea-ice Conditions on 

Arctic Marine Mammals. Marine Biodiversity. 

Kraus, S., A. Read, E. Anderson, K. Baldwin, A. Solow, T. Spradlin, and J. Williamson. 1997. A Field Test of 

the Use of Acoustic Alarms to Reduce Incidental Mortality of Harbor Porpoise in Gill Nets. Nature 

388:341. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 333 

Kruse, J. 1982. Subsistence and the North Slope Inupiat: The Effects of Energy Development. Monograph No. 

4. Anchorage, AK: University of Alaska, Anchorage, Institute of Social and Economic Research. 

Kruse, J., J. Kleinfeld, and R. Travis. 1981. Energy Development and the North Slope Inupiat: Quantitative 

Analysis of Social and Economic Change. Man in the Arctic Program, Monograph No. 1 Anchorage, 

AK: University of Alaska, ISER. 

Kruse, J.A. 1991. Alaska Inupiat Subsistence and Wage Employment Patterns: Understanding Individual 

Choice. Human Organization 504. 

Kujawinski, E.B., M.C. Kido Soule, D.L. Valentine, AK. Boysen, K. Longnecker, M.C. Redmond. 2011. Fate 

of Dispersants Associated with the Deepwater Horizon Oil Spill Environ. Sci. Technol. 2011, 45, 

1298–1306 

Kuropat, P., and J. P. Bryant. 1980. Foraging behavior of cow caribou on the Utukok calving grounds in 

northwestern Alaska. Pages 64-70 in E. Reimers, E. Gaare, and S. Skjenneberg, editors. Proceedings of 

the Second International Reindeer/Caribou Symposium, Roros, Norway, 1979. 

Kutz, S.J., E.P. Hoberg, J. Nagy, L. Polley, and B. Elkin. 2004. “Emerging” Parasitic Infections in Arctic 

Ungulates. Integretive and Comparative Biology 44:109-118. 

Laidre, K.L., I. Stirling, L.F. Lowry, Ø. Wiig, M.P. Heide-Jørgensen, and S.H. Ferguson. 2008. Quantifying the 

sensitivity of arctic marine mammals to climate-induced habitat change. Ecological Applications 18(2) 

Supplement: S97-S125. 

Lambertsen, R. H., K.J. Rasmussen, W.C. Lancaster, and R.J. Hintz. 2005. Functional Morphology of the 

Mouth of the Bowhead Whale and its Implications for Conservation. Journal of Mammalogy 862342-

352 

Larned, W.W., R. Stehn, and R. Platte. 2006. Eider Breeding Population Survey Arctic Coastal Plain, Alaska 

2006. Unpublished report. Anchorage, AK: USDOI, FWS, Migratory Bird Management, 53 pp. 

Lane, P. V. Z., L. Llinás, S. L. Smith, and D. Pilz. 2008. Zooplankton distribution in the western Arctic during 

summer 2002: Hydrographic habitats and implications for food chain dynamics. Journal of Marine 

Systems 70 (1-2) (3): 97-133. 

Larsen, T. 1985. Polar Bear Denning and Cub Production in Svalbard, Norway. J. Wildlife Management 

492:320-326. 

Lawhead, B.E. 1997. Caribou and Oil Development in Northern Alaska: Lessons from the Central Arctic Herd. 

In: NPR-A Symposium Proceedings, Science, Traditional Knowledge, and the Resources of the 

Northeast Planning Area of the National Petroleum Reserve-Alaska, D. Yokel, comp. Anchorage, Ak., 

Apr. 15-18, 1997. Anchorage, AK: USDOI, MMS and BLM, pp. 7-5 to 7-7. 

Lee, R. F. and D.S. Page. 1997. Petroleum Hydrocarbons and Their Effects in Subtidal Regions after Major Oil 

Spills. Marine Pollution Bulletin 34(11): 928-940. 

Lenart, E.A. 2007. Units 26B and 26C caribou. In: Caribou Management Report of Survey and Inventory 

Activities, 1 July 2004-30 June 2006. Pages 284-308. P. Harper, editor. Alaska Department of Fish 

and Game. Project 3.0. Juneau, Alaska, USA. 

Lent, P.C. 1970. Muskox Maternal Behavior: a Preliminary Description. American Zoologist 104:35. 

Levinton, J. S. 1982. Marine ecology. Englewood Cliffs, CA: Prentice-Hall. 
BOEMRE Sale 193 Revised Draft SEIS 

334 Literature Cited

Lewbel, G.S. 1984. Environmental Hazards to Petroleum Industry Development. In: Proceedings of a 

Synthesis Meeting: The Barrow Arch Environment and Possible Consequences of Planned Offshore 

Oil and Gas Development (Sale 85), J.C. Truett, ed. Girdwood, Ak., Oct. 30-Nov. 1, 1983. 

Anchorage, AK: USDOC, NOAA, OCSEAP, and USDOI, MMS, pp. 31-46. 

Li, H. and Boufadel, M.C. 2010. Long-term persistence of oil from the Exxon Valdez spill in two-layer beaches. 

3(2):96-99. 

Lindsay, B. 2009. Grizzly Bears Take Northern Vacation. The Science Creative Quarterly, (4). 6 pp. Available 

at http://www.scq.ubc.ca/grizzly-bears-take-northern-vacation/. 

Ljungblad, R. W., S. E. Moore, J. T. Clarke, J. C. Bennett. 1986. Aeirial surveys of endangered whales in the 

Northern Bering, Eastern Chukchi and Alaskan Beaufort Seas, 1985: with a seven year review, 1979-

85. OCS Study, MMS 86-0002. NOSC Technical Report 1111. Anchorage, AK; USDOI, MMS, 

Alaska OCS Region. 142 pp. 

Ljungblad, R. W., S. E. Moore, J. T. Clarke, J. C. Bennett. 1987. Distribution, abundance, behavior and 

bioacoustics of endangered whales in the Western Beaufort and Northeastern Chukchi Seas, 1979-86: 

with a seven year review, 1979-85. OCS Study, MMS 87-0039. NOSC Technical Report 1232 

Anchorage, AK; USDOI, MMS, Alaska OCS Region. 213 pp. 

Ljungbad, D. K., S. E. Moore, J. T. Clark, and J. C. Bennett. 1988. Distribution, Abundance, Behavior and 

Bioacoustics of Endangered whales in the Western Beaufort and Northeastern Chukchi Seas, 1979-87. 

Final Report: OSC Study MMS-87-0122. Minerals Management Service, Alaska OCS Region, 

anchorage Alaska. 

Ljungblad, R. W. and D.R. Van Schoik,. 1982. Aerial surveys of endangered whales in the, Northern Bering, 

Eastern Chukchi, and Alaskan Beaufort Seas, Spring 1984. Anchorage, AK; USDOI, MMS, Alaska 

OCS Region,;35 pp.+ appendices. 

Logerwell, E., K. Rand, S.Parker-Stetter, J. Horne, T. Weingartner, and B. Bluhm. 2010. Beaufort Sea Marine 

Fish Monitoring 2008: Pilot Survey and Test of Hypotheses. Report BOEMRE 2010-048. Alaska OCS 

Region. Anchorage, AK 262 pp. 

Long, E.R., D.D. MacDonald, S.L. Smith, and F.D. Calder. 1995. Incidence of Adverse Biological Effects 

within the Ranges of Chemical Concentrations in Marine and Estuarine Sediments. Environmental 

Management 19:81-97. 

Long, E.R., L.J. Field, and D.D. Macdonald. 1998. Predicting Toxicity in Marine Sediments with Numerical 

Sediment Quality Guidelines. Environ. Toxicol. Chem. 17:714-727. 

Long, F., Jr. 1993. (Testimony). Public Meeting on the Letter of Authorization (LOA) for Bowhead Whale 

Monitoring at the Kuvlum Prospect, Beaufort Sea, Barrow, Alaska, June 4 and 5, 1993, National 

Marine Fisheries Service. Anchorage, AK: National Marine Fisheries Service, 16 pp. 

Lonne, O. and B. Gullickson. 1989. Size, age, diet of polar cod (Boreogadus saida) in ice covered waters. Polar 

Biology 9: 187-191. 

Loughlin, T. R. 1994. Marine Mammals and the Exxon Valdez. San Diego, CA: Academic Press, Inc. 

Lowry, L. and K. Frost. 1981. Distribution, growth and foods of arctic cod (Boreogadus saida) in the Bering, 

Chukchi and Beaufort seas. The Canadian Field Naturalist 95: 186-190. 

Lowry, L., Frost, K., and J. Burns. 1980. Feeding of Bearded Seals in the Bering and Chukchi Seas and Trophic 

Interaction with Pacific Walruses. Arctic 33(2):330-342 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 335 

Lowry, L.F., K.J. Frost, R. Davis, D.P. DeMaster, and R.S. Suydam. 1998. Movements and Behavior of 

Satellite-Tagged Spotted Seals (Phoca larga) in the Bering and Chukchi Sea. Polar Biology 9(4):221-

230. 

Lowry, L.F., R. R. Nelson, and K. J. Frost. 1987. Observations of killer whales, (Orcinus orca), in western 

Alaska: Sighting, strandings and predation on other marine mammals. Canadian Field-Naturalist 

101:6–12. 

Lubchenco J, McNutt M, Lehr B, Sogge M, Miller M, Hammond S, Conner W. 2010. Deepwater Horizon/BP 

Oil Budget: What happened to the oil? Silver Spring, MD: National Oceanic and Atmospheric 

Administration. Available at http://www.noaanews.noaa.gov/stories2010/PDFs/ 

OilBudget_description_%2083final.pdf. 

Lysne, L.A., E.J. Mallek, and C.P. Dau. 2004. Near Shore Surveys of Alaska's Arctic Coast, 1999-2003. 

Fairbanks, AK: USDOI, FWS, 60 pp. 

MacDonald, I. R., B. A. Bluhm, K. Iken, S. Gagaev, and S. Strong. 2010. Benthic macrofauna and megafauna 

assemblages in the Arctic deep-sea Canada Basin. Deep Sea Research Part II: Topical Studies in 

Oceanography 57 (1-2) (1): 136-52. 

Mackay, D. and P.G. Wells. 1983. Effectiveness, Behavior, and Toxicity of Dispersants. In: Proceedings of the 

1983 Oil Spill Conference (Prevention, Behavior, Control, Cleanup), San Antonio, Tex., Feb. 28-Mar. 

3, 1983. Washington, DC: American Petroleum Institute, pp. 65-71. 

Madsen, J. 1985. Impact of Disturbance on Field Utilization of Pink-Footed Geese in West Jutland, Denmark. 

Biological Conservation 33:53-63. Mahoney, A., Eicken, H., Shapiro, L. 

Magoon, L.B., and Bird, K.J., 1985, Alaskan North Slope Petroleum Geochemistry for the Shublik Formation, 

Kingak Shale, Pebble Shale, and Torok Formation: in: Alaska North Slope Oil/Rock Correlation 

Study, American Association of Petroleum Geologists, Studies in Geology No. 20, Magoon, L.B., and 

Claypool, G.E. (eds.), pp. 31-48. 

Magoon, L.B., and Claypool, G.E., 1981, Two oil types on North Slope of Alaska—implications for 

exploration: American Association of Petroleum Geologists Bulletin, v. 65, no. 4, p.644-652. 

Mahon, S., R.F. Addison and D.E. Willis. 1987. Effects of Scotian Shelf Natural Gas Condensate on the 

Mummichog. Marine Pollution Bulletin 18(2) 74-77. 

Manen, C.A. and M.J. Pelto. 1984. Transport and Fate of Spilled Oil. In: Proceedings of a Synthesis Meeting: 

The North Aleutian Shelf Environment and Possible Consequences of Offshore Oil and Gas 

Development (Sale 75), L.K. Thorsteinson, ed. Anchorage, Ak., Mar. 9-11, 1982. Anchorage, AK: 

USDOC, NOAA, OCSEAP and USDOI, MMS, Alaska OCS Region, pp. 11-34. 

Mar, Inc., SL Ross Environmental Research Ltd., D.F. Dickins Associates Ltd., and Emergencies Science and 

Technology Division. Empirical Weathering Propoerties of Oil in Ice and Snow. 2008. Anchorage, 

AK. USDOI, MMS, Alaska OCS Region. OCS Study MMS 2008-033. 166 pp. 

Marmot, M. and R. Wilkinson. 2004. Social Determinants of Health: The Solid Facts. Geneva: World Health 

Organization. 
BOEMRE Sale 193 Revised Draft SEIS 

336 Literature Cited

Martin, B., Laurinolli, M., Hannay D., and Bohan, R. 2008. Chukchi Sea Acoustic Monitoring Program. In: 

Funk, D.W., Rodrigues, R., Funk, D.S., and Koski, W.R. (eds). Joint monitoring program in the 

Chukchi and Beaufort seas, July-November 2007. LGL Alaska Report P971-1, Report from LGL 

Alaska Research Associates, Inc., LGL Ltd., JASCO Research, Ltd., and Greeneridge Sciences, Inc., 

for Shell Offshore, nc., ConocoPhillips Alaska, Inc., and National Marine Fisheries Service, U.S. Fish 

and Wildlife Service. 445 pp. plus Appendices. 

Masterson, W.D., 2001, Petroleum filling history of central North Slope fields, Ph.D. thesis, University of 

Texas at Dallas, 222 pp. 

Matkin, C. O., E. L. Saultis, G. M. Ellis, P. Olesuik, S. D. Rice. 2008. Ongoing population-level impacts on 

killer whales Orincus orca following the ‘Exxon Valdez’ oil spill in Prince William Sound, Alaska. 

Marine Ecology Progress Series 356: 269-281. 

McCain, W.D., Jr., 1973, The Properties of Petroleum Fluids: Petroleum Publishing Company, Tulsa, OK, 325 

pp. 

McFarlin, K.M., R. A. Perkins, W. W. Gardiner, J. D. Word and J. Q. Word. 2011. Toxicity of physically and 

chemically dispersed oil to selected Arctic species. Unpublished Manuscript Control Number 149, 

Submitted 17 January 2011. International Oil Spill Conference Proceedings of the Workshop. 

McNutt, M.; Camilli, R.; Guthrie, G. Hsieh H.; Labson, V.; Lehr, B. Maclay D.; Ratzel, A., and Sogge, M. 

2011 Assessment of Flow Rate Estimates for the Deepwater Horizon / Macondo Well Oil Spill Flow 

Rate Technical Group report to the National Incident Command, Interagency Solutions Group. 

Washington, D.C.: U.S. Department of Interior. Available at http://www.doi.gov/deepwaterhorizon/ 

loader.cfm?csModule=security/getfile&PageID=237763. 

McLellan, B. and D.M. Shackleton. 1989. Immediate Reactions of Grizzly Bears to Human Activities. 

Wildlife Society Bulletin 17:269-274. 

McLellan, B.N. 1990. Relationships Between Human Industrial Activity and Grizzly Bears. In: Eighth 

International Conference on Bear Research and Management. Bears-Their Biology and Mangement, 

L.M. Darling and W.R. Archibald, eds. Victoria, B.C. Vancouver, BC, Canada: International 

Association for Bear Research and Management, pp. 57-64. 

McMullen, E. 1993. Testimony dated March 24, 1993, of Elenore McMullen, Chief, Native Village of Port 

Graham, Alaska, before the U.S. House of Representatives’ Committee on Merchant Marine and 

Fisheries. Washington, DC: U.S. Government Printing Office. 

Mecklenburg C.W., P. R.Møller and D. Steinke. 2011. Biodiversity of arctic marine fishes: taxonomy and 

zoogeography. Marine Biodiversity 41:109-140 

Mecklenburg CW, Stein DL, Sheiko BA, Chernova NV, Mecklenburg TA, Holladay BA. 2007. Russian–

American Long-term Census of the Arctic: benthic fishes trawled in the Chukchi Sea and Bering Strait, 

August 2004. Northwest Nat 88: 168–187 

Mecklenburg, C. W., T.A. Mecklenburg, and L.K. Thorsteinson. 2002. Fishes of Alaska. Bethesda, MD: 

American Fisheries Society. 

Melinger, D, K., K. M. Stafford, C. L. Berchok, J. Delarue. 2010. Where do the Chukchi Sea fin whales come 

from? Looking for answers in the structure of songs recorded in the Bering Sea and Western North 

Pacific. JASCO Appl. Sci., 432-1496 Lower Water St., Halifax, NS B3J 1R9, Canada NOAA / AFSC, 

Seattle, WA 98115. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 337 

Melinkov, V. V., I. A. Zagrebin, G. M. Zelensky, L. I. Ainana. 2007. Killer Whales (Orincus orca) in waters 

adjacent to the Chukotka Peninsula. J. Cetacean Res. Manage 9(1): 53-63. 

Michel, J. 1992. Chapter 2. Oil behavior and toxicity. In: Introduction to coastal habitats and biological 

resources for spill response. NOAA Report No. HMRAD 92-4. U.S. Dept. of Commerce, National 

Oceanic and Atmospheric Administration, Office of Response and Restoration. 

Miles, P. R., C. I. Malme, and W. J. Richardson. 1987. Prediction of drilling site-specific interactions of 

industrial acoustic stimuli and endangered whales in the Alaskan Beaufort Sea. OCS Study MMS 87-

0084. Anchorage, AK, USDOI, Alaska OCS Region, 341 pp. 

Millennium Ecosystems Assessment. 2005. Ecosystems and Human Well-Being Synthesis. Washington, DC: 

Center for Resource Economics, Island Press. 

Miller S.D. and M.A. Chihuly. 1987. Characteristics of Nonsport Brown Bear Deaths in Alaska. In: Seventh 

International Conference on Bear Research and Management-Bears- their Biology and Management, 

P. Zager, J. Beecham G. Matula H. Reynolds III, eds. Williamsburg, Va. Washington, DC: Port City 

Press, Inc, pp. 51-58. 

Miller, ER, F.L., and A. Gunn. 1980. Behavioral Responses of Muskox Herds to Simulation of Cargo Slinging 

by Helicopter, Northwest Territories. Canadian Field-Naturalist. 94:52-60 

Miller, F.L. and A. Gunn. 1979. Responses of Peary Caribou and Muskoxen to Turbo-Helicopter Harassment, 

Prince of Wales Island, Northwest Territories, 1976-1977. Occasional Paper No 40. Edmonton, Alb., 

Canada: Canadian Wildlife Service, 90 pp. 

Miller, G.W. 2002. Seismic Program Described, 2001. In: Marine Mammal and Acoustical Monitoring of 

Anderson Exploration Limited's Open-Water Seismic Program in the Southeastern Beaufort Sea, 2001, 

LGL and JASCO Research Ltd, eds. LGL Report TA 2618-1. King City, Ont., Canada: LGL 

Ecological Research Associates, Inc., 207 pp. 

Miller, G.W., R.E. Elliott, and W.J. Richardson. 1998. Whales. In: Marine Mammal and Acoustical 

Monitoring of BP Exploration (Alaska)'s Open-Water Seismic Program in the Alaskan Beaufort Sea, 

1997, LGL and Greeneridge, eds. LGL Report TA 2150-3. King City, Ont., Canada: LGL Ecological 

Research Associates, Inc., 124 pp. 

Mitson, R.B. and H.P. Knudsen. 2003. Causes and Effects of Underwater Noise on Fish Abundance 

Estimation. Aquatic Living Resources 16:255-263. 

Mobley, C.M., J.C. Haggarty, C.J. Utermohle, M. Eldridge, R.E. Reanier, A. Crowell, B.A. Ream, D.R. Yeaner, 

J.M. Erlandson, P.E. Buck, W.B. Workman, and K.W. Workman. 1990. The 1989 Exxon Valdez 

Cultural Resource Program. Anchorage, AK: Exxon Shipping Company and Exxon Company, USA, 

300 pp. 

Mohr, J.L., N.J. Wilimovsky, and E.Y. Dawson. 1957. An Arctic Alaskan Kelp Bed. Arctic 10 (1): 45-52. 

Moles, A. and B. Norcross. 1998. Effects of oil-laden sediments on growth and health of juvenile flatfishes. 

Canadian Journal of Fisheries and Aquatic Sciences 55:605-610. 10.1139/f97-278 

Moles, A. and T.L. Wade. 2001. Parasitism and Phagocytic Function among Sand Lance Ammodytes 

hexapterus Pallas Exposed to Crude Oil-Laden Sediments. Bull. Environ. Contam. Toxicol. 66:528-

535. 
BOEMRE Sale 193 Revised Draft SEIS 

338 Literature Cited

Monnett, C. 2010. Maps of tagged belugas. e-mail report from R. Suydam, NSB Wildlife Department, Barrow, 

AK to C. Monnett. Subject: maps of tagged beluga locations and note of an observation of 500-1000 

belugas in Elson Lagoon from Plover Point in late July of 2010. 

Monnett, C. and S.D. Treacy. 2005. Aerial Surveys of Endangered Whales in the Beaufort Sea Fall 2002-2004. 

OCS Study MMS 2005-037. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

Moore, S.E. and Clarke, J.T. 1992. Patterns of bowhead whale distribution and abundance near Barrow, Alaska, 

in fall 1982-1989. Marine Mammal Science 8(1): 27-36. 

Moore, S.E. and J.T. Clarke. 2002. Potential Impact of Offshore Human Activities on Gray Whales 

(Eschrichtius robustus). Cetacean Research and Management 4(1):19-25. 

Moore S.E. and D.P. DeMaster. 1997. Cetacean Habitats in the Alaskan Arctic. Journal of Northwest Atlantic 

Fishery Science 22:55-69. 

Moore, S. E. , D. P. DeMaster, and P. K. Dayton. 2000. Cetacean habitat selection in the Alaska Arctic in 

Summer and Autumn. Arctic 53:432-447. 

Moore, S.E. and R.R. Reeves. 1993. Distribution and movement. p. 313-386 In: J.J. Burns, J.J. Montague, and 

C.J. Cowles (eds.), The bowhead whale. Spec. Publ. 2. Soc. Mar. Mamm., Lawrence, KS. 787 pp. 

Moore, S.E., D.P. DeMaster, and P.K. Dayton. 2000. Cetacean Habitat Selection in the Alaskan Arctic During 

Summer and Autumn. Arctic 53(4):432-447. 

Moore,S. E,. J. C. George, G. Sheffield, J. Bacon, and C. J. Ashijan, 2010. Bowhead Whale Distribution and 

Feeding near Barrow, Alaska, in the late summer 2005-06. Arctic 63(2):195-205. 

Moore, S. E., K. M Stafford, and L. M. Munger. 2010. Acoustic and Visual Surveys for Bowhead Whales in the 

Western Beaufort and far Northeastern Chukchi Seas. Deep Sea Research Part II 57(1-2) 153-157. 

Moss, J.H., J.M. Murphy, E.V. Farley, L.B. Eisner, and A.G. Andrews. 2009. Juvenile pink and chum salmon 

distribution, diet, and growth in the northern Bering and Chukchi seas. N. Pac. Anadr. Fish Comm. 

Bull. 5: 191–196. 

Mulherin, N., D. Sodhi, and E. Smallidge. 1994. Northern Sea Route and Icebreaking Technology: An 

Overview of Current Conditions. New Hampshire: U.S. Army Corps of Engineers, Cold Regions 

Research and Engineering Lab, 162 pp. 

Mymrin, N.I., The Communities of Novoe Chaplino, Sireniki Uelen and Yanrakinnot, and H.P. Huntington. 

1999. Traditional Knowledge of the Ecology of Beluga Whales (Delphinapterus leucas) in the 

Northern Bering Sea, Chukotka, Russia. Arctic 52(1):62-70. 

Nahrgang, J., Camus, L., Gonzalez, P., Goksøyr, A., Christiansen, J.S., Hop, H., 2009. PAH biomarker 

responses in polar cod (Boreogadus saida) exposed to benzo(a)pyrene. Aquatic Toxicology 94: 309–

319 

Nahrgang, J., Camus, L., Gonzalez, P., Jönsson, M., Christiansen, J.S., Hop, H. 2010a. Biomarker responses in 

polar cod (Boreogadus saida) exposed to dietary crude oil. Aquatic Toxicology 96:77-83. 

Nahrgang,J, L. Camusa, M.G. Carlsc, P.Gonzalezd, M. Jönssona, I.C. Tabane, R.K. Bechmanne, J.S. 

Christiansen, H. Hop. 2010b. Biomarker responses in polar cod (Boreogadus saida) exposed to the 

water. Aquatic Toxicology 97: 234–242. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 339 

Nahrgang, J., L. Camusa, Fredrik Broms, J.S. Christiansen, H. Hop. 2010c. Seasonal baseline levels of 

physiological and biochemical parameters in polar cod (Boreogadus saida): Implications for 

environmental monitoring. Marine Pollution Bulletin 60:1336–1345 

NASA. 2005. Arctic Sea Ice Continues to Decline, Arctic Temperatures Continue to Rise In 2005. 

National Association for the Advancement of Colored People (NAACP). 2010. NAACP blasts BP for oil spill 

response. July 10, 2010. Available at http://www.naacp.org/blog/entry/naacp-blasts-bp-foroil-spillresponse/. 

National Institute for Occupational Safety and Health (NIOSH). Benzene NOISH Report. Available at 

http://www.cdc.gov/niosh/npg/npgd0049.html. 

National Research Council. 1985. Oil in the Sea: Inputs, Fates, and Effects. Washington, DC: National 

Academy, Press, 601 pp. 

National Research Council. 2003a. Ocean Noise and Marine Mammals. Washington, DC: The National 

Academy Press. 

National Research Council. 2003b. Cumulative Environmental Effects of Oil and Gas Activities on Alaska's 

North Slope. www.nap.edu/openbook/0309087376/html/1.html. Washington, DC: The National 

Academies Press, 465 pp. 

National Research Council (NRC). 2003c. Oil in the Sea III: Inputs, Fates and Effects.Washington, D.C., 

National Academy Press. 280 pp. 

National Research Council. 2005a. Marine Mammal Populations and Ocean Noise. Determining When Noise 

Causes Biologically Significant Effects. Washington, DC: The National Academies Press. 

National Research Council. 2005b. Oil Spill Dispersants Efficacy and Effects. Washington, DC: National 

Academy Press. 

National Resources Defense Council. 1999. Sounding the Depths. Supertankers, Sonar, and the Rise of 

Undersea Noise. Washington, DC: NRDC. 

Neff, J. M. 1990. Effects of oil on marine mammal populations: Model simulations. InL Sea Mammals and Oil: 

Confornting the Risks, J. R. Geraci and D. J. St. Aubine, eds. San Diego, CA: Acedemic Press, Inc. 

and Harcourt, Brace Jovanovich, pp 35-54. 

Neff, J. M. 2002. Bioaccumulation in marine organisms: Effect of contaminants from oil well produced water. 

Amsterdam: Elsevier Science. 

Nerini, M. 1984. A review of gray whale feeding ecology. In: Jones, M.L., S.L. Swartz, and S. Leatherwood 

(eds.). The Gray Whale, Eschrichtius robustus. Academic Pres, Inc. Orlando, Fl. pp. 423–450. 

Newell, J. 2004. The Russian Far East: A Reference Guide for Conservation and Development. McKinleyville, 

CA: Daniel & Daniel Publishers, Inc. in association with Friends of the Earth, Japan. 

Newman, M. C., and W. H. Clements. 2008. Ecotoxicology: A comprehensive treatment. Boca Raton, FL: 

CRC. 

Nighswander, T.S. and N. Peacock. 1999. The Communication of Health Risk from Subsistence Food in a 

Cross Cultural Setting: Lessons Learned from the Exxon Valdez Oil Spill. In: Evaluating and 

Communicating Subsistence Seafood Safety in a Cross-Cultural Context,L.J. Field, J.A. Fall, T.S. 

Nighswander, N. Peacock, and U. Varanasi, eds. Pensacola, FL: SETAC Press, 338 pp. 
BOEMRE Sale 193 Revised Draft SEIS 

340 Literature Cited

Nihoul, J. C. & Kostianoy, A. G. Eds. 2009. Influence of Climate Change on the Changing Arctic and SubArctic Conditions. Chapter Mesoscale atmospheric vortices in the Okhotsk and Bearing Seas: Results 

of satellite multisensory study, by Mitnik, L. Springer Netherlands: Belgium. doi 10-1007/978-1-4020-

9460-6. 

NMFS. 2003a. Biological Opinion on Issuance of Annual Quotas Authorizing the Harvest of Bowhead Whales 

to the Alaska Eskimo Whaling Commission for the Period 2003 through 2007. Anchorage, AK: 

USDOC, NMFS. 

NMFS. 2003b. Environmental Assessment for Issuing Annual Quotas to the Alaska Eskimo Whaling 

Commission for a Subsistence Hunt on Bowhead whales for the Years 2003 through 2007. 

Anchorage, AK: USDOC, NMFS, 67 pp. plus appendices. 

NMFS. 2004. White Paper: Large Whale Ship Strikes Relative to Vessel Speed. Unpublished Draft Document. 

Available from: http://www.nmfs.noaa.gov/pr/pdfs/shipstrike/ss_speed.pdf (Accessed 7 January 2011). 

NMFS. 2008. Endangered Species Act, Section 7 Consultation: Biological Opinion: Oil and Gas Leasing and 

Exploration Activities in the U.S. Beaufort and Chukchi Seas, Alaska and Authorization of Small 

Takes Under the Marine Mammal Protection Act. Seattle, WA: USDOC, NOAA, 140 pp. Available at 

http://www.mms.gov/alaska/ref/BioOpinions/2008_0717_bo.pdf. 

NMFS. 2010. Cetacean Assessment and Ecology Program Bowhead Whale Aerial Surveys: Preliminary Data. 

USDOC, NOAA, National Marine Fisheries Service, Alaska Fisheries Science Center, National 

Marein Mammal Laboratory. Available at http://www.afsc.noaa.gov/nmml/cetacean/bwasp/index.php. 

NMFS-ORR. 2011. Environmental Sensitivity Rankings and Maps. Available at http://oceanservice.noaa.gov/ 

dataexplorer/. Accessed on April 14, 2011. 

NOAA, 1983. Nowruz Oil Field. Incident News Emergency Response Division, Office of Response and 

Restoration. Available at http://www.incidentnews.gov/incident/6262. 

NOAA. 1994. Shoreline Countermeasures Manual, Alaska, NOAA Hazardous Materials Response and 

Assessment Division, published in 2001 by the American Petroleum Institute. 

NOAA. 2006a. Biological Opinion: Oil and Gas Leasing and Exploration Activities in the U.S. Beaufort and 

Chukchi Seas, Alaska. Seattle, WA: USDOC, NOAA. 

NOAA. 2010. Deep Water Horizon MC252 Gulf Incident Oil Budget. Available at 

http://www.noaanews.noaa.gov/stories2010/PDFs/DeepwaterHorizonOilBudget20100801.pdf. 

NOAA. 2011a. Responding to Oil Spills–In Situ Burning-Environmental Impacts–What are the potential 

ecological effects of in-situ burning (ISB). NOAA Office of Response and Restoration website. 

Available at http://response.restoration.noaa.gov (accessed on April 24, 2011). 

NOAA. 2011b. Tides Under the Ice: Measuring Water Levels at Barrow, Alaska 2008-2011. U.S. Hydro 

Conference Proceedings, Tampa, Florida. Submitted May 2011. 

NOCOR Engineering and Research. 1975. The interaction of crude oil with Arctic sea ice, Beaufort Sea. 

Technical Report No. 27. Victoria, BC: Canada Department of the Environment. Beaufort Sea Project, 

145+ pp. 

Norcross, B.L., B.A. Holladay, M.S. Busby and K.L. Mier. 2010. Demersal and larval fish assemblages in the 

Chukchi Sea. IN: Observations and Exploration of the Arctic's Canada Basin and the Chukchi Sea: the 

Hidden Ocean and RUSALCA Expeditions Deep Sea Research Part II: Topical Studies in 

Oceanography. 57(1-2): 57-70. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 341 

North Slope Borough. 1997. Subsistence Harvest Documentation Project Data for Nuiqsut, Alaska. Barrow, 

AK: North Slope Borough. 

North Slope Borough. 1998. Economic Profile and Census Report. Barrow, AK: North Slope Borough. 

North Slope Borough. 1999. North Slope Borough 1998/99 Economic Profile and Census Report. Vol. VIII. 

Barrow, AK: North Slope Borough, Dept. of Planning and Community Services. 

Northern Economics, Inc. 2006. The North Slope Economy, 1965-2006. OCS Study, MMS 2006-020. 

Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

NPFMC. 2009. Fishery Management Plan for Fish Resources of the Arctic Management Area. Anchorage, AK. 

North Pacific Fishery Management Council (NPFMC). 147 pp. 

NPFMC. 1990. Fishery Management Plan for the Salmon Fisheries in the EEZ off the Coast of Alaska. 

Anchorage, AK. North Pacific Fishery Management Council (NPFMC). 210 pp. 

NSIDC. 2000. Arctic climatology and meteorology: Winds in the arctic. Available at 

http://nsidc.org/arcticmet/factors/winds.html; taken from the Arctic Climatology Project. 2000. 

Environmental Working Group Arctic meteorology and climate atlas. Edited by F. Fetterer and V. 

Radionov. Boulder, CO: National Snow and Ice Data Center. CD-ROM. 

NSIDC. 2007. Arctic Sea Ice Shatters All Previous Record Lows. NSIDC Press Release. 1 October 2007. 

Boulder, CO: Cooperative Institute for Research in Environmental Sciences, National Snow and Ice 

Data Center, 5 pp. Available at http://nsidc.org/news/press/2007_seaiceminimum/ 

20071001_pressrelease.html. 

NSIDC. 2010a. Weather and Feedbacks Lead to Third-lowest Extent. NSIDC Press Release. Boulder, Co: 

Cooperative Institute for Research in Environmental Sciences, National Snow and Ice Data Center; 

2010; 4 October 2010. 5 pp. Available at http://nsidc.org/arcticseaicenews/2010/100410.html 

(accessed October 5, 2010). 

NSIDC. 2010b. Updated minimum Arctic Sea Ice Extent. NSIDC Press Release. Boulder, Co: Cooperative 

Institute for Research in Environmental Sciences, National Snow and Ice Data Center; 2010; 27 

September 2010. 3pp. Available at http://nsidc.org/arcticseaicenews/2010/092710.html (accessed 

October 5, 2010). 

Nuttall, M. 2005. Encyclopedia of the Arctic. New York: Routledge. 

Ocean Studies Board. 2005. Oil Spill Dispersants: Efficacy and Effects. National Research Council of the 

National Academies Division on Earth and Life Studies. National Academies Press: Washington, D.C. 

Available at http://books.nap.edu/openbook.php?record_id=11283&page=R1 

Oechel, W.C. and K. Van Cleve. 1986. The Role of Bryophytes in Nutrient Cycling in the Taiga. In: Forest 

Ecosystems in the Alaskan Taiga, K. Van Cleve, F.S. Chapin, III. P.W. Flanagan, L.A. Viereck, and 

C.T. Dryness, eds. New York: Springer-Verlag, pp. 121-137. 

O'Hara, K., N. Atkins, and S. Ludicello. 1986. Marine Wildlife Entanglement in North America. Washington, 

DC: Center for Marine Conservation, 219 pp. 

Okkenon, S. R., C. J. Ashijan, R. G. Campbell, D. Jones. 2009. Upwelling and aggregation of zooplankton on 

the western Beaufort Shelf as inferred from acoustic Doppler current profiler measurements. Alaska 

Marine Science Symposium, Jan. 19-22, 2009, Anchorage, AK. 
BOEMRE Sale 193 Revised Draft SEIS 

342 Literature Cited

Olesiuk, P.E., L.M. Nichol, M.J. Sowden, and J.K.B. Ford. 1995. Effect of Sounds Generated by Acoustic 

Deterrent Device on the Abundance and Disribution of Harbor Porpoise (Phocoena phocoena) in 

Retreat Passage, British Columbia. Nanaimo, BC, Canada: Fisheries and Oceans Canada, Pacific 

Biological Station, 47 pp. 

Olson, T.L. and B.K. Gilbert. 1994. Variable Impacts of People on Brown Bear Use of an Alaskan River. In: 

Ninth International Conference on Bear Research and Management, J.J. Claar and P. Schullery, eds. 

Missoula, Mont. Victoria, BC, Canada: International Assoc. for Bear Research and Management, 500 

pp. 

OSIR, 1998. Oil Spills from Production and Exploration Activities Vol II no. 8. Cutter Information Corp. 4 pp. 

Ott, R., C. Peterson, and S. Rice. 2001. Exxon Valdez Oil Spill (EVOS) Legacy: Shifting Paradigms in Oil 

Ecotoxicology. http://www.alaskaforum.org. 

Overland, J.E. and M. Wang. 2007. Future Regional Arctic Sea Ice Declines. Geophysical Research Letters 

34: L17705. 

Overland, James E and Wang, Muyin. 2010. Large-Scale Atmospheric Circulation Changes Are Associated 

With the Recent Loss of Arctic Sea Ice. Tellus. Series a: Dynamic Meteorology and Oceanography 

62(1): 1-9. 

Owens, E., and J. Michel. 2003. Environmental Sensitivity Index (ESI) Classification for the Beaufort Sea and 

Chukchi Sea Coasts, Alaska OCS Region. In: Ninth Information Transfer Meeting and Barrow 

Information Update Meeting, Final Proceedings, March 10, 11, and 12, 2003, Anchorage, Alaska; 

March 14, 2003, Barrow, Alaska. OCS Study MMS 2003-042. U.S. DOI/MMS, Alaska OCS Region. 

Owens, Edward H., Taylor, Elliott, and Humphrey, Blair. 2008. The persistence and character of stranded oil on 

coarse-sediment beaches. Marine Pollution Bulletin 561:14-26. 

Paine, R.T. and S.A. Levin. 1981. Inter-Tidal Landscapes: Disturbance and the Dynamics of pattern. Ecol. 

Monogr. 51:145-178. 

Painter, P. 2011. The Separation of Oil and Tar from Sand Using Ionic Liquids. Unpublished document. March 

8, 2011. Materials Science and Engineering. Penn State University. Available at 

http://www.matse.psu.edu/news/ionicliquids. Accessed on April 28, 2011. 

Palinkas, L.A., J.S. Petterson, J.C. Russell, and M.A. Downs. 2004. Ethnic Differences in Symptoms of PostTramatic Stress after the Exxon Valdez Oil Spill. Prehospital Disaster Medicine 191:102-112. 

Palinkas, L.A., M.A. Downs, J.S. Petterson, and J. Russell. 1993. Social, Cultural, and Psychological Impacts of 

the Exxon Valdez Oil Spill. Human Organization 521:1-13. 

Patenaude M. J., M. J. Smultea, W. R. Koski, W. J. Richardson, and C. R. Greene. 1997. Aircraft sound and 

aircraft disturbance to bowhead and beluga whales during the spring migration in the Alaskan Beaufort 

Sea. King City, Ontario, Canada: LGL Ltd. Environmental Research Associates, 37 pp. 

Patin, S. 1999. Environmental Impact of the Offshore Oil and Gas Industry. East Northport, NY: EcoMonitor 

Publ., 425 pp. 

Paul, J.M., A.J. Paul, and W.E. Barber. 1997. Reproductive Biology and Distribution of the Snow Crab from 

the Northeastern Chukchi Sea. American Fisheries Society Symposium 19:287-294. 

Payne, J. R.; J.R. Clayton, and B.E. Kirstein. 2003. Oil Suspended Particulate Material Interactions and 

Sedimentation. Spill Science and Technology. 2003; 8(2)201-221. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 343 

Payne, J.R., B.E. Kirstein, G.D. McNabb, Jr., J.L. Lambech, R. Redding, R.E. Jordan, W. Hom, C. de Oliveira, 

G.S. Smith, D, M. Baxter, and R. Gaegel. 1984a. Multivariate Analysis of Petroleum Weathering in the 

Marine Environment -Sub Arctic. Vol. I and II Appendix. Technical Results. Environmental 

Assessment of the Alaskan Continental Shelf. Final Reports of Principal Investigators, Vol. 21 (Feb. 

1984). Juneau, AK: USDOC, NOAA, and USDOI, MMS, 686 pp. 

PCCI Marine and Environmental Engineering (PCCI). 1999. Oil spill containment, remote sensing and tracking 

for deepwater blowouts: Status of existing and emerging technologies, final report. Prepared for U.S. 

Dept. of the Interior, Minerals Management Service, Alexandria, VA. Available at 

http://www.boemre.gov/tarprojects/311/311AA.pdf. 

Peacock, N. and L.J. Field., 1999. The March 1989 Exxon Valdez Oil Spill: A Case Study in Responding to 

Subsistence Food Safety Issues. In: Evaluating and Communicating Subsistence Seafood Safety in a 

Cross-Cultural Context, L.J. Field, J.A. Fall, T.S. Nighswander, N. Peacock, and U. Varanasi, eds. 

Pensacola, FL: SETAC Press, 338 pp. 

Peacock, E., R. Nelson, A. Solow, J. Warren, J. Baker, and C. Reddy. 2005. The West Falmouth Oil Spill: 100 

Kg of Oil Found to Persist Decades Later. Environmental Forensics 6:273-281. 

doi:10.1080/15275920500194480. 

Pearson,W.H., D.L. Woodruff and P.C. Sugarman. 1984. The burrowing behavior of sand lance, Ammodytes 

hexapterus: Effects of oil-contaminated food. Marine Environmental Research 11: 17-32. 

Pedersen, S., R.J. Wolfe, C. Scott, and R.A. Caulfield. 2000. Subsistence Economics and Oil Development: 

Case Studies from Nuiqsut and Kaktovik, Alaska. Fairbanks, AK: University of Alaska, Fairbanks, 

Coastal Marine Institute. 

Perovich , W. Meier, J. Maslanik, and J. Richter-Menge. 2010. Sea Ice [in Arctic Report Card 2010]. Available 

at http://www.arctic.noaa.gov/reportcard/seaice.html (accessed December 8, 2010). 

Perry, S.L., D.P. Demaster, and G.K. Silber. 1999b. The Humpback Whale. Marine Fisheries Review 611:24-

37. 

Peters, K.E., Ramos, L.S., Zumberge, J.E., Valin, Z.C., Scotese, C.R., and Gautier, D.L., 2007, Circum-Arctic 

petroleum systems identified using decision-tree chemometrics: American Association of Petroleum 

Geologists Bulletin 91(6): 877-913. 

Petersen, M.R., W.W. Larned, and D.C. Douglas. 1999. At-Sea Distribution of Spectacled Eiders: A 120-YearOld Mystery Resolved. Auk 1164:1009-1020. 

Peterson, C.H., S.D. Rice, J.W. Short, D. Esler, J.L. Bodkin, B.E. Ballachey, and D.B. Irons. 2003. Long-Term 

Ecosystem Responses to the Exxon Valdez Oil Spill. Science 302:2082-2086. 

Peterson, T.C. and R.S. Vose. 1997. An Overview of the Global Historical Climatology Network Temperature 

Database. Bulletin of the American Meteorological Society 78:2837-2849. 

Pezeshki, S.R., M.W. Hester, Q. Lin, and J.A. Nyman. 2000. The effects of oil spill and clean-up on dominant 

US Gulf coast marsh macrophytes: a review. Environmental Pollution 108: 129-139. 

Phillips, R.L. 1991. Written Communication Date Apr. 18, 1991, from R.L. Phillips, USGS, Menlo Park, Calif.; 

Subject: Cores in the northeastern Chukchi Sea 
BOEMRE Sale 193 Revised Draft SEIS 

344 Literature Cited

Phillips, R.L. and T.E. Reiss. 1985. Nearshore Marine Geologic Investigations, Point Barrow to Skull Cliff 

Northeast Chukchi Sea. In: Geologic Processes and Hazards of the Beaufort and Chukchi Sea Shelf 

and Coastal Regions, P.W. Barnes, E. Reimnitz R. E. Hunter R. L. Phillips and S. Wolf, eds. OCSEAP 

Final Reports of Principal Investigators, Vol. 34 (Aug. 1985). Anchorage, AK: USDOC, NOAA, and 

USDOI, MMS, pp. 157-181. 

Phillips, R.L., R.E. Reiss, E. Kempena, and E. Reimnitz. 1982. Nearshore Marine Geologic Investigations - 

Northeast Chukchi Sea, Wainwright to Skull Cliff. In: Geologic Processes and Hazards of the Beaufort 

Sea Shelf and Coastal Region., P.W. Barnes and E. Reimnitz, eds. Annual Report, Att. C. Juneau, AK: 

USDOC, NOAA, OCSEAP, 32 pp. 

Pickart, R. S., T. J. Weingartner, L. J. Pratt, S. Zimmermann, and D. J. Torres. 2005. Flow of wintertransformed pacific water into the western Arctic. Deep Sea Research Part II: Topical Studies in 

Oceanography 52 (24-26) (12): 3175-98. 

Pickart, R.S., L. J. Pratt, D. J. Torres, T. E. Whitledge, A.Y. Proshutinsky, K. Aagaard, T.A. Agnew, G. W. K. 

Moore, and H. J. Dail. 2010. Evolution and dynamics of the flow through herald canyon in the western 

Chukchi Sea. Deep Sea Research Part II: Topical Studies in Oceanography 57 (1-2) (1): 5-26. 

Picou, J.S. and D.A. Gill. 1993. Long-Term Social Psychological Impacts of the Exxon Valdez Oil Spill. In: 

Exxon Valdez Oil Spill Symposium Abstract Book, B. Spies, L.J. Evans, B. Wright, M. Leonard, and 

C. Holba, eds. and comps. Anchorage, Ak., Feb. 2-5, 1993. Anchorage, AK: Exxon Valdez Oil Spill 

Trustee Council; University of Alaska, Sea Grant College Program; and American Fisheries Society, 

Alaska Chapter, pp. 223-226. 

Picou, J.S. and D.A. Gill. 1996. The Exxon Valdez Oil Spill and Chronic Psychological Stress. In: Proceedings 

of the Exxon Valdez Oil Spill Symposium, Anchorage, Ak., Feb. 2-5, 1993. Bethesda, MD: American 

Fisheries Society, pp. 879-893. 

Picou, J.S., D.A. Gill, C.L. Dyer, and E.W. Curry. 1992. Disruption and Stress in an Alaskan Fishing 

Community: Initial and Continuing Impacts of the Exxon Valdez Oil Spill. Industrial Crisis Quarterly 

63:235-257. 

Pinto, J.M., W.H. Pearson, and J.W. Anderson. 1984. Sediment Preferences and Oil contamination in the 

Pacific Sand Lance Ammodytes hexapterus. Marine Biology 83:193-204. 

Polar Research Board. 2003. Cumulative Environmental Effects of Oil and Gas Activities on Alaska’s North 

Slope. National Research Council of the National Academies Division on Earth and Life Studies. 

National Academies Press: Washington, D.C. Available at http://www.nap.edu/ 

openbook.php?record_id=10639&page=R1 

Poppel, B., J. Kruse, G. Duhaime, and L. Abryutina. 2007. Survey of Living Conditions in the Arctic. Results. 

Anchorage, AK: University of Alaska, Anchorage, Institute for Social and Economic Research. 

Popper, A.N., R.R. Fay, C. Platt, and O. Sand. 2003. Sound Detection Mechanisms and Capabilities of Teleost 

Fishes. In: Sensory Processing in Aquatic Environments., S.P. Collin and N.J. Marxhall, eds. New 

York: Springer-Verlag, pp. 338. 

Post, E., and 24 others. 2009. Ecological Dynamics Across the Arctic Associated with Recent Climate Change. 

Science 325:1355-1358. 

Powell, A.N., A.R. Taylor, and R.B. Lanctot. 2005. Pre-Migratory Movements and Physiology of Shorebirds 

Staging on Alaska’s North Slope. Annual Report No. 11. OCS Study MMS 2005-055. Fairbanks, AK: 

University of Alaska, Coastal Marine Institute, pp. 138-146. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 345 

Power, G. 1997. A review of fish ecology in Arctic North America. Pages 13-39 in: J.Reynolds, editor, Fish 

ecology in Arctic North America. American Fisheries Society Symposium 19, Bethesda, Maryland. 

Prince, R. C., R.M. Garrett, R.E. Bare, M.J. Grossman, T. Townsend, J.M. Suflita, K. Lee, E.H. Owens, G.A. 

Sergy, J.F. Braddock, J.E. Lindstrom, and R.R. Lessard. 2003. The Roles of Photooxidation and 

Biodegradation in Long-term Weathering of Crude and Heavy Fuel Oils. Spill Science & Technology 

Bulletin 8(2): 145-156. 

Prince, R.C., E.H. Owens, and G.A. Sergy. 2002. Weathering of an Arctic oil spill over 20 years: the BIOS 

experiment revisited. Baffin Island Oil Spill. Marine Pollution Bulletin,Volume: 44(11): 1236-1242. 

Prince, R.C., E.H. Owens, and G.A. Sergy. 2002. Weathering of an Arctic oil spill over 20 years: the BIOS 

experiment revisited. Baffin Island Oil Spill. Marine Pollution Bulletin,Volume: 44, Issue: 11, 1236-

1242. 

Purcell, J.E., R.R. Hopcroft, K.N. Kosobokova and T.E. Whitledge. 2010. Distribution, abundance, and 

predation effects of epipelagic ctenophores and jellyfish in the western Arctic Ocean. 

doi:10.1016/j.dsr2.2009.08.011. IN: Observations and Exploration of the Arctic's Canada Basin and 

the Chukchi Sea: the Hidden Ocean and RUSALCA Expeditions Deep Sea Research Part II: Topical 

Studies in Oceanography. Volume 57(1-2): 127-135. 

Purser J, Radford AN. 2011. Acoustic Noise Induces Attention Shifts and Reduces Foraging Performance in 

Three-Spined Sticklebacks (Gasterosteus aculeatus). PLoS ONE 6(2): e17478. 

doi:10.1371/journal.pone.0017478. 

Purves, F. 1978. The interaction of Crude Oil and Natural Gas with Laboratory-grown Saline Ice. Prepared by 

ARCTEC Canada Limited for the Environmental Protection Service, Environment Canada, Report No. 

EPS-$-EC-78-9. 

Quakenbush, L. T., R. Suydam, T. Obritschkewitsch, and M. Deering. 2004. Breeding biology of Steller’s 

eiders (Polysticta stelleri) near Barrow, Alaska, 1991-99. Arctic 57: 166-182. 

Quakenbush, L., B. Anderson, F. Pitelka, and B. McCaffery. 2002. Historical and Present Breeding Season 

Distribution of Steller's Eiders in Alaska. Western Birds 33:99-120. 

Quakenbush, L., R.S. Suydam, K.M. Fluetsch, and C.L. Donaldson. 1995. Breeding Biology of Steller's Eiders 

Nesting Near Barrow, Alaska, 1991-1994. Technical Report NAES-TR-95-03. Fairbanks, AK: 

USDOI, FWS, 53 pp. 

Quakenbush, L.T. 1988. Spotted Seal. In: Selected Marine Mammals of Alaska, J.W. Lentfer, ed. Washington, 

DC: Marine Mammal Commission, pp. 107-124. 

Quakenbush, L.T., J.J. Citta, J.C. Craig, R. Smith, and M.P. Heide-Jorgensen. 2009. Fall movements of 

bowhead whales in the Chukchi Sea. Paper presented at the Alaska Marine Science Symposium, 

January 19-23, 2009, Anchorage, AK. 

Quakenbush, L.T.R., J.T. Citta, J.C. George, R.J. Small, Mads Peter Heide-Jorgensen. 2010a. Fall and Winter 

Movements of Bowhead Whales (Balaena mysticetus) in the Chukchi Sea and Within a Potential 

Petroleum Development Area. Arctic 63(3): 289-307, September 2010. 

Quakenbush, L. T., R. J. Small, and J. J. Citta. 2010b. Satellite Tracking of Western Arctic Bowhead Whales. 

OCS Study BOEMRE 2010-033. Anchorage, AK: USDOI, BOEMRE, Alaska OCS Region, 65 pp. 

(plus appendices). 
BOEMRE Sale 193 Revised Draft SEIS 

346 Literature Cited

Quijón, P. A., M. C. Kelly, and P. V. R. Snelgrove. 2008. The role of sinking phytodetritus in structuring 

shallow-water benthic communities. Journal of Experimental Marine Biology and Ecology 366 (1-2) 

(11/15): 134-45. 

Radford, C.A., J. A. Stanley, C. T. Tindle, J. C. Montgomery, A. G. Jeffs. 2010. Localised coastal habitats have 

distinct underwater sound signatures. Marine Ecology Progress Series 401: 21–29. 

Rahn, K.A. 1982. On the Causes, Characteristics and Potential Environmental Effects of Aerosol in the Arctic 

Atmosphere. In: The Arctic Ocean: The Hydrographic Environment and the Fate of Pollutants, L. Ray, 

ed. New York: John Wiley and Sons, pp. 163-195. 

Ramachandran SD, MJ Sweezey, PV Hodson; SC Courtenay, K Lee, T King and JA Dixon. 2006. Influence of 

Salinity and Fish Species on PAH Uptake from Dispersed Crude Oil. Marine Pollution Bulletin 2(10): 

1182-1189. 

Ramseur, J.L. 2010. Deepwater Horizon Oil Spill: The Fate of the Oil. Washington, D.C. Congressional 

Research Service. The Library of Congress. 

Rand, K. and E. Logerwell, 2010. The first demersal trawl survey of benthic fish and invertebrates in the 

Beaufort Sea since the late 1970s. Polar Biology: published online November 3, 2010. 

Raskoff, K. A., R. R. Hopcroft, K. N. Kosobokova, J. E. Purcell, and M. Youngbluth. 2010. Jellies under ice: 

ROV observations from the Arctic 2005 hidden ocean expedition. Deep Sea Research Part II: Topical 

Studies in Oceanography 57 (1-2) (1): 111-26. 

Read, A.J. 1999. Harbor Porpoise Phocoena phocoena (Linneaus, 1758). In: Handbook of Marine Mammals, 

S.H. Ridgway and R.Harrison, eds. Vol. 6. The Second Book of Dolphins and the Porpoises. New 

York: Academic Press, 486 pp. 

Reed, M., P. Daling, M.O. Moldestad, P.J. Brandvik, J. Resby, F. Leirvik, O. Johansen, K. Skognes, B. Hetland, 

and T.J. Schrader. 2005. Revision of the OCS-Weathering Model: Phases II and III. OCS Study 

2005-020. Anchorage, AK: USDOI, MMS, Alaska OCS Region, 15 pp. (plus appendices). 

Reed, M., M.H. Emilsen, B. Hetland, O. Johansen, S. Buffington, and B. Hoverstad. 2006. Numerical Model for 

Estimation of Pipeline Oil Spill Volumes: Progress in Marine Environmental Modelling. 

Environmental Modelling & Software 21:2178-189. 

Reeves R.R., B.S. Stewart, and S. Leatherwood. 1992. The Sierra Club Handbook of Seals and Sirenians. Hong 

Kong: Dai Nippon Printing Co. Ltd. 

Reger. D., J.D. McMahan, and C.E. Holmes. 1992. Effect of Crude Oil Contamination on Some Archaeological 

Sites in the Gulf of Alaska. Office of History and Archaeology Report No. 30. Anchorage, AK: State 

of Alaska, Dept. of Natural Resources, Div. of Parks and Outdoor Recreation. 

Reible, D. 2010. After the oil is no longer leaking. Environmental Science and Technology 44: 5685-5686. 

Reimnitz, E. and D.K. Maurer. 1979. Effects of Storm Surges on the Beaufort Sea Coast, Northern Alaska. 

Arctic 32(4): 329-344. 

Reynolds, P.E. 1986. Responses of Muskoxen Groups to Aircraft Overflights in the Arctic National Wildlife 

Refuge, 19821985. In: Arctic National Wildlife Refuge Coastal Plain Resource Assessment 1985 

Update Report. Baseline Study of the Fish, Wildlife, and Their Habitats, G.W. Garner and P.E. 

Reynolds, eds. Volume 3, Appendix V Impacts. ANWR Progress Report No. FY86-5-Impacts. 

Anchorage, AK: USDOI, FWS, 1,281 pp. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 347 

Reynolds, P.E. 1992. Seasonal Differences in the Distribution and Movements of Muskoxen (Ovibos 

moschatus) in Northeastern Alaska. Rangifer 123:171-172. 

Rice, D. W., A. A. Wolman, and H. W. Braham. 1984. The Gray Whale, Eschrichtius robustus: Marine 

Fisheries Review 464: 7-14. 

Rice, D.W. and A.A. Wolman. 1971. In: The Life History and Ecology of the Gray Whale (Eschrichtius 

robustus). Special Publication No. 3. Seattle, WA: The American Society of Mammalogists, 142 pp. 

Rice, S.D., J.W. Short, R.A. Heintz, M.G. Carls, and A. Moles., 2000. Life History Consequences of Oil 

Pollution in Fish Natal Habitat. In: Energy 2000: The Beginning of a New Millennium, P. Catania, ed. 

Lancaster, UK: Technomic Publishing Co., pp. 1210-1215. 

Rice, S.D., R.E. Thomas, M.G. Carls, R.A. Heintz, A.C. Wertheimer, M.L.Murphy, J.W. Short, and A. Moles. 

2001. Impacts to Pink Salmon following the Exxon Valdez Oil Spill: Persistence, Toxicity, Sensitivity, 

and Controversy. Reviews in Fisheries Science 9(3):165- 211. 

Richard, P.R., A.R. Martin, and R. Orr. 2001. Summer and Autumn Movements of Belugas of the Eastern 

Beaufort Sea Stock. Arctic 54(3):223-236. 

Richardson, W.J and C.I. Malme. 1993. Man-Made Noise and Behavioral Responses. In: The Bowhead 

Whale, J.J. Burns, J.J. Montague, and C.J. Cowles, eds. Special Publication of The Society for Marine 

Mammalogy, 2. Lawrence, KS: The Society for Marine Mammalogy, pp. 631-700. 

Richardson, W.J., C.R. Greene, Jr., C.I. Malme, and D.H. Thomson. 1995a. Marine Mammals and Noise. San 

Diego, CA: Academic Press, Inc. 

Rigor, I.G., R.L. Colony, and S. Martin. 2000. Variations in Surface Air Temperature Observations in the 

Arctic, 1979-97. Journal of Climate 13(5): 896-914. 

Ritchie, L.A. and D.A. Gill. 2004. Social Capital and Subsistence in the wake of the Exxon Valdez Oil Spill. 

Paper presented at the 2004 Meeting of the Rural Sociological Society, Sacramento, Calif., October 

2004. Mississippi State University. 

Rochelle, C. 1998. Observations of killer whale (Orcinus orca) predation in the northeastern Chukchi and 

western Beaufort Seas. Marine Mamm. Sci. 14(2):330-332 

Rodrigues R., R.H. Pollard, and R.O. Skoog. 1994. Inventory of Arctic Fox Dens in the Prudhoe Bay Oil 

Field. Abstract. In: Proceedings of the North Slope Environmental Studies Conference, Anchorage, 

Ak. Anchroage, AK: ARCO Alaska, Inc, p. 33. 

Roseneau, D. 2010. E-mail to Jeff Denton at BOEMRE from D. Roseneau, Maritime NWR, FWS; note dated 

October 15, 2010. Subject : Marine mammal observations from D. Roseneau field seasons over the last 

several years. 

Roseneau, D.G. and D.R. Herter. 1984. Marine and Coastal Birds. In: Proceedings of a Synthesis Meeting: The 

Barrow Arch Environment and Possible Consequences of Planned Offshore Oil and Gas Development. 

Anchorage, AK: USDOC, NOAA, OCSEAP, pp. 81-115. 

Rothe, T. and S. Arthur. 1994. Eiders. Wildlife Notebook Series. Juneau, AK: State of Alaska, Dept. of Fish and 

Game, Div. Wildlife Conservation. 

Rotterman, L. M. and C.M. Monnett. 2002. Length-Mass and Total Body Length of Adult Female Sea Otters 

in Prince William Sound Before and After the Exxon Valdez Oil Spill. Marine Mammal Science 

184:977-993 
BOEMRE Sale 193 Revised Draft SEIS 

348 Literature Cited

Rugh, D. J. and M. A. Fraker. 1981. Gray whale sightings in the eastern Beaufort Sea. Arctic 34:135-139. 

Rugh, D.J., K.E.W. Shelden, and A. Schulman-Jainger. 2001. Timing of the southbound migration of gray 

whales. J. Cetacean Res. and Manage. 3(1): 31-39. 

Rugh, D.J., Koski, W.R., George, J.C. and Zeh, J. 2008. Interyear Re-identification of Bowhead Whales During 

Their Spring Migration Past Barrow, Alaska, 1984-1994. J. Cetacean Res. Manage. 10(3):195-200. 

Rugh, D.J., M.M Muto, S.E. Moore, and D.P. DeMaster. 1999. Status review of the Eastern North Pacific stock 

of gray whales. U.S. Dep. Commer., NOAA Tech. Memo. NMFS-AFSC-103. 

Rye, H., O.Johansen, M.Reed, N. Ekrol, X. Deqi. 2000. Exposure of fish larvae to hydrocarbon concentration 

fields generated by subsurface blowouts. Spill Science and Technology Bulletin 6(2): 113-123. 

Rye, H., P.J. Brandvik, and T. Strøm. 1997. Subsurface Blowouts: Results from Field Experiments. Spill 

Science & Technology Bulletin 4 (4): 239-256. 

Ryerson, T. B.; Aikin, K. C.; W.M. Angevine, W. M.; Atlas, E. L.; Blake, D. R.; Brock, C. A.; Fehsenfeld, F. 

C.; Gao, R.-S.; de Gouw, J. A.; Fahey, D. W.; Holloway, J. S.; Lack1, D. A. Lueb R. A.; Meinardi, S.; 

Middlebrook, A. M.; Murphy, D. M.; Neuman, J. A. Nowak J. B.; Parrish, D. D.; Peischl, J.; Perring, 

A. E.; Pollack , I. B.; Ravishankara, A. R.; Roberts, J. M.; Schwarz, J. P.; Spackman, J. R.; Stark, H.; 

Warneke, C., and Watts, L. A. 2011. Atmospheric emissions from the Deepwater Horizon spill 

constrain air-water partitioning, hydrocarbon fate, and leak rate. Geophysical Research Letters. 

submitted. 

Sameoto, D. 1984. Review of current information on Arctic cod (Boreogadus saida Lepechin) and 

Biobilography Bedford Institute of Oceanography, Canada Fisheries and Oceans, Ocean Science and 

Surveys Atlantic. 71 pp. 

Schallenberger, A. 1980. Review of Oil and Gas Exploitation Impacts on Grizzly Bears. In: Bears-Their 

Biology and Management, Fourth International Conference on Bear Research and Management, C.J. 

Martinka and K.J. McArthur, eds. Kalispell, Mont. Tonto Basin, AZ: Bear Biology Association, pp. 

271-277. 

Schliebe, S., K. D. Rode, J. S. Gleason, J. Wilder, K. Proffitt, T. J. Evans and S. Miller. 2007. Effects of sea ice 

extent and food availability on spatial and temporal distribution of polar bears during the fall openwater period in the Southern Beaufort Sea. Polar Biology 

Schliebe, S K., D. Rode, J.S. Gleason, J. Wilder, K. Proffitt, T.J. Evans, and S. Miller. 2008. Effects of Sea Ice 

Extent and Food Availability on Spatial and Temporal Distribution of Polar Bears during the Fall 

Open-Water Period in the Southern Beaufort Sea. Polar Biology. 

Schliebe, S., T.J. Evans, S. Miller, C.J. Perham, J.M. Wilder, and L.J. Lierheimer. 2005. Polar Bear 

Management in Alaska, 2000-2004. Anchorage, AK: USDOI, FWS, 25 pp. 

Schweitzer, P. 2005. Email dated Nov. 1, 2005, to T. Newbury and M. Burwell, MMS Alaska OCS Region, 

from P. Schweitzer; subject: the state of subsistence on the Russian side of the Chukchi Sea. 

Semiletov, I., Makshtas, A., Akasofu, S.I., Andreas, F.L., 2004. Atmospheric CO2 Balance: The Role of Arctic 

Sea Ice. Geophysical Research Letters 31, L05121. 

Serreze, M.C., M.M. Holland, and J. Stroeve. 2007. Prospectives on Arctic's Shrinking Sea Ice Cover. Science 

315:1533-1536. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 349 

Seuront, L. 2010. Zooplankton avoidance behaviour as a response to point sources of hydrocarboncontaminated water. DOI:10.1071/MF09055 Marine and Freshwater Research 61(3): 263–270. 

Shelden, K.E.W., D.P. DeMaster, D.J. Rugh, and A.M. Olson. 2001. Developing Classification Criteria under 

the U.S. Endangered Species Act: Bowhead Whales as a Case Study. Conservation Biology 155:1300-

1307. 

Shell Gulf of Mexico Inc. 2009. Exploration Plan, 2010 Exploration Drilling Program, Posey Blocks 6713, 

6714, 6763, 6764 and 6912, Karo Blocks 6864 and 7007, Burger, Crackerjack, and SW Shoebill 

Prospects, OCS Lease Sale 193, Chukchi Sea, Alaska. Anchorage, AK: Shell Gulf of Mexico Inc. 

http://www.mms.gov/alaska/ref/ProjectHistory/2009_Chukchi_Shell/2009_1020_Chukchi_EP/EP_201

0_Chukchi.HTM 

Shepard, R. and A. Rode. 1996. The Health Consequences of Modernization: Evidence from Circumpolar 

Peoples. Cambridge, UK: Cambridge University Press. 

Shepro, C.E. and D.C.Maas. 1999. North Slope Borough 1998/1999 Economic Profile and Census Report: 

Vol. III. Barrow, AK: NSB Dept. of Planning and Community Services. 

Sherwood, K.W. and J.D. Craig. 2001. Prospects for Development of Alaska Natural Gas: A Revew. Available 

on CD. Anchorage, AK: USDOI, BOEMRE, Alaska OCS Region. 

Shideler R. and J. Hechtel. 2000. Grizzly Bear. In: The Natural History of an Arctic Oil Field Development 

and the Biota, J.C. Truett and S. R. Johnson, eds. San Diego, CA: Academic Press, 105-132 pp. 

Shindell, D. & Faluvegi, G. 2009. Climate Response to Regional Radiative Forcing during the Twentieth 

Century. Nature Geoscience (2), pp. 294-300. doi: 10.1038/NGE0473 

Short, J.W., S.D. Rice, R. Heintz, M.G. Carls, and A. Moles. 2003. Long-Term Effects of Crude Oil on 

Developing Fish: Lessons from the Exxon Valdez Oil Spill. Energy Sources 256: 7750-1-9. 

Simpkins, M.A., L.M. Hiruki-Raring, G. Sheffield, J.M. Grebmeier, and J.L. Bengtson. 2003. Habitat 

Selection by Ice-Associated Pinnipeds near St. Lawrence Island, Alaska in March 2001. Polar Biology 

26:577-586. 

Simpson S.D., M.G. Meekan, N.J. Larsen, R.D. McCauley, and A.Jeffs. 2010. Behavioral plasticity in larval 

reef fish: orientation is influenced by recent acoustic experiences. Behavioral Ecology 21(5): 1098-

1105 

Sintef. 2010. Contingency for Arctic and Ice-covered Waters. Report # 32, Joint Industry Program on Oil Spill, 

Summary Report, 04, 10, 2010. Authors: Sorstrom, S.E., Brandvik, P.J., et. al. Available at 

http://www.sintef.no/project/JIP_Oil_In_Ice/Dokumenter/publications/JIP-rep-no-32-Summaryreport.pdf 

S.L. Ross Environmental Research Ltd. 2002. Dispersant Effectiveness Testing in Cold Water. S.L. Ross 

Environmental Research Ltd., Ottawa, Ontario, and Mar, Inc., Leonardo, NJ., August 2002. Available 

at http://www.boemre.gov/tarprojectcategories/ArcticOilSpillResponseResearch.htm 

S.L. Ross Environmental Research Ltd. 2003. Dispersant Effectiveness Testing on Alaskan Oils in Cold Water. 

S. L. Ross Environmental Research Ltd., Ottawa, Ontario and MAR, Inc., Leonardo, N.J., August 

2003. Available at http://www.boemre.gov/tarprojectcategories/ArcticOilSpillResponseResearch.htm 

S.L. Ross Environmental Research Ltd. 2006. Dispersant Effectiveness Testing in Cold Water on Four Alaskan 

Crude Oils. SL: Ross Environmental Research and MAR, Inc., 59 pp. July 2006. Available at 

http://www.boemre.gov/tarprojectcategories/ArcticOilSpillResponseResearch.htm 
BOEMRE Sale 193 Revised Draft SEIS 

350 Literature Cited

S.L. Ross Environmental Research Ltd. 2007. Corexit 9500 Dispersant Effectiveness Testing in Cold Water on 

Four Alaskan Crude Oils. SL: Ross Environmental Research and MAR, Inc., 35 pp. May 2007. 

Available at http://www.boemre.gov/tarprojectcategories/ArcticOilSpillResponseResearch.htm. 

S.L. Ross Environmental Research Ltd., D.F. Dickins and Assocs. Ltd., and Vaudrey and Assocs. Ltd. 1998. 

Evaluation of Cleanup Capabilities for Large Blowout Spills in the Alaskan Beaufort Sea During 

Periods of Broken Ice. Anchorage, AK: Alaska Clean Seas and USDOI, MMS, Alaska OCS Region. 

S.L. Ross Environmental Research Ltd., Alun Lewis Oil Spill Consultancy, Bercha Group, and PCCI. 

Persistence of Crude Oil Spills on Open Water. 2003. USDOI, MMS, Alaska OCS Region. OCS Study 

MMS 2003-0047. 74pp. 

Slabbekoorn H, N. Bouton, I. van Opzeeland, A. Coers, C. ten Cate, et al. 2010. A noisy spring: the impact of 

globally rising underwater sound levels on fish. Trends Ecol Evol 25: 419–427. 

Slizkin, A.G.. Tikhookeanskiy Nauchno-issledovatel'skiy Institut Rybnogo Khozyaystva I Okeanografii Tinro. 

Izvestiya. 1982. 106:26-33. 8p. Language: Russian. (AN SPRI65502). 

Smith, A.E. and M.R.J. Hill. 1996. Polar Bear, Ursus maritimus, Depredation of Canada Goose, Branta 

canadensis, Nests. The Canadian Field-Naturalist 110:339-340. 

Smith, T. G. 1985. Polar bears, Ursus maritimus, as Predators of Belugas, Delphinapterus leucas. The 

Canadian Field-Naturalist 99:71-75. 

Smith, T.G. 1987. The Ringed Seal, Phoca hispida, of the Canadian Western Arctic. Can. Bull. Fish Aquat. 

Sci. 216:81 pp. 

Smith, T.G., and J.R. Geraci. 1975. The Effect of Contact and Ingestion of Crude Oil on Ringed Seals of the 

Beaufort Sea. Dept. of the Environment, Victoria, British Columbia, Beaufort Sea Technical Rpt. #5. 

66 pp. 

Smith, W. O., and D. G. Barber. 2007. Polynyas: Windows to the world. Elsevier oceanography series, 74. 

Amsterdam: Elsevier Science. 

Smythe, C.W. 1990. In the Second Year: Continuing Village Impacts of the Exxon Valdez Oil Spill. In: 1990 

Alaska Science Conference, Proceedings of the 41st Arctic Science Connference: Circumpolar 

Perspectives, Anchorage, Ak., Oct. 8-10, 1990. Anchorage, AK: American Association for the 

Advancement of Science, Alaska Division. 

Solheim, A. and A. Elverhøi. 1993. Gas-related Sea Floor Craters in the Barents Sea. Geo-Marine Letters 13 

(4): 235-243. 

Solovieva, D. V. 1997. Timing, Habitat Use, and Breeding Biology of Steller’s Eider in the Lena Delta, 

Russia. Wetlands International Seaduck Specialist Group Bulletin 7: 35-39. 

Southall, B. L., A. E. Bowles, W. T. Ellison, J. J. Finneran, R. L. Gentry, C. R. Greene, Jr., D. Kastak, D. R. 

Ketten, J. H. Miller, P. E. Nachtigall, W. J. Richardson, J. A. Thomas, and P. L. Tyack. 2007. Marine 

mammal noise exposure criteria: initial scientific recommendations. Aquatic Mammals 33: 411-521. 

Sowls, A.L., S.A. Hatch, and C.J. Lensink. 1978. Catalog of Alaskan Seabird Colonies. FWS/OBS-78/78. 

Washington, DC: USDOI, FWS, Office of Biological Services. 

Speckman, S., V. Chernook, D. Burn, M. Udevitz, A. Kochnev, A. Vasilev, C. Jay, A. Lisovsky, A. Fischbach, 

R. Benter. 2011. Results and evaluation of a survey to estimate Pacific walrus population size, 2006. 

Marine Mammal Science, volume 27 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 351 

Spraker, T.R., L.F. Lowry, and K. J. Frost. 1994. Gross necropsy and histopathological lesions found in harbor 

seals. Pages 281-311 in T. R. Loughlin, editor. Marine Mammals and the Exxon Valdez. Academic 

Press, Inc., San Diego, CA. 

Springer, A. M., C. P. McRoy, and K. R. Turco. 1989. The paradox of pelagic food webs in the northern Bering 

Sea—II. zooplankton communities. Continental Shelf Research 9 (4) (4): 359-86. 

St. Aubin, D.J. 1988. Physiologic and Toxicologic Effects on Pinnipeds. Chapter 3. In: Synthesis of Effects 

of Oil on Marine Mammals, J.R. Geraci and J.D. St. Aubin, eds. OCS Study, MMS 88-0049. Vienna, 

VA: USDOI, MMS, Atlantic OCS Region, 292 leaves. 

St. Aubin, D.J., R.H. Stinson, and J.R. Geraci. 1984. Aspects of the Structure and Composition of Baleen and 

Some Effects of Exposure to Petroleum Hydrocarbons. Canadian Journal of Zoology 622:193-198. 

St. Aubin, D.J. 1990. Physiologic and toxic effects on Pinnipeds. p. 103-127, In: J.R. Geraci and D.J. St. Aubin 

(eds.), Sea mammals and oil: confronting the risks, Academic Press, San Diego. 282 pp. 

Stafford, K. M., S. E. Moore, M. Spillane, and S. Wiggins. 2007. Gray whale calls recorded near Barrow, 

Alaska throughout the winter of 2003-04. Arctic 60:167-172. 

Standing, M.B., 1977, Volumetric and phase behavior of oil field hydrocarbon systems: Society of Petroleum 

Engineers of AIME, Dallas, TX, 130 pp. 

State of Alaska, Department of Natural Resources. 2006. Alaska Heritage Resources Survey File. Anchorage, 

AK: ADNR. 

State of Alaska, Dept. of Environmental Conservation. 2002. Summary of Scientific Knowledge and its 

implications for Alaska’s State Implementation Plan. Juneau, AK: ADEC, 53 pp. 

Stehn, R., W. Larned, R. Platte, J. Fischer, and T. Bowman. 2006. Spectacled Eider Status and Trend in Alaska. 

Unpublished report. Anchorage, AK: USDOI, FWS, 17 pp. 

Sterling, M. C.; J.S. Bonner, C.S. Page, C.B. Fuller, A.S.S. Ernest, and R.L. Autenrieth. 2004. Modeling Crude 

Oil Droplet-Sediment Aggregation in Nearshore Waters. Environmental Science and Technology 

384627-4634. 

Stige, L. C., G. Ottersen, D. O. Hjermann, P. Dalpadado, L. K. Jensen, and N. C. Stenseth. 2010. Environmental 

toxicology: Population modeling of cod larvae shows high sensitivity to loss of zooplankton prey. 

Marine Pollution Bulletin 62 (2): 395-8. 

Stirling, I. and E.H. McEwan. 1975. The Caloric Value of Whole Ringed Seals (Phoca hispida) in Relation to 

Polar Bear (Ursus maritimus) Ecology and Hunting Behavior. Can. J. Fish. Aquat. Sci. 538:1021-

1027. 

Stirling, I., and N. A. Øritsland. 1995. Relationships between estimates of ringed seal (Phoca hispida) and polar 

bear (Ursus maritimus) populations in the Canadian Arctic. Canadian Journal of Fisheries and Aquatic 

Sciences 52: 2594-2612. 

Stirling, Ian and W. Ralph Archibald. 1977. Aspects of predation of seals by polar bears. J. Fish. Res. Board 

Can. 34(8): 1126-1129. 

Stirling, Ian. 2002. Polar bears and seals in the Eastern Beaufort Sea and Amundsen Gulf: a synthesis of 

population trends and ecological relationships over three decades. Arctic 55(1): 59-76. 
BOEMRE Sale 193 Revised Draft SEIS 

352 Literature Cited

Stringer, W.J. and J.E. Groves. 1991. Location and Areal Extent of Polynyas in the Bering and Chukchi Seas. 

Arctic 44(1):164-171. 

Stroeve, J.C., M.C. Serreze, F. Fetterer, T. Arbetter, W. Meier, J. Maslanik, and K. Knowles. 2005. Tracking 

the Arctic's Shrinking Ice Cover: Another Extreme September Minimum in 2004. Geophysical 

Research Letters 32:L04501. doi:10.1029/2004GL021810. 

Stroeve, J., M. Serreze, S. Drobot, S. Gearheard, M. Holland, M. Maslanik, M. Meier, and T. Scambos. 2008. 

Arctic Sea Ice Extent Plummets in 2007. EOS Trans., AGU, 89(2):13-14. 

Stroeve, J. C.; Maslanik, J.; Serreze, M. C.; Rigor, I.; Meier, W., and Fowler, C.. 2011. Sea ice response to an 

extreme negative phase of the Arctic Oscillation during winter 2009/2010. Geophysical Research 

Letters 38(2):L02502. 

Struzik, E. 2003. Grizzlies on Ice: what is Aklak doing in the kingdom of Nanook?. Canadian Geographic 

123(6): 38-48. 

Suchanek, T. H. 1993. Oil impacts on marine invertebrate populations and communities. American Zoologist 33 

(6): 510. 

Suter, G. W. 2007. Ecological risk assessment. Boca Raton, FL: CRC. 

Suydam R.S., L.F. Lowry, K.J. Frost, G.M. O'Corry-Crowe, and D. Pikok, Jr. 2001. Satellite Tracking of 

Eastern Chukchi Sea Beluga Whales into the Arctic Ocean. Arctic 543:237-243. 

Suydam, R. S. and J. C. George. 1992. Recent Sightings of Harbor Porpoise, (Phecoena phocoena) Near Point 

Barrow, Alaska. Canadian Field Naturalist 106:489-492. 

Suydam, R., J. C. George, C. Hanns, G. Sheffield. 2006. Subsistence harvest of bowhead whales (Balaena 

mysticetus) by Alaskan Eskimos during 2005. Paper SC/58/BRG21 presented to the Scientific 

Committee of the International Whaling Commission. 

Suydam, R., J. C. George, C. Rosa, B. Person, C. Hanns, G. Sheffield, and J. Bacon. 2007. Subsistence harvest 

of bowhead whales (Balaena mysticetus) by Alaskan Eskimos during 2006. Unpubl. report submitted 

to Int. Whal. Comm. (SC/59/BRG4). 7 pp. 

Suydam, R., J.C. George, C. Rosa, B. Person, C. Hanns, G. Sheffield, and J. Bacon. 2008. Subsistence harvest 

of bowhead whales (Balaena mysticetus) by Alaskan Eskimos during 2007. Unpubl. report submitted 

to Int. Whal. Commn. (SC/60/BRG10). 7 pp. 

Suydam, R., J.C. George, C. Rosa, B. Person, C. Hanns, G. Sheffield, and J. Bacon. 2009. Subsistence Harvest 

of Bowhead Whales (Balaena mysticetus) by Alaskan Eskimos During 2007. Unpubl. report submitted 

to Int. Whal. Comm. (SC/61/BRG6). 6 pp. 

Suydam, R., J.C. George, C. Rosa, B. Person, C. Hanns, and G. Sheffield. 2010. Subsistence harvest of 

bowhead whales (Balaena mysticetus) by Alaskan Eskimos during 2009. Unpubl. report submitted to 

Int. Whal. Commn. (SC/62/BRG18). 5 pp. 

Suydam, R.S. 1997. Threats to the Recovery of Rare, Threatened, and Endangered Birds: Steller's Eider. In: 

NPR-A Symposium Proceedings, Anchorage, AK: USDOI, BLM. 

Suydam, R.S., L.F. Lowry, and K.J. Frost. 2005. Distribution and Movements of Beluga Whales from the 

Eastern Chukchi Sea Stock during Summer and Early Autumn. Final Report. Anchorage, AK: UsDOI, 

MMS, Alaska OCS Region, 48 pp. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 353 

Swartz, S.L. and M.L. Jones. 1981. Demographic Studies and Habitat Assessment of Gray Whales, 

Eschrichtius robustus, in laguna San Ignacio, Baha California, Mexico. MMC Report MMC - 78/03. 

Washington, DC: Marine Mammal Commission, 34 pp. 

Taylor, B., R. LeDuc, J. C. George, R. Suydam. S. Moore, and D. Rugh. 2007. Synthesis of Lines of Evidence 

for Population Structure for Bowhead Whales in the Bering-Chukchi-Beaufort Region. Unpubl. report 

to Int. Whal. Comm. (SC/59/BRG35). 12 pp. 

Taylor, M. 1993.Grizzly Bear Sightings in Viscount Melville Sound. In: Proceedings of the 11th Working 

Meeting of the IUCN/SSC Polar Bear Specialist Group, 25-27 January 1993, Copenhagen, Denmark, 

Ø. Wiig, E.W. Born, and G.W. Garner eds. 191-192. 

Taylor, M. 1995. Grizzly Bear Sightings in Viscount Melville Sound. In, Polar Bears, Proceedings of the 

Eleventh Working Meeting of the IUCN/SSC Polar Bear Specialist Group, 25-27 January 1993, 

Copenhagen, Denmark, eds. Ø. Wiig, E.W. Born, and G. W. Garner. pp. 191-192. 

Thewissen, J. G. M., J. C. Geporge, Rosa, and C., T. Kishida. 2010. Olfaction and brain size in the bowhead 

whale (Balaena mysticetus). Mar. Mamm. Sci. 27(2): 282-294. 

Thomas, C.P., T.C. Doughty, J.H. Hackworth, W.G. North, and E.P. Robertson. 1996. Economics of Alaska 

North Slope Gas Utilization Options. INEL 96/0322. Washington, DC: U.S. Dept. of Energy, Office of 

Fossil Energy, pp. 3-4. 

Thompson, M.C., J.Q. Hines, and F.S.L. Williamson. 1966. Discovery of the Downy Young of Kittlitz's 

Murrelet. Auk 83:349-351. 

Thorsteinson, L.K, L.E. Jarvela, and D.A. Hale. 1991. Arctic Fish Habitat Use Investigations: Nearshore 

Studies in the Alaskan Beaufort Sea, Summer 1990. Annual Report. Anchorage, AK: USDOC, 

NOAA, National Ocean Services, 166 pp. 

Tietsche, S.; Notz, D.; Jungclaus, J. H., and J. Marotzke. 2011. Recovery mechanisms of Arctic summer sea 

ice. Geophysical Research Letters 38(2):L02707. 

Tissot, B.P., and Welte, D.H., 1984, Petroleum Formation and Occurrence: 2nd Ed., Springer-Verlap, New 

York, 699 pp. 

Tomilin, A.G. 1957. Mammals of the USSR and Adjacent Countries., Israel Program for Scientific 

Translation, Translator. Cetacea (in Russian), Vol. 9. Moscow: Isdatel'stvo Akademii Nauk SSR, 717 

pp. 

Treacy, S. D. 1996. Aerial surveys of endangered whales in the Beaufort Sea fall 1995. OCS Study, MMS 

1996-0006. USDOI, MMS, Alaska OCS Region, Anchorage, Alaska. 129 p. 

Tynan C.T. and D.P. DeMaster. 1997. Observations and Predictions of Arctic Climate Change:Potential 

Effects on Marine Mammals. Arctic 504:308-322. 

United Nations Environment Programme. 2005. GEO Yearbook 2004/4: An Overview of Our Changing 

Environment. Nairobi, Kenya: United Nations Environment Programme. 

Urban, M. 2006. Road Facilitation of Trematode Infections in Snails of Northern Alaska. Conservation Biology 

20:1143-1149. 

URS Corporation. 2005. North Slope Borough, Background Report. Barrow, Alaska: North Slope Borough. 
BOEMRE Sale 193 Revised Draft SEIS 

354 Literature Cited

U.S. Army Corps of Engineers. 2005. Draft Environmental Impact Statement. Navigational Improvements, 

Delong Mountain Terminal. 2 Vols. Anchorage, AK: U.S. Army Corps of Engineers. 

U.S. Department of Labor. 2010. Quarterly census of employment and wages. Available on the Internet at 

http://data.bls.gov:8080/PDQ/outside.jsp?survey=en 

USDOC, Bureau of the Census. 2000. htpp://quickfacts.census.gov/qfd/index.html. Washington, DC: 

USDOC, Bureau of the Census. 

USDOC, Bureau of the Census. 2002. Area Boroughs, Cities and U.S. Census Places. Washington, DC: 

USDOC, Bureau of the Census. 

USDOC, USCG and USEPA. 2010. Characteristics of Response Strategies: A Guide for Spill Response 

Planning in Marine Environments is based on information contained in Environmental Considerations 

for Marine Oil Spill Response, published by the American Petroleum Institute, Seattle, WA. pp. 76. 

USDOI, BLM. 2002. Renewal of the Federal Grant for the Trans-Alaska Pipeline System Right-of-Way, Final 

Environmental Impact Statement. BLM/AK/PT-03/005+2880+990. Anchorage, AK: USDOI, BLM. 

USDOI, BLM. 2004a. Alpine Satellite Development Plan Draft Environmental Impact Statement. 

BLM/AK/PL04/007+3130+931. Anchorage, AK: USDOI, BLM, 2 Vols. 

USDOI, BLM. 2004b. Alpine Satellite Development Plan Final Environmental Impact Statement. Anchorage, 

AK: USDOI, BLM. 

USDOI, BLM. 2005. Northeast NPR-A final Amended Integrated Activity Plan/EIS. Anchorage, AK: USDOI, 

BLM. 

USDOI, BLM. 2006. Subsistence Advisory Panel. Anchorage, AK: USDOI, BLM. 

USDOI, BLM. 2006a. Kobuk-Seward Peninsula Planning Environmental Impact Statement. Anchorage, AK: 

USDOI, BLM. 

USDOI, BLM, 2008. Northeast National Petroleum Reserve-Alaska FINAL Supplemental/Integrated Activity 

Plan/Environmental Impact Statement. May 2008. 

USDOI, BLM and MMS. 2003. Northwest National Petroleum Reserve-Alaska Final Integrated Activity 

Plan/Environmental Impact Statement. BLM/AK/PL-04/002+3130+930. Anchorage, AK: USDOI, 

BLM and MMS, 3 Vols. 

USDOI, BOEMRE, 2011. Gulf of Mexico OCS, Oil and Gas Lease Sale, Western Planning Area Lease Sale 

218, Draft Supplemental Environmental Impact Statement. OCS EIS/EA BOEMRE 2011-018. New 

Orleans, LA. UDOI, BOEMRE, Gulf of Mexico OCS Region. Available at 

http://www.gomr.boemre.gov/homepg/regulate/environ/nepa/nepaprocess.html. 

USDOI, BOEMRE, AIB. 2011. Well control incident information for Supplemental EI, Sale 193. Email from 

Melinda Mayes to Fred King RSLE and Mike Routhier, NEPA Coordinator. Apil 4, 2011. 

USDOI, FWS. 2005a. Beringian Seabird Colony Catalog: Computer Database. Anchorage, AK: USDOI, 

FWS, Migratory Bird Management. 

USDOI, FWS. 1995. Habitat Conservation Strategy for Polar Bears in Alaska. Anchorage, AK: USDOI, FWS. 

USDOI, FWS. 1999. Population Status and Trends of Sea Ducks in Alaska. U.S. Department of the Interior, 

Fish and Wildlife Service, Migratory Bird Management, Anchorage, Alaska. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 355 

USDOI, FWS. 2002. Polar Bear (Ursus maritimus) Southern Beaufort Sea Stock. Anchorage, AK: USDOI, 

FWS, pp. 1-5. 

USDOI, FWS. 2002b. Spectacled eider fact sheet. U.S. Department of the Interior, Fish and Wildlife Service, 

Ecological Services, Endangered Species Branch, Anchorage, Alaska. 

USDOI, FWS. 2002c. Stellar’s Eider Recovery Plan. U.S. Department of Interior, Fish and Wildlife Service. 

Ecological Services. Fairbanks, AK. 

USDOI, FWS. 2006a. Memorandum dated Jan. 5, 2006, to Minerals Management Service, Anchorage, from 

Fish and Wildlife Service, Fairbanks; subject: ESA-listed species likely to be found in the Beaufort 

Sea. 

USDOI, FWS. 2007. Biological Opinion for Lease Sale 193. Available at http://alaska.boemre.gov/ 

ref/BioOpinions/BO193/bo_193.pdf (accessed 2011 January 26). Fairbanks, AK: USDOI, FWS Field 

Office. 

USDOI, FWS. 2009. Final Biological Opinion for Beaufort and Chukchi Sea Program Area Lease Sales and 

Associated Seismic Surveys and Exploratory Drilling. Fairbanks, AK: USDOI, FWS Field Office. 

Available at http://www.mms.gov/alaska/ref/BioOpinions/2009_0903_BO4BFCK.pdf 

USDOI, FWS. 2010. North Slope Walrus Haul-out Update. USFWS Press Release: September 22, 2010. 

Available at http://alaska.fws.gov/index_archive.htm (accessed 2011 January 6). 

USDOI, MMS. 1987. Public Hearing on the Draft Chukchi Sea Lease Sale 109, Wainwright, AK. Anchorage, 

AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 1987b. Chukchi Sea Oil and Gas Lease Sale 109 Final Environmental Impact Statement. OCS 

EIS/EA MMS 2008-055. Anchorage, AK: USDOI, MMS. Available at http://alaska.boemre.gov/ref/ 

EIS%20EA/Chukchi_FEIS_126/Chukchi_FEIS_109/87_0110Vol1.pdf 

USDOI, MMS. 1990a. Beaufort Sea Planning Area Oil and Gas Lease Sale 124 Final Environmental Impact 

Statement. OCS EIS/EA, MMS 90-0063. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 1990b. Chukchi Sea Oil and Gas Lease Sale 126 Final Environmental Impact Statement. OCS 

EIS/EA MMS 90-0095. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 1995. Barrow Public Hearing, Official Transcript of Proceedings, Beaufort Sea Sale 144 Draft 

EIS. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 1998a. Beaufort Sea Planning Area Oil and Gas Leas Sale 170 Final EIS. OCS EIS/EA, MMS 

98-0007. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 1998b. Liberty Scoping Meeting, Nuiqsut, Ak., Anchorage, AK: USDOI, MMS, Alaska OCS 

Region. 

USDOI, MMS. 2001. Nuiqsut Public Hearing on the Liberty Development and Production Plan Draft EIS, 

Nuiqsut, Ak., Mar. 19, 2001. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 2002. Final Environmental Impact Statement for the Outer Continental Shelf Oil and Gas 

Leasing Program: 2002 to 2007. Herndon, VA: USDOI, MMS. 

USDOI, MMS. 2003a. Beaufort Sea Planning Area Sales 186, 195, and 202 Oil and Gas Lease Sale Final EIS. 

OCS EIS/EA, MMS 2003-001. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 
BOEMRE Sale 193 Revised Draft SEIS 

356 Literature Cited

USDOI, MMS. 2003b. Cook Inlet Planning Area Oil and Gas Lease Sales 191 and 199 Final EIS. OCS 

EIS/EA, MMS 2003001. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 2004. Proposed Oil and Gas Lease Sale 195 Beaufort Sea Planning Area Environmental 

Assessment. OCS EIS/EA MMS 2004-028. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 2005. National Office Potential Incident of Noncompliance List. Bureau of Ocean Energy 

Management. Herndon, VA. 

USDOI, MMS. 2006. Draft Environmental Impact Statement, Oil and Gas Lease Sale 193, Chukchi Sea 

Planning Area and Seismic Surveying Activities. OCS EIS/EA MMS 2006-0060. Anchorage, AK: 

USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 2006a. Biological Evaluation of Steller’s Eider (Polysticta stelleri), Spectacled Eider 

(Somateria fischeri), and Kittlitz’s Murrelet (Brachyramphus brevirostris) for Seismic Surveys in the 

Northeast Chukchi Sea and Western Beaufort Sea Planning Areas. Anchorage, AK: USDOI, MMS, 

Alaska OCS Region. Available at http://alaska.boemre.gov/ref/Biological_opinions_evaluations.htm. 

USDOI, MMS. 2006b. Biological Evaluation of the Potential Effects of Oil and Gas Leasing and Exploration in 

the Alaska OCS Beaufort Sea and Chukchi Sea Planning Areas on Endangered Bowhead Whales 

(Balaena mysticetus), Fin Whales (Balaenoptera physalus), and Humpback Whales (Megaptera 

novaeangliae). L.M. Rotterman. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 2006c. Proposed OCS Lease Sale 202 Beaufort Sea Planning Area Environmental Assessment. 

OCS EIS/EA, MMS 2006-001. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 2006e. Programmatic Environmental Assessment Arctic Ocean Outer Continental Shelf Seismic 

Surveys -2006. OCS EIS/EA, MMS 2006-038. Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 2007. Final Environmental Impact Statement for the Outer Continental Shelf Oil and Gas 

Leasing Program 2007-2012. Herndon, VA: USDOI, MMS. 

USDOI, MMS. 2007a. Final Environmental Impact Statement for Oil and Gas Lease Sale 193 and SeismicSurveying Activities in the Chukchi Sea. OCS EIS/EA MMS 2007-026. Anchorage, AK: USDOI, 

MMS, Alaska OCS Region. Available at http://alaska.boemre.gov/ref/eis_ea.htm. 

USDOI, MMS. 2008a. Beaufort Sea and Chukchi Sea Planning Areas Oil and Gas Lease Sales 209, 212, 217 

and 221 Draft Environmental Impact Statement. “Arctic Multi-Sale.” OCS EIS/EA MMS 2008-055. 

Anchorage, AK: USDOI, MMS. Available at http://www.alaska.boemre.gov/ref/EIS%20EA/ 

ArcticMultiSale_209/_DEIS.htm 

USDOI, MMS. 2008b. Biological Evaluation of the Potential Effects of Oil and Gas Leasing and Exploration in 

the Alaska OCS Beaufort Sea and Chukchi Sea Planning Areas on Endangered Bowhead Whales 

(Balaena mysticetus), Fin Whales (Balaenoptera physalus), and Humpback Whales (Megaptera 

novaeangliae). Anchorage, AK: USDOI, MMS, Alaska OCS Region. 

USDOI, MMS. 2009. Assessing Risk and Modeling a Sudden Gas Release Due to Gas Pipeline Ruptures. 

Prepared by L. Ross Environmental Research Ltd, SINTEF and Wellflow Dynamics, Herndon VA. 

USDOI, MMS. 2009b. An assessment of the potential effects of oil and gas leasing activities in the Beaufort 

Sea and Chukchi Sea planning areas on Steller‘s eiders (Polysticta stelleri), spectacled eiders 

(Somateria fischeri), Kittlitz‘s murrelet (Brachyramphus brevirostris), yellow-billed loons (Gravia 

adamsii), and polar bears (Ursus maritimus). Minerals Management Service. Final Version. July 2009. 

221pp. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 357 

USDOI, USCG and BOEMRE. 2011. Deepwater Join Investigation Team announces revised schedule. 

Available at http: //www.deepwaterinvestigation.com/go/doc/3043/1025771. 

USEPA. 1996. Compilation of Air Pollutant Emission Factors (AP-42). Table 3.4-1. 

USEPA. 2006. Environmental Justice. Environmental Protection Agency. Available at http://www.epa.gov/ 

compliance/environmentaljustice/ 

USEPA. 2008. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006. April 15, 

2008. Environmental Protection Agency. 

USEPA. 2010. Odors from the BP oil spill. U.S. Environmental Protection Agency. Available on the Internet at 

http://www.epa.gov/BPSpill/odor.html 

USEPA. 2011a. Mobile Air Monitoring on the Gulf Coast: TAGA Buses. U.S. Environmental Protection 

Agency. Available at http://www.epa.gov/BPSpill/taga.html#dispersants. 

USEPA. 2011b. Vessel General Permit. U.S. Environmental Protection Agency. Available at 

http://cfpub.epa.gov/npdes/home.cfm?program_id=350 Retrieved April 8, 2011. 

Valkenburg, P. and J.L. Davis. 1985. The Reaction of Caribou to Aircraft: A Comparison of Two Herds. In: 

Caribou and Human Activity. Proceedings of the First North American Workshop, A.M. Martell and 

D.E. Russell, eds. Whitehorse, Y.T., Canada, Ottawa, Ont., Canada: Canadian Wildlife Service, pp. 

7-9. 

Veltkamp, B. and J.R. Wilcox. 2007. Study Final Report for the Nearshore Beaufort Sea Meteorological 

Monitoring and Data Synthesis Project. OCS Study MMS 2007-011. Available at 

http://alaska.boemre.gov/reports/2007rpts/2007_011/2007_011.pdf. 

von Ziegesar, O., E. Miller, and M.E. Dahlheim., 1994. Impacts on Humpback Whales in Prince William 

Sound. In: Marine Mammals and the Exxon Valdez,T.R. Loughlin, ed. San Diego, CA: Academic 

Press, Inc., pp. 173-191. 

Walker, D.A., P.J. Webber, E. Binnian, K.R. Everett, N.D. Lederer, E. Norstrand, and M.D. Walker. 1987. 

Cumulative Impacts of Oil Fields on Northern Alaskan Landscapes. Science 2384828:757-761. 

Wang, S., C.M. Lewis, Jr., M. Jakobsson, S. Ramachandran, N. Ray, G. Bedoya, W. Rojas, M. Parra, J. Molina, 

C. Gallo, G. Mazzotti, G. Poletti, K. Hill, A. Hurtado, D. Labuda, W. Klitz, R. Barrantes, M. Bortolini, 

F. Salzano, M. Petzl-Erler, L. Tsuneto, E. Llop, F. Rothhammer, L. Excoffier, M. Feldman, N. 

Rosenberg, and A. Ruiz-Linares, 2007. Genetic Variation and Population Structure in Native 

Americans. PLoS Genetics November , 3 (11): e185. doi:10.1371/journal.pgen.0030185. 

PMID 18039031. 

Weeks, W. 2010. On sea ice. Fairbanks, AK: University of Alaska Press. 

Weingartner, T.J., D.J. Cavalieri, K. Aagaard, and S. Yasunori. 1998. Circulation, Dense Water Formation and 

Outflow on the Northeast Chukchi Shelf. Journal of Geophysical Research 103C4:7647-7661. 

Welch, H.E., Crawford, R.E., and Hop, H.1993 Occurrence of Arctic cod (Boreogadus saida) schools and their 

vulnerability to predation in the Canadian High Arctic. 46:331-339 

Whitney, J. 1994. Past Experience with Spill Response in Cook Inlet. Anchorage, AK: USDOC, NOAA, 

Hazardous Materials Response and Assessment Div. 
BOEMRE Sale 193 Revised Draft SEIS 

358 Literature Cited

Widdows, J., P. Donkin and S. V. Evans. 1987. Physiological responses of Mytilus edulis during chronic oil 

exposure and recovery. DOI:10.1016/0141-1136(87)90014-6. Marine Environmental Research 23(1): 

15-32. 

Wilson D.L., J.N. Fanjoy, and R.S. Billings. 2004. Gulfwide Emission Inventory Study for theRegional Haze 

and Ozone Modeling Effort: Final Report. U.S. Dept. of the Interior, Minerals Management Service, 

Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2004-072. 

Wilson KW. 1976. Effects of Oil Dispersants on the Developing Embryos of Marine Fish. Marine Biology 36: 

259-268. 

Wilson, J. Y., Cooke, S. R., Moore, M. J. ; Martineau, D., Mikaelian I., Metner D. A., Lyle Lockhart, W., 

Stegman, J. J. 2005. Systemic effects of arctic pollutants in beluga whales indicated by CYP1A1 

expression. Environmental health perspectives ISSN 0091-6765. vol. 113, no11, pp. 1594-1599 [6 

page(s) (article)] 

Winters, J.F. and R.T. Shideler. 1990. An Annotated Bibliography of Selected References of Muskoxen 

Relevant to the National Petroleum Reserve-Alaska. Fairbanks, AK: ADF&G, 82 pp. 

WMO. 2010. World Data Centre for Greenhouse Gases: Ozone Barrow, Alaska, NOAA/ESRL. Data record 

1973-2010. Available at http://gaw.kishou.go.jp/cgi-bin/wdcgg/download.cgi?index= 

BRW471N00-NOAA¶m=200612120563&select=inventory#hourly. 

Wolcow, D.B. 2005. Climate Change the Culprit Behind Grizzly Bears in Arctic. University of Alberta, Express 

News. 3 pp. Available at http://www.expressnews.ualberta.ca/print.cfm?id-6500. Accessed 6/30/2008. 

Wolfe, D.A., M.J. Hameedi, J.A. Galst, G. Watabayashi, J. Short, C.O. O’Claire, S. Rice, J. Michel, J.R. Payne, 

Braddock, J., S. Hanna, D. Sale. 1994. The Fate of the Oil Spilled from the Exxon Valdez, The Mass 

Balance is the Most Complete and Accurate of Any Major Oil Spill. Environmental Science and 

Technology 28(13):561-568. 

Woodgate, R.A., K. Aagaard, and T.J.O. Weingartner. 2005. A Year in the Physical Oceanography of the 

Chukchi Sea: Moored Measurements from Autumn 1990-1991. Deep Sea Research Publishing in Dec 

2005. 

Woodgate, R.A., Weingartner, T, and Lindsay, R. 2010. The 2007 Bering Strait oceanic heat flux and 

anomalous Arctic sea-ice retreat. Geophys. Res. Lett. 37(1):L01602. 

Wooley, C., S. Hillman, and D. O’Brien. 1997. Mapping Cultural Resource Sites for the Prince William Sound 

Graphical Resource Database. In: Proceedings of the 20th Arctic and Marine Pollution (AMOP) 

Technical Seminar, Vancouver, BC, Canada. 

Wooley, C.B. and J.C. Haggarty. 1993. Archaeological Site Protection: An Integral Component of the Exxon 

Valdez Shoreline Cleanup. In: Third Symposium on Environmental Toxicology and Risk Assessment: 

Aquatic, Plant, and Terrestrial, Atlanta, Ga., Apr. 26-29, 1993. Philadelphia, PA: American Society for 

Testing and Materials. 

Word, J., M. Pinza, W.Gardiner. 2008. Literature Review of the Effects of Dispersed Oil with Emphasis on 

Cold Water Environments of the Beaufort and Chukchi Seas, Prepared for Shell Global Solutions, 

Houston, TX and American Petroleum Institute, Washington DC. 117 pp. 

Wurl, O., and J. P. Obbard. 2004. A review of pollutants in the sea-surface microlayer (SML): A unique habitat 

for marine organisms. Marine Pollution Bulletin 48 (11-12) (6): 1016-30. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Literature Cited 359 

Würsig, B. 1990. Cetaceans and oil: ecologic perspectives. pp. 129-65. In: J.R. Geraci and D.J. St Aubin (eds.) 

Sea Mammals and Oil: Confronting the Risks. Academic Press, Inc., San Diego. xvi+282 pp. 

Zhang, J.; Steele, M., and Schweiger, A.. 2010. Arctic sea ice response to atmospheric forcings with varying 

levels of anthropogenic warming and climate variability. Geophysical Research Letters 37(20): 

L20505. 

 

Appendix A

Analysis of 

Incomplete or Missing Information

Sale 193 Revised Draft SEIS BOEMRE 

Appendix A A1

Appendix A: Analysis of Incomplete or Missing Information 

Appendix A provides an analysis of individual statements from the Sale 193 FEIS that identify 

incomplete or unavailable information pursuant to 40 CFR 1502.22 (regulation restated below). 

Although the Sale 193 FEIS is replete with discussion on the strengths and weaknesses of available 

data, BOEMRE analysts were generally able to complete thorough analyses and draw informed 

conclusions from the information available. The following analysis comprehensively addresses each 

item of incomplete or unavailable information. 

Background 

Chukchi Sea Lease Sale 193 was held in February 2008, with BOEMRE accepting high bids of 

approximately $2.6 billion and issuing 487 leases for approximately 2.8 million acres. As a result of 

a lawsuit challenging the sale, the U.S. District Court for the District of Alaska remanded Sale 193 for 

further NEPA analysis of three general concerns. Specifically, the Court found that the Agency failed 

to: 

(1) analyze the environmental impact of natural gas development, despite industry interest and 

specific lease incentives for such development; 

(2) determine whether missing information identified by the agency was relevant or essential 

under 40 C.F.R. § 1502.22; and 

(3) determine whether the cost of obtaining the missing information was exorbitant, or the means 

of doing so unknown. 

The first concern above is addressed within the body of the Sale 193 Revised Draft SEIS where 

BOEMRE has provided additional analysis on natural gas development and production. This 

Appendix addresses the second and third concerns by cataloguing statements within the Sale 193 

FEIS that acknowledged incomplete or unavailable information, and by providing a structured 

analysis of those statements. The concerns articulated by the Court were evaluated sequentially in 

this analysis by both resource analysts and managers (see Methodology below). Briefly, information 

was considered relevant if it could be connected to reasonably foreseeable significant adverse impacts 

as stipulated by CEQ regulation and following the significance criteria described for each resource in 

the Sale 193 FEIS. All statements indicating relevant incomplete or unavailable information that 

would be relevant were then evaluated to determine whether the information was essential to a 

reasoned choice among alternatives. To be essential, the information must provide a means for 

making a clear distinction between two or more alternatives. Lastly, if missing information was 

determined to be relevant and essential, managers evaluated the potential means of obtaining the 

information to determine whether cost would be exorbitant. 

Methodology 

Appendix A catalogues all statements within the Sale 193 FEIS that acknowledged incomplete or 

unavailable information. This list includes statements identified by the plaintiffs in litigation as well 

as additional statements independently identified by BOEMRE analysts for the purpose of this 

analysis. Each statement of incomplete or unavailable information then underwent a robust review 

process to ensure consistency with 40 CFR 1502.22, the relevant text of which reads: 

1502.22 Incomplete or unavailable information. 

When an agency is evaluating reasonably foreseeable significant adverse effects on the human environment 

in an environmental impact statement and there is incomplete or unavailable information, the agency shall 

always make clear that such information is lacking. 
BOEMRE Sale 193 Revised Draft SEIS 

A2 Appendix A

(a) If the incomplete information relevant to reasonably foreseeable significant adverse impacts is 

essential to a reasoned choice among alternatives and the overall costs of obtaining it are not 

exorbitant, the agency shall include the information in the environmental impact statement. 

(b) If the information relevant to reasonably foreseeable significant adverse impacts cannot be obtained 

because the overall costs of obtaining it are exorbitant or the means to obtain it are not known, the 

agency shall include within the environmental impact statement: 

1. A statement that such information is incomplete or unavailable; 

2. a statement of the relevance of the incomplete or unavailable information to evaluating 

reasonably foreseeable significant adverse impacts on the human environment; 

3. a summary of existing credible scientific evidence which is relevant to evaluating the 

reasonably foreseeable significant adverse impacts on the human environment, and 

4. the agency's evaluation of such impacts based upon theoretical approaches or research 

methods generally accepted in the scientific community. For the purposes of this section, 

"reasonably foreseeable" includes impacts which have catastrophic consequences, even if 

their probability of occurrence is low, provided that the analysis of the impacts is supported 

by credible scientific evidence, is not based on pure conjecture, and is within the rule of 

reason. 

To promote thorough, consistent, and efficient review of the hundreds of catalogued statements, 

BOEMRE analysts used a structured review approach (illustrated by the figure below). This 

approach, taken directly from the language of 40 CFR 1502.22, consists of three steps. Each step 

asks a “Yes” or “No” question, the answer to which determines whether the analysis of the statement 

either progresses to the next step or the statement requires no further review. Where analysts 

answered “Yes,” they simply moved on to the next question. Where analysts answered “No,” they 

recorded the reasoning behind the answer in the spreadsheet that constitutes the body of Appendix A, 

thus concluding review of that statement. The completed analysis for all catalogued statements was 

then reviewed by supervisory and staff specialists, who confirmed the analysis and determined that it 

satisfied 40 CFR 1502.22 (and DOI regulations for implementing NEPA at 43 CFR 46.125). 

Step 1: Is the missing 

info “relevant to 

reasonably foreseeable 

significant adverse 

effects on the human 

environment”? 

Step 2: Is the 

missing info 

“essential to a 

reasoned choice 

among 

alternatives”? 

Step 3: Is the 

missing info 

“obtainable”? 

[Info is 

obtainable if 

both 1) the 

overall costs 

are not 

exorbitant, 

AND 2) the 

means to 

acquire it are 

known.] 

Agency 

obtains the 

info and 

analyzes it 

within the 

EIS 

EIS need not 

discuss 

information; if 

addressed as 

missing, must 

also address 

relevance. 

EIS must 

state that the 

information is 

lacking and 

explain why 

it is not 

essential to 

the decision. 

EIS includes 40 

CFR 

1502.22(b)(1-4) 

analysis 

Y

N 

Y Y 

N 

N
Sale 193 Revised Draft SEIS BOEMRE 

Appendix A A3

Results 

BOEMRE analysts determined that while many statements of incomplete or unavailable information 

were broadly relevant to the important issues at hand, none were essential for a reasoned choice 

among alternatives. As the statements were analyzed, some common themes became apparent with 

respect to the catalogued statements. These included the following: 

 The availability of sufficient information to support sound scientific judgments and 

reasoned managerial decisions, even without the identified incomplete or unavailable 

information. This concept recognizes that while there will always be some level of incomplete 

information (especially regarding dynamic ecosystems), there is often enough information to 

formulate and support sound scientific judgments. Scientists frequently agree on larger issues 

and trends despite the lack of a particular item of information. For example, while scientists may 

not know each cause of natural mortality for bowheads, it is well known (and more important) 

that this population as a whole is growing. Also, some information is simply not of a type that 

would alter scientific judgments or affect decision-making. Some information simply is not 

significant or relevant enough to be considered essential to a reasoned decision among 

alternatives. For example, additional information about the winter food habits of a whale that is 

only present within the action area during summer months may not be significant or relevant 

enough to be considered essential to a reasoned decision among alternatives. 

 The presumption that adverse effects would certainly occur under the specific circumstance 

to which the incomplete information applies. For instance, it is already presumed that a large 

oil spill could cause significant adverse impacts to wildlife and other resources, through myriad 

direct and indirect effects. Thus, it is not essential for the decision-maker, who is already made 

aware of the probability and severity of these potential impacts, to understand every particular 

mechanism through which these adverse impacts could occur. Additional information specific to 

how spilled oil may affect the functioning of a whale’s blowhole, for example, is not required for 

an understanding of the probability and severity of risks associated with each alternative. 

 The commonality of potential impacts amongst all action alternatives, which lessened the 

utility of incomplete information to the decision-maker. For example, in the unlikely event of 

a large oil spill, it is well-understood that environmental impacts could be severe. The severity of 

potential impacts would be nearly identical under any action alternative; therefore, very specific 

types of information relevant to species, particular life history traits, or behavior do not help 

substantially in distinguishing among alternatives. 

 The existence of other environmental laws and regulations that would preclude significant 

adverse effects on particular resources. For example, comprehensive regulatory standards 

under the Clean Air Act are sufficient to preclude air quality impacts from reaching a level of 

significance. Incomplete information regarding air quality issues is in this sense less useful to the 

decision maker, who is assured that no matter which alternative he or she selects, significant 

adverse effects to air quality will be avoided. 

 The understanding that certain items of presently missing or incomplete information will be 

known (and utilized to avoid or minimize adverse impacts) at a later stage of OCS Lands 

Act environmental review. The OCS Lands Act creates a four-stage process for planning, 

leasing, exploration, and development and production of oil and gas resources in Federal waters. 

The first two stages (the 5-Year Program stage and the Lease Sale stage) are largely 

programmatic in nature—the pending decision pertains to Stage 2, the lease sale stage. It is 

inherent in the process that information such as the specific locations or times of development 

and production activities (proposals for which are examined in Step 4) are not known at lease sale 

stage (Step 2). Instead, BOEMRE would thoroughly review specific development & production 

plans at Step 4, if and when a project proponent actually submits a plan. Thus, while certain 
BOEMRE Sale 193 Revised Draft SEIS 

A4 Appendix A

information may, in fact, be essential at a later stage of OCS Lands Act, such information may 

not be essential to a reasoned choice among alternatives at this lease sale stage. 

It should be noted that no statements written specifically for the body of the SEIS are included or 

analyzed within this Appendix. The SEIS is written in compliance with the requirements of 40 CFR 

1502.22. The types of procedural deficiencies within the original Sale 193 FEIS that formed the basis 

for the second and third concerns of the District Court’s remand do not recur within the SEIS. For 

instance, the SEIS does not include unexplained statements regarding incomplete information Only 

one section of the SEIS references incomplete information “relevant to reasonably foreseeable 

significant adverse effects.” In that section, the SEIS follows 1502.22 by assessing whether the 

incomplete information is “essential to a reasoned choice among alternatives.” The SEIS then 

provides an explanation as to why this incomplete information is not essential to a reasoned choice 

among alternatives, discharging the agency’s 1502.22 obligations. No incomplete information 

pertinent to natural gas development and production progresses to step 3 of 1502.22 analysis, which 

would have required a determination as to “whether the cost of obtaining the missing information is 

exorbitant, or the means of doing so unknown.” 

As mentioned above, there is one environmental resource where significant adverse effects from 

natural gas development and productions are considered reasonably foreseeable: Archaeological 

Resources. In Section IV.C.16, BOEMRE acknowledges that it does not possess complete 

information on the existence or location and characteristics of unknown archaeological resources. 

This “missing” information is “relevant to reasonably foreseeable significant adverse effects,” given 

the possibility that natural gas development activities could irreversibly damage currently unknown 

sites, which would constitute a significant adverse effect. This “missing” information is, however, 

not “essential for a reasoned choice among alternatives.” As the SEIS explains, potential impacts to 

archaeological resources are similar among all action alternatives, given that pipelines would, in each 

case, utilize the same existing oil infrastructure corridor; additional information on the location of 

archaeological resources would be gathered through required preconstruction surveys and utilized to 

avoid or minimize impacts during the Development & Production phase; and other environmental 

laws and regulations (i.e. pipeline protocols, Section 106 of the NHPA) would greatly reduce the 

potential for significant adverse effects under each alternative. The text of the SEIS also provides the 

decision-maker with comparative analysis of the slight differences between alternatives when it 

states: “Comparing alternatives, there is a positive correlation between the size of the area deferred 

from leasing and potential impacts to archaeological resources, but the overall potential for impacts 

remains small under each alternative.” By identifying all missing information relevant to reasonably 

foreseeable significant adverse effects, and then explaining why the missing information is not 

essential to a decision among alternatives at the lease sale stage, the SEIS fully complies with 40 CFR 

1502.22. 
1502.22 Analysis

Page Number: ES-5

Actual Statement:

There is uncertainty about effects on cetaceans in the event of a large spill. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to adverse effects that are already assumed to occur under certain circumstances. The analysis 

already assumes that if a large oil spill occurs, significant impacts to cetaceans could follow. Neither the probability nor severity 

of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: II-33

Actual Statement:

A review of available science and management literature shows that, at present, there are no empirical data to document 

potential impacts from seismic surveys reaching a local population-level effect. The experiments conducted to date have not 

contained adequate controls to allow us to predict the nature of a change or that any change would occur.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

This passage of the EIS explains that despite a diligent literature review, we were unable to identify any data that suggested 

seismic surveys could result in significant adverse effects to fish populations. This finding does not conclude that such studies 

exist. As explained in the FEIS, available scientific information is sufficient to conclude that no significant adverse effects are 

reasonably foreseeable (FEIS page IV-74). The lack of empirical data documenting population-level effects does not qualify as 

missing information relevant to reasonably foreseeable significant environmental effects. 

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: II-34

Actual Statement:

Given a lack of contemporary abundance and distribution information, large oil spill effects on rare or unique species (including 

potential extirpation) could occur, but would likely go unnoticed or undetected.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

It is well understood that the environmental impacts associated with a large oil spill could be severe. Rare species could be 

affected by such an event wherever they may occur throughout the lease sale area. These impacts are explained in great detail 

throughout Chapter 4 of the FEIS. Overall, it is clear that: (1) no large oil spills or spill-related impacts could result from a 

selection of the No Action Alternative; (2) potential spill impacts (including impacts to rare or unique species) are nearly identical 

under each action alternative (i.e. Alternatives 1, 3 and 4.); and (3) the probability of a large spill occurring is identical under each 

action alternative . In light of these considerations, the decision-maker already has sufficient information regarding the relative 

probability and various impacts of a large oil spill to allow a reasoned choice among lease sale alternatives. The identified 

"incomplete information" is therefore not essential to a reasoned choice among lease sale alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A5
Page Number: II-35

Actual Statement:

Uncertainty exists about the potential effects of seismic surveys on bowhead whales (especially on calf survival and growth and

female reproduction) in the Chukchi Sea due to a lack of current data about their use of the Proposed Action area during periods 

when seismic surveys could be occurring. What is known, however, is that the observed response of bowhead whales to seismic 

survey noise varies among studies. Some of the variability appears to be context specific (i.e. feeding versus migrating whales) 

and also may be related to the whales' reproductive status and/or sex or age.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have an unmitigable adverse impact on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project-or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from "industrial noises," BOEMRE remains confident that the existing regulatory framework is sufficient to prevent 

noise impacts from having more than a negligible level of effect. A negligible level of effect, as defined by the MMPA, could not 

rise to "significance," as defined in Section IV.A.1. of the FEIS. The FEIS anticipates that significant adverse effects to marine 

mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonably foreseeable significant adverse effects. It should also be noted that the 

bowhead whale is protected against significant adverse effects from the Endangered Species Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: II-36

Actual Statement:

Bowheads respond to drilling noise at different distances depending on the types of platform from which the drilling is occurring. 

Data indicate that many whales can be expected to avoid an active drillship at 10- 20 km or possibly more.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

This statement offers valuable, quantitative information on whale avoidance; however, it does not indicate missing information 

relevant to reasonably foreseeable adverse effects on the human environment.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: II-36

Actual Statement:

The long-term response of bowheads to production facilities located at the southern end of the migration corridor is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The southern end of the bowhead migration corridor is in the Bering Sea, outside of the proposed action area. This information is 

not related to any reasonably foreseeable significant adverse effect on the human environment associated with this Proposed 

Action.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A6 Appendix A
Page Number: II-36

Actual Statement:

There is uncertainty about the effects on bowheads (or any large cetacean) from the event of a large oil spill.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

These effects, as well as the probability of these effects occurring, would be the same under each action alternative. The 

decision-maker already has sufficient information regarding the relative probability (as between the No Action Alternative and 

each action alternative) and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information regarding the effects on bowheads (or any large cetacean) from the event of a large oil spill is not essential to a

reasoned choice among alternatives at this stage.

Page Number: II-37

Actual Statement:

Several areas historically documented to be important to marine and coastal birds in Sale 193 area, as well as the entire 

proposed lease sale area, lack site-specific data on habitat-use patterns, routes, and timing to assess impacts. For many 

species, the most recent data is between 15 and 30 years old, making accurate analysis difficult. Overall, several species or 

species-groups have a high probability of experiencing substantial negative impacts. The risk that several regional bird 

populations could experience significant adverse impacts is high. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the distribution of marine and coastal birds in the action area. However, 

sufficient information (population ranges, preferred habitat types, etc.) is available to support sound scientific judgments and 

informed decision-making at this lease sale stage, which is relatively programmatic in nature. Detailed and current information 

regarding specific populations at specific locations at specific times of year will be further evaluated during subsequent stages of 

the OCSLA process that focus on specific proposals in specific locations. In sum, this "incomplete information" is not essential to 

a reasoned choice among alternatives at this stage.

Page Number: II-37

Actual Statement:

Based on the paucity of information available on marine mammal ecology in the Chukchi Sea and on specific locations of future 

developments, we are unable to determine at this time if significant impacts will or will not occur.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

As this general statement indicates, there will be some level of incomplete information on marine mammal ecology in the Chukchi

Sea. However, sufficient information is available to support sound scientific judgments and reasoned managerial decisions at the 

lease sale stage. Activities with the potential to affect marine mammals will be subject to additional BOEMRE as well as NMFS 

and/or FWS review processes. Appropriate mitigation measures can and will be applied as proposals for specific activities are 

submitted. This multi-stage process permits more detailed review of each proposal and development of more tailored mitigation 

measures. Substantive and procedural requirements of the MMPA (and as applicable, the ESA) will serve to prevent significant 

adverse impacts. These requirements are common to all alternatives. In light of the above, any "incomplete information" 

regarding marine mammal ecology and specific locations of future developments is not essential to a reasoned choice between 

alternatives at this current stage. 

Sale 193 Revised Draft SEIS BOEMRE Appendix A A7
Page Number: II-37

Actual Statement:

Because of the lack of data it is unknown if noise introduced into the environment from industrial activities, including drilling and 

seismic operations, will have an adverse impact on non-endangered and non-threatened marine mammals in the Proposed Action 

area.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from "industrial noises," BOEMRE remains confident that the existing regulatory framework is sufficient to prevent 

noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could not rise 

to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to marine 

mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonably foreseeable significant adverse effects. 

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: II-42

Actual Statement:

Because of the lack of data on marine mammal distributions and habitat use in offshore areas of the Chukchi Sea, it is uncertain 

what the level of effects would be in offshore areas.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the distribution of marine mammals in the Chukchi Sea. However, 

sufficient information is available to support sound scientific judgments and reasoned managerial decisions at the lease sale 

stage. Further environmental review using site- and project-specific information will occur at later stages of the OCSLA process. 

Significant impacts will be avoided under all alternatives via ESA Section 7 consultation and substantive ESA and MMPA 

requirements. Overall, additional information on this subject is not essential for a reasoned choice among alternatives at this 

stage.

BOEMRE Sale 193 Revised Draft SEIS A8 Appendix A
Page Number: II-45

Actual Statement:

However, because of the lack of data on marine mammal distributions and habitat use in offshore areas of the Chukchi Sea, it is

uncertain what the level of effects would be in offshore areas. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the distribution and habitat use of marine mammals in the Chukchi Sea. 

However, as explained in Chapter 4 of the FEIS, much information is known. Sufficient information is available to support sound 

scientific judgments and reasoned managerial decisions at the lease sale stage. Additional information on these subjects is not 

essential to a reasoned choice among alternatives. Further environmental review using site- and project-specific information will 

occur at later stages of the OCSLA process. Significant impacts will be avoided under all alternatives via ESA Section 7 

consultation and substantive ESA and MMPA requirements. This would occur under all alternatives -- a fact which further reduces

the utility of any additional information at the current stage. In sum, additional information on this subject is not essential for a 

reasoned choice among alternatives.

Page Number: III-123

Actual Statement:

Due to a lack of specific data from the Chukchi Sea which would indicate where relative sea level stood at 13,000 years B.P., 

MMS is using the -60 m isobath as a conservative estimate of where the shoreline would have been in the Chukchi Sea at 12,000 

years B.P. ... Although no data are available for the time period of 13,000 B.P., we have adopted -60 m as the possible depth of 

the sea level still-stand, corresponding to approximately 13,000 years B.P.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

This missing information pertains to potential impacts to archeological resources. Detailed information on the location of 

archeological resources is not needed during the first two stages of OCSLA environmental review, which are largely programmatic

in nature. Site-specific surveys would be required at later stages for activities with potential to disturb these resources. This is 

equally true for all action alternatives. Thus, this information is not essential for a reasoned choice among alternatives at the 

lease sale stage.

Page Number: III-123

Actual Statement:

No surveys of these shipwrecks have been made; therefore, no exact locations are known. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

Detailed information on the location of archeological resources is not needed during the first two stages of OCSLA environmental 

review, which are largely programmatic in nature. Site-specific surveys would be required at later stages for activities with 

potential to disturb these resources. This is equally true for all action alternatives. Thus, this information is not essential for a 

reasoned choice among alternatives at the lease sale stage.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A9
Page Number: III-15

Actual Statement:

The recurrence interval of ice gouging on the seafloor of the Chukchi Sea is unknown at this time. Quantitative information on ice 

gouges is sparse to nonexistent in the Chukchi Sea, except for localized surveys. Ice-gouge data were last collected on a 

regional basis more than 20 years ago, when instrument and navigation quality was less accurate than current technology. The 

MMS has collated all of the available ice-gouge and strudel-scour data for site-specific surveys and development surveys in the

Beaufort Sea and is just beginning this effort in the Chukchi. At this time, there are insufficient interpreted data to predict the 

occurrence, extent, and magnitude of these features in a quantitative fashion for the region as a whole

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Additional quantitative information on historical ice gouging is not relevant to any reasonably foreseeable significant adverse

effects identified in the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-22

Actual Statement:

Data are limited, but at least in one instance it has been shown that ice-deformation noise produced frequencies of 4-200 Hz 

(Greene, 1981).

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Additional information on the frequency of noise produced by ice-deformation is not relevant to any reasonably foreseeable 

significant adverse effects identified in the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-32

Actual Statement:

Surveys of coastal and marine fish resources in the Chukchi and Beaufort seas are typically conducted during periods that ice 

cover is greatly reduced (late July, August, or September) and information concerning the distribution, abundance, habitat use,

etc., of marine fishes outside this period is limited. Due to the lack of specific information for many species, it is necessary to 

discuss the biology and ecology at the family level.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the distribution, abundance, habitat use, etc. outside of the open-water 

period in the Chukchi Sea. While certainly relevant in a general sense, this information is not essential to a reasoned choice

among alternatives at the lease sale stage. Sufficient information on these issues is already available to support sound scientific 

judgments and reasoned managerial decisions regarding fish populations (see Chapters 3 and 4 of the FEIS). Given the nature 

of the proposed action, no significant impacts are expected to occur to these resources under any alternative. Additional, sitespecific review requirements (specifically NEPA and EFH consultation) that would apply at later stages of the OCS process would

identify any appropriate mitigation measures. Moreover, the missing information pertains to impacts that would be common to all 

action alternatives, and would be of limited utility in deciding between these options. Additional information is therefore not 

essential for a reasoned choice among alternatives.

BOEMRE Sale 193 Revised Draft SEIS A10 Appendix A
Page Number: III-32

Actual Statement:

Despite these previous works, several data deficiencies remain. Information of current distribution and abundance (e.g., fish per 

square kilometer) estimates, age structure, population trends, or habitat use areas are not available for fish populations in the 

northeastern Chukchi Sea. Many fish studies reporting distribution and/or abundance are 20-30 years old. Other studies are still 

older. For example, the only survey of demersal fishes in the region is more than 20 years old. Fish assemblages and populations 

in other marine ecosystems of Alaska (e.g., Gulf of Alaska, Bering Sea) have undergone observable shifts in diversity, 

distribution, and abundance during the last 20-30 years; it is not known if the findings of Frost and Lowry (1983) still accurately 

portray the diversity and abundance of demersal fishes in the Alaskan Beaufort Sea. The same is true for other dated studies. It is 

possible that they no longer accurately and precisely reflect the current distribution, abundance, and habitat use patterns of fish 

resources in the northeastern Chukchi and western Beaufort seas. Such information could be stale, or in some cases, stagnant. If 

so, accurate information concerning the distribution, abundance, and habitat use patterns of fish resources is incomplete and/or 

unavailable from which to accurately and/or precisely assess environmental impacts from the Proposed Action.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information concerning fish population distribution, abundance, habitat use, etc. in certain 

areas of the Chukchi Sea. While important overall, this information is not essential to a reasoned choice among alternatives at 

the lease sale stage. Sufficient information is available to support sound scientific judgments and reasoned managerial decisions 

regarding fish populations. Given the nature of the proposed action, no significant impacts are expected to occur to these 

resources under any alternative. Additional, site-specific review requirements (specifically NEPA and EFH consultation) that 

would apply at later stages of the OCS process would identify any appropriate mitigation measures. Moreover, the missing 

information pertains to impacts that would be common to all action alternatives, and would not aid the decision between those 

alternatives. More information of this type is not essential for a reasoned choice among alternatives.

Page Number: III-33

Actual Statement:

Another important data gap is the lack of information concerning discrete populations for arctic fishes. The literature abounds with 

casual references made of various fish populations without having delimited the population other than by perhaps using arbitrary 

boundaries of a study area, or presenting data without discriminating one discrete population unit from another. Additionally, a few 

marine species are regarded as widespread and/or abundant, yet distribution and density statistics for discrete populations are

scarce, unknown, and therefore, incomplete. Several species are known only from a single specimen of each species; others are 

known from perhaps a handful of specimens collected years to decades ago. Population information is entirely lacking for such 

species.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information concerning discrete populations of arctic fish in the action area. While 

important overall, this information is not essential to a reasoned choice among alternatives at the lease sale stage. Sufficient 

information is available to support sound scientific judgments and reasoned managerial decisions regarding fish populations. 

Given the nature of the proposed action, no significant impacts are expected to occur to these resources under any alternative. 

Additional, site-specific review requirements (specifically NEPA and EFH consultation) that would apply at later stages of the OCS 

process would identify any appropriate mitigation measures. Moreover, the missing information pertains to impacts that would be 

common to all action alternatives, and would not aid the decision between those alternatives. More information of this type is not 

essential for a reasoned choice among alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A11
Page Number: III-34

Actual Statement:

Marine waters support the most diverse, although least well known, fishes of the Alaskan Beaufort Sea region. Studies of marine

fishes in the region are very limited; most of the surveys/studies have been performed in coastal waters landward of the landward 

of 200-m isobath, with scant surveys having sampled deeper waters. . . . [R]obust population estimates or trends for marine 

fishes of the region are unavailable. Distribution or abundance data for marine fish species are known only generally at the 

coarsest grain of resolution (for example, common, uncommon, rare).... Detailed information generally is lacking concerning the 

spread, density, or patchiness of their distribution in the overall Chukchi Sea region. Data concerning habitat-related densities; 

growth, reproduction, or survival rates within regional or local habitats; or productivity rates by habitat, essentially are unknown for 

fishes inhabiting waters seaward of the nearshore, brackish-water ecotone.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

 

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information concerning habitat-related densities, productivity rates, etc. in the action area. 

While important overall, this information is not essential to a reasoned choice among alternatives at the lease sale stage. 

Sufficient information is available to support sound scientific judgments and reasoned managerial decisions regarding fish 

populations. Given the nature of the proposed action, no significant impacts are expected to occur to these resources under any 

alternative. Additional, site-specific review requirements (specifically NEPA and EFH consultation) that would apply at later 

stages of the OCS process would identify any appropriate mitigation measures. Moreover, the missing information pertains to 

impacts that would be common to all action alternatives, and would not aid the decision between those alternatives. This 

information is not essential to a reasoned choice among alternatives.

Page Number: III-35

Actual Statement:

Life-history data for many of the demersal species using neritic substrates is lacking (e.g., whitespotted greenling, twohorn 

sculpin, spinyhook sculpin, veteran poacher); consequently, assessing the species resilience to perturbations is not feasible until 

additional information becomes available.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete life history information for demersal species using neritic substrates. This information is 

not essential to a reasoned choice among alternatives at the lease sale stage. Sufficient information is available to support sound 

scientific judgments and reasoned managerial decisions regarding fish populations. Given the nature of the proposed action, no 

significant impacts are expected to occur to these resources under any alternative. Additional, site-specific review requirements 

(specifically NEPA and EFH consultation) that would apply at later stages of the OCS process would identify any appropriate 

mitigation measures. Moreover, the missing information pertains to impacts that would be common to all action alternatives, and 

would not aid the decision between those alternatives. This information is not essential to a reasoned choice among alternatives.

BOEMRE Sale 193 Revised Draft SEIS A12 Appendix A
Page Number: III-35

Actual Statement:

No species of this assemblage are assessed as being of low resilience, because life-history data are lacking.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The absence of an indication that certain species may be less resilient does not represent missing information essential to a 

reasoned choice among alternatives.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-35

Actual Statement:

Surveys and studies of pelagic fishes inhabiting “offshore waters” (as defined by Jarvela and Thorsteinson [1999] as marine 

waters deeper than 2 m), especially those more than 30 m in depth, are scant. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population abundance, distribution, or vulnerability for pelagic fish in the 

Arctic. Such baseline information is important; however, sufficient information is available to support sound scientific judgments 

and reasoned managerial decisions at the lease sale stage. More detailed, site-specific information would be collected at later

OSCLA review stages, when project proposals and locations would be available. Furthermore, the missing information pertains to 

impacts that are common to all alternatives, which tends to reduce the utility of such information to the decision-maker. Overall 

this information is not essential to a reasoned choice among alternatives at the lease sale stage.

Page Number: III-35

Actual Statement:

The more intimate aspects of their behavior are, however, still little known....

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Information on the intimate aspects of behaviors of cryopelagic fish is not relevant to reasonably foreseeable significant adverse 

effects identified in the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A13
Page Number: III-36

Actual Statement:

Arctic cod and Pacific sand lance are assumed to be of medium resilience to exploitation; polar cod and toothed cod are data 

deficient such that an assessment of resilience is not feasible with available information.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The proposed action would not entail any commercial fishing, and no commercial fishing occurs within the action area. The 

resiliency of these species to exploitation is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-36

Actual Statement:

Life-history statistics for most species covered in this assemblage are data deficient, chiefly for lack of fish surveys and studies in 

oceanic waters of the Alaskan arctic.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the oceanic-demersal assemblage of marine fish in the Chukchi Sea. Such 

background information is generally relevant to impacts assessment. However, sufficient information is already available to 

support sound scientific judgments and reasoned managerial decisions at the lease sale stage, which is somewhat general and 

programmatic in nature. Given the nature of the proposed action, no significant impacts are expected to occur to these resources 

under any alternative. Additional, site-specific review requirements (specifically NEPA and EFH consultation) that would apply at 

later stages of the OCS process would identify any appropriate mitigation measures. Also, the missing information pertains to 

impacts that are common to all action alternatives, which further limits the utility of this information. More information of this type 

is not essential for a reasoned choice among alternatives.

Page Number: III-39

Actual Statement:

Little is known of the movements undertaken during the 18 months the salmon spend at sea.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

As this general statement points out, there is some level of uncertainty regarding movement patterns of juvenile pink salmon 

while at sea. However, sufficient information regarding the life cycle and movements of pink salmon is available to support sound 

scientific judgments and reasoned managerial decisions. Additional information on this issue would be of marginal utility and is 

not essential to a reasoned choice among alternatives.

BOEMRE Sale 193 Revised Draft SEIS A14 Appendix A
Page Number: III-40

Actual Statement:

Chum salmon fry, like pink salmon, do not overwinter in streams but migrate (mostly at night) out of streams directly to sea 

shortly after emergence. The timing of outmigration in the arctic is unknown, but occurs between February and June (chiefly 

during April and May) in more southern waters.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of uncertainty as to the exact time period that certain salmon fry may emerge from Arctic streams along 

the Chukchi Sea coast. While relevant to potential impacts, this information is not essential to a reasoned choice among 

alternatives at the lease sale stage. Sufficient information is available to support sound scientific judgments and reasoned 

managerial decisions. Furthermore, the missing information pertains to impacts that are common to all alternatives. Subsequent 

NEPA and EFH analyses will examine these issues as necessary at a later stage of the OCSLA process, when more information 

regarding specific sites and activities is known. This information is not essential to a reasoned choice among alternatives at this 

stage.

Page Number: III-40

Actual Statement:

Fish resources of the northeastern Chukchi Sea were last surveyed 15-17 years ago. Additionally, other surveys over the years 

and area reflect a pattern of temporally and spatially irregular and disjunct sampling. Such disorganized sampling and data 

reporting greatly influences the information quality necessary to determine population trends and adjustments to environmental 

perturbations. Establishing a current, accurate, and precise baseline is critical to assessing potential changes to biotic resources. 

It is unknown if the distribution and abundance information gathered by the last surveys remains an accurate and precise 

description of arctic fish populations today. This is an important because the Chukchi and Bering seas are considered to be large 

marine ecosystems serving as principle bellwethers to climate change in North America and the Arctic Ocean.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the Arctic fish population trends, population adjustments to environmental 

perturbations, and the relationship of the Chukchi Sea to climate change effects in North America. However, sufficient 

information is available to support sound scientific judgments and reasoned managerial decisions on these issues and general 

trends. Furthermore, the missing information pertains to impacts that are common to all alternatives, which limits the value of this 

information in selecting between alternatives. Overall, additional information on these subjects is not essential to a reasoned

choice among alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A15
Page Number: III-41

Actual Statement:

Adjustments by one or more fish populations often require adjustments within or among large marine ecosystems, influencing the 

distribution and/or abundance of competitors, prey, and predators. Consequently, it appears reasonable to believe that the 

composition, distribution, and abundance of fish resources in the northwestern Chukchi Sea is changing and is now different from 

that measured in the surveys conducted 15-17 years ago or earlier. The magnitude of these differences is unknown.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the adjustments of Arctic fish populations to changes in the distribution of 

their predators, prey, and competitors in the Chukchi Sea in recent years. While potentially relevant, this information is not

essential for a reasoned choice among alternatives. Sufficient information is available to support sound scientific judgments and 

reasoned managerial decisions. Furthermore, the missing information pertains to impacts that are common to all alternatives, 

which reduces the value of the information in distinguishing between alternatives. 

Page Number: III-42

Actual Statement:

No information was found as to the species inhabiting the areas; hence, we cannot describe their biology and ecology as relating 

to a baseline description. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population abundance, distribution, or vulnerability of marine invertebrate 

fisheries in specific areas within the Arctic. Such baseline information is important; however, sufficient information about these 

general topics is available to support sound scientific judgments and reasoned managerial decisions. Furthermore, the missing 

information pertains to impacts that are common to all alternatives, which limits the utility of the information to the decision-maker. 

Overall this information is not essential to a reasoned choice among alternatives at the lease sale stage. 

Page Number: III-45

Actual Statement:

There is scientific uncertainty about the population structure of bowheads that use the Arctic Ocean.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

This statement highlights the nearly axiomatic truth that there will always be some level of scientific uncertainty regarding any 

dynamic population of animals. Sufficient information regarding bowhead whales is available (and analyzed in the FEIS) to 

support sound scientific judgments and reasoned managerial decisions, and additional information is not essential for reasoned 

decisions among alternatives.

BOEMRE Sale 193 Revised Draft SEIS A16 Appendix A
Page Number: III-45

Actual Statement:

Conservation concerns include: . . uncertain potential impacts of climate warming. . .. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While there is some degree of unavoidable uncertainty as to the potential impacts of climate warming, much information 

regarding its basic mechanisms and general effects does exist and is analyzed in the FEIS. The amount and value of the 

information available is sufficient to support sound scientific judgments and reasoned managerial decisions. Further, the missing 

information applies equally to all alternatives, and would be of limited utility in distinguishing between respective levels of potential 

impact. For these reasons, additional information on this topic is not essential to a reasoned choice amongst alternatives. 

Page Number: III-45

Actual Statement:

No data are available indicating that, other than historic commercial whaling, any previous human activity has had a significant 

adverse impact on the current status of BCB Seas bowheads or their recovery.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The lack of an indication that human activity has had a significant adverse impact on the current status of the BCB Seas bowhead 

or their recovery does not qualify as missing information relevant to reasonably foreseeable adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-45

Actual Statement:

The uncertainty of the stock structure adds some uncertainty to summaries of the status of bowheads that may be impacted by 

the Proposed Action.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

Scientists may not be 100% certain about the best way to organize their conceptual stock structures for bowheads in the larger 

region. However, sufficient information exists to support sound scientific judgments and reasoned managerial decisions regarding 

potential impacts of the Proposed Action and alternatives on Chukchi Sea bowheads. Additional certainty on the structure of 

bowhead stocks is not essential to a reasoned choice among alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A17
Page Number: III-45

Actual Statement:

Recent data to evaluate bowhead use of the Chukchi Sea Planning Area, or adjacent areas to the south, are lacking.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

As this general statement indicates, there will be some level of incomplete information on bowhead use of the Chukchi Sea and 

nearby areas. However, that sufficient information on these topics is available and has been analyzed. Also, activities with the 

potential to affect marine mammals are subject to additional BOEMRE as well as NMFS and/or FWS review processes. 

Appropriate mitigation measures can and will be applied as proposals for specific activities are submitted. This multi-stage 

process permits more detailed review of each proposal, and development of more tailored mitigation measures. As per the 

MMPA and ESA, significant impacts must be avoided. These procedural and substantive requirements (which would ensure that 

site-specific information is analyzed and that potential impacts to marine mammals do not rise to significance) would apply 

equally under each alternative. Thus, additional knowledge about bowhead use of these areas is not essential to a reasoned 

choice among alternatives at this stage of the review process.

Page Number: III-46

Actual Statement:

[I]f whales become more ‘skittish’ and more highly sensitized following a hunt, it may be that their subsequent reactions, over the 

short-term, to other forms of noise and disturbance are heightened by such activity. Data are not available that permit evaluation 

of this possible, speculative interaction.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There is some level of uncertainty regarding the speculative potential for short-term impacts to whales following hunts. However, 

sufficient information regarding whales' behavior, avoidance patterns, etc. are available to support sound scientific judgments and 

reasoned managerial decisions. It should also be noted that these possibilities have already been taken into account in the 

development of various alternatives and deferral areas. Enough is already known about the potential for impacts such that 

reasoned choices among alternatives can be made. Additional information on these issues is not essential. 

Page Number: III-46

Actual Statement:

The NMFS has concluded that there is no reliable information about population-abundance trends, and that reliable estimates of 

current or historical abundance are not available, for the entire Northeast Pacific fin whale stock.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The fin whale is known to be an occasional visitor to the action area. Sufficient information on its (limited) use of the Chukchi 

exists to support sound scientific judgments and reasoned managerial decisions. Additional information regarding current or 

historical abundance of the Northeast Pacific fin whale stock is not essential to a reasoned choice among alternatives. Moreover, 

the substantive and procedural requirements of the MMPA and ESA would serve to preclude significant impacts to the fin whale 

under each alternative.

BOEMRE Sale 193 Revised Draft SEIS A18 Appendix A
Page Number: III-46

Actual Statement:

We are not aware of data indicating how far hunting-related sounds (for example, the sounds of vessels and/or bombs) can 

propagate in areas where hunting typically occurs, but this is likely to vary with environmental conditions. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no connection between the missing information and reasonably foreseeable significant adverse effects associated with 

the Proposed Action or alternatives. The FEIS does not anticipate significant adverse effects to marine mammals outside the 

unlikely event of a large oil spill. Additionally, subsistence hunting would occur to the same extent under all alternatives, a fact 

which limits the utility of such information to the decision-maker.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-47

Actual Statement:

There are no recent data to confirm their use or lack of use of the Chukchi Sea Planning Area, or adjacent areas to the south.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The lack of data confirming presence [or absence of some specified thing] within the action area does not constitute missing 

information relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-48

Actual Statement:

Available information does not indicate humpback whales inhabit the Chukchi Sea OCS project area. There are no recent data to 

confirm their lack of use of the Chukchi Sea OCS Planning Area, or adjacent areas to the south.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The lack of data confirming presence of humpback whales within the action area does not constitute missing information relevant

to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A19
Page Number: III-48

Actual Statement:

Additional data are needed to determine if these data actually typify the bowhead population, and there is no single hypothesis

adequate to explain the pattern. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The identified population (stock) of bowhead whales is clearly identified in the 193 FEIS (page III-45) and any scientific 

uncertainty regarding genetic information is not relevant to reasonably foreseeable significant adverse effects identified in the 193 

FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-49

Actual Statement:

There is little information regarding causes of natural mortality for BCB Seas bowhead whales.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on bowhead whale mortality; however, knowing the different ways that 

bowhead whales die is not as important as understanding general population trends. For bowheads, the population trend is 

significantly positive. Overall, sufficient information exists to support sound scientific judgments and reasoned managerial 

decisions. Any incomplete information on this point is not essential to a reasoned choice among alternatives. Furthermore, the 

missing information pertains to impacts that are common to all alternatives, and would have limited value to the decision maker in 

distinguishing between the respective impacts of various alternatives.

Page Number: III-49

Actual Statement:

Little is known about the effects of microbial or viral agents on natural mortality.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the effects of microbial or viral agents on natural mortality of bowheads; 

however, knowing the different ways that bowhead whales die is not as important as understanding general population trends. 

For bowheads, the population trend is significantly positive. Overall, sufficient information exists to support sound scientific 

judgments and reasoned managerial decisions. Any incomplete information is not essential to a reasoned choice among 

alternatives. Furthermore, the missing information pertains to impacts that are common to all alternatives, and would be of 

limited utility in distinguishing between the respective impacts of various alternatives.

BOEMRE Sale 193 Revised Draft SEIS A20 Appendix A
Page Number: III-49

Actual Statement:

The amount of feeding in the Bering Sea in the winter is unknown as is the amount of feeding in the Bering Strait in the fall 

(Richardson and Thomson, 2002).

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

This data gap pertains to areas not affected by the proposed action, and is not related to any reasonably foreseeable significant 

adverse effects. 

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-50

Actual Statement:

The MMS funded large-scale surveys in this area when there was oil and gas leasing and exploration, but while surveys in the 

Beaufort Sea have continued, the last surveys in the Chukchi Sea were about 15 years ago. These data were summarized by 

Mel’nikov, Zelensky, and Ainana (1997), Moore (1992), Moore and Clarke (1990), and Moore, DeMaster, and Dayton (2000). We 

have plotted counts of bowheads in the Chukchi Sea during those surveys (Fig. III.B-4), because they visually provide limited 

insight into areas where bowheads may be exposed to oil and gas activities should they occur in the Chukchi Sea Planning Area. 

However, we caution against over-interpretation of these data out of context of survey effort and, because these data were 

collected between 1979 and 1991, they should not be interpreted as indicating current use of the Chukchi Sea by bowhead 

whales; they are the best data available.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While there will be some level of incomplete information on the bowhead whale use of the Chukchi Sea, BOEMRE (formerly 

MMS) has conducted or commissioned extensive study of bowhead use of the Chukchi Sea, and a general understanding of the 

bowhead migration has been accumulated. Existing information on general use and migration patterns is sufficient to support 

sound scientific judgments and reasoned managerial decisions, especially during the earlier stages of OCSLA review, which are 

necessarily more programmatic in nature. Overall, this incomplete information is not essential to a reasoned choice among 

alternatives.

Page Number: III-51

Actual Statement:

Data are limited on the bowhead fall migration through the Chukchi Sea before the whales move south into the Bering Sea.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While there will be some level of incomplete information on the bowhead whale use of particular portions of the Chukchi Sea, 

BOEMRE (formerly MMS) has conducted or commissioned extensive study of bowhead use of the Chukchi Sea, and a general 

understanding of the bowhead migration (including fall migration) has been accumulated. Existing information on general use and 

migration patterns is sufficient to support sound scientific judgments and reasoned managerial decisions, especially during the

earlier stages of OCSLA review, which are largely programmatic in nature. Overall, this incomplete information is not essential to 

a reasoned choice among alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A21
Page Number: III-52

Actual Statement:

Both MMS and the NSB believe that there are major questions about bowhead whale feeding that remain to be answered (Stang 

and George, 2003). Most of the available information about this topic (and presented in this EIS) is based on studies and 

observations conducted in the Alaska Beaufort Sea.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

As this general statement indicates, there will be some level of incomplete information on bowhead feeding in the Chukchi Sea. 

However, sufficient information is available to support sound scientific judgments and reasoned managerial decisions at the lease 

sale stage. Activities with the potential to affect marine mammals will be subject to additional BOEMRE as well as NMFS and/or

FWS review processes. Appropriate mitigation measures can and will be applied as proposals for specific activities are 

submitted. This multi-stage process permits more detailed review of each proposal, and development of more tailored mitigation

measures. As per the MMPA and ESA, significant impacts must be avoided; these laws apply under all alternatives. In light of 

the above, any incomplete information regarding bowhead feeding is not essential to a reasoned choice between alternatives at 

the lease sale stage. 

Page Number: III-53

Actual Statement:

It is unclear how important this feeding is in terms of meeting the annual food needs of the population or to meeting the food 

needs of particular segments of the population (e.g., see discussion in Richardson and Thomson, 2002). Many assumptions, 

such as those about residence time, an approximations influence current conclusions. Because marked individuals have not 

been studied, it is unclear how much variability also exists among classes of individuals or individuals within a class in habitat 

residency times, or what factors influence residency times.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

As this general statement indicates, there will be some level of incomplete information on bowhead feeding needs, residency 

times, etc in the Chukchi Sea. However, sufficient information is available to support sound scientific judgments and reasoned

managerial decisions at the lease sale stage. Activities with the potential to affect marine mammals will be subject to additional 

BOEMRE as well as NMFS and/or FWS review processes. Appropriate mitigation measures can and will be applied as proposals 

for specific activities are submitted. This multi-stage process permits more detailed review of each proposal, and development of 

more tailored mitigation measures. As per the MMPA and ESA, significant impacts must be avoided; these laws apply under all 

alternatives. In light of the above, any incomplete information regarding marine mammal ecology and specific locations of future 

developments is not essential to a reasoned choice between alternatives at the lease sale stage. 

BOEMRE Sale 193 Revised Draft SEIS A22 Appendix A
Page Number: III-54

Actual Statement:

The amount of feeding in the Chukchi Sea and Bering Strait in the fall is unknown as is the amount of feeding in the Bering Sea in 

the winter (Richardson and Thomson, 2002). Richardson and Thomson (2002:xxxviii) concluded that: “...behavioral, aerial-survey, 

and stomach-content data, as well as certain energetics data...show that bowheads also feed widely across the eastern and 

central Beaufort Sea in summer and fall.” In mid- to late fall, at least some bowheads feed in the southwest Chukchi. Detailed 

feeding studies have not been conducted in the Bering Sea in the winter.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While there will be some level of incomplete information on the bowhead whale use of particular portions of the Chukchi Sea, 

BOEMRE (formerly MMS) has conducted or commissioned extensive study of bowhead use of the Chukchi Sea, and a general 

understanding of bowhead migration and feeding has been accumulated. Existing information on general use and migration 

patterns is sufficient to support sound scientific judgments and reasoned managerial decisions, especially during the earlier 

stages of OCSLA review, which are largely programmatic in nature. Furthermore, the missing information pertains to potential 

impacts equally applicable to each action alternative, meaning that additional information on this subject is not likely to be useful 

to decision making at this stage. Overall, this incomplete information is not essential to a reasoned choice among alternatives.

Page Number: III-54

Actual Statement:

No comparable data on feeding, girth, or energy content have been obtained during and after the whales feed in the Chukchi sea 

in mid- to late fall. Assumptions about residence times influence these energetics-related estimates. As noted, available data 

indicate there is variability in habitat use among years. Because marked individuals have not been studied, it is unclear how 

much variability also exists among individuals in habitat residency times or what factors influence residency times.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

Again, there will be some level of incomplete information on bowhead feeding needs, residency times, etc in the Chukchi Sea. 

However, sufficient information is available to support sound scientific judgments and reasoned managerial decisions at the lease 

sale stage. Activities with the potential to affect marine mammals will be subject to additional BOEMRE as well as NMFS and/or

FWS review processes. Appropriate mitigation measures can and will be applied as proposals for specific activities are 

submitted. This multi-stage process permits more detailed review of each proposal, and development of more tailored mitigation

measures. As per the MMPA and ESA, significant impacts must be avoided; these laws apply under all alternatives. In light of 

the above, "incomplete information" regarding marine mammal ecology and specific locations of future developments is not 

essential to a reasoned choice between alternatives at the lease sale stage. 

Sale 193 Revised Draft SEIS BOEMRE Appendix A A23
Page Number: III-55

Actual Statement:

There are locations in the Beaufort Sea and the western Chukchi Sea where large numbers of bowheads have been observed 

feeding in many years. However, the significance of feeding in particular areas to the overall food requirements of the population 

or segments of the population is not clear.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While there will be some level of incomplete information on the significance of particular bowhead whale feeding areas within and 

near the action, BOEMRE (formerly MMS) has conducted or commissioned extensive study of bowhead use of the Chukchi Sea, 

and a general understanding of the bowhead migration and feeding has been accumulated. Existing information on general use 

and migration patterns is sufficient to support sound scientific judgments and reasoned managerial decisions, especially during

the earlier stages of OCSLA review, which are necessarily more programmatic in nature. Furthermore, the missing information 

pertains to potential impacts equally applicable to each action alternatives, meaning that additional information on this subject is 

not likely to be useful to decision making at this stage. Overall, this incomplete information is not essential to a reasoned choice 

among alternatives.

Page Number: III-55

Actual Statement:

Recent data on distribution, abundance, or habitat use in the Chukchi Sea Planning Area are not available.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While there will always be some lag between environmental change and available data that reflects that change, BOEMRE 

(formerly MMS) has conducted or commissioned extensive study of bowhead use of the Chukchi Sea, and a general 

understanding of the bowhead distribution, abundance, and habitat use is known. Existing information is sufficient to support 

sound scientific judgments and reasoned managerial decisions, especially during the earlier stages of OCSLA review, which are 

necessarily more programmatic in nature. Overall, this incomplete information is not essential to a reasoned choice among 

alternatives.

Page Number: III-56

Actual Statement:

The NMFS has concluded that there is no reliable information about population-abundance trends, and that reliable estimates of 

current or historical abundance are not available, for the entire Northeast Pacific fin whale stock (Angliss and Lodge, 2002; 

Angliss and Outlaw, 2005:rev. 10/24/04). They provided a Potential Biological Removal for the Northeast Pacific Stock of 11.4.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The fin whale is known to be an occasional visitor to the action area. Sufficient information on its (limited) use of the Chukchi 

exists to support sound scientific judgments and reasoned managerial decisions. Additional information regarding current or 

historical abundance of the Northeast Pacific fin whale stock is not essential to a reasoned choice among alternatives. Moreover, 

the substantive and procedural requirements of the MMPA and ESA would serve to preclude adverse impacts to the fin whale 

under each alternative.

BOEMRE Sale 193 Revised Draft SEIS A24 Appendix A
Page Number: III-56

Actual Statement:

There is little information about natural causes of mortality (Perry, DeMaster, and Silber, 1999a). The NMFS summarized that 

‘There are no known habitat issues that are of particular concern for this stock’ (Angliss and Lodge, 2002, 2005). Perry, 

DeMaster, and Silber (1999a:51) listed the possible influences of disease or predation as ‘Unknown.’ 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on whale mortality. However, knowing the different ways that whales die is not 

as important as understanding general population trends, which are understood for all whale species that use the action area. 

Overall, sufficient information exists to support sound scientific judgments and reasoned managerial decisions. Incomplete 

information on these issues is not essential to a reasoned choice among alternatives. Furthermore, the missing information 

pertains to impacts that are common to all alternatives, and would not be very useful in distinguishing between the respective 

impacts of various alternatives.

Page Number: III-57

Actual Statement:

The importance of specific feeding areas to populations or subpopulations of fin whales in the North Pacific is not understood.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The fin whale is known to be an occasional visitor to the action area. Sufficient information on its (limited) use of the Chukchi 

exists to support sound scientific judgments and reasoned managerial decisions. Additional information on specific feeding is not 

essential to a reasoned choice among alternatives at this point in the OCSLA process, which entails more site-specific analysis 

at later stages. Moreover, the substantive and procedural requirements of the MMPA and ESA would serve to preclude adverse 

impacts to the fin whale under each alternative.

Page Number: III-57

Actual Statement:

Information is not available to us that would permit evaluation of the current use of this area by fin whales.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

Although there will be some level of incomplete information on fin whale habitat use, sufficient information is available to support 

sound scientific judgments and reasoned managerial decisions at the lease sale stage. It is known, for instance, that the fin 

whale is an infrequent though occasional visitor to certain portions of the Chukchi Sale Area. Activities with the potential to affect 

marine mammals will be subject to additional BOEMRE as well as NMFS and/or FWS review processes. Appropriate mitigation 

measures can and will be applied as proposals for specific activities are submitted. This multi-stage process permits more 

detailed review of each proposal, and development of more tailored mitigation measures. As per the MMPA and ESA, significant 

impacts must be avoided; these laws apply under all alternatives. In light of the above, additional information regarding fin whale 

presence/absence is not essential to a reasoned choice between alternatives at the lease sale stage. 

Sale 193 Revised Draft SEIS BOEMRE Appendix A A25
Page Number: III-58

Actual Statement:

There is ‘no clear consensus’ (Calambokidis et al., 1997:6) about the population stock structure of humpback whales in the North 

Pacific due to insufficient information (Angliss and Lodge, 2002) (see further discussion in USDOI, MMS,2003a,b).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The humpback whale is known to be a rare though occasional visitor to the action area. Sufficient information on its (limited) use 

of the Chukchi exists to support sound scientific judgments and reasoned managerial decisions. Additional clarity on the stock

structure of the Northeast Pacific humpback whale is not essential to a reasoned choice among alternatives. Moreover, the 

substantive and procedural requirements of the MMPA and ESA would serve to preclude adverse impacts to humpback whales 

under each alternative.

Page Number: III-59

Actual Statement:

Angliss and Outlaw (2005) stated that: ‘There are no reliable estimates for the abundance of humpback whales at feeding areas 

for this stock’ (the Western North Pacific Stock) ‘because surveys of the known feeding areas are incomplete, and because not all 

feeding areas are known.’ There are not conclusive or reliable data on current population trends for the western North Pacific 

stock (Perry, DeMaster, and Silber, 1999b; Angliss and Outlaw, 2005).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The humpback whale is known to be a rare though occasional visitor to the action area. Sufficient information on its (limited) use 

of the Chukchi exists to support sound scientific judgments and reasoned managerial decisions. Additional information regarding 

specific feeding areas and exact population counts of the Northeast Pacific humpback whale stock is not essential to a reasoned

choice among alternatives. Moreover, the substantive and procedural requirements of the MMPA and ESA would serve to 

preclude adverse impacts to humpback whales under each alternative.

Page Number: III-59

Actual Statement:

There is no conclusive information on what population those humpbacks that enter the Chukchi Sea belong to. Based on the 

breakdown presented above, however, it is most likely that these whales would belong to the Western North Pacific stock. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Additional information on which population those humpbacks that enter the Chukchi Sea belong to is not relevant to reasonably 

foreseeable significant adverse effects identified by the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A26 Appendix A
Page Number: III-59

Actual Statement:

The reliability of pre- and post-exploitation and of current abundance estimates is uncertain. ... Perry, DeMaster, and Silber 

(1999b) caution that it is unclear whether these estimates are for the entire North Pacific or only the eastern North Pacific. With 

respect to the estimate of Johnson and Wolman and another post-exploitation estimate of 1,400 by Gambell (1976), 

Calambokidis et al. (1997) concluded that “...the methods used for these estimates are uncertain and their reliability questionable. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Additional information on pre- and post-exploitation and of current abundance estimates is not relevant to any reasonably 

foreseeable significant adverse effects identified by the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-60

Actual Statement:

Causes of natural mortality in humpbacks in the North Pacific are relatively unknown, and rates have not been estimated.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on humpback whale mortality. However, knowing the different ways that 

whales die is not as important as understanding general population trends, which are understood for all whale species that use 

the action area. Overall, sufficient information exists to support sound scientific judgments and reasoned managerial decisions. 

Any incomplete information is not essential to a reasoned choice among alternatives. Furthermore, the missing information 

pertains to impacts that are common to all alternatives, and would have limited value in distinguishing between the respective 

impacts of various alternatives.

Page Number: III-62

Actual Statement:

Noting “limited data.” 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on murre foraging areas in the Chukchi Sea. However, sufficient information is 

available to support sound scientific judgments and reasoned managerial decisions regarding potential impacts. Current, sitespecific analysis of murre distribution and foraging areas is more feasible during later stages of OCSLA, once specific project

proposals are submitted. Furthermore, the missing information largely pertains to impacts that are common to all action 

alternatives, and would not contribute much to a decision between them. In light of the above, any incomplete information on this 

subject is not essential to a reasoned choice among lease sale alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A27
Page Number: III-62

Actual Statement:

The current status of horned puffins in the Chukchi Sea is unknown.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

This general statement points to the fact that there will always be some level of incomplete information on the past and current 

distribution and abundance of horned puffins in the Chukchi Sea. However, sufficient information is available to support sound 

scientific judgments and reasoned managerial decisions regarding potential impacts to this species under each alternative. Any 

incomplete information on these issues is therefore not essential to a reasoned choice among alternatives. It should also be 

remembered that subsequent environmental reviews under later OCSLA review stages will be able to consider more current 

information regarding specific project locations, and thus provide a more robust review than is possible at the lease sale stage.

Page Number: III-62

Actual Statement:

The current status of the tufted puffin in the Chukchi Sea is also unknown.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

This general statement points to the fact that there will always be some level of incomplete information on the past and current 

distribution and abundance of tufted puffins in the Chukchi Sea. However, sufficient information is available to support sound 

scientific judgments and reasoned managerial decisions regarding potential impacts to this species under each alternative. Any 

incomplete information on these issues is therefore not essential to a reasoned choice among alternatives. It should also be 

remembered that subsequent environmental reviews under later OCSLA review stages will be able to consider more current 

information regarding specific project locations, and thus provide a more robust review than is possible at the lease sale stage.

Page Number: III-62

Actual Statement:

In this way, horned puffins could be similar to murres, although the degree to which prey species/foraging areas overlap is 

unknown.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on seabird foraging areas and dietary overlap in the project area. However,

sufficient information is available regarding both horned puffins and murres to support sound scientific judgments and reasoned

managerial decisions for both types of birds. These species are both listed under the ESA, have been the subject of in-depth 

consultation with USFWS, and will be further analyzed should specific project proposals result from a lease sale. Additional 

information of the type referenced here is not essential to a reasoned choice among alternatives at this stage.

BOEMRE Sale 193 Revised Draft SEIS A28 Appendix A
Page Number: III-63

Actual Statement:

The current status of the black-legged kittiwake (Rissa tridactyla) in the Chukchi Sea is unknown.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

This general statement points to the fact that there will always be some level of incomplete information on the past and current 

distribution and abundance of black-legged kittiwake in the Chukchi Sea. However, sufficient information is available to support 

sound scientific judgments and reasoned managerial decisions regarding potential impacts to this species under each alternative. 

Any incomplete information on these issues is therefore not essential to a reasoned choice among alternatives. It should also be 

remembered that subsequent environmental reviews under later OCSLA review stages will be able to consider more current 

information regarding specific project locations, and thus provide a more robust review than is possible at the lease sale stage.

Page Number: III-63

Actual Statement:

The portion of this population in the proposed lease sale area is unknown, but could be substantial late in the open-water season. 

Seasonal areas of concentration, if any, are unknown.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

This general statement points to the fact that there will always be some level of incomplete information on the past and current 

distribution and abundance of marine and coastal bird species in the Chukchi Sea. However, sufficient information is available to 

support sound scientific judgments and reasoned managerial decisions regarding potential impacts to this species under each 

alternative. Any incomplete information on these issues is therefore not essential to a reasoned choice among alternatives. It

should also be remembered that subsequent environmental reviews under later OCSLA review stages will be able to consider 

more current information regarding specific project locations, and thus provide a more robust review than is possible at the lease 

sale stage.

Page Number: III-63

Actual Statement:

The current status of the northern fulmar (Fulmarus glacialis) is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on the northern fulmer. Such effects 

would not occur, even in the unlikely event of a large oil spill. Therefore, "missing" information on the current status of northern 

fulmars is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A29
Page Number: III-63

Actual Statement:

The current status of the short-tailed shearwater (Puffinus tenuirostris) in the Chukchi Sea is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on the short-tailed shearwater. Such 

effects would not occur, even in the unlikely event of a large oil spill. Therefore, "missing" information on the current status of 

short-tailed shearwaters is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-63

Actual Statement:

The current status of parakeet (Cyclorrhynchus psittacula), least (Aethia pusilla) and crested (A. cristatella) auklets in the Chukchi 

Sea is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on the parakeet or least and crested

auklets. Such effects would not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the 

current status of these auklets is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-63

Actual Statement:

The current status of the black guillemot (Cepphus grylle) in the Chukchi Sea is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on the black guillemot. Such effects 

would not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the current status of black 

guillemots is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A30 Appendix A
Page Number: III-64

Actual Statement:

The current status of the ivory gull (Pagophila eburnea) in the Chukchi Sea is unknown. Divoky (1987) reported that ivory gulls are 

closely associated with the ice edge throughout their lifecycle. Ivory gulls are considered uncommon to rare in pelagic waters of 

the Chukchi during summer, and small numbers migrate through in fall to wintering areas in the northern Bering Sea.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on the ivory gull. Such effects would 

not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the current status of ivory gulls is 

not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-64

Actual Statement:

The current status of the Arctic tern (Sterna paradisaea) in the Chukchi Sea is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on the Arctic tern. Such effects would 

not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the current status of Arctic terns 

is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-64

Actual Statement:

The current status of the glaucous gull (Larus hyperboreus) in the Chukchi Sea is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on the glaucous gull. Such effects 

would not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the current status of 

glaucous gulls is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A31
Page Number: III-64

Actual Statement:

The current status of jaegers in the Chukchi Sea is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on any species of jaegers in the 

Chukchi Sea. Such effects would not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on 

the current status of these jaegers is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-65

Actual Statement:

Compared to what is known about yellow-billed loons near the Beaufort Sea coast, there is very little known about the coastal 

areas bordering the Chukchi Sea.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

This general statement points to the fact that there will always be some level of incomplete information on the distribution and 

abundance of yellow-billed loons. Although less information is known about the Chukchi coast as compared to the Beaufort coast,

there still exists sufficient information overall to support sound scientific judgments and reasoned managerial decisions regarding 

potential impacts to yellow-billed loons under each Chukchi Sea lease sale alternative. Any incomplete information on these 

issues is therefore not essential to a reasoned choice among alternatives. It should also be remembered that subsequent 

environmental reviews under later OCSLA review stages will be able to consider more current information regarding specific 

project locations, and thus provide a more robust review than is possible at the lease sale stage.

Page Number: III-66

Actual Statement:

During spring migration, the common eider (Somateria mollissima) typically migrates along the Chukchi Sea coast, using offshore

open-water leads. Offshore migration distances are poorly understood for the Chukchi Sea, but in the Beaufort Sea they are 

usually found within 48 km (29 mi) of shore.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on the common eider. Such effects 

would not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the current status of 

common eiders is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A32 Appendix A
Page Number: III-68

Actual Statement:

Pacific Brant “The current status of the Pacific brant along the Chukchi Sea is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on the Pacific brant. Such effects 

would not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the current status of Pacific 

brants is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-68

Actual Statement:

The current status of greater white-fronted geese along the Chukchi Sea coast is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on greater white-fronted geese. Such 

effects would not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the current status of 

greater white-fronted geese is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-68

Actual Statement:

Ritchie et al. (2006) reported that the number of snow geese nesting on the Ikpikpuk River delta continued to increase 

substantially from numbers recorded prior to 1999. There are no comparable data for the Kukpowruk River delta colony.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on snow geese. Such effects would 

not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the current status of snow geese 

is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A33
Page Number: III-69

Actual Statement:

The North American population of bar-tailed godwits (Limosa lapponica baueri) breeds in western and northern Alaska. 

Postbreeding bar-tailed godwits move to staging grounds along the Bering Sea Coast and then apparently fly nonstop 11,000 km 

to New Zealand. Recent counts conducted at both breeding and nonbreeding sites provide evidence of a serious and rapid 

population decline (McCaffrey et al., 2006), but the cause of the decline is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on bar-tailed godwits. Such effects

would not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the current status of bartailed godwits is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-69

Actual Statement:

The abundance and distribution of bar-tailed godwits in northern Alaska and coastal areas of the Chukchi Sea are not well 

understood.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on bar-tailed godwits. Such effects

would not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the current status of bartailed godwits is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-70

Actual Statement:

Buff-Breasted Sandpiper (species of concern) Noting “limited data.” 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects on the Buff-Breasted Sandpiper. Such 

effects would not occur, even in the unlikely event of a large oil spill. Therefore, any "missing" information on the current status of 

Buff-Breasted Sandpipers is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A34 Appendix A
Page Number: III-71

Actual Statement:

Little is known about the biology or population dynamics of ice seals, and they have received little attention compared with other 

Bering/Chukchi Sea species known to be in decline. Accurate population estimates for ice seals are not available and are not 

easily attainable due to their wide distribution and problems associated with research in remote, ice-covered waters (Quakenbush 

and Sheffield, 2006). Although little is known about the population status of ice seals, there is cause for concern. Sea ice is

changing in thickness, persistence, and distribution (Sec. III.A.4, Sea Ice), and evidence indicates that oceanographic conditions 

have been changing in the Bering Sea (Sec. III.A.3, Oceanography), which suggests that changes in the ecosystem may be 

occurring as well (Quakenbush and Sheffield, 2006).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population status of ice-seals in the Chukchi Sea. However, sufficient 

information is available to support sound scientific judgments and reasoned managerial decisions. More accurate population 

counts and distribution predictions are not essential for a reasoned choice among alternatives at this stage. Further, this 

information pertains to impacts that would be common under each action alternative, a fact which further reduces the utility of this 

information to the decision-maker. The MMPA and its implementing regulations would ensure that potential impacts remain 

negligible under each alternative. The only risk for impacts above "negligible" pertains to a large oil spill, the probability of which 

does not differ between action alternatives.

Page Number: III-71

Actual Statement:

No reliable estimate for the size of the Alaska ringed seal stock is available (Angliss and Outlaw, 2005) . . ..

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population status of ice-seals in the Chukchi Sea. However, sufficient 

information is available to support sound scientific judgments and reasoned managerial decisions. More accurate population 

counts and distribution prediction are not essential for a reasoned choice among alternatives at this stage. Also, this information 

pertains to impacts that would be common under each action alternative, a fact which further reduces the utility of this information 

to the decision-maker. The MMPA and its implementing regulations would ensure that potential impacts remain negligible under 

each alternative. The only risk for impacts above "negligible" pertains to a large oil spill, the probability of which does not differ 

between action alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A35
Page Number: III-72

Actual Statement:

No reliable estimate for the size of the Alaska spotted seal stock is available (Angliss and Outlaw, 2005).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population status of ice-seals in the Chukchi Sea. However, sufficient 

information is available to support sound scientific judgments and reasoned managerial decisions. More accurate population 

counts and distribution prediction are not essential for a reasoned choice among alternatives at this stage. Also, this information 

pertains to impacts that would be common under each action alternative, a fact which further reduces the utility of this information 

to the decision-maker. The MMPA and its implementing regulations would ensure that potential impacts remain negligible under 

each alternative. The only risk for impacts above "negligible" pertains to a large oil spill, the probability of which does not differ 

between action alternatives.

Page Number: III-73

Actual Statement:

Ribbon seals inhabit the North Pacific Ocean and the adjacent fringes of the Arctic Ocean. In Alaska, they range northward from

Bristol Bay in the Bering Sea and into the Chukchi and western Beaufort seas. They are found in the open sea, on pack ice, and 

rarely on shorefast ice (Kelly, 1988). As the ice recedes in May to mid-July, they move farther north in the Bering Sea, hauling out 

on the receding ice edge and remnant ice (Burns, Shapiro, and Fay, 1981). Seal distribution throughout the rest of the year is 

largely unknown; however, recent information suggests that many ribbon seals migrate into the Chukchi Sea for the summer 

months (Kelly, 1988).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the distribution and population status of ice-seals in the Chukchi Sea. 

However, sufficient information is available to support sound scientific judgments and reasoned managerial decisions. More 

accurate population counts and distribution predictions are not essential for a reasoned choice among alternatives at this stage. 

This information pertains to impacts that would be common under each action alternative, a fact which further reduces the utility 

of this information to the decision-maker. The MMPA and its implementing regulations would ensure that potential impacts 

remain negligible under each alternative. The only risk for impacts above "negligible" pertains to a large oil spill, the probability of 

which does not differ between action alternatives.

BOEMRE Sale 193 Revised Draft SEIS A36 Appendix A
Page Number: III-73

Actual Statement:

No reliable estimate for the size of the Alaska ribbon seal stock is available (Angliss and Outlaw, 2005).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population status of ice-seals in the Chukchi Sea. However, sufficient 

information is available to support sound scientific judgments and reasoned managerial decisions. More accurate population 

counts and distribution prediction are not essential for a reasoned choice among alternatives at this stage. This information 

pertains to impacts that would be common under each action alternative, a fact which further reduces the utility of this information 

to the decision-maker. The MMPA and its implementing regulations would ensure that potential impacts remain negligible level 

under each alternative. The only risk for impacts above "negligible" pertains to a large oil spill, the probability of which does not 

differ between action alternatives.

Page Number: III-74

Actual Statement:

No reliable estimate for the size of the Alaska bearded seal stock currently is available (Angliss and Outlaw, 2005). Bengtson et 

al. (2005) conducted surveys in the eastern Chukchi Sea but could not estimate abundance from their data.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population status of ice-seals in the Chukchi Sea. However, sufficient 

information is available to support sound scientific judgments and reasoned managerial decisions. More accurate population 

counts and distribution prediction are not essential for a reasoned choice among alternatives at this stage. This information 

pertains to impacts that would be common under each action alternative, a fact which further reduces the utility of this information 

to the decision-maker. The MMPA and its implementing regulations would ensure that potential impacts remain negligible under 

each alternative. The only risk for impacts above "negligible" pertains to a large oil spill, the probability of which does not differ 

between action alternatives.

Page Number: III-74

Actual Statement:

No reliable estimate is currently available for the size of the Alaskan stock of Pacific walrus (Angliss and Outlaw, 2005). However, 

available evidence indicates that the population is likely in decline (Kelly, Quakenbush, and Taras, 1999; Kochnev, 2004).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population status of walrus in the Chukchi Sea. However, sufficient 

information is available to support sound scientific judgments and reasoned managerial decisions. More accurate population 

counts are not essential for a reasoned choice among alternatives at this stage. This information pertains to impacts that would 

be common under each action alternative, a fact which further reduces the utility of this information to the decision-maker. The 

MMPA and its implementing regulations would ensure that potential impacts remain negligible under each alternative. The only 

risk for impacts above "negligible" pertains to a large oil spill, the probability of which does not differ between action alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A37
Page Number: III-76

Actual Statement:

No reliable estimate for the size of the Alaska Pacific walrus stock is available (Angliss and Outlaw, 2005).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population status of walrus in the Chukchi Sea. However, sufficient 

information is available to support sound scientific judgments and reasoned managerial decisions. More accurate population 

counts and distribution prediction are not essential for a reasoned choice among alternatives at this stage. This information 

pertains to impacts that would be common under each action alternative, a fact which further reduces the utility of this information 

to the decision-maker. The MMPA and its implementing regulations would ensure that potential impacts remain negligible under 

each alternative. The only risk for impacts above "negligible" pertains to a large oil spill, the probability of which does not differ 

between action alternatives.

Page Number: III-76

Actual Statement:

The population size has never been known with certainty; however, the most recent survey estimate was approximately 201,039 

animals (Gilbert et al., 1992).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population status of walrus in the Chukchi Sea. However, sufficient 

information is available to support sound scientific judgments and reasoned managerial decisions. More accurate population 

counts and distribution prediction are not essential for a reasoned choice among alternatives at this stage. This information 

pertains to impacts that would be common under each action alternative, a fact which further reduces the utility of this information 

to the decision-maker. The MMPA and its implementing regulations would ensure that potential impacts remain negligible under 

each alternative. The only risk for impacts above "negligible" pertains to a large oil spill, the probability of which does not differ 

between action alternatives.

Page Number: III-76

Actual Statement:

Based on recent telemetry studies on eastern Chukchi belugas, it is likely that members from both stocks occur in similar places 

and at similar times during the fall migration although the significance of this is unknown (Suydam, Lowry, and Frost, 2005).

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Lack of information specific to the potential "significance" of two beluga stocks occurring at the same place at similar times during 

the fall migration does not constitute missing information relevant to reasonably foreseeable significant adverse effects. 

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A38 Appendix A
Page Number: III-77

Actual Statement:

Winter food habits of belugas are largely unknown; ... 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Belugas move out of the project area during the winter, into Russian waters and the Bering Sea. The feeding habits of beluga 

during these times is not related to any reasonably foreseeable adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-77

Actual Statement:

Belugas generally are associated with ice and relatively deep water throughout the summer and autumn, which may reflect their 

preference for feeding on ice-associated arctic cod (Moore et al., 2000). Late-summer distribution and fall-migration patterns are 

poorly known, wintering areas are effectively unknown, and areas that are particularly important for feeding have not been 

identified (Suydam, Lowry, and Frost, 2005).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the seasonal distributions, including feeding areas, of belugas in the 

Chukchi Sea. However, sufficient information is available to support sound scientific judgments and reasoned managerial 

decisions. Additional NEPA review processes will take into account project details and specific locations. Also, substantive 

provisions of the MMPA would protect the beluga under all alternatives. In light of these considerations, additional information on 

beluga migration patterns is not essential to a reasoned choice among alternatives at this time.

Page Number: III-78

Actual Statement:

There are no reliable estimates for the Alaska stock of minke whales. A provisional estimate was made for the Bering Sea of 810

individuals; however, this is not used for the Alaska stock because the entire stock’s range was not surveyed.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population status of minke whales in Alaska waters. However, sufficient 

information is available to support sound scientific judgments and reasoned managerial decisions. More accurate counts are not

essential for a reasoned choice among alternatives. Furthermore, the missing information pertains to impacts that are common 

to all alternatives, limiting the utility of this information to the decision maker. 

Sale 193 Revised Draft SEIS BOEMRE Appendix A A39
Page Number: III-78

Actual Statement:

The harbor porpoise inhabits shallow, coastal areas in temperate, subarctic, and arctic waters of the Northern Hemisphere (Read, 

1999). In the North Pacific, harbor porpoises range from Point Barrow, Alaska to Point Conception, California (Gaskin, 1984). In 

Alaska, three separate stocks have been recommended, although there is insufficient biological data to support the designation at 

this time.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Lack of biological data to support subdividing the harbor porpoise population into separate stocks does not qualify as missing 

information relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-81

Actual Statement:

The maximum reproductive age for polar bears is unknown, but is likely well into their 20’s (Amstrup, 2003).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

Sufficient information regarding the general reproductive capacity of polar bears is known to support sound scientific judgments 

and reasoned managerial decisions. Additional information on the maximum reproductive age for polar bears is not essential for

a reasoned choice among alternatives.

Page Number: III-84

Actual Statement:

A reliable estimate for the CBS stock of polar bears, which ranges into the southern Beaufort Sea, does not exist, and its current 

status is in question. In 2002, the IUCN/SSG Polar Bear Specialist Group estimated the size of the CBS population at 2000+ 

bears, though the certainty of this estimate was considered poor (Lunn, Schliebe, and Born, 2002).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on population status of polar bears in the Chukchi and Bering Seas. 

However, sufficient information is available to support sound scientific judgments and reasoned managerial decisions. More 

accurate counts are not essential for a reasoned choice among alternatives. Furthermore, the missing information pertains to 

impacts that are common to all alternatives, limiting the utility of this information to the decision maker. 

BOEMRE Sale 193 Revised Draft SEIS A40 Appendix A
Page Number: III-84

Actual Statement:

[W]ith the collapse of the Soviet empire in 1991, levels of illegal harvest dramatically increased in Chukotka in the Russian Far 

East (Amstrup, 2000; USDOI, FWS, 2003). While the magnitude of the Russian harvest from the CBS is not precisely known, 

some estimates place it as high as 400 bears per year, although the figure is more likely between 100 and 250 bears per year.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The exact size of illegal harvest of polar bears in Russia is not related to any component of the proposed action or relevant to 

reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: III-84

Actual Statement:

[B]ecause of the unknown rate of illegal take currently taking place, in 2006 the IUCN/SSG Polar Bear Specialist Group 

designated the status of the CBS stock as “declining” from its previous estimate of 2000+ animals (IUCN/SSG Polar Bear 

Specialist Group, 2006).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the exact amount of illegal take of polar bear. However, specialists have 

agreed to a population size and trend for management purposes. Such information was used to support sound scientific 

judgments and reasoned managerial decisions. Additional data regarding illegal take is not essential for a reasoned choice 

among alternatives. Furthermore, missing information pertains to activities outside the scope of the Proposed Action, and 

potential impacts are common to all alternatives, which limits the utility of this information to the decision maker.

Page Number: III-88

Actual Statement:

The number of muskoxen that occur within the Proposed Action is unknown. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no potential for significant adverse effects to muskoxen. More specific information on the number of muskoxen within 

the Proposed Action area is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A41
Page Number: IV-32

Actual Statement:

Direct estimates or measurements of total recoverable concentrations of metals in discharged drilling muds are not available. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

As explained in the FEIS, there is no reasonably foreseeable potential for the discharge of drilling muds to cause significant 

adverse effects. Additional information on metal concentrations is not relevant to reasonably foreseeable significant adverse 

effects.

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

Page Number: IV-51

Actual Statement:

Because of the paucity of studies in the Chukchi Sea, a review of the available science and management literature shows that at

present, there are no empirical data to document potential impacts from seismic surveys reaching a local population-level effect; 

also, the experiments conducted to date have not contained adequate controls in place to allow us to predict the nature of a 

change or that any change would occur. (see #3 above)

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The absence of data demonstrating population-level impacts does not constitute missing information relevant to reasonably 

foreseeable significant adverse impacts.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-54

Actual Statement:

While we cannot say with certainty the impacts of seismic surveys on fish feeding behavior, there is no present evidence that the 

behavioral impact of seismic surveys has a major effect on fish feeding, except perhaps in the immediate vicinity of an active 

survey vessel.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The lack of data demonstrating a major effect does not qualify as missing information relevant to reasonably foreseeable 

significant adverse effects. The FEIS did not identify a possibility of significant adverse effects from these identified activities.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A42 Appendix A
Page Number: IV-60

Actual Statement:

Eggs deposited in the proximity of the contaminated substrate over a series of years likely would be exposed to oil (PAH’s) 

retained in the substrate, as PAH’s in weathered oil can be biologically available for long periods and very toxic to sensitive

lifestages, subsequently leading to lethal and sublethal effects to those offspring of successive generations. It is not known what 

such a behavioral response may have on the dynamics of the population; however, the spawning site likely would be unavailable 

for use for multiple generations, depending on the sensitivity of the capelin to detecting contaminated substrates and how long the 

oil persists in the localized habitat.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that if oil contacted spawning locations, significant impacts would occur. Neither 

the probability nor severity of such impacts would vary amongst any of the action alternatives. Additional information on the 

myriad potential mechanisms of effect, specific behavioral responses, or exact duration of impacts, while potentially useful, is not 

essential to a reasoned choice among alternatives.

Page Number: IV-61

Actual Statement:

A number of diadromous species in the region have complicated life-history patterns that are not fully understood.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete understanding of the complicated life histories of diadromous fish species in the Chukchi 

Sea. However, sufficient information is available to support sound scientific judgments and reasoned managerial decisions. 

Additional information is not essential to a reasoned choice among alternatives.

Page Number: IV-61

Actual Statement:

Effects on recruitment would be particularly difficult to assess, because very few studies of offshore fishes have been made.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the recruitment patterns of all fishes in offshore areas of the Chukchi Sea. 

However, sufficient information is available to support sound scientific judgments and reasoned managerial decisions. Under 

each alternative, additional review processes (e.g., NEPA during subsequent OCSLA stages, and EFH consultation) will utilize 

site- and project-specific analysis to identify any appropriate mitigation measures. Thus additional information on recruitment 

patterns of offshore fish is not essential to a reasoned choice among alternatives at this stage of the process.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A43
Page Number: IV-62

Actual Statement:

Although arctic cod can be extremely abundant in nearshore lagoonal areas, the importance of nearshore versus offshore 

environments to the lifecycle is not known (Craig et al., 1982). Although it is known that juvenile arctic cod associate with floating 

ice, it is unknown to what degree this association contributes to the development and survival of young fishes later recruiting to 

the breeding population. If early lifehistory stages of arctic cod were concentrated in nearshore environments, in patches in the 

open ocean, or under floating ice, they certainly would be more vulnerable to effects from an oil spill impacting such habitats.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the association of juvenile arctic cod and sea ice, especially as it pertains to 

survival and recruitment, in the Chukchi Sea. While potentially important, this information is not essential to a reasoned choice 

among alternatives at this time. Sufficient information is available to support sound scientific judgments and reasoned managerial 

decisions. Additional review processes (NEPA, EFH) would take into account the more detailed site and project information 

which would be available at that time. 

Page Number: IV-63

Actual Statement:

Also unknown are the distribution and abundance of spawning sites used by capelin in the Alaskan Arctic. The type of sandy 

gravel beach used by capelin occurs over much of the Chukchi Sea coastline.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the a distribution and abundance of capelin spawning sites along the coast 

of the Chukchi Sea. This level of available information is sufficient to support sound scientific judgments and reasoned 

managerial decisions, even in the absence of additional data of this type. Additional review processes (NEPA, EFH) would take 

into account the more detailed site and project information which would be available at that time. 

Page Number: IV-67

Actual Statement:

Although the mechanism for the apparent decline in smolt abundance is uncertain, the result of overescapement and too many 

salmon fry to be supported by the available prey may be the cause. The extent of the decline was speculative. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no connection between the uncertainty about the mechanism for the apparent decline in smolt abundance observed in a 

southern portion of Alaska and any reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A44 Appendix A
Page Number: IV-72

Actual Statement:

While small-spills are required to be reported, the number of unreported spills is unknown. Not all spills would be expected to

receive a spill-response. Overall, it is unclear whether, over the long-term and in the absence of a monitoring program to assess 

effects, any negative impacts to fish resources from chronic small spills would be detected.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The lack of an indication that any small oil spills going unreported may or may not be causing impacts does not qualify as missing 

information relevant to reasonably foreseeable adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-74

Actual Statement:

A review of the available science and management literature shows that at present, there are no empirical data to document 

potential impacts from seismic surveys reaching a local population-level effect. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The absence of data demonstrating population-level impacts does not constitute missing information relevant to reasonably 

foreseeable significant adverse impacts.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-74

Actual Statement:

A review of the available science and management literature shows that at present, there are no empirical data to document 

potential impacts from seismic surveys reaching a local population-level effect. The experiments conducted to date have not 

contained adequate controls to allow us to predict the nature of a change or that any change would occur

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The absence of data demonstrating population-level impacts does not constitute missing information relevant to reasonably 

foreseeable significant adverse impacts.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A45
Page Number: IV-81

Actual Statement:

Absent direct information on potential effects on baleen calves, we draw on more general mammalian literature about potential 

effects on very young individuals.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the potential effects of oil on baleen whale calves in the project area. Such 

information is important; however, sufficient information (specifically the wealth of mammalian literature referenced for this 

analysis) is available to support sound scientific judgments and reasoned managerial decisions. Direct information on potential 

effects to baleen calves is not essential for a reasoned choice among alternatives at this stage. Further, impacts will be reduced 

and/or precluded through additional, site-specific review and ESA Section 7 consultation in the future.

Page Number: IV-82

Actual Statement:

There are multiple sources of uncertainty in our analyses. These include, but are not limited to uncertainty about the action: where 

seismic surveys will occur; how many surveys will occur; how much noise will be produced purposely by the firing of airguns; what 

the exact shape of related ancillary activities (such as support vessel type and activity) will be; where exploration drilling could 

occur; where leases will be let; where a spill could occur; where production platforms and pipelines may be based; etc. More 

important, there is acknowledged scientific uncertainty about the potential effects of noise, especially repeated exposure to loud 

noise, on baleen whales (NRC, 2003, 2005; minutes from meetings of the Marine Mammal Commission Sound Advisory Panel, 

2004, 2005 from their web site). There is uncertainty and controversy regarding the potential effects of oil spills on large 

cetaceans. There are very few, if any, data available about potential effects of either noise or oil spills on cetacean calves. Lastly, 

and importantly, data are not available sufficient to characterize the current seasonal and temporal use of the Chukchi Sea 

Planning Area by bowheads and other whales, or to fully understand the importance of parts of the Beaufort Sea to bowhead 

whales. Thus, it is difficult to predict exposure in some parts of the area where the action could occur and to understand fully the 

potential effects of any exposure.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The first half of this statement contains general language which demonstrates some of the benefits of conducting multi-stage 

environmental review as per the four-stage OCSLA process. This information, while not essential at this stage, will be used at 

later stages to inform detailed environmental reviews and avoid impacts. The second half of this statement contains general 

language highlighting points of uncertainty within current science regarding whales and potential impacts to whales. There will be 

some level of incomplete information on the potential effects of oil exploration and development activities on baleen whales, 

including bowhead whale calves, in the Chukchi Sea. However, sufficient information is available to support sound scientific 

judgments and reasoned managerial decisions. Also, additional review processes (i.e. ESA Section 7 consultation, etc.) will help 

ensure lack of significant impacts to these animals. Thus additional information is not essential to a reasoned choice among 

alternatives. Also, it should be noted that the only component of the Proposed Action that could significantly effect whales is the 

small risk of a large oil spill. The probability of such an event is the same under all action alternatives, which limits the utility of 

this information to the decision maker.

BOEMRE Sale 193 Revised Draft SEIS A46 Appendix A
Page Number: IV-86

Actual Statement:

[T] here are few instances where data are sufficient to evaluate the total energy exposure of a marine mammal from a given 

source. At present, we do not have the data necessary to make such a determination or understand how it might change our 

analysis.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS anticipates that significant adverse effects to marine 

mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-86

Actual Statement:

Despite the increasing concern and attention noted above, there still is uncertainty about the potential impacts of sound on marine 

mammals; on the factors that determine response and effects; and especially on the long-term, cumulative consequences of 

increasing noise in the world’s oceans from multiple sources (NRC, 2003, 2005). The NRC (2005) concluded that it is unknown 

how or in what cases responses of marine mammals to anthropogenic sound rise to the levels of biologically significant effects.

This group also developed an approach of injury and behavioral “take equivalents”. These take equivalents use a severity index 

that estimates the fraction of a take experienced by an individual animal. This severity index is higher if the activity could be 

causing harassment at a critical location or during a critical time (e.g., calving habitat). Because we have uncertainty about 

exactly where and how much activity will occur, the recommendations from the NRC (2005) are qualitatively incorporated in 

MMSs analysis.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. (It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.)

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A47
Page Number: IV-87

Actual Statement:

While there is some general information available, evaluation of the impacts of noise on marine mammal species, particularly on

cetaceans, is greatly hampered by a considerable uncertainty about their hearing capabilities and the range of sounds used by 

the whales for different functions (Richardson et al., 1995a; Gordon et al., 1998; NRC, 2003, 2005). This is particularly true for 

baleen whales. Very little is known about the actual hearing capabilities of the large whales or the impacts of sound on them, 

especially on them physically. While research in this area is increasing, it is likely that we will continue to have great uncertainty 

about physiological effects on baleen whales because of the difficulties in studying them. Baleen whale hearing has not been 

studied directly. There are no specific data on sensitivity, frequency or intensity discrimination, or localization (Richardson et al., 

1995a). Thus, predictions about probable impacts on baleen whales generally are based on assumptions about their hearing 

rather than actual studies of their hearing (Richardson et al., 1995a; Gordon et al., 1998; Ketten, 1998).

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. (It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.)

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-87

Actual Statement:

Based on indirect evidence, at least some baleen whales are quite sensitive to frequencies below 1,000 Hz but can hear sounds 

up to a considerably higher but unknown frequency.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. (It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.)

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A48 Appendix A
Page Number: IV-87

Actual Statement:

...even though there are no direct data from hearing tests on any baleen whale.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-88

Actual Statement:

Little data are available about how, over the long term, most marine mammal species (especially large cetaceans) respond either

behaviorally or physically to intense sound and to long-term increases in ambient noise levels. Large cetaceans cannot be easily 

examined after exposure to a particular sound source.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A49
Page Number: IV-88

Actual Statement:

There are no data on which to determine the kinds or intensities of sound that could cause a TTS in a baleen whale.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-88

Actual Statement:

Repeated long exposures to intense sound or sudden onset of intense sounds generally characterize sounds that cause 

permanent threshold shift in humans. Ketten (1998) stated that age-related hearing loss in humans is related to the accumulation 

of permanent-thresholdshift and TTS damage to the ear. Whether similar age-related damage occurs in cetaceans is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A50 Appendix A
Page Number: IV-88

Actual Statement:

Most experiments have looked at the characteristics (e.g., intensity, frequency) of sounds at which TTS and permanent threshold

shift occurred. However, while research on this issue is occurring, it is still uncertain what the impacts may be of repeated 

exposure to such sounds and whether the marine mammals would avoid such sounds after exposure, even if the exposure was 

causing temporary or permanent hearing damage, if they were sufficiently motivated to remain in the area (e.g., because of a 

concentrated food resource).

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-89

Actual Statement:

Long-term impacts of OCS seismic-survey noise on the hearing abilities of individual marine mammals are unknown...

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A51
Page Number: IV-89

Actual Statement:

Long-term impacts of OCS seismic-survey noise on the hearing abilities of individual marine mammals are unknown, and 

information about the hearing capabilities of large baleen whales is mostly lacking. As noted previously, the assumption is made 

that the area of greatest hearing sensitivity is at frequencies known to be used for intraspecific communication. However, because 

real knowledge of sound sensitivity is lacking, we believe it is prudent to assume in our analyses that sensitivities shown by one 

species of baleen whale also could apply to another. This reasonable approach provides the means to infer possible impacts on 

other species (such as the fin whale), especially when using studies on a species such as the humpback, which uses a large 

sound repertoire in intraspecific communication.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-89

Actual Statement:

Long-term impacts of OCS seismic-survey noise on the hearing abilities of individual marine mammals are unknown, and 

information about the hearing capabilities of large baleen whales is mostly lacking.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A52 Appendix A
Page Number: IV-89

Actual Statement:

It is not known whether (or which) marine mammals can . . . and do adapt their vocalizations to background noise.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-92

Actual Statement:

No information was available regarding the time required for these whales to return to normal behavior.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A53
Page Number: IV-97

Actual Statement:

Several summaries related to the potential effects of seismic surveys have been written (Richardson et al., 1995a,b; McCauley et 

al., 2000; Gordon et al., 1998, 2004). Gordon et al. (1998:Sec. 6.4.3.1) summarized that: “Given the current state of knowledge, 

it is not possible to reach firm conclusions on the potential for seismic pulses to cause...hearing damage in marine mammals.” 

Later in this review, they reach the same conclusion about the state of knowledge about the potential to cause biologically 

significant masking. “This review has certainly emphasized the paucity of knowledge and the high level of uncertainty surrounding 

so many aspects of the effects of sound on marine mammals” (Gordon et al., 1998:Sec. 6.12). While uncertainty is reduced, the 

statements above are still accurate.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. (It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.)

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-117

Actual Statement:

The effects of oil contacting skin are largely speculative, as there is no information about how long spilled oil will adhere to the 

skin of a free-ranging whale.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

BOEMRE Sale 193 Revised Draft SEIS A54 Appendix A
Page Number: IV-118

Actual Statement:

The potential effect of crude oil on the function of the cetacean blowhole is unknown.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that if oil contacted cetacean blowholes, significant impacts would occur. Neither 

the probability nor severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has

sufficient information regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among 

alternatives. Additional information on the myriad potential mechanisms of effects, specific behavioral responses, or exact 

duration of impacts, while potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-118

Actual Statement:

There is great uncertainty about the potential effects of ingestion of spilled oil on bowheads, especially on bowhead calves. 

Decreased food assimilation could be particularly important in very young animals, those that seasonally feed, and those that 

need to put on high levels of fat to survive their environment.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that if oil were ingested by bowheads, significant impacts would occur. Neither 

the probability nor severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has

sufficient information regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among 

alternatives. Additional information on the myriad potential mechanisms of effects, specific behavioral responses, or exact 

duration of impacts, while potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-118

Actual Statement:

It is not known if bowheads would leave a feeding area where prey was abundant following a spill.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to one of many varieties of potential adverse effects that the analysis already assumes could 

occur under certain circumstances. The analysis assumes that significant impacts could occur regardless of whether bowheads 

leave a feeding area where prey was abundant following a spill. Neither the probability nor severity of these impacts would vary 

amongst any of the action alternatives. The decision-maker already has sufficient information regarding the relative probability 

and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional information on the myriad 

potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while potentially useful, is not 

essential to a reasoned choice among alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A55
Page Number: IV-118

Actual Statement:

Lambertsen et al. (2005) concluded that the current state of knowledge of how oil would affect the function of the mouth of right 

whales and bowheads can be considered poor, despite considerable past research on the effects of oil on cetaceans.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-118

Actual Statement:

They also concluded that their results highlight the uncertainty about how rapidly oil would depurate at the near zero temperatures 

of arctic waters and whether baleen function would be restored after oiling.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-118

Actual Statement:

Earlier studies on baleen fouling were summarized by Geraci (1990) who, with colleagues, had also undertaken studies of the 

effects of oil on baleen function. Geraci (1990) noted that while there was a great deal of interest in the possibility that residues of 

oil may adhere to baleen plates so as to block the flow of water and interfere with feeding, the concerns are largely speculative. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

BOEMRE Sale 193 Revised Draft SEIS A56 Appendix A
Page Number: IV-119

Actual Statement:

The potential effects to bowheads of exposure to PAC’s through their food are unknown. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no connection between the potential adverse impact and the action alternatives. Bowheads can accumulate PACs 

through their foods across their entire range over their entire lifetime regardless of the lease sale decision. The Proposed Action 

would not contribute appreciably to contamination of bowheads. This information, therefore, is not relevant to reasonably 

foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-120

Actual Statement:

There is a paucity of information about whether bowhead whales may be temporarily displaced from areas affected by an oil spill

or cleanup operations. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-121

Actual Statement:

Primarily because of the uniqueness of the bowhead and its apparently obligate use of spring lead and polynyas as its migratory

path between wintering and summering grounds, MMS is uncertain of the potential severity of impact should a large oil spill occur 

within such a system, especially if spring migration were underway and hundreds of females were calving in or near those leads.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a subset of adverse effects that is already assumed to occur under certain circumstances. 

The analysis already assumes that if spilled oil entered the spring lead and polynya systems, significant impacts could occur. 

Neither the probability nor severity of such impacts would vary amongst any of the action alternatives. The decision-maker 

already has sufficient information regarding the relative probability and various impacts of a large oil spill to allow a reasoned 

choice among alternatives. Additional information on the myriad potential mechanisms of effects, specific behavioral responses,

or exact duration of impacts, while potentially useful, is not essential to a reasoned choice among alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A57
Page Number: IV-121

Actual Statement:

The effects of an oil spill on cetacean newborns or other calves and the potential effects of contact or detection of spilled oil by 

near-term, or post-partum females are not known.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that if oil contacted newborn, calf, near-term, or post-partum whales, then 

significant impacts would occur. Neither the probability nor severity of such impacts would vary amongst any of the action 

alternatives. The decision-maker already has sufficient information regarding the relative probability and various impacts of a 

large oil spill to allow a reasoned choice among alternatives. Additional information on the myriad potential mechanisms of 

effects, specific behavioral responses, or exact duration of impacts, while potentially useful, is not essential to a reasoned choice 

among alternatives.

Page Number: IV-121

Actual Statement:

The factors associated with the presence of such groups are not yet clear. It is not known if they would leave the area heavily

contaminated with crude oil.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-121

Actual Statement:

Variability in the distribution of bowhead whales in the Beaufort Sea over time and among years, and lack of recent data on 

bowhead seasonal distribution and abundance in the Chukchi Sea makes attempts to quantitatively model the numbers of whales 

that might be contacted by oil problematic.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. The decision-maker already 

has sufficient information regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice 

among alternatives. Additional information on the myriad potential mechanisms of effects, specific behavioral responses, or exact 

duration of impacts, while potentially useful, is not essential to a reasoned choice among alternatives.

BOEMRE Sale 193 Revised Draft SEIS A58 Appendix A
Page Number: IV-122

Actual Statement:

[I]t is difficult to predict the impact of a large spill on either humpback whales or especially on fin whales. Based on literature on 

other mammals indicating severe adverse effects of inhalation of the toxic aromatic components of fresh oil, mortality of 

cetaceans could occur if they surfaced in large quantities of fresh oil. However, if such mortality occurred, it would be not be 

consistent with many, perhaps most, published findings of expected impacts of oil on cetaceans. The potential for there to be longterm sublethal (for example, reduced body condition, poorer health, or longer dependency periods), or lethal effects from large oil 

spill on cetaceans essentially is unknown. There are no data on cetaceans adequate to evaluate the probability of such effects.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-122

Actual Statement:

Geraci and St. Aubin (1990) stated that the notable weakness in modeling is that there is no information on the type and duration 

of oil exposure required to produce an effect. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. The decision-maker already 

has sufficient information regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice 

among alternatives. Additional information on the myriad potential mechanisms of effects, specific behavioral responses, or exact 

duration of impacts, while potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-122

Actual Statement:

There are no data or other information available that would suggest that there could be a population level effect on fin whales

from any activity or event, such as an oil spill, that could result from the activities resulting from Sale 193.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The lack of data indicating that a population level effect could occur does not qualify as missing information relevant to reasonably 

foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A59
Page Number: IV-123

Actual Statement:

The response of bowhead whales to construction in high use areas is unknown and is expected to vary with the site and the type 

of facility being constructed. Similarly, the long-term response of bowheads to production facilities other than gravel islands

located at the southern end of the migration corridor is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis concludes that the only potential cause of significant adverse effects to marine mammals from the Proposed 

Action would be a large oil spill. Potential impacts from development would not rise to a level of "significant adverse." Additional 

data on bowhead response to construction in high use areas would not be relevant to reasonably foreseeable significant adverse 

effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-123

Actual Statement:

The observed response of bowhead whales to seismic noise has varied among studies. The factors associated with variability 

are not entirely clear. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative (including seismic activities) would be required to comply with the Marine Mammal 

Protection Act, including its prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more 

than a negligible effect on the species (or stock) in question, and that would not have unmitigable adverse impacts on the 

availability of the marine mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to 

monitoring and reporting of such taking are set forth to ensure the activity will have the least practicable adverse effect on the 

species or stock and its habitat. The MMPA regulatory thresholds for take of marine mammals via noise err on the side of 

caution, and are designed to encompass a variety of potential direct and indirect effects. Take authorization generally incorporate 

project- or activity-specific mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty 

regarding the potential level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory 

framework is sufficient to prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as 

defined by the MMPA could not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that 

significant adverse effects to marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of 

these considerations, this item of "incomplete information" is not relevant to any reasonable foreseeable significant adverse 

effects. It should also be noted that several marine mammal species receive additional protections against significant adverse 

effects from the Endangered Species Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A60 Appendix A
Page Number: IV-125

Actual Statement:

In conclusion, there is uncertainty about effects on bowheads (or any large cetacean) in the event of a large oil spill. There are, in 

some years and in some locations, relatively large aggregations of feeding bowhead whales within the proposed lease-sale area. 

If a large amount of fresh oil contacted a significant portion of such an aggregation, effects potentially could be greater than 

typically would be assumed and we cannot rule out population-level effects if a large number of females and newborn or very 

young calves were contacted by a very large amount of fresh crude oil.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. The decision-maker already 

has sufficient information regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice 

among alternatives. Additional information on the myriad potential mechanisms of effects, specific behavioral responses, or exact 

duration of impacts, while potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-125

Actual Statement:

There is great uncertainty about the effects of fresh crude oil on cetacean calves. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A61
Page Number: IV-126

Actual Statement:

There are several areas historically documented to be important to marine and coastal birds in the proposed lease sale area. 

These areas, as well as the entire proposed lease sale area, lack site-specific data on habitat use patterns, routes and timing to 

assess impacts. For many species, the most recent data is between 15 and 30 years old, making accurate analysis difficult.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While site-specific data on habitat use patterns, routes and timing are certainly useful in assessing impacts, this information is not 

essential to a reasoned choice among alternatives in this case and at this stage of the decision-making process. Much 

information is already known on the general habits of the many species of birds that use the Chukchi Sea. This level of available 

information is sufficient to support sound scientific judgments and reasoned managerial decisions, even in the absence of 

additional data of this type. The protections that these birds receive under the MBTA (and for some species, the ESA) will serve 

to preclude or reduce impacts. Also, one should remember the 4-stage OCSLA process at work here. The current decision to be 

made is at step 2 of the process, the lease sale stage, which is relatively programmatic in nature. Certain site- and projectspecific details can only be known at later steps in this process. Any appropriate additional mitigation measures can and will be 

developed at those later stages, when important information about project locations and details can be known. 

Page Number: IV-127

Actual Statement:

Few studies have assessed the effects of seismic surveys on marine birds and waterfowl.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

This item does not identify any missing information relevant to reasonably foreseeable significant adverse effects. A low number 

of studies on an issue does not equate to missing information.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-127

Actual Statement:

Seismic airgun pulses have the potential to physically harm or kill diving birds. The threshold for physiological damage, namely to 

the auditory system, for marine birds is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS's thorough analysis of potential impacts to birds, including birds that engage in diving, indicated that use of airguns did 

not pose the potential for any significant adverse effects. Additional information on the threshold for physiological damage to 

diving birds is therefore not relevant to any reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A62 Appendix A
Page Number: IV-127

Actual Statement:

Therefore, it is unclear whether changes in diving frequency were due to disturbance from seismic vessels or local abundance of

prey items. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects from disturbance of diving frequency. 

Uncertainty as to whether changes in diving frequency could be from seismic vessels or local abundance of prey items is not 

relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-130

Actual Statement:

Data regarding bird behavior around drill ships has not been published, but reactions may be similar to seismic surveys where 

birds likely would avoid diving within a certain distance of the drill ship because of underwater noise and other rig activity. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis does not identify any reasonably foreseeable significant adverse effects from disturbance of diving activities. 

Additional data regarding bird behavior around (specifically) drill ships is not relevant to reasonably foreseeable significant

adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-130

Actual Statement:

Potential avenues of disturbance associated with the Proposed Action during development include construction of a production 

platform, an onshore base, pipelines, and roads; gravel mining/transport; pipeline maintenance; and oil-spill-response training. 

The location of these facilities is unknown. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While the location of such facilities could potentially be relevant to reasonably foreseeable significant adverse effects, the 

structure of the 4-stage OCSLA review process is such that the specific locations of potential facilities cannot be known at this 

point in time. Once identified during a later review stage, this information will be used to inform site-specific reviews and to 

reduce and/or avoid adverse impacts. This process would apply under each action alternative. In sum, specific locations of future 

facilities are not essential to a reasoned choice among alternatives at this stage, which is more programmatic in nature.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A63
Page Number: IV-132

Actual Statement:

The current distribution and abundance of these predators along the Chukchi Sea coast are unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS's thorough analysis of potential impacts to birds did not identify predators as a potential source of significant adverse 

effects. Additional information on the distribution and abundance of bird predators along the Chukchi coast is therefore not 

relevant to any reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-133

Actual Statement:

It is unknown if exposed adults could become permanently sterilized.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on whether exposed adult birds could become permanently sterilized is not essential to a reasoned choice among 

alternatives.

Page Number: IV-133

Actual Statement:

The effects of exposure can range from lethal to sublethal, although acute exposure can often lead to lethal effects. The true

numbers of birds killed by acute toxicity often are difficult to document, because many birds do not wash up on shore or are 

difficult to detect by aerial surveys. Sublethal effects are especially difficult to assess in wild birds due to the wide variety of 

factors that could lead to such things as reproductive impairment or susceptibility to disease. For example, sublethal effects from 

oil could lead to immuno-suppression and, therefore, increase susceptibility to disease. However, birds often die from disease

without any known prior exposure to petroleum. Accordingly, it is often difficult to determine whether a bird died to sublethal 

effects of oil or simply from a disease.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

This piece of incomplete information pertains to quantification of potential impacts that may occur in the unlikely event of a large 

oil spill. It is well understood that the environmental impacts associated with a large oil spill could be severe, to birds as well as 

many other environmental resources. These impacts are explained in great detail throughout Chapter 4 of the FEIS as well as 

the SEIS. Potential impacts are nearly identical under each action alternative (i.e. Alternatives 1, 3 and 4.) The probability of 

such an event occurring is also identical under each action alternative. It is also well understood that no large oil spills or spillrelated impacts could result from a selection of the No Action Alternative. In light of these considerations, the decision-maker 

already has sufficient information regarding the relative probability and various impacts of a major oil spill to allow a reasoned 

choice among alternatives, with or without this particular piece of incomplete information. Although the missing information 

regards a very important issue, it is not essential for a reasoned choice among lease sale alternatives.

BOEMRE Sale 193 Revised Draft SEIS A64 Appendix A
Page Number: IV-140

Actual Statement:

Yellow-billed loons in the Chukchi Sea are at particular risk due to their low numbers and low reproductive rate. The species is 

little studied and basic biological information (such as the seasonal distribution of immature and non-breeding yellow-billed loons) 

is unknown. Additional research could improve our understanding of the vulnerabilities of the yellow-billed and other loons using 

nearshore areas of the Chukchi Sea and western Beaufort Sea.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While site-specific data on the seasonal distribution of immature and non-breeding yellow-billed loons would be useful in 

assessing impacts, this information is not essential to a reasoned choice among alternatives in this case and at this stage of the 

decision-making process. Much information is already known on the general distribution of the yellow-billed loon in the Chukchi 

Sea. This level of available information is sufficient to support sound scientific judgments and reasoned managerial decisions, 

even in the absence of additional data of this type. The protections that these birds receive under the MBTA (and now as a 

Candidate species under the ESA) will serve to preclude or reduce impacts. Also, one should remember the 4-stage OCSLA 

process at work here. The current decision to be made is at step 2 of the process, the lease sale stage, which is relatively 

programmatic in nature. Certain site- and project-specific details can only be known at later steps in this process. Any 

appropriate additional mitigation measures can and will be developed at those later stages, when important information about 

project locations and details can be known. 

Page Number: IV-140

Actual Statement:

Collisions are not documented for shearwaters, but these types of events typically are poorly documented.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The absence of data indicating shearwater mortality from striking vessels/structures does not qualify as missing information and 

is not relevant to reasonably foreseeable adverse effects on the human environment.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-142

Actual Statement:

The number of birds that could be affected at sea during spring or fall migration is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS does not anticipate any potential for significant adverse effects on common eiders, even in the event of a large oil spill. 

Thus, the statement does not indicate any missing information relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A65
Page Number: IV-142

Actual Statement:

The portion of Chukchi Sea kittiwakes in the proposed lease-sale area is unknown. Seasonal areas of concentration, if any, are

unknown. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While more detailed understanding of seasonal concentrations (i.e. knowing the exact portion of the Chukchi Sea population in 

the proposed lease-sale area) of kittiwakes would be helpful, this information is not essential to a reasoned choice among 

alternatives in this case and at this stage of the decision-making process. Much information is already known on the general 

habits of kittiwakes in the Chukchi Sea. This level of available information is sufficient to support sound scientific judgments and 

reasoned managerial decisions, even in the absence of additional data of this type. The protections that these birds receive 

under the MBTA will serve to preclude or reduce impacts. Also, one should remember the 4-stage OCSLA process at work here. 

The current decision to be made is at step 2 of the process, the lease sale stage, which is relatively programmatic in nature. 

Certain site- and project-specific details can only be known at later steps in this process. Any appropriate additional mitigation 

measures can and will be developed at those later stages, when important information about project locations and details can be

known. 

Page Number: IV-142

Actual Statement:

These areas would be closer to potential sites of a development platform, and king eiders would be contacted more quickly by an

oil spill originating offshore than birds closer to shore. King eiders have been observed in Peard Bay and, though their abundance 

is unknown, it probably is less than common eiders based on surveys in the early 1980’s by Kinney (1985). The effects of oil 

exposure would be similar to common eiders, but the number of birds affected likely would be less in Peard Bay and Kasegaluk 

Lagoon. The number of birds that could be affected at sea during spring or fall migration is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS did not identify any reasonably foreseeable significant adverse effects to king eiders, even in the unlikely event of a 

large oil spill. The specific types of information regarding king eiders referenced in the item here are thus not relevant to 

reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A66 Appendix A
Page Number: IV-143

Actual Statement:

Current population estimates at these colonies are unknown.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While a more current population estimate for colonies at Cape Thompson and Cape Lisburne would be useful, this information is 

not essential to a reasoned choice among alternatives in this case and at this stage of the decision-making process. Much 

information is already known on the general habits of seabirds in the Chukchi Sea. This level of available information is sufficient 

to support sound scientific judgments and reasoned managerial decisions, even in the absence of additional data of this type. 

The protections that these birds receive under the MBTA will serve to preclude or reduce impacts. Also, one should remember 

the 4-stage OCSLA process at work here. The current decision to be made is at step 2 of the process, the lease sale stage, 

which is relatively programmatic in nature. Certain site- and project-specific details can only be known at later steps in this 

process. Appropriate additional mitigation measures will be developed at those later stages, when important information about 

project locations and details can be known. 

Page Number: IV-143

Actual Statement:

Reliable estimates of the number of phalaropes using these two locations are unavailable; 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

As this statement indicates, there will be some level of incomplete information on current numbers of phalaropes at various 

locations. However, there still exists sufficient information to support sound scientific judgments and reasoned managerial 

decisions regarding potential impacts to phalaropes under each Chukchi Sea lease sale alternative. Precise and up-to-the-minute

population counts are not essential to a reasoned choice among alternatives at this relatively programmatic stage. It should also 

be remembered that subsequent environmental reviews under later OCSLA review stages will be able to consider more current 

information regarding specific project locations, and thus provide a more robust review than is possible at the lease sale stage.

Page Number: IV-144

Actual Statement:

Dunlins are another prominent species in Kasegaluk Lagoon and Peard Bay in late summer and fall. As with other species of 

shorebirds and waterfowl, a spill during periods of peak abundance could impact large numbers of dunlins. Less is known about 

the numbers, timing, and patterns of habitat use of Kasegaluk Lagoon and Peard Bay by bar-tailed godwits but, given their recent 

population declines, effects of an oil spill could be particularly important.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS analysis identified no significant adverse effects to bar-tailed godwits, even during the unlikely event of a large oil spill. 

Additional information on the numbers, timing, and patterns of use of Kasegaluk Lagoon and Peard Bay by these birds would not 

be relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A67
Page Number: IV-145

Actual Statement:

Despite the importance of these areas, as well as the entire Chukchi Sea within the proposed lease-sale area, little recent sitespecific data are available on habitat-use patterns, routes, and timing to assess impacts. For many species, the most recent data 

are between 15 and 30 years old, making accurate analysis difficult. Because of this long data gap, it is unknown if population

abundance or distribution of many species have changed.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While additional recent and site-specific data on habitat-use patterns, routes and timing would certainly be useful in assessing 

impacts, this information is not essential to a reasoned choice among alternatives in this case and at this stage of the decisionmaking process. Much information is already known on the general habits of the many species of birds that use the Chukchi 

Sea. This level of available information is sufficient to support sound scientific judgments and reasoned managerial decisions, 

even in the absence of additional data of this type. The protections that these birds receive under the MBTA will serve to 

preclude or reduce impacts. Also, one should remember the 4-stage OCSLA process at work here. The current decision to be 

made is at step 2 of the process, the lease sale stage, which is largely programmatic in nature. Certain site- and project-specific 

details can only be known at later steps in this process. Any appropriate additional mitigation measures can and will be 

developed at those later stages, when important information about project locations and details can be known. 

Page Number: IV-145

Actual Statement:

Marine and coastal birds could be exposed to a variety of potential negative effects during seismic surveys, exploration drilling, 

and production including disturbances, collisions, habitat loss, petroleum exposure, and exposure to toxic contamination. The 

greatest potential for substantial adverse impacts typically would arise from collisions, aircraft disturbance, and large and chronic 

low-volume spills in important coastal bird habitats. These areas are Kasegaluk Lagoon, Ledyard Bay, Peard Bay, barrier islands, 

the spring open-water lead system, and the seabird-nesting colonies at Cape Lisburne and Cape Thompson. Despite the 

importance of these areas, as well as the entire Chukchi Sea within the proposed lease-sale area, little recent site-specific data 

are available on habitat-use patterns, routes, and timing to assess impacts. For many species, the most recent data are between

15 and 30 years old, making accurate analysis difficult. Because of this long data gap, it is unknown if population abundance or 

distribution of many species have changed.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While additional recent and site-specific data on habitat-use patterns, routes and timing would certainly be useful in assessing 

impacts, this information is not essential to a reasoned choice among alternatives in this case and at this stage of the decisionmaking process. Much information is already known on the general habits of the many species of birds that use the Chukchi 

Sea. This level of available information is sufficient to support sound scientific judgments and reasoned managerial decisions, 

even in the absence of additional data of this type. The protections that these birds receive under the MBTA will serve to 

preclude or reduce impacts. Also, one should remember the 4-stage OCSLA process at work here. The current decision to be 

made is at step 2 of the process, the lease sale stage, which is largely programmatic in nature. Certain site- and project-specific 

details can only be known at later steps in this process. Any appropriate additional mitigation measures can and will be 

developed at those later stages, when important information about project locations and details can be known. 

BOEMRE Sale 193 Revised Draft SEIS A68 Appendix A
Page Number: IV-145

Actual Statement:

Based on the paucity of information available on marine mammal ecology, and specifically on habitat use patterns, in the Chukchi 

Sea and based on the lack of specific information regarding the location of future developments, we are unable to determine at 

this time if significant impacts would or would not occur to marine mammal populations in the project area as a result of the 

Proposed Action.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

As this general statement indicates, there will be some level of incomplete information on marine mammal ecology in the Chukchi

Sea. However, sufficient information is available to support sound scientific judgments and reasoned managerial decisions at the 

lease sale stage. Activities with the potential to affect marine mammals will be subject to additional BOEMRE as well as NMFS 

and/or FWS review processes. Appropriate mitigation measures can and will be applied as proposals for specific activities are 

submitted. This multi-stage process permits more detailed review of each proposal, and development of more tailored mitigation

measures. As per the MMPA and ESA, significant impacts must be avoided. This separate, thorough review and minimized 

potential for significant impacts is common to all alternatives. In light of the above, any "incomplete information" regarding marine 

mammal ecology and specific locations of future developments is not essential to a reasoned choice between alternatives at the 

lease sale stage. 

Page Number: IV-145

Actual Statement:

Careful mitigation can help reduce the effects of future industrial developments and their accumulation through time. However, 

the effects of full-scale industrial development of the waters of the Chukchi Sea likely would accumulate through displacement of 

marine mammals from their preferred habitats, increased mortality, and decreased reproductive success. Because of the lack of 

data on which to base informed decisions, it is unknown if noise introduced into the environment from industrial activities, 

including drilling and seismic operations, will have an adverse impact on non-endangered and non-threatened marine mammals 

in the Proposed Action area. Increasing vessel traffic in the Northwest Passage, defined as the marine route between the Pacific 

and Atlantic oceans through the Arctic Ocean across the top of North America, which includes the Proposed Action area, 

increases the risks of oil and fuel spills and vessel strikes of marine mammals.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

Sufficient information about marine mammals response to development and noise is available to support sound scientific 

judgments and reasoned managerial decisions at the lease sale stage. Activities with the potential to affect marine mammals, 

such as drilling and seismic operations, will be subject to additional BOEMRE as well as NMFS and/or FWS review processes. 

Appropriate mitigation measures can and will be applied as proposals for specific activities are submitted. This multi-stage 

process permits more detailed review of each proposal, and development of more tailored mitigation measures. As per the 

MMPA and ESA, significant impacts must be avoided. This separate, thorough review and minimized potential for significant 

impacts is common to all alternatives. In light of the above, any "incomplete information" regarding potential noise impacts from 

future projects is not essential to a reasoned choice between alternatives at the lease sale stage. 

Sale 193 Revised Draft SEIS BOEMRE Appendix A A69
Page Number: IV-147

Actual Statement:

It is uncertain how seismic surveys potentially might impact seal-food resources in the immediate vicinity of the survey.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The thorough FEIS analysis of potential effects of seismic surveys did not identify impacts to seal food resources in the 

immediate vicinity of a survey to be a notable concern. This item is not relevant to reasonably foreseeable significant adverse 

effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-147

Actual Statement:

Although it is unlikely that airgun operations during most seismic surveys would cause PTS in marine mammals, caution is 

warranted given the limited knowledge about noise-induced hearing damage in marine mammals.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have an unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. 

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A70 Appendix A
Page Number: IV-148

Actual Statement:

Seismic operations are expected to create significantly more noise than general vessel and icebreaker traffic; however, there are 

no data available to evaluate the potential response of walruses to seismic operations.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. (It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.)

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-148

Actual Statement:

Quantitative research on the sensitivity of walruses to noise has been limited because no audiograms (a test to determine the 

range of frequencies and minimum hearing threshold) have been done on walruses.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have an unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorization generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. (It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.)

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A71
Page Number: IV-148

Actual Statement:

Although the hearing sensitivity of walruses is poorly known, source levels are thought to be high enough to cause temporary 

hearing loss in other species of pinnipeds.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have an unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorization generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. (It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.)

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-150

Actual Statement:

Overall, little research has been done to study the effects of seismic activity, and related vessel and air traffic, on the behavior of 

toothed whales other than the sperm whale. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities (including the seismic activities and related vessel and air traffic) under each action alternative would be required to 

comply with the Marine Mammal Protection Act, including its prohibition on "take." NMFS may grant authorizations for incidental 

take for activities having no more than a negligible effect on the species (or stock) in question, and that would not have 

unmitigable adverse impacts on the availability of the marine mammals for subsistence uses. Also, permissible methods of 

taking and requirements pertaining to monitoring and reporting of such taking are set forth to ensure the activity will have the least 

practicable adverse effect on the species or stock and its habitat. The MMPA regulatory thresholds for take of marine mammals 

via noise err on the side of caution, and are designed to encompass a variety of potential direct and indirect effects. Take 

authorizations generally incorporate project- or activity-specific mitigation measures to avoid or further reduce potential impacts. 

Despite the indication of uncertainty regarding the potential level of effect from certain activities, BOEMRE remains confident that 

the existing regulatory framework is sufficient to prevent noise impacts from having more than a negligible level of effect. A 

negligible level of effect as defined by the MMPA could not rise to "significance" as defined in Section IV.A.1. of the FEIS. The 

FEIS itself anticipates that significant adverse effects to marine mammals could only occur as a result of the unlikely event of a 

large oil spill. In light of these considerations, this item of "incomplete information" is not relevant to any reasonable foreseeable 

significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A72 Appendix A
Page Number: IV-151

Actual Statement:

Given the greater potential for anthropogenic-noise impacts on baleen whales, more research has been done to focus on 

potential effects on baleen whales than with toothed whales (although data is still considered limited).

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

This statement does not indicate missing information relevant to reasonably foreseeable adverse effects on the human 

environment.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-151

Actual Statement:

No studies are available specific to the effects of seismic-survey noise on minke whales, but the potential for impacts would be 

considered within the range of other baleen whales. Also, no known long-term impacts have been documented on gray and minke 

whale behavior as a result of seismic activity.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A73
Page Number: IV-152

Actual Statement:

Unfortunately, it has not been possible to predict the type and magnitude of marine mammal responses to the variety of 

disturbances caused by oil and gas operations and industrial developments in the Arctic. More importantly, it has not been 

possible to evaluate the potential effects on populations.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have an unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorization generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. (It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.)

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-154

Actual Statement:

The need to rely on indirect methods of assessing the environmental impact of human activity on marine mammals is a recurring 

problem (Inglis and Gust, 2003). Impact assessments for cetaceans typically emphasize immediate behavioral responses to 

human activities (Samuels and Bejder, 2004), the biological relevance of which is rarely known (Corkeron, 2004).

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have an unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorization generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, additional 

information on the biological relevance of cetacean's immediate behavioral responses to human activities is not relevant to any

reasonable foreseeable significant adverse effects. It should also be noted that several marine mammal species receive 

additional protections against significant adverse effects from the Endangered Species Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A74 Appendix A
Page Number: IV-154

Actual Statement:

[M]onitoring plans typically emphasize readily obtainable, short-term behavioral measures that can be directly related to 

disturbance factors (Bejder et al., 2006). However, it is rarely known in what ways short-term responses translate to longer term 

changes in reproduction, survival, or population size (Gill, Norris, and Sutherland, 2001; Beale and Monaghan, 2004a), and it is 

seldom possible to infer biological significance based on short-term behavioral observations.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have an unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, the ability to 

infer biological significance of short-term behavioral observations is not relevant to any reasonable foreseeable significant 

adverse effects. It should also be noted that several marine mammal species receive additional protections against significant

adverse effects from the Endangered Species Act.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-156

Actual Statement:

[W]ithout historical data on distribution and abundance, it is not possible to measure the impacts of an oil spill on marine 

mammals. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The decision-maker already has sufficient information regarding the relative probability and various impacts of a large oil spill to 

allow a reasoned choice among alternatives. The analysis already assumes that a large oil spill would lead to significant 

impacts. Neither the probability nor severity of such impacts would vary amongst any of the action alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A75
Page Number: IV-157

Actual Statement:

Determining oil-spill effects on walrus prey species is difficult. Clam-patch size and density are highly variable, and such 

information for high-latitude mollusks is sparse and highly variable (Ray et al., 2006). 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration and extent of impacts 

(including potential impacts on high-latitude mollusks), while potentially useful, is not essential to a reasoned choice among 

alternatives.

Page Number: IV-158

Actual Statement:

[T]he potential for long-term sublethal (for example, reduced body condition, poorer health, or longer dependency periods), or 

lethal effects from large oil spill on cetaceans is unknown. However, observations of cetaceans behaving in a lethargic fashion or 

having labored breathing has been documented in more than one species, including in gray whales after the EVOS, in which large 

numbers of individuals were subsequently found dead.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-159

Actual Statement:

The potential effect of crude oil on the function of the cetacean blowhole is unknown. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

BOEMRE Sale 193 Revised Draft SEIS A76 Appendix A
Page Number: IV-159

Actual Statement:

Although there is very little definitive evidence linking cetacean death or serious injury to oil exposure, 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The lack of evidence of an effect does not constitute missing information relevant to a reasonably foreseeable significant adverse 

effect.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-160

Actual Statement:

The potential for there to be long-term sublethal (for example, reduced body condition, poorer health, reduced immune function,

reduced reproduction or longer dependency periods) effects on large cetaceans from a large oil spill essentially is unknown. 

There are no data on large cetaceans adequate to evaluate the probability of sublethal effects. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-160

Actual Statement:

The effects of oil contacting skin largely are speculative. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that if oil contacted cetacean skin, significant impacts would occur. Neither the

probability nor severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has 

sufficient information regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among 

alternatives. Additional information on the myriad potential mechanisms of effects, specific behavioral responses, or exact 

duration of impacts, while potentially useful, is not essential to a reasoned choice among alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A77
Page Number: IV-161

Actual Statement:

A large oil spill could have significant impacts to beluga prey species, including anadromous and coastal spawning species such

as salmon (Sec. IV.C.1.d). If a significant impact to anadromous and coastal spawning species occurred, the effects on belugas 

would be detrimental, but the magnitude unknown.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

This piece of incomplete information pertains to potential impacts that may occur in the unlikely event of a large oil spill. It is well 

understood that the environmental impacts associated with a large oil spill could be severe, in terms of beluga prey species and 

to beluga themselves. These impacts are explained in great detail throughout Chapter 4 of the FEIS as well as the SEIS. 

Potential impacts are nearly identical under each action alternative (i.e. Alternatives 1, 3 and 4.) The probability of such an event 

occurring is also identical under each action alternative. It is also well understood that no large oil spills or spill-related impacts 

could result from a selection of the No Action Alternative. In light of these considerations, the decision-maker already has 

sufficient information regarding the relative probability and various impacts of a major oil spill to allow a reasoned choice among 

alternatives, with or without this particular piece of incomplete information. Although the missing information regards a very

important issue, it is not essential for a reasoned choice among lease sale alternatives.

Page Number: IV-161

Actual Statement:

The effects of a large oil spill and subsequent exposure of whales to fresh crude oil are uncertain, speculative, and controversial.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-161

Actual Statement:

There are no data available on which to evaluate the potential effect of a large or very large spill on baleen whale calves, on

females who are very near term or who have just given birth, or on females accompanied by calves of any age.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

BOEMRE Sale 193 Revised Draft SEIS A78 Appendix A
Page Number: IV-161

Actual Statement:

There is great uncertainty about the effects of fresh crude oil on cetacean calves. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that if cetacean calves were exposed to fresh crude, significant impacts would 

occur. Neither the probability nor severity of such impacts would vary amongst any of the action alternatives. The decisionmaker already has sufficient information regarding the relative probability and various impacts of a large oil spill to allow a

reasoned choice among alternatives. Additional information on the myriad potential mechanisms of effects, specific behavioral 

responses, or exact duration of impacts, while potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-161

Actual Statement:

There is some uncertainty and disagreement within the scientific community on the results of studies on the impacts of the EVOS

on large cetaceans (for example, Loughlin, 1994; Dahlheim and Matkin, 1994; Dahlheim and Loughlin, 1990). 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The analysis already assumes that a large oil spill would lead to significant impacts to cetaceans if they or their habitats are 

exposed. Neither the probability nor severity of such impacts would vary amongst any of the action alternatives. The decisionmaker already has sufficient information regarding the relative probability and various impacts of a large oil spill to allow a

reasoned choice among alternatives. Additional information on the myriad potential mechanisms of effects, specific behavioral 

responses, or exact duration of impacts, while potentially useful, is not essential to a reasoned choice among alternatives. This is 

especially true where the uncertainty alluded to pertains specifically to the results of past studies of other areas.

Page Number: IV-162

Actual Statement:

In light of the uncertainty over the potential impacts of exploration and development activities, the earliest possible establishment 

of long-term monitoring programs for vulnerable species in the project area should be pursued. The design of long-term 

monitoring should take into account the likely size of any effect and the probability of detecting it within a reasonable time span 

(IWC, 2006).

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

This item simply makes a recommendation based on the premise that there is certain incomplete information, and does not 

indicate any connection between allegedly missing information and any significant adverse impacts.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A79
Page Number: IV-162

Actual Statement:

In conclusion, there is uncertainty about effects on cetaceans in the event of a large spill. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The analysis already assumes that a large oil spill would lead to significant impacts to cetaceans if they or their habitats are 

exposed. Neither the probability nor severity of such impacts would vary amongst any of the action alternatives. The decisionmaker already has sufficient information regarding the relative probability and various impacts of a large oil spill to allow a

reasoned choice among alternatives. Additional information on the myriad potential mechanisms of effects, specific behavioral 

responses, or exact duration of impacts, while potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-163

Actual Statement:

Understanding the distribution and timing of movements of belugas is important for planning lease sales in the Chukchi Sea and 

designing possible mitigation measures. Late-summer distribution and fall-migration patterns are poorly known, wintering areas 

effectively are unknown, and areas that are particularly important for feeding have not been identified (Suydam, Lowry, and Frost, 

2005).

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

While additional information on the distribution and timing of movements of belugas would be useful, this information is not 

essential to a reasoned choice among alternatives in this case. Much information is already known on the general habits of the

belugas that use the Chukchi Sea. This level of available information is sufficient to support sound scientific judgments and 

reasoned managerial decisions regarding formulation and selection of lease sale alternatives. The protections that this species 

receives under the MMPA will also serve to preclude or reduce impacts under all action alternatives.

Page Number: IV-165

Actual Statement:

With the limited background information available regarding large oil spills in the offshore arctic environment, the outcome of a 

large oil spill is uncertain. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

This piece of incomplete information pertains to potential impacts that may occur in the unlikely event of a large oil spill. It is well 

understood that the environmental impacts associated with a major oil spill could be severe, to polar bears as well as many other 

environmental resources. These impacts are explained in great detail throughout Chapter 4 of the FEIS as well as the SEIS. 

Potential impacts are nearly identical under each action alternative (i.e. Alternatives 1, 3 and 4.) The probability of such an event 

occurring is also identical under each action alternative. It is also well understood that no large oil spills or spill-related impacts 

could result from a selection of the No Action Alternative. In light of these considerations, the decision-maker already has 

sufficient information regarding the relative probability and various impacts of a major oil spill to allow a reasoned choice among 

alternatives, with or without this particular piece of incomplete information. Although the missing information regards a very

important issue, it is not essential for a reasoned choice among lease sale alternatives.

BOEMRE Sale 193 Revised Draft SEIS A80 Appendix A
Page Number: IV-166

Actual Statement:

Coastal areas provide important denning habitat for polar bears. Terrestrial denning areas for bears of the CBS polar bear stock 

are less well understood than those for the SBS polar bear stock.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the CBS stock denning areas compared to the SBS stock. However, 

sufficient information is available to support sound scientific judgments and reasoned managerial decisions. Additional 

information on this topic is not essential to a reasoned choice among alternatives. Moreover, additional processes (e.g. ESA 

Section 7) will help ensure lack of significant impacts under each alternative if/when projects are sited.

Page Number: IV-168

Actual Statement:

Although no recent population estimate is available for the CBS population, all available data indicate that it is already in decline 

and that current levels of illegal harvest in Russia are unsustainable.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the exact amount of illegal harvest of polar bears in Russia; however, the 

important information is that specialists have agreed to a population size and trend for management purposes. Such information

was used to support sound scientific judgments and reasoned managerial decisions. Additional information on this point is not 

essential for a reasoned choice among alternatives at the lease sale stage. Furthermore, the missing information pertains to 

impacts that are common to all alternatives, a fact which tends to reduce the utility of such information to the decision-maker. 

Sale 193 Revised Draft SEIS BOEMRE Appendix A A81
Page Number: IV-194

Actual Statement:

Bowheads respond to drilling noise at different distances depending on the types of platform from which the drilling is occurring. 

Data indicate that many whales can be expected to avoid an active drillship at 10-20 km or possibly more. The response of 

bowhead whales to construction in high-use areas is unknown and is expected to vary with the site and the type of facility being 

constructed. Similarly, the long-term response of bowheads to production facilities other than gravel islands located at the 

southern end of the migration corridor is unknown 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill, a separate issues from the construction

discussed in the item here. In light of these considerations, this item of "incomplete information" is not relevant to any reasonable 

foreseeable significant adverse effects. 

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-194

Actual Statement:

The response of bowhead whales to construction in high-use areas is unknown and is expected to vary with the site and the type 

of facility being constructed.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have an unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill, a separate issues from the construction

discussed in the item here. In light of these considerations, this item of "incomplete information" is not relevant to any reasonable 

foreseeable significant adverse effects. 

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A82 Appendix A
Page Number: IV-216

Actual Statement:

It is unknown what effects an oil spill would have on bowhead whales, but it is likely that some whales would experience 

temporary, nonlethal effects from the oiling of skin, inhaling hydrocarbon vapors, ingesting oil contaminated prey, fouling of their 

baleen, losing their food source, and temporary displacement from some feeding areas.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. The severity of such 

impacts would not vary amongst any of the action alternatives. The decision-maker already has sufficient information regarding

the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-217

Actual Statement:

Little information is known about oil-spill effects on seals although any large oil spill in nearshore marine or coastal riverine 

environments could cause injury or death to these sea mammals, potentially cause them to move off of their normal course, and 

make them unavailable for subsistence harvest.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to a small subset of adverse effects that is already assumed to occur under certain 

circumstances. The analysis already assumes that a large oil spill would lead to significant impacts. Neither the probability nor 

severity of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: IV-217

Actual Statement:

There is uncertainty about effects on bowheads (or any large cetacean) in the event of a large spill. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The analysis already assumes that a large oil spill would lead to significant impacts to cetaceans if they or their habitats are 

exposed. Neither the probability nor severity of such impacts would vary amongst any of the action alternatives. The decisionmaker already has sufficient information regarding the relative probability and various impacts of a large oil spill to allow a

reasoned choice among alternatives. Additional information on the myriad potential mechanisms of effects, specific behavioral 

responses, or exact duration of impacts, while potentially useful, is not essential to a reasoned choice among alternatives.

Sale 193 Revised Draft SEIS BOEMRE Appendix A A83
Page Number: IV-217

Actual Statement:

For beluga whales, there also is uncertainty about effects on them in the event of a very large spill. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the level of effects on marine mammals from oil contact. This information 

is important; however, it pertains to a small subset of potential adverse effects that is already assumed to occur under particular 

circumstances, i.e., those that may occur in the unlikely event of a large oil spill. For reasons discussed in many other 

responses, the decision-maker already has sufficient information regarding the relative probability and various impacts of an oil 

spill to allow a reasoned choice among alternatives.

Page Number: IV-218

Actual Statement:

Given a lack of contemporary abundance and distribution information, large oil spill effects on rare or unique species (including 

potential extirpation) could occur, but would likely go unnoticed or undetected.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There will be some level of incomplete information on the effects of oil on rare fish species in the Arctic. This information is 

important; however, it pertains to a small subset of potential adverse effects that is already assumed to occur under particular 

circumstances, i.e., those that may occur in the unlikely event of a large oil spill. For reasons discussed in many of these 

responses, the decision-maker already has sufficient information regarding the relative probability and various impacts of an oil 

spill to allow a reasoned choice among alternatives.

Page Number: IV-256

Actual Statement:

The disparate mortality rates are less well understood. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no connection between disparate mortality (i.e. cancer) rates among local people and any reasonably foreseeable 

significant adverse effects from the Proposed Action.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A84 Appendix A
Page Number: IV-258

Actual Statement:

Because there are no available data on local fine-particulate concentrations, no data on hazardous air pollutants, and little data on 

intraregional variation in other USEPA-criteria pollutants, it is impossible to determine the possible contribution of these 

environmental factors.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The possible contribution of these environmental factors has no connection to the Proposed Action and has no relevance to any 

reasonably foreseeable significant adverse effects identified in the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-265

Actual Statement:

However, there are significant gaps in the data for the period 1979-1989. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no discernible connection between this incomplete information and any reasonably foreseeable significant adverse 

effects identified in the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: IV-269

Actual Statement:

However, because of the lack of data on marine mammal distributions and habitat use in offshore areas of the Chukchi Sea, it is

uncertain what the level of effects would be in offshore areas.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

As this general statement indicates, there will be some level of incomplete information on marine mammal distribution and habitat 

use in offshore areas of the Chukchi Sea. However, sufficient information is available to support sound scientific judgments and 

reasoned managerial decisions at the lease sale stage. Activities with the potential to affect marine mammals will be subject to 

additional BOEMRE as well as NMFS and/or FWS review processes. Appropriate mitigation measures can and will be applied as 

proposals for specific activities are submitted. This multi-stage process permits more detailed review of each proposal, and 

development of more tailored mitigation measures. As per the MMPA and ESA, significant impacts must be avoided; these laws 

apply under all alternatives. In light of the above, any "incomplete information" regarding marine mammal distribution and habitat 

use is not essential to a reasoned choice between alternatives at the lease sale stage. 

Sale 193 Revised Draft SEIS BOEMRE Appendix A A85
Page Number: V-16

Actual Statement:

It is not known to what extent local sources in Alaska contribute to arctic haze in the State.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no connection between the extent to which local sources in Alaska contribute to Arctic haze and any reasonably 

foreseeable significant adverse effects identified in the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-16

Actual Statement:

Emissions of nitrous oxide were not calculated due to a lack of information about emission factors; however, these emissions are 

expected to be much smaller than for the other greenhouse gases. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Based on the calculations for the emissions for other greenhouse gases, no significant adverse effects from emissions of nitrous 

oxide are anticipated. Thus, any missing information is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-19

Actual Statement:

There are no data available that indicate that, other than historic commercial whaling, any previous human activity has had a 

significant population-level adverse impact on the current status of BCB Seas bowhead whale or their recovery. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The lack of an indication that any human activity has had a significant adverse impact on the current status of the BCB Seas 

bowhead or their recovery does not qualify as missing information relevant to reasonably foreseeable adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-20

Actual Statement:

Whether there are long-lasting behavioral effects from this activity are unknown, but overall habitat use appears to be relatively 

unaffected. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS did not identify any significant adverse effects to whales from subsistence whale hunting. The missing information is

not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A86 Appendix A
Page Number: V-20

Actual Statement:

There are not sufficient data about past human activities, including, but not limited to, past offshore oil and gas related seismic 

surveys, or ice-management activities, to address whether there are any long-term impacts on behavior from such activities in 

either evaluation area.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS did not identify any significant adverse effects to bowheads from past offshore oil and gas related seismic surveys or

ice-management activities. The missing information is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-20

Actual Statement:

[D]ata on other potential perturbations (e.g., past seismic surveys and oil spills) are not sufficient to clearly know the level of 

effects.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS did not identify any significant adverse effects to bowheads from past seismic surveys or oil spills. The missing 

information is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-20

Actual Statement:

The factors related to the variability in bowhead responsiveness to anthropogenic noise are unclear and other populations are not 

as well studied. It also is unclear whether there is a human-related cause underlying the high level (at least in some instances) of 

behavioral responsiveness to human noise of the bowhead whale. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities (including those producing relatively high levels of anthropogenic noise) under each action alternative would be required 

to comply with the Marine Mammal Protection Act, including its prohibition on "take." NMFS may grant authorizations for 

incidental take for activities having no more than a negligible effect on the species (or stock) in question, and that would not have 

unmitigable adverse impacts on the availability of the marine mammals for subsistence uses. Also, permissible methods of 

taking and requirements pertaining to monitoring and reporting of such taking are set forth to ensure the activity will have the least 

practicable adverse effect on the species or stock and its habitat. The MMPA regulatory thresholds for take of marine mammals 

via noise err on the side of caution, and are designed to encompass a variety of potential direct and indirect effects. Take 

authorizations generally incorporate project- or activity-specific mitigation measures to avoid or further reduce potential impacts. 

Despite the indication of uncertainty regarding the potential level of effect from certain activities, BOEMRE remains confident that 

the existing regulatory framework is sufficient to prevent noise impacts from having more than a negligible level of effect. A 

negligible level of effect as defined by the MMPA could not rise to "significance" as defined in Section IV.A.1. of the FEIS. The 

FEIS itself anticipates that significant adverse effects to marine mammals could only occur as a result of the unlikely event of a 

large oil spill. In light of these considerations, any "incomplete information" on variability in bowhead responsiveness to 

anthropogenic noise is not relevant to any reasonable foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A87
Page Number: V-20

Actual Statement:

Because the potential effects of some specific perturbations (large oil spills, repeated exposure to noise, shipping, etc.) are

uncertain, an even greater level of uncertainty exists about the cumulative impact of all of the potential factors, especially over the 

long timeframes that must be considered for this species. While such uncertainty exists about the details of some but not all 

cumulative effects, it also is the case that the Western Arctic stock of bowheads is relatively very well studied and monitored. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

As the conclusion to this statement indicates, there is sufficient information available to support sound scientific judgments and 

reasoned managerial decisions regarding the effect of these perturbations on bowheads. Additional information on these issues is 

not essential to a reasoned choice among alternatives.

Page Number: V-20

Actual Statement:

While other potential effectors primarily have the potential to cause, or to be related to, behavioral or sublethal adverse effects to 

this population, or to cause the deaths of a small number of individuals, little or no evidence exists of other common humanrelated causes of mortality.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The lack of information indicating the existence of additional human-related causes of mortality does not qualify as missing 

information relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-21

Actual Statement:

Data are lacking about how far hunting-related sounds (e.g., the sounds of vessels and/or bombs) can propagate in areas where 

hunting typically occurs, but this is likely to vary with environmental conditions. It is not known if a whale issues an “alarm call” or 

a “distress call” after it, or another whale, is struck prior to reducing call rates.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no connection between the missing information and any reasonably foreseeable significant adverse effects associated 

with the Proposed Action or alternatives. The FEIS does not anticipate any significant adverse effects to marine mammals outside 

the unlikely event of a large oil spill. Additionally, subsistence hunting would occur to the same extent under all alternatives, a 

fact which further reduces the utility of such information to the decision-make here.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A88 Appendix A
Page Number: V-21

Actual Statement:

However, information about long-term habitat avoidance occurring with present levels of activity is not available. Additionally, if, 

as reported above, whales become more “skittish” and more highly sensitized following a hunt, it may be that their subsequent 

reactions over the short-term to other forms of noise and disturbance are heightened by such activity. Data are not available that 

permit evaluation of this possible, speculative interaction.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

There is some level of uncertainty regarding the speculative potential for short-term impacts to whales following hunts. However, 

sufficient information regarding whales behavior, avoidance patterns, etc are available to support sound scientific judgments and 

reasoned managerial decisions. It should also be noted that these possibilities have already been taken into account in the 

development of various alternatives and deferral areas. Enough is already known about this potential for impacts such that 

reasoned choices among alternatives can be made. Additional information is not essential. 

Page Number: V-22

Actual Statement:

There are insufficient data to make reliable predictions of the effects of Arctic climate change on bowhead whales.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no connection between this missing information and any reasonably foreseeable significant adverse effects to bowheads 

identified in the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-22

Actual Statement:

If climate changes occur, it is likely that shipping would increase throughout the range of the bowhead, especially in the southern 

portions of the Arctic Ocean. If commercial fisheries were to expand, bowhead whale death and or injury due to interactions with 

fishing gear, possibly injury and/or death due to incidental take in commercial fisheries, and temporary effects on behavior 

potentially could occur. There are, however, no data that would permit a quantitative prediction of the aforementioned possible

effects.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The lack of data on potential impacts to bowheads from commercial fishing is not relevant to any reasonably foreseeable 

significant adverse effects identified in the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A89
Page Number: V-23

Actual Statement:

Noise associated with ships or other boats potentially could cause bowheads to alter their movement patterns or make other 

changes in habitat use. Clapham and Brownell (1999) summarized that “...effects of ship noise on whale behavior and ultimately 

on reproductive success are largely unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

This assertion, which appears in one particular study, does not qualify as missing information relevant to reasonably foreseeable 

significant adverse effects. Vessel noise is not anticipated to cause any significant adverse effects to bowheads.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-25

Actual Statement:

[R]ecent monitoring studies indicated that most fall migrating whales avoid an area with a radius about 20-30 km around a 

seismic vessel operating in nearshore waters; however, there are no data that indicate that such avoidance is long-lasting after 

cessation of the activity.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The absence of data indicating long-lasting avoidance following seismic survey does not qualify as missing information relevant to 

reasonably foreseeable significance adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-25

Actual Statement:

Available data . . . are inadequate to fully address issues about effects of past oil and gas activity specifically in the Chukchi Sea 

on bowhead behavior.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS did not identify any significant adverse effects to bowheads from past oil and gas activities in the Chukchi Sea. The

missing information is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A90 Appendix A
Page Number: V-25

Actual Statement:

[W]e cannot adequately assess potential effects on patterns or durations of bowhead habitat use. Because of the inadequacy of 

the data on activities, and because of the limitations inherent in studying large baleen whales, MMS was not able to assess 

whether there were any adverse health effects to individuals during the period of relatively intensive seismic survey activity in the 

1980’s.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no connection between this missing information and any reasonably foreseeable significant adverse effects identified in 

the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-25

Actual Statement:

However there are significant gaps in the data for the period 1979-1989 and very limited information was obtained on ice 

management (Wainwright, 2002). 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no discernible connection between ice management data from 1979-1989 and any reasonably foreseeable significant 

adverse effects identified in the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A91
Page Number: V-26

Actual Statement:

Data on other activities, such as hunting activity, barge traffic, and shipping noise are incomplete. Thus, while it is clear there 

have been multiple noise and disturbance sources in the Beaufort Sea over the past 30 years, because of the incompleteness of 

data, even for the 1990’s, for many types of activities, we cannot evaluate the cumulative effects on bowhead whales resulting 

from multiple noise and disturbance sources (e.g., 2D seismic in State and Federal waters, drilling, ice management, highresolution acoustic surveys, vessel traffic, construction, geotechnical borehole drilling, aircraft surveys, and hunting). Because 

data also are incomplete for the Chukchi Sea, we reach the same general conclusions.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Activities under each action alternative would be required to comply with the Marine Mammal Protection Act, including its 

prohibition on "take." NMFS may grant authorizations for incidental take for activities having no more than a negligible effect on 

the species (or stock) in question, and that would not have unmitigable adverse impacts on the availability of the marine 

mammals for subsistence uses. Also, permissible methods of taking and requirements pertaining to monitoring and reporting of 

such taking are set forth to ensure the activity will have the least practicable adverse effect on the species or stock and its habitat. 

The MMPA regulatory thresholds for take of marine mammals via noise err on the side of caution, and are designed to 

encompass a variety of potential direct and indirect effects. Take authorizations generally incorporate project- or activity-specific 

mitigation measures to avoid or further reduce potential impacts. Despite the indication of uncertainty regarding the potential 

level of effect from anthropogenic noise, BOEMRE remains confident that the existing regulatory framework is sufficient to 

prevent noise impacts from having more than a negligible level of effect. A negligible level of effect as defined by the MMPA could 

not rise to "significance" as defined in Section IV.A.1. of the FEIS. The FEIS itself anticipates that significant adverse effects to 

marine mammals could only occur as a result of the unlikely event of a large oil spill. In light of these considerations, this item of 

"incomplete information" is not relevant to any reasonable foreseeable significant adverse effects. (It should also be noted that 

several marine mammal species receive additional protections against significant adverse effects from the Endangered Species 

Act.)

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-27

Actual Statement:

However, data are inadequate to fully evaluate potential impacts on whales during this period, including the duration of habitat use 

effects or numbers and types of individuals that did not use high-use areas because of the activities.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

There is no connection between the missing information and any reasonably foreseeable significant adverse effects identified in

the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A92 Appendix A
Page Number: V-27

Actual Statement:

However, we reiterate that due to the limitations of available information and due to the limitations inherent in the study of baleen 

whales, there is uncertainty about the range of potential effects of a large spill on bowhead whales, especially if a large 

aggregation of females with calves were to be contacted by fresh oil. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

The missing information pertains to adverse effects that are already assumed to occur under certain circumstances. The analysis 

already assumes that if a large oil spill occurs, significant impacts to cetaceans could follow. Neither the probability nor severity 

of such impacts would vary amongst any of the action alternatives. The decision-maker already has sufficient information 

regarding the relative probability and various impacts of a large oil spill to allow a reasoned choice among alternatives. Additional 

information on the myriad potential mechanisms of effects, specific behavioral responses, or exact duration of impacts, while 

potentially useful, is not essential to a reasoned choice among alternatives.

Page Number: V-28

Actual Statement:

The possible influences of disease or predation and of overutilization are listed as ‘Unknown.’

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Lack of information on the possible threat of disease or predation or overutilization of fin whales does not constitute missing

information relevant to reasonably foreseeable significant adverse effects. There is no connection between the proposed action

and these issues.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-29

Actual Statement:

The threat of disease or predation is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Lack of information on the possible threat of disease or predation on humpback whales does not constitute missing information 

relevant to reasonably foreseeable significant adverse effects. There is no correlation between the proposed action and these 

issues.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A93
Page Number: V-29

Actual Statement:

There are no records of humpbacks killed or injured in the fisheries in which fishers self report (Angliss and Lodge, 2002), but the 

reliability of such data is unknown.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The lack of records indicating that humpbacks were killed or injured by commercial fishing operations does not constitute missing 

information relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-30

Actual Statement:

The impacts of pollution and habitat degradation due to coastal development are not known.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS does not anticipate any adverse effects on humpback whales from pollution or habitat degradation associated with 

coastal development. The statement does not indicate any missing information relevant to reasonably foreseeable significant 

adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-31

Actual Statement:

Very little information has been published on the effects of contaminants on the Pacific walrus, and MMS is aware of no analysis 

of cumulative effects that has been published to date. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Lack of published information on contamination impacts on the Pacific walrus does not constitute missing information relevant to 

reasonably foreseeable significant adverse effects. No such effects of this type to Pacific walrus were identified in the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A94 Appendix A
Page Number: V-32

Actual Statement:

Because very little is known about the distributions, population sizes or habitat use of marine mammals in the Chukchi Sea, it is 

difficult to determine if significant impacts will or will not occur to marine mammals as a result of the proposed action.

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

As this general statement indicates, there will be some level of incomplete information on marine mammal distribution, population 

size and habitat use in the Chukchi Sea. However, sufficient information is available to support sound scientific judgments and 

reasoned managerial decisions at the lease sale stage. Activities with the potential to affect marine mammals will be subject to 

additional BOEMRE as well as NMFS and/or FWS review processes. Appropriate mitigation measures can and will be applied as 

proposals for specific activities are submitted. This multi-stage process permits more detailed review of each proposal, and 

development of more tailored mitigation measures. As per the MMPA and ESA, significant impacts must be avoided. This 

separate, thorough review and minimized potential for significant impacts is common to all alternatives. In light of the above, any 

incomplete information regarding marine mammal distribution, population size and habitat use is not essential to a reasoned 

choice between alternatives at the lease sale stage. 

Page Number: V-32

Actual Statement:

Unfortunately, there is no information to determine whether or not there are health effects for walruses at this cadmium level. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Lack of information demonstrating adverse health effects does not qualify as missing information relevant to reasonably 

foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-35

Actual Statement:

[T]he relationship between the expanding gray whale population to amphipod community dynamics is unknown but is of 

considerable interest.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

While this statement indicates that this information may be of some interest to certain scientists, it does not indicate any missing 

information relevant to reasonably foreseeable adverse effects on the human environment.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A95
Page Number: V-36

Actual Statement:

However, with the collapse of the Soviet empire in 1991, levels of illegal harvest dramatically increased in Chukotka in the 

Russian Far East (Amstrup, 2000; USDOI, FWS, 2003). While the magnitude of the Russian harvest from the CBS is not 

precisely known, some estimates place it as high as 400 bears per year, although the figure is more likely between 100 and 250 

bears per year. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The exact size of illegal harvest of polar bears in Russia is not related to any component of the Proposed Action or relevant to 

reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-36

Actual Statement:

Quantitative data are lacking that specifically addresses the potential cumulative impacts of development on polar bears and the 

effects of disturbance related to human activities on polar bear habitat use, as well as recruitment and survival (Perham, 2005). 

There also is a high degree of uncertainty regarding the spatial scope of potential Industry activities on the Alaskan OCS.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Sufficient data existed to determine that no significant adverse effects to polar bears would occur as a result of the Proposed

Action, absent a large oil spill, a consideration distinct from the disturbance impacts discussed in this item. Additional quantitative 

data specifically addressing the cumulative impacts of development on polar bears is therefore not relevant to reasonably 

foreseeable significant adverse effects. Uncertainty regarding the spatial scope of potential industry activities on the Alaskan 

OCS is inherent to the lease sale stage; this statement does not identify any missing information that is relevant to reasonably 

foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-36

Actual Statement:

However, with the collapse of the Soviet empire in 1991, levels of illegal harvest dramatically increased in Chukotka in the 

Russian Far East (Amstrup, 2000; USDOI, FWS, 2003). While the magnitude of the Russian harvest from the CBS is not 

precisely known, some estimates place it as high as 400 bears per year, although the figure is more likely between 100 and 250 

bears per year. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The exact size of the illegal polar bear harvest in Russia is not relevant to reasonably foreseeable significant adverse effects of 

the Proposed Action or alternatives.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A96 Appendix A
Page Number: V-46

Actual Statement:

Limited monitoring data prevent effective assessment of cumulative subsistence-resource damage; resource displacement; 

changes in hunter access to resources; increased competition; contamination levels in subsistence resources; harvest reductions; 

or increased effort, risk, and cost to hunters. Limited data also limit our assessment of the effectiveness of mitigation measures.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The FEIS did not identify any significant adverse effects to subsistence activities from these activities or trends. The missing 

information is not relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-48

Actual Statement:

However, we reiterate that due to the limitations of available information and due to the limitations inherent in the study of baleen 

whales, there is uncertainty about the range of potential effects of a large spill on bowhead whales, especially if a large 

aggregation of females with calves were to be contacted by fresh oil. The NMFS has concluded that, given the abundance of 

plankton resources in the Beaufort Sea, it is unlikely that the availability of food resources for bowheads would be affected. 

Because of existing information available for other mammals regarding the toxic effects of fresh crude oil, and because of 

inconclusive results of studies on cetaceans after the EVOS, we are uncertain about the potential for mortality of more than a few 

individuals. 

Is the Statement Relevant to Potentially Significant Effects? YES

If NO, explain:

Is the Statement Essential to Making a Reasoned Choice? NO

If NO, explain:

This piece of incomplete information pertains to quantification of potential impacts that may occur in the unlikely event of a large 

oil spill. It is well understood that the environmental impacts associated with a large oil spill could be severe, to baleen whales as 

well as many other environmental resources. These impacts are explained in great detail throughout Chapter 4 of the FEIS as 

well as the SEIS. Potential impacts are nearly identical under each action alternative (i.e. Alternatives 1, 3 and 4). The 

probability of such an event occurring is also identical under each action alternative. It is also well understood that no major oil 

spills or spill-related impacts could result from a selection of the No Action Alternative. In light of these considerations, the 

decision-maker already has sufficient information regarding the relative probability and various impacts of a large oil spill to allow 

a reasoned choice among alternatives, with or without this particular piece of incomplete information. Although the missing 

information regards a very important issue, it is not essential for a reasoned choice among lease sale alternatives.

Page Number: V-49

Actual Statement:

However, data are inadequate to fully evaluate potential impacts on whales during this period, including the duration of habitat use 

effects or numbers and types of individuals that did not use high-use areas because of the activities. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

The missing data identified are associated with the ability to evaluate effects on bowhead whales from activities in the mid-1970s. 

These effects are not connected to the proposed action and are not relevant to reasonably foreseeable significant adverse effects 

identified by the FEIS.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Sale 193 Revised Draft SEIS BOEMRE Appendix A A97
Page Number: V-52

Actual Statement:

Quantitative data that specifically address potential cumulative impacts of development on polar bears and the effects of 

disturbance related to human activities on polar bear habitat, recruitment, and survival are lacking. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

Sufficient data existed to determine that no significant adverse effects to polar bears would occur as a result of the Proposed

Action, absent a large oil spill, a consideration distinct from the "disturbance" impacts discussed in this item. Additional 

quantitative data specifically addressing the cumulative impacts of development on polar bears is therefore not relevant to 

reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-59

Actual Statement:

These Arctic alterations would then be expected to affect global climate, although the models and mechanisms for predicting 

actual global consequences are still not clearly understood. Are observed temperature changes in the Arctic directly related to 

global warming? The answer is not clear, because data often are not known for extensive time periods and, when data are 

available, often they are not comparable. 

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

As the FEIS (page V-16) explains, the proposed action has no appreciable influence on climate change. This information is not 

relevant to reasonably foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

Page Number: V-68

Actual Statement:

Stress to sociocultural systems that result from the encroachment of oil-production facilities into areas used for subsistence,

although the cumulative effects of the relationship is difficult to precisely measure quantitatively because of lack of baseline data.

Is the Statement Relevant to Potentially Significant Effects? NO

If NO, explain:

A thorough quantitative and qualitative analysis of potential direct, indirect, and cumulative impacts to sociocultural systems did 

not identify any reasonably foreseeable significant adverse effects. Therefore a lack of baseline data is not relevant to reasonably 

foreseeable significant adverse effects.

Is the Statement Essential to Making a Reasoned Choice?

If NO, explain:

BOEMRE Sale 193 Revised Draft SEIS A98 Appendix A
APPENDIX B 

VERY LARGE OIL SPILL 

 

INFORMATION, MODELS, ESTIMATES, 

 

SUPPORTING TABLES AND FIGURES
 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B i

Table of Contents 

1. Estimates of Source and Size ......................................................................................................... B1

1.1. OCS Well Control Incidents ............................................................................................... B1

1.2. Historical Worldwide Spills Greater than or Equal to 1 Million Barrels from Wells......... B2

1.3. Oil Spill Risk Analysis ....................................................................................................... B4

2. Behavior and Fate of Crude Oils.................................................................................................... B5

2.1 Release from A Well Control Incident ................................................................................ B5

2.2. Ice Present........................................................................................................................... B5

2.3. Open Water......................................................................................................................... B6

2.4. Persistence .......................................................................................................................... B6

3. Very Large Oil-Spill Weathering ................................................................................................... B6

4. Results of the Oil Spill Trajectory Model ...................................................................................... B7

4.1. Conditional Probabilities .................................................................................................... B8

4.2. Oil Spill Trajectory Results ................................................................................................ B9

4.3. Generalities Through Time................................................................................................. B9

4.4. Cumulative Area Contacted by a Very Large Oil Spill .................................................... B10

List of Tables 

Table B-1. Number of well control incidents with pollution per year in the Gulf of Mexico and 

Pacific OCS Regions and total OCS wells. .................................................................... B2

Table B-2. International Historical Spills from Wells Greater than or Equal to 1 MMbbl. ............. B4

Table B-3. Fate and behavior of a hypothetical 20,000-barrel crude oil spill in the Chukchi Sea. .. B7

Table B-4. Fate and behavior of a hypothetical 60,000-barrel crude oil spill in the Chukchi Sea. .. B7

Table B-5. Discontinuous Area Contacted in Square Kilometers by a Very Large Crude Oil Spill in 

the Chukchi Sea during Summer. ................................................................................. B10

Table B-6. Discontinuous Area Contacted in Square Kilometers by a Very Large Crude Oil Spill in 

the Chukchi Sea during Winter. ................................................................................... B11

Table B-7. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain environmental resource area within 60 days during 

summer. (Chukchi Sea Sale 193, Table A.2-28) .......................................................... B14

Table B-8. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain environmental resource area within 360 days during 

summer (Chukchi Sea Sale 193, Table A.2-30). .......................................................... B15

Table B-9. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain land segment within 60 days during summer (Chukchi 

Sea Sale 193, Table A.2-34)......................................................................................... B16

Table B-10. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain land segment within 360 days during summer 

(Chukchi Sea Sale 193, Table A.2-36). ........................................................................ B17

Table B-11. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain grouped land segment within 60 days during summer 

(Chukchi Sea Sale 193, Table A.2-40). ........................................................................ B18
Sale 193 Revised Draft SEIS BOEMRE 

ii Appendix B 

Table B-12. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain grouped land segment within 360 days during summer 

(Chukchi Sea Sale 193, Table A.2-42). ........................................................................ B18

Table B-13. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain boundary segment within 60 days during summer 

(Chukchi Sea Sale 193, Table A.2-46). ........................................................................ B19

Table B-14. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain boundary segment within 360 days during summer 

(Chukchi Sea Sale 193, Table A.2-48). ........................................................................ B19

Table B-15. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain environmental resource area within 60 days during 

winter (Chukchi Sea Sale 193, Table A.2-52).............................................................. B19

Table B-16. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain environmental resource area within 360 days during 

winter (Chukchi Sea Sale 193, Table A.2-54).............................................................. B20

Table B-17. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain land segment within 60 days during winter (Chukchi 

Sea Sale 193, Table A.2-58)......................................................................................... B21

Table B-18. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain land segment within 360 days during winter (Chukchi 

Sea Sale 193, Table A.2-60)......................................................................................... B22

Table B-19. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain grouped land segment within 60 days during winter 

(Chukchi Sea Sale 193, Table A.2-64). ........................................................................ B23

Table B-20. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain grouped land segment within 360 days during winter 

(Chukchi Sea Sale 193, Table A.2-66). ........................................................................ B24

Table B-21. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain boundary segment within 60 days during winter 

(Chukchi Sea Sale 193, Table A.2-70). ........................................................................ B24

Table B-22. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact a certain boundary segment within 360 days during winter 

(Chukchi Sea Sale 193, Table A.2-72). ........................................................................ B24

Table B-23. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting from a 

given location that will contact a portion of Opilio Arctic EFH area within 3, 10, 30, 60, 

180 or 360 days during summer. .................................................................................. B25

Table B-24. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting from a 

given location that will contact a portion of Opilio Arctic EFH area within 3, 10, 30, 60, 

180 or 360 days during winter...................................................................................... B25

Table B-25. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting from a 

given location that will contact a portion of Safron Cod EFH area within 3, 10, 30, 60, 

180 or 360 days during summer. .................................................................................. B26
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B iii

Table B-26. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting from a 

given location that will contact a portion of Safron Cod EFH area within 3, 10, 30, 60, 

180 or 360 days during winter...................................................................................... B26

Table B-27. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact environmental resource area 74, 83 or 91within 60 days, during 

summer Chukchi Sea Sale 212/221 (USDOI, MMS, 2008a: Table A.3-4).................. B26

Table B-28. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given 

location that will contact environmental resource area 74, 83 or 91within 360 days, 

during summer Chukchi Sea Sale 212/221 (USDOI, MMS, 2008a: Table A.3-5). ..... B26

List of Figures 

Figure B-1. Study area used in the oil spill trajectory analysis. (Map A.1-1 in Sale 193 FEIS)..... B28

Figure B-2. Environmental Resource Areas used in the oil spill trajectory analysis. (Map A.1-2a in 

Sale 193 FEIS).............................................................................................................. B29

Figure B-3. Environmental Resource Areas used in the oil spill trajectory analysis. (Map A.1-2b in 

Sale 193 FEIS).............................................................................................................. B30

Figure B-4. Environmental Resource Areas used in the oil spill trajectory analysis. (A.1-2c in Sale 

193 FEIS)...................................................................................................................... B31

Figure B-5. Environmental Resource Areas used in the oil spill trajectory analysis. (A.1-2d in Sale 

193 FEIS)...................................................................................................................... B32

Figure B-6. Land Segments (1–39) used in the oil spill trajectory analysis. (Map A.1-3a in Sale 193 

FEIS)............................................................................................................................. B33

Figure B-7. Land Segments (40–85) used in the oil spill trajectory analysis. (Map A.1-3b in Sale 

193 FEIS)...................................................................................................................... B34

Figure B-8. Land Segments (86–126) used in the oil spill trajectory analysis. (Map A.1-3c in Sale 

193 FEIS)...................................................................................................................... B35

Figure B-9. Grouped Land Segments used in the oil spill trajectory analysis. (Map A.1-3d in Sale 

193 FEIS)...................................................................................................................... B36

Figure B-10. Hypothetical Launch Areas and pipelines used in the oil spill trajectory analysis for 

Alternative 1. (Map A.1-4a in Sale 193 FEIS) ............................................................ B37

Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B1

Appendix B. Oil-Spill Information, Models, and Estimates 

The Sale 193 Chukchi Sea FEIS details the results of the oil spill analysis in Appendix A of that 

document (USDOI, MMS, 2007), and is incorporated by reference. That information includes (1) 

estimates of the source, type, and size of oil spills, (2) behavior and fate of crude oils, (3) modeling 

simulations of oil weathering, (4) estimates of where an offshore oil spill may go, (5) oil-spill-riskanalysis, and (6) small oil spills. The updates in this Sale 193 SEIS Appendix B include information 

on topics 1 through 5 above which are relevant to the VLOS (very large oil spill) analysis. 

1. Estimates of Source and Size 

Very large spills could potentially come from four sources associated with OCS exploration or 

development operations: (1) pipelines (2) facilities (3) tankers or (4) support vessels. We reviewed 

those four sources and determined well control incidents have the potential for the largest spill 

volumes, assuming all primary and secondary safeguards fail and the well does not bridge. At this 

time, pipelines are the preferred mode of petroleum transport (over tankers) in the Chukchi OCS and, 

therefore, we did not consider the loss of a fully loaded tanker. The loss of the entire volume in an 

offshore pipeline would be less than a long duration well control incident with high flow rates. 

Support vessels were considered based on foundering and the loss of their entire fuel tanks and 

determined to be less volume than a well control incident where all primary and secondary safeguards 

failed. For purposes of analysis we examine a well control incident which escalates into a 

catastrophic blowout. 

1.1. OCS Well Control Incidents 

The Sale 193 FEIS section A.1.c., Historical Crude Oil Spills from Well Control Incidents on the 

Outer Continental Shelf is updated with information through December 2010, which includes the 

Deepwater Horizon. Table B-1 shows the number of well control incidents with pollution per year in 

the Gulf of Mexico and Pacific OCS Regions through 2010. There have been no well control 

incidents in the Alaska OCS Region or Atlantic OCS Region. 

From 1971-2009, 249 well control incidents occurred during exploratory operations and development 

and production operations on the OCS (this includes incidents associated with exploratory and 

development drilling, completion, workover, plugging and abandonment, and production operations). 

During this period, 41,514 wells were drilled on the OCS and 15.978 billion barrels (Bbbl) of oil were 

produced. Of the 249 well control incidents that occurred during this period, 50 resulted in the 

spillage of condensate/crude oil ranging from < 1 bbl to 450 bbls. The total spilled from these 50 

incidents was 1,829 bbls. This volume spilled was approximately 0.00001147% of the volume 

produced during this period. In 2010, four well control incidents occurred, including the Deepwater 

Horizon incident. Although a final spillage volume from the Deepwater Horizon incident has not 

been determined by BOEMRE, the current estimate from Lubchenco et al. (2010) and McNutt et al. 

(2011) is 4.9 million bbls. The three other well control incidents that occurred in 2010 did not result 

in the spillage of condensate/crude oil. 

From 1971-2010, there were a total of 41,781 wells drilled in the OCS comprising 40,565 wells in the 

Gulf of Mexico, 1,086 wells in the Pacific Region, 46 wells in the Atlantic Region, and 84 wells in 

the Alaska Region. Of these, 26,245 were development wells, 15,491 were exploration wells, and 43 

were core tests or relief wells. The overall well control incident rate for drilling is 1 well control 

incident per 292 wells drilled, compared to 1 per 410 wells for development, and 1 per 201 wells for 

exploration. These well control incident rates include all well control incidents from drilling 

operations whether they spilled oil or not. 
BOEMRE Sale 193 Revised Draft SEIS 

B2 Appendix B 

From 1971-2010, industry has drilled 223 exploration wells in the Pacific OCS, 46 in the Atlantic 

OCS, 15,138 in the Gulf of Mexico OCS, and 84 in the Alaska OCS, for a total of 15,491 exploration 

wells. During this period, there were 77 well control incidents associated with exploration drilling. 

Of those 77 well control incidents, 14 resulted in crude and condensate oil spills ranging from 0.5 bbl 

to 200 bbls, for a total of 354 bbls, excluding the estimated volume from the Deepwater Horizon 

incident. From 1971–2010, one well control incident resulted in a spill volume of 1,000 bbls or more 

and that was the Deepwater Horizon incident. 

1.2. Historical Worldwide Spills Greater than or Equal to 1 Million 

Barrels from Wells 

Very large spills happen very infrequently, and there are limited data for use in our statistical analysis 

and predictive efforts. The chance of a very large spill occurring is very low. Five of the well 

control-incident events ≥1,000 bbl in the OCS database occurred between 1964 and 1970 (Table B-1). 

Following the Santa Barbara well control incident in 1969 and two large spills from well control 

incidents in the Gulf of Mexico in 1970, amendments to the OCS Lands Act through OCS orders 

significantly strengthened safety, inspection, and pollution-prevention requirements for OCS offshore 

activities. Well control training, redundant pollution-prevention equipment, and subsurface safety 

devices are among the provisions that were adopted in the regulatory program at that time. For 39 

years no OCS well control incidents resulted in a large oil spill. The sixth OCS well control incident 

resulting in a large spill, the Deepwater Horizon, occurred in 2010 and has also precipitated changes 

in regulations. Although no official volume has been determined by BOEMRE it is clear from the 

spill volume estimates that the Deepwater Horizon exceeds the threshold of a VLOS; the current 

estimate from Lubchenco et al. (2010) and McNutt et al. (2011) is 4.9 million bbls. and is likely 

greater than 1 million barrels (Lubchenco et al. 2010, McNutt et al. 2010). 

Internationally, from 1979 through 2010, six oil well incidents, resulting in an oil spill of greater than 

or equal to 1 million bbl, were identified from the peer reviewed or “gray” literature (Table B-1). 

Two of the well incidents were the result of military action. There were roughly 781 Bbbl of oil 

produced worldwide from 1979–2009 (British Petroleum, 2010). These data provide an approximate 

rate of about 1 incident for every 130 Bbbl of oil produced worldwide. Using international data 

increases the size of the data set and is more likely to capture rare events. However, it assumes that 

non-US events are relevant to US events to the extent that technology, maintenance, operational 

standards and other factors are equal; but this is not likely to be the case (especially in cases of 

military action). Nonetheless, it does show these types of events are rare. 

Table B-1. Number of well control incidents with pollution per year in the Gulf of Mexico and Pacific 

OCS Regions and total OCS wells. 

Condensate/Crude Oil Spilled 

(Barrels) 

Product

-ion Drilling Workover/ Completion 

Well 

Type 

Well 

Type 

Wells 

Drilled 

Year 

Total Number of 

Incidents 

Incidents with 

Condensate/ Crude 

Oil 

Workover, 

Production, 

Completion, P&A 

Drilling 

and Development 

Total Exploration 

Total Total 

Exploration 

Development 

Unknown 

Total 

Development 

Exploration 

Total 

1956 1 0 — — 0 — 1 — 1 0 — 204 46 258 

1957 1 0 — — 0 — 1 — 1 0 — 333 58 391 

1958 2 1 0.9 — 0.9 — 1 1 — 0 1 210 65 275 

1959 1 0 — — 0 — 1 — 1 0 — 229 96 325 

1960 2 0 — — 0 1 1 1 — 0 — 290 138 428 

1961 0 0 — — 0 — — — — 0 — 351 133 484 

1962 1 0 — — 0 — 1 — 1 0 — 385 159 544 

1963 1 0 — — 0 — 1 1 — 0 — 400 209 609 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B3

Condensate/Crude Oil Spilled 

(Barrels) 

Product

-ion Drilling Workover/ Completion 

Well 

Type 

Well 

Type 

Wells 

Drilled 

Year 

Total Number of 

Incidents 

Incidents with 

Condensate/ Crude 

Oil 

Workover, 

Production, 

Completion, P&A 

Drilling 

and Development 

Total Exploration 

Total Total 

Exploration 

Development 

Unknown 

Total 

Development 

Exploration 

Total 

1964 7 3 10,280 100 10,380 4 3 2 1 0 — 507 234 742 

1965 5 2 0.9 1688 1,688.9 1 4 1 3 0 — 648 194 842 

1966 2 2 0.9 0.9 1.8 — 1 — 1 0 1 628 299 973 

1967 2 1 0.9 — 0.9 0 — — — — 2 638 321 988 

1968 8 0 — — 0 1 6 2 4 — 1 735 358 1094 

1969 3 3 — 82,500.9 82,500.9 0 3 1 2 0 — 731 254 993 

1970 3 2 118,000.0 — 118,000.0 1 1 — 1 0 1 756 248 1006 

1956-

1970 39 14 128,283.60 84,289.80 212,573.40 8 25 9 16 0 6 7,045 2,812 9,952 

Major Regulatory Changes to Outer Continental Shelf Lands Act 

1971 6 2 460 — 460 2 2 1 1 0 2 620 285 909 

1972 6 2 2 0.9 2.9 1 4 2 2 — 1 608 309 917 

1973 3 1 0.9 0.9 0 3 2 1 — — 569 321 890 

1974 6 2 275 — 275 2 2 1 1 — 2 512 355 869 

1975 7 1 0.9 — 0.9 — 5 4 1 — 2 569 334 904 

1976 6 0 — — 0 1 5 1 4 — — 851 317 1169 

1977 10 1 2 — 2 1 4 3 1 — 5 975 398 1373 

1978 12 1 0.9 — 0.9 — 8 4 4 — 4 935 361 1298 

1979 5 2 1.8 1.8 — 5 4 1 — — 895 420 1316 

1980 8 1 1 — 1 2 4 3 1 — 2 943 412 1356 

1981 10 5 66.7 0.9 67.6 1 3 1 2 — 6 1012 400 1412 

1982 9 2 1.8 — 1.8 — 5 1 4 — 4 970 457 1427 

1983 12 1 — 2 2 — 10 5 5 — 2 872 458 1330 

1984 5 0 — — 0 — 4 3 1 — 1 862 663 1525 

1985 6 1 50 — 50 0 4 3 1 — 2 783 574 1361 

1986 2 0 — — 0 — 1 — 1 — 1 517 296 813 

1987 8 2 61 — 61 3 2 2 — — 3 534 439 973 

1988 4 1 4.5 — 4.5 1 2 1 1 — 1 510 584 1094 

1989 12 0 — — 0 3 7 4 3 0 2 572 489 1061 

1990 7 3 17.5 — 17.5 0 3 1 1 1 4 638 521 1159 

1991 8 1 — 0.8 0.8 — 6 3 3 0 2 483 350 833 

1992 3 1 — 100 100 — 3 3 — — — 376 229 605 

1993 4 0 — — 0 — 4 1 3 — — 645 365 1010 

1994 1 0 — — 0 — — — — — 1 686 438 1124 

1995 1 0 — — 0 — 1 0 1 — — 784 395 1179 

1996 4 0 — — 0 — 2 1 1 — 2 805 462 1267 

1997 5 0 — — 0 — 4 1 3 — 1 932 549 1481 

1998 9 3 2.6 1.62 4.22 3 3 2 1 — 3 665 495 1161 

1999 5 1 125 — 125 — 3 1 2 — 2 676 371 1048 

2000 9 3 0.02 200.5 200.52 — 8 6 2 — 1 950 443 1396 

2001 10 1 1 — 1 2 5 2 3 — 3 867 411 1278 

2002 6 3 350.505 — 350.505 2 3 1 2 1 654 310 964 

2003 5 1 10 — 10 2 2 0 1 1 1 557 354 911 

2004 6 4 2.5 22.06 24.56 1 3 3 — — 2 569 363 932 

2005 4 0 — — 0 — 4 1 3 — — 482 355 841 

2006 2 2 10 24.5 34.5 — 1 1 — — 1 375 414 789 

2007 8 — — — — 2 2 2 4 328 300 630 

2008 9 0 — — 0 3 4 1 3 2 304 267 571 

2009 6 2 27.94 — 27.94 1 1 1 4 179 147 338 

2010 4 1 — TBD TBD 3 1 1 0 181 80 267 

1971-

2010* 253 51 1,472.87 355.98 1,828.85 36 143 77 64 2 74 26,245 15,491 41,781 

Notes: Wells drilled columns include hydrocarbon, sulfur and salt wells. The total column includes core tests and relief wells in addition to exploration and 

development wells; therefore the total column may be slightly higher than the sum of the development and exploration wells columns for some years. 

TBD - the final volume for the Deepwater Horizon that occurred on 4/20/2010 has not been determined by BOEMRE. 

* The 1971-2010 spill volume totals for the columns showing Drilling and Total Exploration and Development do not include the volume for the Deepwater Horizon 

incident that occurred on 4/20/2010. 
BOEMRE Sale 193 Revised Draft SEIS 

B4 Appendix B 

Source: BOEMRE, Accident Investigation Board (2011) 

Table B-2. International Historical Spills from Wells Greater than or Equal to 1 MMbbl. 

Name Location Begin End Duration Barrels Source 

Lakeview Gusher United States, Kern 

County, California 

3/14/1910 9/1911 18 months 9,000,000 Anonymous, 

2003 

Gulf War Oil 

Spill* 

Kuwait 1/23/1991 5,500,000-

11,000,000 

1,2,3,4, 

Fingas, 2000 

Deepwater 

Horizon/Macondo 

United States, OCS, Gulf 

of Mexico 

4/20/2010 7/15/2010 87 Days 4,900,000 McNutt et al., 

2011 

Ixtoc Mexico, Gulf of Mexico 6/3/1979 295 Days 3,500,000 OSIR, 1998; 

Etkin, 2009; 

Fingas, 2000 

Well No 5. 

Fergana Valley 

Uzbekistan, Fergana 

Valley, Mingbulak Oil 

Field 

3/2/1992 > 4 weeks 2,095,238 OSIR, 1998; 

Fingas, 2000 

Nowruz Oil Field 

No. 3 Well* Iran, Persian Gulf 2/4/1983 9/18/1983 224 days 1,904,762 

OSIR, 1998; 

NOAA, 1983 

D-103 Libya, near Al Fuqaha 8/11/1980 5 months 1,000,000 OSIR, 1998; 

Fingas, 2000 

Note: * Military attack-related events 

Source: USDOI, BOEMRE, (2011) compiled from cited references. 

1.3. Oil Spill Risk Analysis 

The information from Bercha (2006) was used in the USDOI MMS (2007) oil-spill analyses in the 

Chukchi Sea. The BOEMRE revisited the input variables used in the Bercha (2006) fault tree 

analysis. The intent was to compare the well control incident frequencies used in the fault tree 

analysis to the general rate estimated from 1971-2010 to determine if it was within the bounds of the 

original estimated well control incident frequencies. 

To model the historical data variability for Arctic exploration well blowouts, Bercha applied a 

numerical simulation approach to develop the probability distribution for blowouts of 150,000 bbl 

(23,848 m3

) or greater, and arrived at a frequency ranging from a low of 1.5 x 10-4 per well to a high 

of 6.97 x 10-4 per well. The expected value for a blowout of this size was computed to be 3.94 x 10-4

per well (Bercha 2006). To address causal factors associated with blowouts, Bercha applied 

adjustments for improvements to logistics support and drilling contractor qualifications that resulted 

in lower predicted frequencies for Arctic drilling operations. No fault-tree analysis or unique Arctic 

effects were applied as a modification to existing spill causes for exploration, development, or 

production drilling frequency distributions. For exploration wells drilled in analogous water depths to 

planned Chukchi Sea wells (30-60 m), Bercha (2006) estimated the adjusted frequency is 

6.8 x 10-4 per well for a blowout sized between 10,000 bbl (1,590 m3

) and 149,000 bbl (23,689 m3) 

and 3.9 x 10-4 per well for a blowout >150,000 bbl (23,848 m3

). 

Based on the well control incident data in Table B-1, the frequency of OCS well control incidents 

spilling fluids ≥150,000 bbl from 1971-2010 has not exceeded the frequencies used in the fault tree 

analysis for the Sale 193 oil spill analysis. 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B5

2. Behavior and Fate of Crude Oils 

The Sale 193 FEIS Appendix A.1, section B summarizes the behavior and fate of crude oil and is 

incorporated by reference. This section summarizes and updates relevant information to the VLOS 

analysis. 

2.1 Release from A Well Control Incident 

A very large oil and gas release could rise to the ocean surface from the shallow to moderate depths 

on the seafloor (e.g. 1979 Ixtoc I) or fall to the surface of the ocean. The force of the gas would 

facilitate small oil droplets (0.5 – 2.0 mm) to form and disperse in the ocean or atmosphere (Dickins 

and Buist, 1981; Belore, McHale and Chapple, 1998; S.L. Ross Environmental Research Ltd, D.F. 

Dickins and Associates Ltd., and Vaudrey and Associates Inc., 1998). A small portion (1-3%) of 

droplets could form a plume as identified from Ixtoc at shallow to moderate depths without the 

injection of dispersants (Boehm and Fiest, 1982). The more soluble compounds within the oil may 

dissolve, particularly from small droplets that are prevalent in the vertical plume, where the vigorous 

turbulence occurs (Adcroft et al. in press). A subsea release in shallow to moderate depths moves 

through three zones: (1) a jet zone causing turbulence and droplet formation, (2) a buoyancy zone 

where gas, oil, and water are carried to the surface and droplet size governs rise velocity, and (3) a 

surface interaction zone where the surface influence carries the oil with the prevailing currents or ice 

and the gas exits into the atmosphere , which causes a surface boil zone (PCCI, 1999, Reed et al., 

2006). Volatile organic carbons would be measurable in the atmosphere downwind of the spill in a 

small area confined to a narrow plume (deGouw et al., 2011, Ryerson et al., in press) during the 

summer open water and broken ice seasons. 

For well control incidents at shallow to moderate depths, the gas is considered to be an ideal gas with 

a specific volume decreasing linearly with pressure. Dissolution of gas from rising bubbles may be 

minimal for incidents at shallow to moderate depth since the residence time of gas bubbles is 

expected to be short (Reed et al. 2006). 

2.2. Ice Present 

Broken ice occurs in the Chukchi Sea during fall freezeup and spring breakup. The ice would restrict 

the oil somewhat and reduce spreading (Gjosteen and Loset, 2004; Faksness et al., in press). 

Weathering of oil in high ice concentrations (70-90%) is significantly slower compared to weathering 

in open water (Brandvik et al. 2010). But unless the oil is frozen into the ice, evaporation would 

continue to occur. Dispersion and emulsification rates are lower in broken ice than in open water. 

During fall freezeup, the oil would freeze into the grease ice and slush before ice sheeting occurs. 

Winds and storms could break up and disperse the ice and oil until the next freezing cycle. These 

freezing cycles could be hours or days. 

Faksness and Brandvik (2008a) studied the dissolved water-soluble components encapsulated in firstyear sea ice. Their data show a concentration gradient from the surface of the ice to the bottom, 

indicating there is transport of the dissolved components through brine channels. Field studies also 

showed that high air temperature leads to more porous ice, and the dissolved water-soluble 

components leak out rapidly; however, under cold air temperatures and less porous ice, the watersoluble components leak more slowly and have potentially toxic concentrations (Faksness and 

Brandvik, 2008b). 

During deep winter the oil would freeze into the forming and existing ice sheets (Dickens, 2011; Mar, 

Inc., et al., 2011). Then, in late spring and summer, the unweathered oil would melt out of the ice at 

different rates, depending on whether it is encapsulated in multiyear or first-year ice, and depending 

on when the oil was frozen into the ice. In first-year ice, most of the oil spilled at any one time would 

percolate up to the ice surface over about a 10-day period. In approximately mid-July, the oil pools 
BOEMRE Sale 193 Revised Draft SEIS 

B6 Appendix B 

would drain into the water among the floes of the opening ice pack. Thus, in first-year ice, oil would 

be pooled on the ice surface for up to 30 days before being discharged from the ice surface to the 

water surface. The pools on the ice surface would concentrate the oil, but only to about 2 millimeters 

thick, allowing evaporation of 5% of the oil, the part of the oil composed of the lighter, more toxic 

components. By the time the oil is released from the melt pools on the ice surface, evaporation will 

have almost stopped, with only an additional 4% of the spilled oil evaporating during an additional 30 

days on the water. 

2.3. Open Water 

The oil would move with the currents, ice, and winds. In addition to sunlight breaking down the oil, 

sunlight also has the potential to cause photo-enhanced toxicity (Barron et al., 2008). 

2.4. Persistence 

The Sale 193 FEIS (USDOI, MMS, 2007a; incorporated by reference) Appendix A, Section B.2 

discusses shoreline type and Table A.1-8 shows the percent environmental sensitivity index (ESI) of 

the adjacent coastlines. Many coastlines of the Chukchi and Beaufort have high ESI shoreline types 

which means oil could weather very slowly. Shoreline oiling and persistence depends on a number of 

factors (Etkin, McCay and Michel, 2007). Certain factors allow for some spills to persist in the 

shoreline and adjacent intertidal areas for decades (Li and Boufadel, 2010; Owens, Taylor and 

Humphrey, 2008; Peacock et al. 2005). A recent study of biodegradation in the Arctic showed that as 

temperature increased in the Arctic summer biodegradation increased (Chang,Whyte and Ghoshal, 

2011). 

Dispersion of oil droplets and suspension of sediments from turbulence at the discharge location 

could facilitate the formation of oil sediment particulate matter, which could be deposited on the 

seafloor in the vicinity of the discharge location (Lee and Page, 1997; Payne, Clayton and Kirstein, 

2003; Sterling et al., 2004; Farwell et al., 2009). The losses of hydrocarbons from both abiotic and 

biotic weathering in subsea Arctic sediments could be slow (Atlas, Horowitz and Dushoshi, 1978; 

Payne, Clayton and Kirstein, 2003). 

Lee and Page (1997) reviewed several large spills and estimated 1–13% of the spilled oil entered 

subtidal zones with an order of magnitude less hydrocarbon concentration than found in intertidal 

sediments. Exceptions (for less hydrocarbon concentrations) were semi-enclosed areas with clay-silt 

surface sediments and high concentrations of suspended sediments (Page et al., 1989). Biodegradaion 

and weathering of intertidal areas in cold waters were on the order of months to decades (Atlas, 

Boehm and Calder, 1981; Prince et al., 2003). Oil persistence in subtidal areas would be weeks to 

years, except for specific areas described above (Lee and Page, 1997). 

3. Very Large Oil-Spill Weathering 

The weathering for very large spills followed the same methodology described in the Sale 193 FEIS 

(Appendix A, Section B.4), and the results for very large oil spills are described below. The oil 

weathering input parameters are as follows: 

 The crude oil properties will be similar to a light crude oil of 35 API. 

 The size of the crude spill ranges from 60,000–20,000 bbl per day. 

 The wind, wave, and temperature conditions are as described. 

 The spill is a subsurface spill at approximately 40 m. 

 Meltout spills occur into 50% ice cover. 

 The properties predicted by the model are those of the thick part of the slick. 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B7

 The spill occurs as a long duration spill estimated at a daily rate. 

 The fate and behavior are as modeled (Tables B-3 and B-4). 

 The oil spill persists for up to 30 days in open water and ice under 4m/s wind. 

For purposes of analysis, we look at the mass balance of the VLOS; in other words, how much is 

evaporated, dispersed, and remaining. At the average wind speeds over the Sale 193 area, dispersion 

is estimated to be moderate, ranging from 2-33% (Tables B-3 and B-4). Approximately one third of 

the spill evaporates within 30 days with most of the evaporation taking place within one day during 

summer and winter. 

Table B-3. Fate and behavior of a hypothetical 20,000-barrel crude oil spill in the Chukchi Sea. 

Summer Spill1 Meltout Spill2

Time After Spill (Days) 1 3 10 30 1 3 10 30 

Oil Remaining (%) 61 53 36 13 67 58 47 35 

Oil Dispersed (%) 10 16 29 50 4 10 17 27 

Oil Evaporated (%) 29 31 35 37 29 32 36 38 

Table B-4. Fate and behavior of a hypothetical 60,000-barrel crude oil spill in the Chukchi Sea. 

Summer Spill1 Meltout Spill2

Time After Spill in Days 1 3 10 30 1 3 10 30 

Oil Remaining (%) 68 62 51 30 71 65 58 48 

Oil Dispersed (%) 5 8 16 33 2 5 9 15 

Oil Evaporated (%) 27 30 33 37 27 30 33 37 

Notes: Calculated with the SINTEF oil-weathering model Version 3.0 of Reed et al. (2005) and a 35 API crude oil. 1

 Summer (June 1-October 31), 8-knot wind speed, 2 degrees Celsius, 0.4-meter wave height. 2 Meltout Spill (November 1-May 31). Spill is assumed to occur into first-year pack ice, pools 2-centimeter thick on ice surface

for 2 days at -1 degrees Celsius prior to meltout into 50% ice cover, 10-knot wind speed, and 0.1 meter wave heights. 

Source: USDOI, BOEMRE, Alaska OCS Region (2011) 

However, at higher wind speeds (e.g., 10-15 m/s wind speed) and during summer, the slick would be 

dispersed and evaporated from the sea surface within a day. Natural dispersion would take place if 

there was sufficient energy on the sea surface, such as breaking waves. The waves would break the 

oil slick into small droplets, typically with a diameter of 1–1000 μm, which are mixed into the water 

masses (Reed et al., 2005). The largest droplets will resurface causing a thin monomolecular layer or 

sheen behind the main body of the oil spill. “Remaining” (in Tables B-3 and B-4) refers to the oil 

remaining after subtracting the above estimates from the total estimated release. Possible fates of the 

remaining oil include remaining in the water column, settling to the sea floor, mixing with sediment, 

ingestion by microbes, or beaching on the shoreline and subsequent removal during shore cleanup 

activities or burial within the beach profile. 

4. Results of the Oil Spill Trajectory Model 

The Sale 193 FEIS, Appendix A, Section C, Estimates of Where a Large Oil Spill May Go is 

incorporated by reference and briefly summarized. The Sale 193 FEIS oil spill trajectory analysis 

used 13 launch areas (LAs) within the sale area representing the places where a hypothetical spill 

could originate from an exploration or development activity. The analysis also used 87 

environmental resource areas (ERAs), 126 land segments (LSs), 39 boundary segments (BSs) and 15 

grouped land segments (GLSs) representing biological, economic or social resources within and 

adjacent to the sale area (Figures B-1 to B-10; USDOI, MMS, 2007, Tables A.1-12 to A.1-16). The 

larger scope of the VLOS scenario warranted consideration of more ERAs than were used in the Sale 

193 FEIS OSRA analysis. Analysts were asked to identify additional ERAs useful for understanding 

the potential impacts of a VLOS. Three additional ERAs (74, 83 and 91) for whales in Russian waters 

were incorporated from Table A.1-15 in the Arctic Multi-Sale Draft EIS (USDOI, MMS, 2008a) and 
BOEMRE Sale 193 Revised Draft SEIS 

B8 Appendix B 

EFH polygons (Appendix C) were analyzed where no other Sale 193 conditional probability data was 

available. 

The Sale 193 FEIS (Appendix A, Section C.1.f.) describes the general circulation models used for oil 

spill trajectories and is incorporated by reference and summarized as follows. Offshore, the model is 

based on a three dimensional general circulation model (Haidvogel, Hedstrom, and Francis, 2001). 

Landfast ice is applied as a mask October through June. Winds are derived from a 15 year reanalysis 

of the TOVs data. 

4.1. Conditional Probabilities 

The Sale 193 FEIS Appendix A.2 presents probabilities that assume that an oil spill occurred and will 

contact a certain offshore environmental resource or land segment within 3, 10, 30, 60, 180 or 360 

days. Assuming a hypothetical high volume and long duration flow, a VLOS would result. This 

section summarizes how the conditional probabilities should be considered and where a VLOS 

(offshore) may go within 60 and within 360 days. The probability that an oil spill will contact a 

specific environmental resource within a given time of travel from a certain location or spill point is 

termed a conditional probability, the condition being that a spill is assumed to have occurred. Each 

trajectory was allowed to continue for as long as 30 days in ice-free water. However, if the 

hypothetical spill contacted the shoreline sooner than 30 days after the start of the spill, the spill 

trajectory was then terminated, and the contact was recorded. 

The Sale 193 FEIS conditional probabilities of a large spill contacting specific resources in a given 

time frame during a particular season were analyzed in each resource section, with discussion of the 

effects from oil spills. A large spill from Launch Areas (LAs) 1–13 and the conditional probabilities 

of contact for specific resources were discussed in the Sale 193 FEIS (Sections IV.C.1.c[4][b], 

IV.C.1.d[3][d], IV.C.1.e[4] IV.C.1.f[1][g], IV.C.1.g[3][g], IV.C.1.h[4], IV.C.1.h[6][e], and 

IV.C.1.l[1][b]). 

We also use the Sale 193 FEIS conditional probabilities to estimate the percentage of trajectories 

contacting biological, social, and economic resources of concern in and adjacent to the Sale 193 area 

from a VLOS. No special OSRA run was conducted in order to estimate the percent of trajectories 

contacting resources from a hypothetical future catastrophic blowout and high volume, long duration 

flow resulting in a VLOS. The Arctic OSRA calculations are run for as long as 360 days and were 

appropriate for very large oil spills with long duration. This analysis summarizes the results of each 

oil spill trajectory simulation tracked up to 60 and 360 days. These results pertain to oil spill 

trajectories from the 13 LAs in the Sale 193 FEIS to various land segments and environmental 

resource areas. 

A long duration spill would consist of multiple trajectories over time as each day passed and the well 

continued to flow. This would change how the conditional probabilities are interpreted. Rather than 

the percent chance of a large spill contacting a biological, social, or economic resource, the results 

would represent the percent of trajectories from a long duration VLOS contacting these resources. 

Section IV.D.2 of this document describes the hypothetical VLOS scenario. A VLOS could begin any 

time between July 15 and October 31, and the time period for a relief well ranges from 39 to 74 days. 

For the shortest period we considered that spilled oil has an on water persistence of up to three weeks, 

and a 60-day contact period for the summer open-water season is appropriate. For the longer period 

we considered that spilled oil could freeze into the sea ice, remain through the winter, and be released 

in the spring—a period of 360 days. 

A VLOS continuing after October 31 must also consider winter trajectory results because winter is 

the period in which trajectories are launched and the winter season begins November 1 in the Chukchi 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B9

Sea model. For purposes of analysis the oil could freeze into the ice and melt out in the Arctic spring 

or summer, so 360 days is the most conservative assessment period for this hypothetical situation. 

Results from this trajectory analysis provide input to the VLOS analysis by estimating where very 

large oil spills might travel on the ocean’s surface and what land segments and biological, social, and 

economic resources might be contacted (assuming a very large spill occurs). The trajectories also 

provide an estimated timeframe in days if contact occurs. For this analysis, only the percentage of 

trajectories contacting the resource was considered. The probability of a catastrophic well control 

incident resulting in a VLOS occurring was not calculated. This analysis assumes that all safety 

measures have failed and a catastrophic blowout resulting in a long duration spill has occurred. 

For purposes of a VLOS trajectory analysis, any percentage of trajectories contacting resources 

(ERA, LS, GLS, or BS) was considered to bring oil to that location. Higher percentages of 

trajectories contacting resources could mean more oil reached the location, depending upon 

weathering, timing of flow rates, and environmental factors. There are factors not explicitly 

considered by the OSRA model that can affect the transport of spilled oil as well as the dimensions, 

volume, and nature of the oil spills contacting environmental resources or the shoreline. These 

include possible cleanup operations, chemical composition or biological weathering of oil spills, or 

the spreading and splitting of oil spills. The BOEMRE analysts have chosen to take a more 

environmentally conservative approach by presuming persistence of spilled oil over the selected time 

duration of the trajectories. Cleanup and weathering are discussed separately in the document with 

consideration of how these could change the outcome of the impact analysis. 

4.2. Oil Spill Trajectory Results 

The percentages of trajectories contacting resources (ERA, LS, GLS, or BS), assuming a VLOS has 

occurred, is taken from the oil-spill-trajectory model results summarized below and listed in 

Appendix B, Tables B-7 through B-28 at the end of this document. 

Section IV.D of this document presents a comparison between the hypothetical launch areas and 

seasons, and, below, the oil spill trajectory results within 60 days and 360 days for summer and 

winter are presented. For specific analysis of oil spill trajectory results with regard to each individual 

biological, social, or economic resource, please see Section IV.E. 

4.3. Generalities Through Time 

Below, we summarize the percentages of trajectories contacting resources (ERA, LS, GLS, or BS) 

during summer within 60 days, and during summer and winter within 360 days. 

60 Days. During summer, <0.5–2% of the trajectories from LA4 or LA9 contact LSs 27 or 32–39 

(Rigol, Eynenekvyk, Enumino, Mys Serdtse-Kamen, Uelen, Russia) and <0.5–3% of the trajectories 

contact LSs 64–67(Point Hope–Ayugatak Lagoon) (see Table B-9). During summer, <0.5–6% of the 

trajectories from LA4–LA13 contact at least one individual LS within LSs 63–89 (Cape Seppings–

Ikpikpuk River) (see Table B-9). Less than 0.5% of the trajectories from LA1 and LA2 contact an 

individual land segment within 60 days over summer (Table B-9). 

Launch areas adjacent to or on top of ERAs have the highest percent chance of trajectories contacting 

these ERAs. During summer, <0.5–60% of trajectories from LA1–LA13 contact individual ERAs 

(Table B-7). During summer, 2–28% of the trajectories contact land from LA1–13 (Table B-7). 

During summer, <0.5%–3% of the trajectories contact boundary segments from LA1–13 (Table B13). 

360 Days. During summer, <0.5–3% of the trajectories from LA4 or LA9 contact LSs 27–39 (Rigol, 

Uelen, Russia) and <0.5–3% of the trajectories contact LSs 64–67 (Point Hope–Ayugatak Lagoon) 

(Table B-10). During summer, <0.5-10% of the trajectories from LA4–LA13 contact at least one 

individual LSs 64–91 (Point Hope–Pitt Point) (Table B-10). Less than 0.5% of the trajectories from 
BOEMRE Sale 193 Revised Draft SEIS 

B10 Appendix B 

LA1 contact an individual land segment within 360 days over summer (Table B-10). During summer, 

<0.5%–12% of the trajectories contact boundary segments from LA1–13 (Table B-14). 

During winter, <0.5–1% of the trajectories from LA1 or LA2 contact LS7, LS8, or LS27 (E. Wrangel 

Island, Rigol). During winter <0.5–5% of the trajectories from LA4 or LA9 contact LSs 27–39 

(Rigol-Uelen, Russia) and <0.5-1% of the trajectories contact LS 64–65(Kukpuk River–Cape 

Lisburne) (Table B-17). During winter, <0.5–5% of the trajectories from LA4–LA13 contact at least 

one individual LS within LSs 70–87 (Kuchiak Creek to Kulgurak Island) (Table B-17). During 

winter <0.5%–18% of the trajectories contact boundary segments from LA1–13 (Table B-22). 

Launch areas adjacent to or on top of ERAs have the highest percentage of trajectories contacting 

ERAs. During summer, <0.5–62% of trajectories from launch areas LA1–LA13 contact individual 

ERAs (Table B-8). During summer, 3-42% of the trajectories contact land from LA1–13(Table B-8). 

During winter, <0.5–68% of trajectories from launch areas LA1–LA13 contact individual ERA’s 

(Table B-16). During winter, 6–36% of the trajectories contact land from LA1–13 (Table B-16). 

4.4. Cumulative Area Contacted by a Very Large Oil Spill 

To provide a representation of the potential cumulative area contacted by a VLOS over time and 

space, BOEMRE created a grid system of cells, each cell defined as 0.1 degree latitude by 0.33333 

degree longitude. As the oil spill trajectories were computed by the model, contact with the grid cells 

was tabulated. For each trajectory, the cumulative area of all grid cells contacted was then calculated 

for the given time period. 

The cumulative area is discontinuous because it does not represent the entire area contacted by the 

VLOS at any one time; rather, it is a cumulative estimate of the area contacted by a VLOS over six 

time periods (3, 10, 30, 60, 180, or 360 days). Tables B-5 and B-6 show the results for summer and 

winter seasons, respectively. The discontinuous cumulative area rises rapidly between 3 and 30 days, 

and then more slowly between 30 and 360 days. For the discontinuous area contacted after 30 days, 

this means the particle—a point along the oil spill trajectory—persisted (did not disperse) more than 

30 days on the surface of the water and was concentrated in the ice until the ice melted out. 

Interestingly, the estimates for discontinuous cumulative area during summer open water are similar 

in size to NOAA fisheries closures for similar timeframes during the Deepwater Horizon event 

(NOAA, 2011). 

Table B-5. Discontinuous Area Contacted in Square Kilometers by a Very Large Crude Oil Spill in the 

Chukchi Sea during Summer. 

Days LA01 LA02 LA03 LA04 LA05 LA06 LA07 

3 47,300 36,700 28,500 39,100 48,400 40,600 28,100 

10 113,800 92,000 76,300 107,100 116,500 94,800 68,900 

30 296,000 245,900 201,300 303,500 302,100 241,000 183,900 

60 340,600 294,500 279,500 353,900 364,100 322,500 305,600 

180 414,400 397,000 392,600 401,400 440,800 440,900 391,700 

360 459,000 437,900 430,900 416,800 477,800 491,800 334,600 

Days LA08 LA09 LA10 LA11 LA12 LA13 

3 29,500 41,200 48,800 48,100 31,300 31,000 

10 78,400 106,000 111,500 103,400 74,800 67,300 

30 215,700 233,800 277,000 253,600 189,600 191,700 

60 364,200 245,800 331,000 335,400 311,300 344,200 

180 491,000 260,000 379,600 444,000 402,800 484,700 

360 547,600 264,500 400,700 476,200 450,400 545,100 

Source: USDOI, BOEMRE, Alaska OCS Region (2011) 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B11

Table B-6. Discontinuous Area Contacted in Square Kilometers by a Very Large Crude Oil Spill in the 

Chukchi Sea during Winter. 

Days LA01 LA02 LA03 LA04 LA05 LA06 LA07 

3 53,700 34,900 25,900 43,800 44,800 36,800 27,600 

10 120,900 82,200 63,000 131,100 100,500 77,600 62,300 

30 276,800 164,000 108,500 316,500 217,400 138,900 127,100 

60 326500 211,600 162,200 385,600 297,700 201,700 176,600 

180 390,400 309,000 292,600 453,400 381,900 331,500 334,600 

360 438,800 379,000 368,400 507,200 440,500 411,000 406,400 

Days LA08 LA09 LA10 LA11 LA12 LA13 

3 31,500 44,100 48,800 40,800 30,100 32,000 

10 83,100 121,900 104,000 79,400 65,200 71,800 

30 196,900 250,100 246,100 154,600 150,500 170,000 

60 270,000 300,100 339,400 230,800 218,900 251,200 

180 410,500 359,600 414,900 348,400 372,900 409,700 

360 474,900 379,300 484,700 413,700 446,400 481,300 

Source: USDOI, BOEMRE, Alaska OCS Region (2011) 

APPENDIX B 

TABLES
BOEMRE Sale 193 Revised Draft SEIS 

B14 Appendix B 

Table B-7. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location that 

will contact a certain environmental resource area within 60 days during summer. (Chukchi Sea Sale 

193, Table A.2-28) 

ID Environmental Resource Area Name LA 

1 

LA

 2 

LA 

3 

LA 

4 

LA 

5 

LA 

6 

LA 

7 

LA 

8 

LA 

9 

LA 

10 

LA 

11 

LA 

12 

LA 

13 

— LAND 2 2 2 8 10 7 8 18 21 27 27 28 32 

1 Kasegaluk Lagoon - - - 3 4 1 - - 2 14 16 5 - 

2 Point Barrow, Plover Islands - - - - - - 2 9 - - - - 8 

3 ERA 3 - - - 2 - - - - 7 2 - - - 

4 ERA 4 - - - - - - - - 3 1 - - - 

6 ERA 6 1 2 2 2 6 8 11 15 - 3 16 35 36 

10 Ledyard Bay Spectacled Eider Critical 

Habitat 1 - - 7 8 2 - - 11 38 22 4 - 

11 Wrangel Island12 nmi Buffer 2 1 1 1 1 1 - - - - - - - 

13 ERA 13 - - - - - - - - - - - - - 

14 Cape Thompson Seabird Colony Area - - - 2 1 - - - 16 6 1 - - 

15 Cape Lisburne Seabird Colony Area - - - 4 3 - - - 22 19 4 - - 

16 ERA 16 - - - 1 - - - - 5 1 - - - 

18 ERA 18 3 1 - 16 7 1 - - 42 19 5 1 - 

19 Chukchi Spring Lead 1 - - - - - - - - 1 - - - - 

20 Chukchi Spring Lead 2 - - - - - - - - - 3 1 - - 

21 Chukchi Spring Lead 3 - - - - - - - - - 2 3 - - 

22 Chukchi Spring Lead 4 - - - - - - - - - - 3 3 - 

23 Chukchi Spring Lead 5 - - - - - - - - - - - 2 2 

24 Beaufort Spring Lead 6 - - - - - - - 1 - - - - 1 

25 Beaufort Spring Lead 7 - - - - - - - - - - - - 1 

29 Ice/Sea Segment 1 - - - - - - 1 5 - - - 1 5 

30 Ice/Sea Segment 2 - - - - - - 1 2 - - - - 2 

31 Ice/Sea Segment 3 - - - - - - 1 2 - - - - 1 

32 Ice/Sea Segment 5 - - - - - - - 1 - - - - - 

35 ERA 35 3 5 7 2 8 16 20 20 - 2 22 60 50 

36 ERA 36 5 4 2 17 26 11 4 1 5 38 51 16 3 

38 Pt. Hope Subsistence Area - - - 1 1 - - - 8 6 1 - - 

39 Point Lay Subsistence Area - - - 3 5 2 - - 2 18 16 3 - 

40 Wainwright Subsistence Area 1 1 - 3 8 5 2 2 1 9 23 27 7 

42 Barrow Subsistence Area 2 - - - - - - 2 12 - - - 1 10 

45 ERA 45 - - - 3 2 - - - 26 13 3 - - 

46 Herald Shoal Polynya 7 3 1 21 9 3 1 - 3 6 4 1 - 

47 Ice/Sea Segment 10 11 5 2 22 31 9 2 1 1 6 12 5 1 

48 Ice/Sea Segment 11 7 15 18 2 17 47 17 7 - 4 20 15 8 

49 Hanna's Shoal Polynya 7 19 46 1 6 22 24 15 - 2 7 8 9 

50 Ice/Sea Segment 12 2 5 6 1 5 16 13 5 - 1 13 38 13 

51 Ice/Sea Segment 13 1 2 3 - 2 7 10 5 - - 5 34 26 

52 Ice/Sea Segment 14 - 1 2 - - 2 7 29 - - 1 4 29 

53 Ice/Sea Segment 15 - - - - - - 2 4 - - - - 3 

54 Ice/Sea Segment 16a - - - - - - 1 3 - - - - 1 

55 Ice/Sea Segment 17 - - - - - - - 1 - - - - - 

56 ERA 56 7 14 22 1 9 40 40 15 - 2 19 56 27 

59 ERA 59 - - - 1 - - - - 2 1 - - - 

61 ERA 61 - - - - - - - - 3 1 - - - 

63 ERA 63 3 2 1 - - - - 1 - - - - - 

64 Peard Bay - 1 2 - 2 4 7 8 - - 3 15 23 

65 Smith Bay - - - - - - - 1 - - - - - 

66 ERA 66 - - - - - - - 4 - - - - 2 

70 ERA 70 9 10 7 - 1 3 1 1 - - 1 1 1 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B15

ID Environmental Resource Area Name LA 

1 

LA

 2 

LA 

3 

LA 

4 

LA 

5 

LA 

6 

LA 

7 

LA 

8 

LA 

9 

LA 

10 

LA 

11 

LA 

12 

LA 

13 

82 ERA 82 - - - - - - - - 1 - - - - 

99 ERA 99 5 5 3 21 36 15 4 1 6 54 70 18 3 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. . Rows with all values less than 0.5 percent 

are not shown. 

Table B-8. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location that 

will contact a certain environmental resource area within 360 days during summer (Chukchi 

Sea Sale 193, Table A.2-30). 

ID Environmental Resource Area Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

— LAND 4 3 6 12 13 10 17 34 28 31 30 34 42 

1 Kasegaluk Lagoon - - - 3 4 1 - - 2 14 16 5 - 

2 Point Barrow, Plover Islands - - 2 - - 2 6 13 - - - 1 10 

3 ERA 3 - - - 2 - - - - 7 2 - - - 

4 ERA 4 - - - - - - - - 3 1 - - - 

6 ERA 6 2 3 6 2 8 12 20 22 - 3 18 39 40 

10 Ledyard Bay Spectacled Eider Critical 

Habitat 1 - - 8 8 2 1 1 11 38 22 4 - 

11 Wrangel Island 12nmi Buffer 2 1 1 1 1 1 - - - 1 1 - - 

13 ERA 13 - - - - - - - - - - - - - 

14 Cape Thompson Seabird Colony Area - - - 2 1 - - - 16 6 1 - - 

15 Cape Lisburne Seabird Colony Area - - - 4 3 - - - 22 19 4 - - 

16 ERA 16 - - - 1 - - - - 7 2 - - - 

18 ERA 18 3 1 - 16 7 1 - - 42 20 5 1 - 

19 Chukchi Spring Lead 1 - - - - - - - - 1 - - - - 

20 Chukchi Spring Lead 2 - - - - - - - - - 3 1 - - 

21 Chukchi Spring Lead 3 - - - - - - - - - 2 3 - - 

22 Chukchi Spring Lead 4 - - - - 1 - - - - - 4 4 - 

23 Chukchi Spring Lead 5 - - - - - - - - - - - 2 2 

24 Beaufort Spring Lead 6 - 1 1 - - 2 3 3 - - 1 1 4 

25 Beaufort Spring Lead 7 - 2 4 - 1 4 6 5 - - 1 2 4 

26 Beaufort Spring Lead 8 - - - - - - 1 1 - - - - 1 

27 Beaufort Spring Lead 9 - - - - - - - 1 - - - - 1 

29 Ice/Sea Segment 1 - - 1 - - 1 3 6 - - - 1 6 

30 Ice/Sea Segment 2 - - 1 - - 1 4 4 - - 1 1 2 

31 Ice/Sea Segment 3 - - 1 - - 1 3 3 - - - - 1 

32 Ice/Sea Segment 4 - - - - - - 1 2 - - - - - 

35 ERA 35 5 7 10 3 10 19 24 23 - 2 24 62 52 

36 ERA 36 5 4 3 18 27 11 4 1 5 39 51 17 3 

38 Pt. Hope Subsistence Area - - - 2 1 - - - 8 6 2 - - 

39 Point Lay Subsistence Area - - - 4 5 2 1 - 2 19 16 3 - 

40 Wainwright Subsistence Area 1 1 1 4 9 6 4 4 1 10 25 29 9 

41 Barrow Subsistence Area 1 - - - - - - - - - - - 1 1 

42 Barrow Subsistence Area 2 - - 1 - - 1 4 14 - - 1 2 11 

45 ERA 45 - - - 3 2 - - - 26 13 3 - - 

46 Herald Shoal Polynya 7 3 1 22 10 3 1 - 3 6 4 1 - 

47 Ice/Sea Segment 10 11 5 2 22 31 9 2 1 1 6 12 5 1 

48 Ice/Sea Segment 11 8 17 20 3 18 49 22 10 - 5 22 20 11 

49 Hanna’s Shoal Polynya 10 23 50 2 10 29 34 23 - 4 12 21 19 

50 Ice/Sea Segment 12 4 8 9 1 7 19 17 8 - 2 15 41 16 

51 Ice/Sea Segment 13 2 4 5 1 4 9 15 9 - 1 8 38 29 

52 Ice/Sea Segment 14 1 3 5 - 1 5 11 30 - - 2 6 30 

53 Ice/Sea Segment 15 - 1 3 - 1 3 5 7 - - 1 2 4 

54 Ice/Sea Segment 16a - 1 3 - 1 3 6 8 - - 1 2 4 

55 Ice/Sea Segment 17 - - - - - 1 2 2 - - - - 1 

56 ERA 56 8 16 24 2 11 42 43 16 - 2 20 57 28 

58 Ice/Sea Segment 20a - - 1 - - - 1 5 - - - - 3 

59 ERA 59 - - - 1 - - - - 2 1 - - - 

60 Ice/Sea Segment 22 - - - - - - - 2 - - - - 1 

61 ERA 61 - - - - - - - - 3 1 - - - 
BOEMRE Sale 193 Revised Draft SEIS 

B16 Appendix B 

ID Environmental Resource Area Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

62 Ice/Sea Segment 24a - - - - - - - 1 - - - - 1 

63 ERA 63 3 2 1 - - - 1 2 - - - 1 1 

64 Peard Bay 1 2 4 - 2 6 13 12 - - 4 18 25 

65 Smith Bay - - - - - - 1 2 - - - - 1 

66 ERA 66 - 1 4 - 1 4 6 7 - - 1 2 3 

67 Herschel Island - - - - - - - 1 - - - - - 

68 Harrison Bay - - - - - - - 1 - - - - - 

69 Harrison Bay/Colville Delta - - - - - - - 1 - - - - 1 

70 ERA 70 9 10 8 - 2 4 2 1 - - 1 2 1 

76 ERA 76 - - - - - - - 1 - - - - 1 

79 ERA 79 - - - - - - - 1 - - - - - 

82 ERA 82 - - - - - - - - 1 - - - - 

83 Kaktovik ERA - - - - - - 1 3 - - - - 2 

99 ERA 99 5 5 3 21 36 15 4 1 6 54 71 19 3 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. . Rows with all values less than 0.5 percent 

are not shown. 

Table B-9. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location that 

will contact a certain land segment within 60 days during summer (Chukchi Sea Sale 193, 

Table A.2-34). 

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA

13 

8 E. Wrangel Island, Skeletov - - - - - - - - - - - - - 

27 Laguna Nut, Rigol' - - - 1 - - - - 1 - - - - 

32 Mys Dzhenretlen, Eynenekvyk - - - - - - - - 1 - - - - 

33 Neskan, Laguna Neskan - - - - - - - - 1 - - - - 

34 Tepken, Memino - - - - - - - - 1 - - - - 

35 Enurmino, Mys Neten - - - - - - - - 2 - - - - 

36 Mys Serdtse-Kamen - - - - - - - - 2 - - - - 

37 Chegitun, Utkan - - - - - - - - 2 - - - - 

38 Enmytagyn, Inchoun, Mitkulen - - - - - - - - 1 - - - - 

39 Cape Dezhnev, Naukan, Uelen - - - - - - - - 1 - - - - 

63 Asikpak Lag., Cape Seppings - - - - - - - - - - - - - 

64 Kukpuk River, Point Hope - - - - - - - - 3 2 - - - 

65 Buckland, Cape Lisburne - - - 1 - - - - 2 2 1 - - 

66 Ayugatak Lagoon - - - - - - - - 1 1 1 - - 

67 Cape Sabine, Pitmegea River - - - - - - - - 1 1 - - - 

68 Agiak Lagoon, Punuk Lagoon - - - - - - - - - 1 - - - 

69 Cape Beaufort, Omalik Lagoon - - - - - - - - - 1 - - - 

70 Kuchaurak and Kuchiak Creek - - - - - - - - - 1 - - - 

71 Kukpowruk River, Sitkok Point - - - - - - - - - 2 1 - - 

72 Point Lay, Siksrikpak Point - - - - - - - - - 3 1 - - 

73 Tungaich Point, Tungak Creek - - - - 1 - - - - 4 2 - - 

74 Kasegaluk Lagoon, Solivik Isl. - - - 1 1 - - - - 3 4 1 - 

75 Akeonik, Icy Cape - - - 1 1 - - - - 2 4 1 - 

76 Avak Inlet, Tunalik River - - - - - - - - - - 1 1 - 

77 Nivat Point, Nokotlek Point - - - - 1 - - - - 1 2 1 - 

78 Point Collie, Sigeakruk Point - - - - 1 - - - - - 2 2 - 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B17

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA

13 

79 Point Belcher, Wainwright - - - - 1 1 1 1 - - 3 6 1 

80 Eluksingiak Point, Kugrua Bay - - - - - 1 - 1 - - 1 4 2 

81 Peard Bay, Point Franklin - - - - 1 1 - - - - 1 4 1 

82 Skull Cliff - - - - - - - - - - - 2 3 

83 Nulavik, Loran Radio Station - - 1 - - 1 1 1 - - - 2 3 

84 Will Rogers & Wiley Post Mem. - - - - - - 2 2 - - - 2 6 

85 Barrow, Browerville, Elson Lag. - - - - - - 3 8 - - - 1 11 

86 Dease Inlet, Plover Islands - - - - - - 1 2 - - - - 2 

87 Igalik & Kulgurak Island - - - - - - - 1 - - - - 1 

88 Cape Simpson, Piasuk River - - - - - - - 1 - - - - - 

89 Ikpikpuk River, Point Poleakoon - - - - - - - 1 - - - - - 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. . Rows with all values less than 0.5 percent 

are not shown. 

Table B-10. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain land segment within 360 days during summer (Chukchi Sea Sale 

193, Table A.2-36). 

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA1

3 

8 E. Wrangel Island, Skeletov - - - - - - - 1 - - - - 1 

26 Ekugvaam, Kepin, Pil'khin - - - - - - - 1 - - - - - 

27 Laguna Nut, Rigol' - - - 1 - - - - 1 - - - - 

28 Vankarem,Vankarem Laguna - - - - - - - - 1 - - - - 

29 Mys Onman, Vel'may - - - - - - - - 1 - - - - 

30 Nutepynmin, Pyngopil'gyn - - - - - - - - 1 - - - - 

31 Alyatki, Zaliv Tasytkhin - - - - - - - - 1 - - - - 

32 Mys Dzhenretlen, Eynenekvyk - - - - - - - - 2 - - - - 

33 Neskan, Laguna Neskan - - - - - - - - 2 1 - - - 

34 Tepken, Memino - - - - - - - - 2 - - - - 

35 Enurmino, Mys Neten - - - - - - - - 3 1 - - - 

36 Mys Serdtse-Kamen - - - - - - - - 2 - - - - 

37 Chegitun, Utkan - - - - - - - - 2 - - - - 

38 Enmytagyn, Inchoun, Mitkulen - - - - - - - - 1 - - - - 

39 Cape Dezhnev, Naukan, Uelen - - - - - - - - 1 - - - - 

63 Asikpak Lag., Cape Seppings - - - - - - - - - - - - - 

64 Kukpuk River, Point Hope - - - - - - - - 3 2 - - - 

65 Buckland, Cape Lisburne - - - 1 1 - - - 2 2 1 - - 

66 Ayugatak Lagoon - - - - - - - - 1 1 1 - - 

67 Cape Sabine, Pitmegea River - - - - - - - - 1 1 - - - 

68 Agiak Lagoon, Punuk Lagoon - - - - - - - - - 1 - - - 

69 Cape Beaufort, Omalik Lagoon - - - - - - - - - 1 - - - 

70 Kuchaurak and Kuchiak Creek - - - - - - - - - 1 - - - 

71 Kukpowruk River, Sitkok Point - - - - - - - - - 2 1 - - 

72 Point Lay, Siksrikpak Point - - - - - - - - - 3 1 - - 

73 Tungaich Point, Tungak Creek - - - 1 1 - - - - 4 2 - - 

74 Kasegaluk Lagoon, Solivik Isl. - - - 1 1 - - - - 3 4 1 - 

75 Akeonik, Icy Cape - - - 1 1 - - - - 2 4 1 - 

76 Avak Inlet, Tunalik River - - - - - - - - - - 1 1 - 

77 Nivat Point, Nokotlek Point - - - - 1 - - - - 1 2 1 - 

78 Point Collie, Sigeakruk Point - - - - 1 - - - - - 3 3 - 
BOEMRE Sale 193 Revised Draft SEIS 

B18 Appendix B 

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA1

3 

79 Point Belcher, Wainwright - - - - 1 2 1 1 - - 3 6 2 

80 Eluksingiak Point, Kugrua Bay - - - - 1 1 1 1 - - 2 5 3 

81 Peard Bay, Point Franklin - - - - 1 1 1 - - - 2 4 2 

82 Skull Cliff - - - - - - - 1 - - 1 3 3 

83 Nulavik, Loran Radio Station - - 1 - 1 1 1 1 - - - 2 3 

84 Will Rogers & Wiley Post Mem. - 1 2 - - 2 5 5 - - 1 3 7 

85 Barrow, Browerville, Elson Lag. - - 1 - - 1 5 10 - - - 2 13 

86 Dease Inlet, Plover Islands - - - - - - 1 3 - - - - 3 

87 Igalik & Kulgurak Island - - - - - - - 2 - - - - 1 

88 Cape Simpson, Piasuk River - - - - - - - 1 - - - - - 

89 Ikpikpuk River Point Poleakoon - - - - - - - 1 - - - - - 

91 Lonely, Pitt Point, Pogik Bay - - - - - - - 1 - - - - 1 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. . Rows with all values less than 0.5 percent 

are not shown. 

Table B-11. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain grouped land segment within 60 days during summer (Chukchi Sea 

Sale 193, Table A.2-40). 

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

84 Wrangel Is Nat Res Natural World 

Heritage Site 1 1 - 1 1 - - - - - - - - 

88 Alaska Maritime National Wildlife Refuge - - - 1 - - - - 3 2 1 - - 

89 National Petroleum Reserve Alaska - - 1 - 2 3 2 8 - 1 7 14 13 

90 Kasegaluk Lagoon Special Use Area - - - - 1 - - - - 1 3 2 - 

91 Teshekpuk Lake Special Use Area - - - - - - - 1 - - - - - 

95 Russia Chukchi Coast 1 1 - 4 2 - - - 12 3 1 - - 

96 United States Chukchi Coast 1 1 1 5 9 6 4 5 9 24 26 26 17 

97 United States Beaufort Coast - - 1 - - - 4 14 - - - 1 15 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. P = Pipeline. Rows with all values less than 

0.5 percent are not shown. 

Table B-12. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain grouped land segment within 360 days during summer (Chukchi 

Sea Sale 193, Table A.2-42). 

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

84 Wrangel Is Nat Res Natural World 

Heritage Site 1 1 1 1 1 1 1 3 - 1 1 - 2 

88 Alaska Maritime National Wildlife Refuge - - - 1 1 - - - 3 2 1 - - 

89 National Petroleum Reserve Alaska - 1 2 1 3 4 5 12 - 2 8 17 16 

90 Kasegaluk Lagoon Special Use Area - - - - 1 - - - - 1 3 2 - 

91 Teshekpuk Lake Special Use Area - - - - - - 1 3 - - - - 1 

95 Russia Chukchi Coast 2 2 1 6 2 1 1 6 19 6 1 1 3 

96 United States Chukchi Coast 1 2 3 6 11 8 9 9 9 25 28 31 20 

97 United States Beaufort Coast - - 2 - - 2 7 20 - - - 3 19 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. Rows with all values less than 0.5 percent 

are not shown. 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B19

Table B-13. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain boundary segment within 60 days during summer (Chukchi Sea 

Sale 193, Table A.2-46). 

ID Boundary Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

2 Bering Strait - - - - - - - - 1 - - - - 

16 Chukchi Sea 1 1 1 - - - - - - - - - - 

17 Chukchi Sea 1 1 1 - - 1 - - - - - - - 

18 Chukchi Sea 1 3 4 - 2 3 3 2 - 1 2 1 1 

19 Chukchi Sea 1 2 3 - 1 1 3 2 - - 1 1 1 

20 Chukchi Sea 1 1 1 - - - 1 1 - - - - - 

21 Chukchi Sea - - 1 - - - 1 1 - - - - - 

22 Chukchi Sea - - - - - - - 1 - - - - - 

23 Beaufort Sea - - - - - - 1 1 - - - - - 

24 Beaufort Sea - - - - - - - 1 - - - - 1 

25 Beaufort Sea - - - - - - - 1 - - - - - 

26 Beaufort Sea - - - - - - 1 1 - - - - 1 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. Rows with all values less than 0.5 percent 

are not shown. 

Table B-14. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain boundary segment within 360 days during summer (Chukchi Sea 

Sale 193, Table A.2-48). 

ID Boundary Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

2 Bering Strait - - - - - - - - 1 - - - - 

16 Chukchi Sea 2 1 1 - - - - - - - - - - 

17 Chukchi Sea 1 2 3 - 1 2 1 - - - 1 - - 

18 Chukchi Sea 3 5 8 1 5 8 9 6 - 3 7 7 5 

19 Chukchi Sea 3 7 10 1 5 8 12 8 - 3 6 9 8 

20 Chukchi Sea 4 7 8 1 5 8 6 4 - 1 5 6 6 

21 Chukchi Sea 1 1 4 - - 2 2 3 - - 1 1 2 

22 Chukchi Sea - - 1 - - - 1 1 - - - 1 1 

23 Beaufort Sea 1 1 3 - - 1 2 2 - - - 1 1 

24 Beaufort Sea - - 1 - - - 1 1 - - - - 1 

25 Beaufort Sea - 1 1 - - 2 1 1 - - 1 2 1 

26 Beaufort Sea - 1 2 - - 1 3 2 - - - 1 2 

27 Beaufort Sea - - 1 - - - 1 2 - - - - 1 

28 Beaufort Sea - - - - - - - 1 - - - - - 

30 Beaufort Sea - - - - - - - 1 - - - - - 

31 Beaufort Sea - - - - - - - 1 - - - - - 

34 Beaufort Sea - - - - - - 1 1 - - - - 1 

35 Beaufort Sea - - - - - - - 1 - - - - 1 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. Rows with all values less than 0.5 percent

are not shown. 

Table B-15. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain environmental resource area within 60 days during winter 

(Chukchi Sea Sale 193, Table A.2-52). 

ID Environmental Resource Area Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

— LAND 2 1 - 6 4 1 1 2 10 18 10 8 6 

1 Kasegaluk Lagoon - - - 1 2 1 - - - 5 4 1 - 

4 ERA 4 - - - - - - - - 5 - - - - 
BOEMRE Sale 193 Revised Draft SEIS 

B20 Appendix B 

ID Environmental Resource Area Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

6 ERA 6 - 1 1 1 2 2 1 3 - 1 5 11 8 

10 Ledyard Bay Spectacled Eider Critical 

Habitat - - - 2 3 1 - - 2 11 6 1 - 

11 Wrangel Island 3 1 - 1 1 - - - - - - - - 

14 Cape Thompson Seabird Colony Area - - - - - - - - 2 1 - - - 

15 Cape Lisburne Seabird Colony Area - - - - 1 - - - 3 4 1 - - 

16 ERA 16 - - - - - - - - 3 - - - - 

19 Chukchi Spring Lead 1 - - - - - - - - 1 1 - - - 

20 Chukchi Spring Lead 2 - - - - 1 - - - 1 7 2 1 - 

21 Chukchi Spring Lead 3 - - - 2 2 - - - 1 8 5 1 - 

22 Chukchi Spring Lead 4 - - - 2 3 1 - - - 4 9 10 - 

23 Chukchi Spring Lead 5 - - - - - - 1 - - - 1 3 3 

24 Beaufort Spring Lead 6 - - - - - - - 2 - - - - 2 

25 Beaufort Spring Lead 7 - - - - - - - 2 - - - - 2 

26 Beaufort Spring Lead 8 - - - - - - - 1 - - - - - 

38 Pt Hope Subsistence Area - - - - - - - - 2 1 - - - 

39 Point Lay Subsistence Area - - - 3 4 1 - - 1 20 9 1 - 

40 Wainwright Subsistence Area - - - 3 4 1 - - - 11 11 14 1 

41 Barrow Subsistence Area 1 - - - - - - - 1 - - - 1 5 

45 ERA 45 - - - - - - - - 7 2 1 - - 

46 Herald Shoal Polynya 8 1 - 18 1 - - - 4 2 - - - 

47 Ice/Sea Segment 10 6 3 1 17 25 4 1 - 1 10 7 2 - 

48 Ice/Sea Segment 11 7 13 12 10 31 49 16 5 2 22 44 22 11 

49 Hanna's Shoal Polynya 10 26 64 6 21 43 45 25 1 11 22 19 25 

50 Ice/Sea Segment 12 1 3 2 1 5 8 6 2 - 4 14 40 13 

51 Ice/Sea Segment 13 - 1 1 - 1 2 2 2 - 1 4 29 18 

52 Ice/Sea Segment 14 - - - - - - 1 17 - - - 3 29 

53 Ice/Sea Segment 15 - - - - - - - 2 - - - - 1 

59 ERA 59 - - - 1 - - - - 2 - - - - 

61 ERA 61 - - - - - - - - 3 - - - - 

64 Peard Bay - - - - - 1 1 1 - - 1 1 2 

70 ERA 70 - 1 1 - - 1 1 - - - - - - 

99 ERA 99 2 1 - 7 13 4 1 - 1 15 19 5 1 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. Rows with all values less than 0.5 percent

are not shown. 

Table B-16. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain environmental resource area within 360 days during winter 

(Chukchi Sea Sale 193, Table A.2-54). 

ID Environmental Resource Area Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA

8 

LA 

9 

LA 

10 

LA 

11 

LA

12 

LA 

13 

P 

1 

— LAND 9 7 6 21 16 9 9 13 36 35 24 26 20 43 

1 Kasegaluk Lagoon - - - 5 6 1 - - 1 11 8 3 - 1 

2 Point Barrow, Plover Islands 2 3 4 1 2 3 4 6 - 1 2 3 5 - 

4 ERA 4 - - - - - - - - 5 - - - - 9 

6 ERA 6 1 2 2 4 8 5 6 9 1 7 13 23 17 1 

10 Ledyard Bay Spectacled Eider Critical 

Habitat - - - 5 7 1 - - 3 16 10 2 - 2 

11 Wrangel Island 4 2 - 1 1 - - - - - - - - - 

14 Cape Thompson Seabird Colony Area - - - - - - - - 2 1 - - - 11 

15 Cape Lisburne Seabird Colony Area - - - 1 1 - - - 4 5 1 1 - 12 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B21

ID Environmental Resource Area Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA

8 

LA 

9 

LA 

10 

LA 

11 

LA

12 

LA 

13 

P 

1 

16 ERA 16 - - - 2 - - - - 12 2 - - - 12 

18 ERA 18 - - - - - - - - - - - - - - 

19 Chukchi Spring Lead 1 - - - - - - - - 2 1 - - - 13 

20 Chukchi Spring Lead 2 - - - 1 1 - - - 1 8 3 1 - 1 

21 Chukchi Spring Lead 3 - - - 3 4 1 - - 1 10 7 1 - 1 

22 Chukchi Spring Lead 4 1 - - 4 6 2 - - 1 7 12 14 1 1 

23 Chukchi Spring Lead 5 - - - - - 1 1 1 - - 2 6 5 - 

24 Beaufort Spring Lead 6 - - - - - - 1 4 - - - 2 5 - 

25 Beaufort Spring Lead 7 - 1 1 - - 1 1 4 - - - 2 5 - 

26 Beaufort Spring Lead 8 - - - - - - - 1 - - - - 1 - 

27 Beaufort Spring Lead 9 - - - - - - - 1 - - - - 1 - 

28 Beaufort Spring Lead 10 - - - - - - - 1 - - - - - - 

29 Ice/Sea Segment 1 - - - - - 1 1 1 - - - - - - 

30 Ice/Sea Segment 2 - 1 1 - - 1 1 1 - - - - 1 - 

31 Ice/Sea Segment 3 - 1 1 - - 1 1 1 - - - - 1 - 

32 Ice/Sea Segment 4 - - 1 - - 1 - - - - - - - - 

35 ERA 35 2 4 4 1 5 6 5 5 - 2 5 7 6 - 

36 ERA 36 1 2 1 2 3 2 1 - - 2 3 3 1 - 

38 Pt. Hope Subsistence Area - - - - - - - - 2 1 - - - 14 

39 Point Lay Subsistence Area 1 - - 6 7 1 - - 2 25 13 3 - 1 

40 Wainwright Subsistence Area 1 1 1 7 10 3 1 1 1 18 19 20 3 1 

41 Barrow Subsistence Area 1 - - - - - - 1 2 - - 1 3 6 - 

42 Barrow Subsistence Area 2 2 3 3 1 3 3 3 3 - 1 2 3 3 - 

45 ERA 45 - - - - 1 - - - 7 3 1 1 - 19 

46 Herald Shoal Polynya 8 1 - 19 2 - - - 4 2 1 - - 2 

47 Ice/Sea Segment 10 7 4 2 19 28 6 1 - 2 13 11 5 1 1 

48 Ice/Sea Segment 11 11 20 18 13 37 54 24 14 3 28 50 35 23 2 

49 Hanna's Shoal Polynya 15 33 68 10 29 51 54 38 2 19 33 33 38 1 

50 Ice/Sea Segment 12 4 6 5 3 11 12 10 4 1 8 20 46 17 1 

51 Ice/Sea Segment 13 2 2 2 2 6 5 5 5 - 4 10 37 22 - 

52 Ice/Sea Segment 14 2 4 5 1 3 5 6 21 - 2 3 7 32 - 

53 Ice/Sea Segment 15 - 1 2 - 1 2 2 4 - 1 1 1 3 - 

54 Ice/Sea Segment 16a - 1 2 - 1 1 1 2 - - - - 1 - 

55 Ice/Sea Segment 17 - 1 1 - - 1 - - - - - - - - 

56 ERA 56 4 8 10 2 6 9 11 9 - 3 5 8 10 - 

58 Ice/Sea Segment 20a - - - - - - 1 1 - - - - 1 - 

59 ERA 59 - - - 2 - - - - 3 1 - - - 2 

61 ERA 61 - - - - - - - - 4 - - - - 7 

63 ERA 63 1 2 1 - 1 1 1 1 - - 1 1 1 - 

64 ERA 64 1 1 2 1 3 3 4 4 - 2 4 8 7 - 

66 ERA 66 1 2 2 1 1 1 1 2 - 1 1 1 2 - 

69 ERA 69 - - - - - - - 1 - - - - - - 

70 ERA 70 1 2 2 - 2 3 3 2 - 1 3 2 3 - 

99 ERA 99 4 5 3 11 20 10 4 2 2 21 27 14 4 2 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. Rows with all values less than 0.5 percent

are not shown. 

Table B-17. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain land segment within 60 days during winter (Chukchi Sea Sale 193, 

Table A.2-58). 

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA

13 

8 E. Wrangel Island, Skeletov 1 - - - - - - - - - - - - 

27 Laguna Nut, Rigol' - - - 1 - - - - 1 - - - - 

30 Nutepynmin, Pyngopil'gyn - - - - - - - - 1 - - - - 

32 Mys Dzhenretlen, Eynenekvyk - - - - - - - - 1 - - - - 

33 Neskan, Laguna Neskan - - - - - - - - - - - - - 
BOEMRE Sale 193 Revised Draft SEIS 

B22 Appendix B 

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA

13 

34 Tepken, Memino - - - - - - - - 1 - - - - 

35 Enurmino, Mys Neten - - - - - - - - 2 - - - - 

36 Mys Serdtse-Kamen - - - - - - - - 1 - - - - 

37 Chegitun, Utkan - - - - - - - - 1 - - - - 

38 Enmytagyn, Inchoun, Mitkulen - - - - - - - - - - - - - 

39 Cape Dezhnev, Naukan, Uelen - - - - - - - - - - - - - 

64 Kukpuk River, Point Hope - - - - - - - - - - - - - 

65 Buckland, Cape Lisburne - - - - - - - - 1 - - - - 

70 Kuchaurak and Kuchiak Creek - - - - - - - - - 1 - - - 

71 Kukpowruk River, Sitkok Point - - - - - - - - - 2 - - - 

72 Point Lay, Siksrikpak Point - - - - - - - - - 3 1 - - 

73 Tungaich Point, Tungak Creek - - - - 1 - - - - 4 1 - - 

74 Kasegaluk Lagoon, Solivik Isl. - - - 1 1 - - - - 3 2 - - 

75 Akeonik, Icy Cape - - - 1 1 - - - - 2 2 - - 

76 Avak Inlet, Tunalik River - - - - - - - - - - - - - 

78 Point Collie, Sigeakruk Point - - - - - - - - - - - 1 - 

79 Point Belcher, Wainwright - - - - - - - - - - 1 2 - 

80 Eluksingiak Point, Kugrua Bay - - - - - - - - - - 1 2 - 

81 Peard Bay, Point Franklin - - - - - - - - - - - - - 

82 Skull Cliff - - - - - - - - - - - - - 

83 Nulavik, Loran Radio Station - - - - - - - - - - - - - 

84 Will Rogers & Wiley Post Mem. - - - - - - - - - - - 1 2 

85 Barrow, Browerville, Elson Lag. - - - - - - - 1 - - - - 3 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. Rows with all values less than 0.5 percent 

are not shown. 

Table B-18. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain land segment within 360 days during winter (Chukchi Sea Sale 193, 

Table A.2-60). 

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

7 E. Wrangel Island 1 - - - - - - - - - - - - 

8 E. Wrangel Island, Skeletov 1 1 - - - - - - - - - - - 

24 - - - - - - - - - - - - - 

25 Ostrov Leny, Yulinu - - - 1 - - - - - - - - - 

26 Ekugvaam, Kepin, Pil'khin - - - 1 - - - - - - - - - 

27 Laguna Nut, Rigol' 1 - - 1 - - - - 1 - - - - 

28 Vankarem,Vankarem Laguna - - - 1 - - - - 1 - - - - 

29 Mys Onman, Vel'may - - - 1 - - - - 1 - - - - 

30 Nutepynmin, Pyngopil'gyn - - - 2 - - - - 2 - - - - 

31 Alyatki, Zaliv Tasytkhin - - - 1 - - - - 2 - - - - 

32 Mys Dzhenretlen, Eynenekvyk - - - 1 - - - - 3 - - - - 

33 Neskan, Laguna Neskan - - - 1 - - - - 3 - - - - 

34 Tepken, Memino - - - - - - - - 4 1 - - - 

35 Enurmino, Mys Neten - - - 1 - - - - 5 1 - - - 

36 Mys Serdtse-Kamen - - - - - - - - 4 - - - - 

37 Chegitun, Utkan - - - - - - - - 3 - - - - 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B23

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

38 Enmytagyn, Inchoun, Mitkulen - - - - - - - - 2 - - - - 

39 Cape Dezhnev, Naukan, Uelen - - - - - - - - 1 - - - - 

64 Kukpuk River, Point Hope - - - - - - - - 1 - - - - 

65 Buckland, Cape Lisburne - - - - - - - - 1 - - - - 

67 Cape Sabine, Pitmegea River - - - - - - - - - - - - - 

70 Kuchaurak and Kuchiak Creek - - - - - - - - - 1 - - - 

71 Kukpowruk River, Sitkok Point - - - - - - - - - 3 1 - - 

72 Point Lay, Siksrikpak Point - - - 1 1 - - - - 4 1 - - 

73 Tungaich Point, Tungak Creek - - - 1 1 - - - 1 5 2 - - 

74 Kasegaluk Lagoon, Solivik Isl. - - - 2 2 - - - - 4 3 1 - 

75 Akeonik, Icy Cape - - - 2 2 - - - - 3 3 1 - 

76 Avak Inlet, Tunalik River - - - - 1 - - - - 1 1 - - 

77 Nivat Point, Nokotlek Point - - - - - - - - - - - - - 

78 Point Collie, Sigeakruk Point - - - 1 1 - - - - 2 2 3 - 

79 Point Belcher, Wainwright - - - - 1 - - - - 1 2 3 - 

80 Eluksingiak Point, Kugrua Bay - - - - 1 - - - - 1 1 4 1 

81 Peard Bay, Point Franklin - - - - 1 1 - - - 1 1 1 - 

82 Skull Cliff - - - - - 1 1 - - - 1 2 1 

83 Nulavik, Loran Radio Station - - - - 1 1 1 1 - - 1 2 2 

84 Will Rogers & Wiley Post Mem. - - - - - - 1 1 - - - 2 3 

85 Barrow, Browerville, Elson Lag. - - - - - - 2 5 - - 1 4 7 

86 Dease Inlet, Plover Islands - - - - - - 1 1 - - - 1 1 

87 Igalik & Kulgurak Island 2 2 2 1 1 2 1 1 - 1 1 1 1 

88 Cape Simpson, Piasuk River 1 1 1 - 1 1 - 1 - - - - - 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. Rows with all values less than 0.5 percent 

are not shown. 

Table B-19. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain grouped land segment within 60 days during winter (Chukchi Sea 

Sale 193, Table A.2-64). 

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

84 Wrangel Is Nat Res Natural World Heritage 

Site 1 - - - - - - - - - - - - 

88 Alaska Maritime National Wildlife Refuge - - - - - - - - 1 - - - - 

89 National Petroleum Reserve Alaska - - - - 1 1 - - - 1 2 3 1 

90 Kasegaluk Lagoon Special Use Area - - - - - - - - - 1 1 - - 

95 Russia Chukchi Coast 2 1 - 3 - - - - 8 1 - - - 

96 United States Chukchi Coast - - - 3 4 1 - 1 2 17 9 7 3 

97 United States Beaufort Coast - - - - - - - 1 - - - - 3 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. Rows with all values less than 0.5 percent 

are not shown. 
BOEMRE Sale 193 Revised Draft SEIS 

B24 Appendix B 

Table B-20. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain grouped land segment within 360 days during winter (Chukchi Sea 

Sale 193, Table A.2-66). 

ID Land Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA 

13 

84 Wrangel Is Nat Res Nat World Heritage 

Site 2 1 - 1 1 - - 1 - - - 1 - 

88 Alaska Maritime National Wildlife Refuge - - - - - - - - 1 - - - - 

89 National Petroleum Reserve Alaska 3 4 4 3 7 6 5 5 - 5 9 13 7 

90 Kasegaluk Lagoon Special Use Area - - - 1 1 - - - - 1 1 1 - 

91 Teshekpuk Lake Special Use Area - - - - 1 - - 1 - - - - 1 

95 Russia Chukchi Coast 6 2 - 12 2 1 - 1 32 5 1 1 1 

96 United States Chukchi Coast 1 1 1 8 12 5 3 3 4 28 21 20 9 

97 United States Beaufort Coast 2 3 4 1 3 4 6 9 - 2 3 6 10 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. Rows with all values less than 0.5 percent

are not shown. 

Table B-21. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain boundary segment within 60 days during winter (Chukchi Sea Sale 

193, Table A.2-70). 

ID Boundary Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA

13 

2 Bering Strait - - - - - - - - 1 - - - - 

15 Chukchi Sea 1 1 - - - - - - - - - - - 

16 Chukchi Sea 1 1 - - 1 1 - - - - - - - 

17 Chukchi Sea 1 1 1 - - - - - - - - - - 

18 Chukchi Sea 5 9 10 1 5 8 7 4 - 2 5 3 3 

19 Chukchi Sea 5 11 12 1 5 9 9 5 - 2 3 3 5 

20 Chukchi Sea 2 5 7 - 4 5 6 6 - 1 2 2 3 

21 Chukchi Sea - 1 2 - 1 1 2 2 - - - - 1 

22 Chukchi Sea - - 1 - - 1 1 2 - - - - 1 

23 Beaufort Sea - - - - - - 1 1 - - - - 1 

24 Beaufort Sea - - - - - - 1 1 - - - - 1 

25 Beaufort Sea - - - - - - - 1 - - - - - 

26 Beaufort Sea - - - - - - - 1 - - - - - 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. Rows with all values less than 0.5 percent

are not shown. 

Table B-22. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact a certain boundary segment within 360 days during winter (Chukchi Sea 

Sale 193, Table A.2-72). 

ID Boundary Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA

13 

2 Bering Strait - - - - - - - - 1 - - - - 

15 Chukchi Sea 2 2 2 - 1 1 1 - - - 1 - 1 

16 Chukchi Sea 2 3 1 - 2 2 1 - - 1 1 1 1 

17 Chukchi Sea 2 2 2 1 1 1 1 1 - 1 1 1 1 

18 Chukchi Sea 7 12 13 2 7 10 9 6 - 5 8 6 6 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B25

ID Boundary Segment Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA 

8 

LA 

9 

LA 

10 

LA

11 

LA

12 

LA

13 

19 Chukchi Sea 10 17 18 4 12 16 17 10 - 7 10 10 11 

20 Chukchi Sea 5 10 13 1 9 11 12 11 - 4 6 6 8 

21 Chukchi Sea 1 2 3 - 2 2 3 4 - 1 2 2 2 

22 Chukchi Sea - - 1 - - 1 2 3 - - 1 1 2 

23 Beaufort Sea 1 1 2 1 1 2 3 4 - 1 1 1 3 

24 Beaufort Sea - 1 1 - 1 1 2 3 - - 1 1 2 

25 Beaufort Sea - - - - - - - 2 - - 1 - 1 

26 Beaufort Sea - 1 1 - 1 1 1 2 - - 1 1 1 

27 Beaufort Sea - - 1 - - 1 2 2 - - - 1 2 

28 Beaufort Sea - - - - - - - 1 - - - - - 

29 Beaufort Sea - - - - - - - 1 - - - - - 

30 Beaufort Sea - - - - - - - 1 - - - - 1 

Notes: ** = Greater than 99.5 percent; - = less than 0.5 percent; LA = Launch Area. Rows with all values less than 0.5 percent

are not shown. 

Table B-23. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting from a given 

location that will contact a portion of Opilio Arctic EFH area within 3, 10, 30, 60, 180 or 360 

days during summer. 

Days LA 

1 

LA 

2 

LA 

3 

LA 

4 

LA 

5 

LA 

6 

LA 

7 

LA

8 

LA 

9 

LA 

10 

LA 

11 

LA 

12 

LA 

13 

3 _ _ _ _ _ _ _ _ <0.5->99.5 _ _ _ _ 

10 _ _ _ _ _ _ _ _ <0.5->99.5 <0.5-1 _ _ _ 

30 _ _ _ <0.5-1 _ _ _ _ <0.5->99.5 <0.5-2 _ _ _ 

60 _ _ _ <0.5-1 _ _ _ _ <0.5->99.5 <0.5-2 _ _ _ 

180 _ _ _ <0.5-1 _ _ _ _ <0.5->99.5 <0.5-2 _ _ _ 

360 _ _ _ <0.5-1 _ _ _ _ <0.5->99.5 <0.5-2 _ _ _ 

Notes: - = less than 0.5 percent; LA = Launch Area. LA9 overlaps a portion of EFH.

Table B-24. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting from a given 

location that will contact a portion of Opilio Arctic EFH area within 3, 10, 30, 60, 180 or 360 

days during winter. 

Days LA 

1 

LA 

2 

LA 

3 

LA 

4 

LA 

5 

LA 

6 

LA 

7 

LA

8 

LA 

9 

LA 

10 

LA 

11 

LA 

12 

LA 

13 

3 _ _ _ _ _ _ _ _ <0.5->99.5 _ _ _ _ 

10 _ _ _ _ _ _ _ _ <0.5->99.5 _ _ _ _ 

30 _ _ _ _ _ _ _ _ <0.5->99.5 <0.5-1 _ _ _ 

60 _ _ _ <0.5-1 _ _ _ _ <0.5->99.5 <0.5-1 _ _ _ 

180 _ _ _ <0.5-1 _ _ _ _ <0.5->99.5 <0.5-1 _ _ _ 

360 _ _ _ <0.5-1 _ _ _ _ <0.5->99.5 <0.5-1 _ _ _ 

Notes: - = less than 0.5 percent; LA = Launch Area. LA9 overlaps a portion of EFH.
BOEMRE Sale 193 Revised Draft SEIS 

B26 Appendix B 

Table B-25. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting from a given 

location that will contact a portion of Safron Cod EFH area within 3, 10, 30, 60, 180 or 360 

days during summer. 

Days LA 

1 

LA 

2 

LA 

3 

LA 

4 

LA 

5 

LA 

6 

LA 

7 

LA

8 

LA 

9 

LA 

10 

LA 

11 

LA 

12 

LA 

13 

3 _ _ _ _ _ _ _ _ <0.5->99.5 <0.5-1 <0.5-2 <0.5-

>99.5 

<0.5-

>99.5 

10 _ _ _ _ _ _ _ _ <0.5->99.5 <0.5-2 <0.5-3 <0.5-

>99.5 

<0.5-

>99.5 

30 _ _ _ <0.5-1 <0.5-1 <0.5-1 <0.5-1 <0.5

-1 <0.5->99.5 <0.5-4 <0.5-7 <0.5-

>99.5 

<0.5-

>99.5 

60 <0.5-1 <0.5-1 <0.5-1 <0.5-2 <0.5-2 <0.5-3 <0.5-3 <0.5

-4 <0.5->99.5 <0.5-5 <0.5-9 <0.5-

>99.5 

<0.5-

>99.5 

180 <0.5-1 <0.5-1 <0.5-2 <0.5-2 <0.5-3 <0.5-4 <0.5-5 <0.5

-6 <0.5->99.5 <0.5-5 <0.5-9 <0.5-

>99.5 

<0.5-

>99.5 

360 <0.5-1 <0.5-1 <0.5-2 <0.5-2 <0.5-3 <0.5-4 <0.5-8 <0.5

-7 <0.5->99.5 <0.5-5 <0.5-9 <0.5-

>99.5 

<0.5-

>99.5 

Notes: - = less than 0.5 percent; LA = Launch Area. LAs 9, 12 and 13 overlaps a portion of EFH. 

Table B-26. Range of fractions of a Very Large Oil Spill (expressed as percentages) starting from a given 

location that will contact a portion of Safron Cod EFH area within 3, 10, 30, 60, 180 or 360 

days during winter. 

Days LA 

1 

LA 

2 

LA 

3 

LA 

4 

LA 

5 

LA 

6 

LA 

7 

LA 

8 

LA 

9 

LA 

10 

LA 

11 

LA 

12 

LA 

13 

3 _ _ _ _ _ _ _ _ <0.5-

>99.5 <0.5-1 <0.5-1 <0.5-

>99.5 

<0.5-

>99.5 

10 _ _ _ _ _ _ _ _ <0.5-

>99.5 <0.5-2 <0.5-2 <0.5-

>99.5 

<0.5-

>99.5 

30 _ _ _ <0.5-1 <0.5-1 _ _ <0.5-1 <0.5-

>99.5 <0.5-4 <0.5-4 <0.5-

>99.5 

<0.5-

>99.5 

60 _ _ <0.5-1 <0.5-2 <0.5-2 <0.5-1 <0.5-1 <0.5-2 <0.5-

>99.5 <0.5-6 <0.5-6 <0.5-

>99.5 

<0.5-

>99.5 

180 <0.5-1 <0.5-1 <0.5-1 <0.5-3 <0.5-5 <0.5-2 <0.5-2 <0.5-4 <0.5-

>99.5 <0.5-7 <0.5-8 <0.5-

>99.5 

<0.5-

>99.5 

360 <0.5-1 <0.5-1 <0.5-1 <0.5-3 <0.5-5 <0.5-2 <0.5-2 <0.5-4 <0.5-

>99.5 <0.5-7 <0.5-8 <0.5-

>99.5 

<0.5-

>99.5 

Notes: - = less than 0.5 percent; LA = Launch Area. LAs 9, 12 and 13 overlaps a portion of EFH. 

Table B-27. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact environmental resource area 74, 83 or 91within 60 days, during summer 

Chukchi Sea Sale 212/221 (USDOI, MMS, 2008a: Table A.3-4). 

ID Environmental Resource Area Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA

8 

LA 

9 

LA 

10 

LA 

11 

LA

12 

LA 

13 

74 Offshore Herald Island 4 1 1 2 2 2 1 - - - 1 2 1 

91 Hope Sea Valley 2 - - 3 1 - - - 1 1 1 - - 

Notes: Only results for ERA 74, 83 and 91 from USDOI, MMS (2008) are shown. Rows with all values<0.5 are not shown. - = 

less than 0.5 percent; LA = Launch Area. 

Table B-28. Fraction of a Very Large Oil Spill (expressed as a percentage) starting at a given location 

that will contact environmental resource area 74, 83 or 91within 360 days, during summer 

Chukchi Sea Sale 212/221 (USDOI, MMS, 2008a: Table A.3-5). 

ID Environmental Resource Area Name LA

1 

LA

2 

LA

3 

LA

4 

LA

5 

LA

6 

LA

7 

LA

8 

LA 

9 

LA 

10 

LA 

11 

LA

12 

LA 

13 

74 Offshore Herald Island 4 1 1 2 2 2 1 - - - 1 2 1 

91 Hope Sea Valley 2 - - 3 1 - - - 1 1 1 - - 

Notes: Only results for ERA 74, 83 and 91 from USDOI, MMS (2008) are shown. Rows with all values<0.5 are not shown. - = 

less than 0.5 percent; LA = Launch Area. 
APPENDIX B 

FIGURES
Sale 193 Revised Draft SEIS 

Appendix B Figure B-1. Study area used in the oil spill trajectory analysis. (Map A.1-1 in Sale 193 FEIS) 
Sale 193 Revised Draft SEIS 

Appendix B 

Figure B-2. Environmental Resource Areas used in the oil spill trajectory analysis. (Map A.1-2a in Sale 193 FEIS) 
Sale 193 Revised Draft SEIS 

Appendix B 

Figure B-3. Environmental Resource Areas used in the oil spill trajectory analysis. (Map A.1-2b in Sale 193 FEIS) 
Sale 193 Revised Draft SEIS 

Appendix B 

Figure B-4. Environmental Resource Areas used in the oil spill trajectory analysis. (A.1-2c in Sale 193 FEIS). 
Sale 193 Revised Draft SEIS 

Appendix B 

Figure B-5. Environmental Resource Areas used in the oil spill trajectory analysis. (A.1-2d in Sale 193 FEIS).
Sale 193 Revised Draft SEIS BOEMRE 

 Appendix B B33 

Figure B-6. Land Segments (1–39) used in the oil spill trajectory analysis. (Map A.1-3a in Sale 193 

FEIS) 
BOEMRE Sale 193 Revised Draft SEIS 

B34 Appendix B 

Figure B-7. Land Segments (40–85) used in the oil spill trajectory analysis. (Map A.1-3b in Sale 193 

FEIS)
Sale 193 Revised Draft SEIS 

Appendix B 

Figure B-8. Land Segments (86–126) used in the oil spill trajectory analysis. (Map A.1-3c in Sale 193 FEIS) 
Sale 193 Revised Draft SEIS 

Appendix B 

Figure B-9. Grouped Land Segments used in the oil spill trajectory analysis. (Map A.1-3d in Sale 193 FEIS)
Sale 193 Revised Draft SEIS BOEMRE 

Appendix B B37 

Figure B-10. Hypothetical Launch Areas and pipelines used in the oil spill trajectory analysis for 

Alternative 1. (Map A.1-4a in Sale 193 FEIS)

 

Appendix C 

Fish Resources and EFH – 

Summary Table and Figures 

Sale 193 Revised Draft SEIS BOEMRE 

Appendix C i

Appendix C. Fish Resources and EFH –Tables and Figures 

List of Tables 

Table C-1. Fish (adult life stage) in coastal and marine waters of the Chukchi Sea: known 

habitat and behavioral stratification and potential effects from VLOS in the 

Chukchi Sea.......................................................................................................C1 

List of Figures 

Figure C-1. Salmon: Essential Fish Habitat (EFH) in marine and riverine systems. (Source: 

NOAA, EFH, 2011). Also illustrated are LAs and LSs for the OSRA Model oil 

spill trajectory analysis......................................................................................C6 

Figure C-2. Least cisco: Anadromous waters in northern Alaska. (Source: ADFG 

Anadromous Waters Catalog, 2011). Also illustrated are LAs and LSs for the 

OSRA Model oil spill trajectory analysis. ........................................................C7 

Figure C-3. Dolly varden: Anadromous waters in northern Alaska. (Source: ADFG 

Anadromous Waters Catalog, 2011). Also illustrated are LAs and LSs for the 

OSRA Model oil spill trajectory analysis. ........................................................C8 

Figure C-4. Arctic char: Freshwater lake and stream habitats used in northern Alaska—

Arctic char also range outside of their freshwater habitats into nearshore and 

marine waters. (Source: ADFG Anadromous Waters Catalog, 2011). Also 

illustrated are LAs and LSs for the OSRA Model oil spill trajectory analysis. C9 

Figure C-5. Broad and humpback whitefish: Anadromous waters in northern Alaska. 

(Source: ADFG Anadromous Waters Catalog, 2011). Also illustrated are LAs 

and LSs for the OSRA Model oil spill trajectory analysis..............................C10 

Figure C-6. Arctic cod: Essential Fish Habitat (EFH). (Source: NOAA, EFH, 2011). Also 

illustrated are LAs and LSs for the OSRA Model oil spill trajectory analysis.

.........................................................................................................................C11 

Figure C-7. Saffron cod: Essential Fish Habitat (EFH). (Source: NOAA, EFH, 2011). Also 

illustrated are LAs and LSs for the OSRA Model oil spill trajectory analysis.

.........................................................................................................................C12 

Figure C-8. Opilio crab: Essential Fish Habitat (EFH). (Source: NOAA, EFH, 2011). Also 

illustrated are LAs and LSs for the OSRA Model oil spill trajectory analysis.

.........................................................................................................................C13 

Figure C-9. Coastal rivers and bays (including anadromous waters) of the Russia far east 

coast. Also illustrated are LAs and LSs for the OSRA Model oil spill trajectory 

analysis. ...........................................................................................................C14 

Sale 193 Revised Draft SEIS 

Appendix C 

Table C-1. Fish (adult life stage) in coastal and marine waters of the Chukchi Sea: known habitat and behavioral stratification 

from VLOS in the Chukchi Sea. 

Family Fish Species Fish Common Name Distribution in Chukchi Sea Life History 

Coastal and 

Nearshore up to 2 m 

Up to 50m depth 

50-100m depth 

100- 500 m depth 

> 500 m depth 

Demersal 

Pelagic 

Petromyzontidae Lampetra tridentata Pacific lamprey Rare Anadromous X X X X X X (lampreys) Lampetra 

camtschatica Arctic lamprey Widespread Anadromous X X X X X X 

Dalatiidae (sleeper sharks) Somniosus pacificus

Pacific sleeper shark Widespread Marine X X X X X X 

Lamnidae (mackerel sharks)1 Lamna ditropis1 salmon shark Rare Marine X X X X X X Squalidae (dogfish sharks) Squalus acanthias spiny dogfish Rare Marine X X X X X X Rajidae (skates) Bathyraja parmifera Alaska skate Rare Marine X X X X Clupeidae (herrings) Clupea pallasii Pacific herring Widespread Marine X X X X X 

Mallotus villosus capelin Widespread Marine X X X X X X 

Osmeridae 

(smelts) 

Osmerus mordax rainbow smelt Widespread Anadromous X X X X X X Coregonus sardinella least cisco Widespread Anadromous X X X X X Coregonus laurettae Bering cisco Widespread Anadromous X X X X X Coregonus nasus broad whitefish Widespread

Anadromous, 

Freshwater X X X X 

Salmonidae/Coregoninae (whitefishes) 

Coregonus pidschian humpback whitefish Widespread

Anadromous, 

Freshwater X X X X 

Salvelinus alpinus Arctic char Widespread

Anadromous, 

Freshwater X X X X 

Salvelinus malma Dolly Varden Widespread Anadromous X X X X X X 

Salmonidae/Salmoninae (trouts and salmons) Oncorhynchus 

gorbuscha pink salmon Widespread Anadromous X X X X X X 
Sale 193 Revised Draft SEIS 

Appendix C 

Family Fish Species Fish Common Name Distribution in Chukchi Sea Life History 

Coastal and 

Nearshore up to 2 m 

Up to 50m depth 

50-100m depth 

100- 500 m depth 

> 500 m depth 

Demersal 

Pelagic 

Oncorhynchus kisutch coho salmon Widespread Anadromous X X X X X X Oncorhynchus tshawytscha chinook salmon Widespread Anadromous X X X X X X Oncorhynchus keta chum salmon Widespread Anadromous X X X X X X Oncorhynchus nerka sockeye salmon Widespread Anadromous X X X X X X Boreogadus saida Arctic cod Widespread Marine X X X X X X Eleginus gracilis saffron cod Widespread Marine X X X X X X Theragra chalcogramma walleye pollock Widespread Marine X X X X X X 

Gadidae (cods)

Gadus macrocephalus Pacific cod Rare 

Marine

 X X X X 

Gasterosteus aculeatus

threespine stickleback Rare 

Anadromous, 

Gasterosteidae Freshwater X X X (sticklebacks

Pungitius pungitius 

ninespine stickleback Widespread

Anadromous, 

Freshwater X X X 

Hexagrammidae (greenlings)

Hexagrammos stelleri 

whitespotted greenling Widespread Marine X X X X 

Triglops pingelii ribbed sculpin Widespread Marine X X X X Hemilepidotus papilio butterfly sculpin Widespread Marine X X X X Hemilepidotus jordani yellow Irish lord Rare Marine X X X X 

Cottidae (sculpins)

Icelus spatula spatulate sculpin Widespread Marine X X X X 

Gymnocanthus tricuspis 

Arctic staghorn sculpin Widespread Marine X X X X 

Cottus aleuticus coastrange sculpin 

Limited 

Distribution 

Brackish, 

Freshwater X X X 

Enophrys diceraus antlered sculpin Widespread Marine X X X X Megalocottus platycephalus belligerent sculpin Widespread Brackish X X X 

Cottidae (sculpins)

Myoxocephalus fourhorn sculpin Widespread Brackish, Marine, X X X 
Sale 193 Revised Draft SEIS 

Appendix C 

Family Fish Species Fish Common Name Distribution in Chukchi Sea Life History 

Coastal and 

Nearshore up to 2 m 

Up to 50m depth 

50-100m depth 

100- 500 m depth 

> 500 m depth 

Demersal 

Pelagic 

quadricornis Freshwater Myoxocephalus scorpius shorthorn sculpin Widespread

Brackish, 

Freshwater X X X 

Myoxocephalus polyacanthocephalus great sculpin Widespread Marine X X X Myoxocephalus scorpioides Arctic sculpin Widespread

Brackish, 

Freshwater X X X 

Myoxocephalus jaok plain sculpin Widespread Marine X X X Microcottus sellaris brightbelly sculpin Rare 

Brackish, 

Freshwater X X X 

Artediellus gomojunovi spinyhook sculpin Rare Marine X X X Artediellus scaber hamecon Widespread 

Brackish, 

Freshwater X X X 

Artediellus pacificus hookhorn sculpin Rare Marine X X X Artediellus ochotensis 

Okhotsk hookear sculpin Rare Marine X X X 

Gymnocanthus pistilliger threaded sculpin Rare Marine X X X Trichocottus brashnikovi hairhead Sculpin Rare Marine X X X Blepsias bilobus crested sculpin Widespread Marine X X X X 

Hemitripteridae (sailfin sculpins) Nautichthys pribilovius eyeshade sculpin Widespread Marine X X X X Psychrolutidae (fathead sculpins) Eurymen gyrinus 

smoothcheek sculpin Rare Marine X X X X 

Hypsagonus quadricornis fourhorn poacher Rare Marine X X X X Pallasina barbata tubenose poacher Rare Marine X X Occella dodecaedron Bering poacher Rare Marine X X X 

Agonidae (poachers) 

Leptagonus Atlantic poacher Rare Marine X X X X 
Sale 193 Revised Draft SEIS 

Appendix C 

Family Fish Species Fish Common Name Distribution in Chukchi Sea Life History 

Coastal and 

Nearshore up to 2 m 

Up to 50m depth 

50-100m depth 

100- 500 m depth 

> 500 m depth 

Demersal 

Pelagic 

decagonus Podothecus veternus veteran poacher 

Rare and 

Patchy Marine X X X X 

Aspidophoroides olrikii Arctic alligatorfish Widespread 

Brackish, 

Freshwater X X X X 

Aspidophoroides monopterygius alligatorfish 

Limited 

Distribution Marine X X X X 

Eumicrotremus andriashevi pimpled lumpsucker Rare Marine X X X Liparis gibbus variegated snailfish Widespread Marine X X X X Liparis tunicatus kelp snailfish Widespread Marine X X X X Liparis bristolensis Bristol snailfish Rare Marine X X X Liparis callyodon spotted snailfish Widespread Marine X X X 

Liparidae (snailfishes) 

Liparis fabricii 

gelatinous snalifish Rare Marine X X X 

Gymnelus hemifasciatus halfbarred pout 

Rare and 

Patchy Marine X X X 

Gymnelus viridis fish doctor 

Rare and 

Patchy Marine X X X X 

Lycodes mucosus saddled eelpout Rare Marine X X X Lycodes turneri estuarine eelpout Widespread Marine X X X 

Zoarcidae (eelpouts) 

Lycodes polaris polar eelpout Widespread Marine X X X Lycodes raridens marbled eelpout Widespread Marine X X X X Lycodes rossi threespot eelpout Rare Marine X X X X Lycodes palearis wattled eelpout Widespread Marine X X X X Lycodes concolor ebony eelpout Rare Marine X X X X Zaprora silenus prowfish Rare Marine X X X Eumesogrammus praecisus 

fourline snakeblenny Widespread Marine X X X X 

Stichaeus punctatus Arctic shanny Widespread Marine X X X Chirolophis snyderi bearded warbonnet Rare Marine X X X 

Stichaeidae (pricklebacks

Leptoclinus daubed shanny Rare Marine X X X 
Sale 193 Revised Draft SEIS 

Appendix C 

Family Fish Species Fish Common Name Distribution in Chukchi Sea Life History 

Coastal and 

Nearshore up to 2 m 

Up to 50m depth 

50-100m depth 

100- 500 m depth 

> 500 m depth 

Demersal 

Pelagic 

maculatus Anisarchus medius stout eelblenny Widespread Marine X X X Lumpenus fabricii slender eelblenny Widespread Marine X X X 

Pholidae (gunnels) Pholis fasciata banded gunnel Rare Marine X X X 

Anarhichas orientalis Bering wolffish Widespread Marine X X X 

Anarhichadidae (wolffishes) 

Anarhichas denticulatus2 Northern wolfish Rare Marine X X X 

Ammodytidae (sand lances)

Ammodytes hexapterus Pacific sand lance Widespread Marine X X X X X Hippoglossus stenolepis Pacific halibut 

Unverified, 

Rare, 

Disjunct Marine X X X X X 

Hippoglossoides robustus Bering flounder Widespread Marine X X X X Reinhardtius hippoglossoides Greenland halibut 

Unverified, 

Patchy Marine X X X X X 

Platichthys stellatus starry flounder Widespread

Marine, 

Brackish X X X X X 

Pleuronectes quadrituberculatus Alaska plaice Widespread Marine X X X X Pleuronectes glacialis Arctic flounder Widespread

Marine, 

Brackish X X X X 

Limanda proboscidea longhead dab Widespread Marine X X Limanda aspera yellowfin sole Widespread Marine X X X X X 

Pleuronectidae (righteye flounders)

Limanda sakhalinensis Sakhalin sole 

Unverified, 

Rare, 

Disjunct Marine X X X X 

Sources: Mecklenburg, Moller and Steinke, 2011; Mecklenburg, et al., 2007; Norcross, et al. 2010; Hopcroft, et al., 2006; Fautin, et al., 2010; Froese anMecklenburg, and Thorsteinson, et al., 2002; Moulton and George, 2000; Stevenson,et al., 2004; Barber, et al., 1994,1997; Craig, 1989; Frost and Lowry
Sale 193 Revised Draft SEIS 

Appendix C 

Figure C-1. Salmon: Essential Fish Habitat (EFH) in marine and riverine systems. (Source: NOAA, EFH, 2011). Also illustrat

the OSRA Model oil spill trajectory analysis.
Sale 193 Revised Draft SEIS 

Appendix C 

Figure C-2. Least cisco: Anadromous waters in northern Alaska. (Source: ADFG Anadromous Waters Catalog, 2011). Also ill

LSs for the OSRA Model oil spill trajectory analysis. 
Sale 193 Revised Draft SEIS 

Appendix C 

Figure C-3. Dolly varden: Anadromous waters in northern Alaska. (Source: ADFG Anadromous Waters Catalog, 2011). Also 

LSs for the OSRA Model oil spill trajectory analysis.
Sale 193 Revised Draft SEIS 

Appendix C 

Figure C-4. Arctic char: Freshwater lake and stream habitats used in northern Alaska—Arctic char also range outside of thei

into nearshore and marine waters. (Source: ADFG Anadromous Waters Catalog, 2011). Also illustrated are LAs and Model oil spill trajectory analysis. 
Sale 193 Revised Draft SEIS 

Appendix C 

Figure C-5. Broad and humpback whitefish: Anadromous waters in northern Alaska. (Source: ADFG Anadromous Waters C

illustrated are LAs and LSs for the OSRA Model oil spill trajectory analysis. 
Sale 193 Revised Draft SEIS 

Appendix C 

Figure C-6. Arctic cod: Essential Fish Habitat (EFH). (Source: NOAA, EFH, 2011). Also illustrated are LAs and LSs for the OS

trajectory analysis. 
BOEMRE Sale 193 Revised Draft SEIS 

C12 Appendix C 

Figure C-7. Saffron cod: Essential Fish Habitat (EFH). (Source: NOAA, EFH, 2011). Also illustrated 

are LAs and LSs for the OSRA Model oil spill trajectory analysis. 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix C C13

Figure C-8. Opilio crab: Essential Fish Habitat (EFH). (Source: NOAA, EFH, 2011). Also illustrated are 

LAs and LSs for the OSRA Model oil spill trajectory analysis. 
BOEMRE Sale 193 Revised Draft SEIS 

C14 Appendix C 

Figure C-9. Coastal rivers and bays (including anadromous waters) of the Russia far east coast. Also 

illustrated are LAs and LSs for the OSRA Model oil spill trajectory analysis. 
APPENDIX D 

ESTIMATE FOR A VERY LARGE OIL SPILL 

 

FROM AN EXPLORATION WELL 

IN THE CHUKCHI SEA OCS PLANNING AREA 

NW ALASKA 
 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix D i 

Table of Contents 

1. Purpose of Chukchi Sea VLOS Well Analysis ............................................................................... D1

2. Selection of Geologic Model for Chukchi Sea VLOS Well............................................................ D1

3. Point of Discharge Into Marine Environment ................................................................................. D1

4. Description of Relief Well Model ................................................................................................... D1

5. The Gemini Solutions AVALON/MERLIN Computer Model ....................................................... D1

6. The Chukchi Sea VLOS Wellbore Design Model........................................................................... D2

7. Proprietary Data in Chukchi Sea VLOS Well Model...................................................................... D3

8. Darcy Radial Flow Equation and Basic Data for Discharge Model................................................ D3

9. Discharge Model Results for the Chukchi Sea VLOS Well............................................................ D5

10. Patterns of Fluid Discharges from the Chukchi Sea VLOS Well.................................................. D5

List of Tables 

Table D-1. Estimates for time periods required to drill a relief well and to kill the discharge at the 

Chukchi Sea VLOS well (provided by BOEMRE AKOCSR Field Operations office). 

Model 3 provides the largest and most protracted discharge and forms the basis for the 

present study................................................................................................................... D8

Table D-2. Selected key input variables for reservoir inflow simulation element of Chukchi Sea 

VLOS well discharge model using AVALON/MERLIN software.............................. D9

Table D-3. Results of AVALON/MERLIN discharge model for Chukchi Sea VLOS well over 

maximum (74-day) time period estimated for mobilization, drilling, and completion of a 

relief well...................................................................................................................... D10

List of Figures 

Figure D-1. Map of Chukchi Sea planning area with Sale 193 leased acreage................................ D12

Figure D-2. A) Klondike oil gravity and sulfur content as compared to Burger condensates and North 

Slope oil types (Tn = Tarn oil; Alp = Alpine oil); B) Isotopic composition of Klondike 

oil as compared to Burger condensates and extracted oils and North Slope oil types.. D13

Figure D-3. Graph profiling daily oil and gas discharge rates, producing gas-oil ratio, and cumulative 

oil discharge over 74-day period of discharge from the Chukchi Sea VLOS well....... D14

Sale 193 Revised Draft SEIS BOEMRE 

Appendix D D1 

Appendix D. Estimate for a Very Large Oil Spill 

1. Purpose of Chukchi Sea VLOS Well Analysis 

This document explains the methods by which BOEMRE created a simulation of a very large 

discharge event for a hypothetical reservoir in the Chukchi Sea. The purpose of creating this 

simulation is to provide a basis for evaluating the environmental consequences from a low 

probability, high impacts event—a high-volume and sustained blowout leading to a very large oil spill 

(VLOS) in the Chukchi Sea. To ensure that all potential environmental consequences of a VLOS are 

considered, this simulation ascertains the highest flow rate of hydrocarbons and the aggregate 

discharge that could plausibly occur from any known prospect in the Sale 193 lease area. 

2. Selection of Geologic Model for Chukchi Sea VLOS Well 

Among the prospects identified by BOEMRE seismic studies within the area of Chukchi Sea Lease 

Sale 193, a candidate prospect has been adopted as the site for a hypothetical blowout and discharge 

of oil into the marine environment from an exploration well. This candidate prospect was selected to 

maximize key geological characteristics that drive high flow rates—principally a thick reservoir 

offering high permeability—and was modeled for potential discharge volumes in a blowout event. 

The particular prospect is not known to contain oil or to offer rocks capable of performing as 

petroleum reservoirs. The geological model for the prospect is assumed to be a successful case and 

the considerable geological risk associated with the prospect is ignored. Lastly, the extremely low 

probability of a discharge event of the modeled magnitude is not considered in the analysis. 

3. Point of Discharge into Marine Environment 

The VLOS is assumed to originate from an exploration well at an unspecified location in the Chukchi 

Sea planning area and within the area identified in Figure D-1. The modeled point of discharge is the 

top of a blowout preventer coincident with the seafloor or “mudline” 131 ft below mean sea level (the 

base of the blowout preventer is placed at the bottom of a cellar ~40 ft deep for protection from 

iceberg keels; the top of the blowout preventer nearly reaches the seafloor). The association of the 

point of discharge with the blowout preventer is consistent with the BOEMRE protocol for 

determinations of worst-case discharges for proposed exploration and development wells. 

4. Description of Relief Well Model 

The oil discharge is assumed to terminate with the completion of a relief well after 74 days of flow, 

the longest time period among three possible scenarios described in Table D-1. The relief well 

scenarios were constructed by petroleum engineers within the office of Field Operations in the Alaska 

office of BOEMRE. The 74-day spill scenario assumes that a drilling platform located outside 

Alaska Arctic and somewhere in the North Pacific must be taken off an active project, re-fitted, and 

mobilized to the blowout site in the Chukchi Sea. No scenario for a “top-kill” or re-establishment of 

well flow control using the existing equipment and surface control techniques (often accomplished 

within a day) is entertained in this study. 

5. The Gemini Solutions AVALON/MERLIN Computer Model 

The computer model used to forecast the flow of fluids out of the Chukchi Sea VLOS well is a stateof-the-art proprietary commercial program by Gemini Solutions, Inc. of Richmond, Texas 

(http://www.geminisi.com/). The program is constructed as a desktop finite-difference simulator that 

divides the active flow system into many small cells and then iterates through time-increments of 

flow with re-assessments that successively modify the state of each cell in the flow system. Finitedifference models use approximations to relevant differential equations to calculate changes (e.g., 
BOEMRE Sale 193 Revised Draft SEIS 

D2 Appendix D 

pressures, fluid saturations, etc. in the case of fluid flow) within each cell. The incremental approach 

minimizes approximation errors by confining calculations to single cells and makes it possible to 

quantify behavior across complex systems with internal discontinuities (e.g., flow from reservoir to 

open well to casing to production manifold to pipeline, etc.). The model is robust, offering the 

capability to model fluid behavior through rank compositional data or through measured physical 

properties that can be used to forecast (through correlations) other properties. 

The Gemini model consists of two components, “AVALON” and “MERLIN”, that respectively 

simulate: (1) flow up a system of tubular passages (or “tubulars”) and (2) inflow (into the bottom of a 

well) from a pressurized porous reservoir. The correlative capacities of these two components of the 

flow system determine the discharge rate that can be achieved through the exit point at the top of the 

well. In theory, the maximum possible discharge rate can be limited by either the aggregate outflow 

capacity of the tubulars or by the reservoir inflow capacity at the base of the well. In the design of 

development wells and take-away pipelines, these two components of the flow system (the tubulars 

and the reservoir) are balanced to achieve the most efficient long-term recovery of formation 

hydrocarbons from the field. For a high-yield reservoir like that modeled for the Chukchi Sea VLOS 

well, the discharge rate is usually limited by the choke effect of wellbore tubulars that are insufficient 

to accommodate inflow from the reservoir. 

The flow up the open (uncased) wellbore and the casing is governed by the tubular sizes (diameter 

and length), roughness, frictional resistance, the driving formation pressure, and the density 

characteristics and thermal effects of the multiphase oil-gas-water mix (ranging from gassy liquid[s] 

to wet gas) moving upward through the wellbore. Flowing bottom-hole pressures at the base of the 

tubulars are a function of the aggregate density of the multiphase wellbore fluids, frictional and 

gravitational resistance to flow, ambient pressure (wellhead exterior), and reservoir pressure. 

The inflow from the reservoir formation is chiefly governed by pore system size and connectivity, 

formation pressure, drive mechanism, fluid compositions, fluid properties at reservoir conditions of 

pressure and temperature, and length of the wellbore segment passing through the reservoir 

formation. 

6. The Chukchi Sea VLOS Wellbore Design Model 

The Chukchi Sea VLOS well has an assumed design standardized to wells drilled to targets at 

comparable depths on the Chukchi and Beaufort shelves in the past. Several strings of casing ranging 

from 30 to 13-3/8 inches in diameter are assembled and cemented in place as the well is deepened 

with a final interior string of 9-5/8 inch casing extending from the shale seal formation above the 

reservoir formation to the base of the blowout preventer. In practice, any problems with wellbore 

instability (spalling or caving of the wall of the wellbore) in the course of drilling might require a 

smaller casing string. However, the model assumes that no problems of this nature are encountered 

below either the 13-3/8 inch or 9-5/8 inch casing strings. 

The blowout preventer rests in a cellar approximately 40 ft deep and 20 ft in diameter. The top of the 

blowout preventer reaches nearly to the mudline (sufficient distance below the mudline to be 

protected from iceberg keels, a requirement for the Arctic OCS). For purposes of the VLOS model, 

the 9-5/8-inch casing is assumed to extend up to the mudline. In effect, the blowout preventer is 

assumed to offer no resistance to flow but is simply an extension of the casing. The pressures exerted 

by the atmosphere and the seawater column together contribute approximately 73 psi to the flowing 

bottom-hole pressure that resists inflow at the face of the reservoir formation in the bottom part of the 

VLOS well. The 9-5/8-inch casing is assumed to have an internal diameter of 8.535 inches and this 

value partly controls throughput capacity. The wellbore below the casing is open (uncased) and 

passes through the reservoir formation to total depth. The open wellbore is assumed to be drilled with 

a bit 8.5 inches in diameter to a depth of 9,000 ft, with washout enlarging the wellbore to ~130% of 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix D D3 

gauge (~11 inches). The washout assumption has the effect of increasing discharge rate. Each 

segment of the flow path is also assigned a length and a roughness factor to evaluate frictional effects. 

7. Proprietary Data in Chukchi Sea VLOS Well Model 

Certain data related to the actual prospect modeled are uniquely derived from proprietary seismic data 

and cannot be revealed without compromising intellectual property rights and causing harm to the 

financial interests of leaseholders. These data include reservoir depth (and related details of casing 

design), specific well location, and targeted formation(s). In any case, these proprietary data are not 

directly relevant to the research issue at hand—the potential environmental impact of a sustained oil 

discharge from any source—and their exclusion from specific reference in this study does not detract 

from the conclusions of the study. 

8. Darcy Radial Flow Equation and Basic Data for Discharge Model 

The most important variables for the reservoir inflow component of the discharge model include the 

aggregate thickness of flow units (h), initial (pore) pressure (pi), permeability (ko) of the reservoir 

formation, and oil viscosity (μo). Inflow rates are particularly sensitive to permeability, which at 

extremes can vary across 7 orders of magnitude (0.01-1,000 md) or greater. Other important 

variables include oil viscosity and reservoir pressure. However, other important variables can vary by 

several factors. 

The flow of fluids out of a reservoir and into a well, or “inflow”, is grossly governed by the Darcy 

radial flow equation, as summarized in its simplest form for an oil reservoir below. The purpose of 

including the equation here is to illustrate the roles of the key variables in determining flow rate, 

denoted in the convention of petroleum engineers as “qo”. Note that no flow-limiting constraints are 

imposed upon outflow by the well tubular configuration above the reservoir in the basic Darcy 

equation. 

Darcy radial flow (steady-state) equation from Ahmed (2010, p. 435, equation 

6-144)

qo = 0.00708*ko*h*(pi-pwf)

 μo*Boi*((ln re/rw) + S) 

where qo= oil flow rate, barrels/day; 

 ko=permeability to oil, md, typically 0.01- >1,000 md; 

 h= thickness, ft, typically 10-200 ft; 

 pi

 = initial reservoir pore pressure, psi, typically 1,500-20,000 psi; 

 pwf = bottom-hole flowing pressure, psi, typically 300-8,000 psi; 

 μo = oil viscosity, cp, typically 0.1 to 30.0 cp; 

 Boi = oil formation volume factor, reservoir bbls per stock-tank bbl, 

typically 1.0-3.0; 

 re = drainage radius, ft, typically 1,000-20,000 ft; 

 rw = radius of well, ft, typically 0.35 to 0.73 ft; 

 S = skin factor, dimensionless, typically 0-500.

Many other variables of lesser importance that do not appear in the Darcy radial flow equation are 

required for the AVALON/MERLIN reservoir inflow model. Table D-2 summarizes some of the key 

reservoir and fluid properties and model parameters that formed the input data to the reservoir inflow 

model. Variables that appear in the Darcy radial flow equation above are highlighted. 

In the Chukchi Sea VLOS well oil discharge model, no factors related to the near-wellbore alteration 

of the reservoir formation that might limit flow rate or arrest the discharge were employed. The “skin 
BOEMRE Sale 193 Revised Draft SEIS 

D4 Appendix D 

factor (S)” shown in the Darcy radial flow equation above usually quantifies the plugging of reservoir 

pores (by drilling fluid solids) that often accompanies the drilling of a well; for the VLOS model “S” 

is set to zero (no effect on discharge rate). The model further assumes no influx into the well of 

brines from the aquifer beneath the oil pool or from separate brine-bearing sandstones that intersect 

the wellbore. In addition, no “bridging” or collapse of the open segment of the wellbore was assumed 

to restrict or terminate flow. No near-wellbore reservoir boundaries (such as faults) were invoked to 

limit the potential drainage area. 

Reservoir pressure and temperature are forecast from data collected in the 5 exploration wells in the 

Chukchi Sea in the 1989-1991 drilling program that followed the 1988 lease sale (109). Reservoir 

formation identification at the subject prospect is a result of extending formation boundaries away 

from well control both offshore and onshore through a grid of proprietary seismic data, including 

recently-acquired three-dimensional (3D) seismic data. Estimates for reservoir porosity and 

permeability are based on regional analog fields and well penetrations outside of oil fields. 

The aggregate thickness of flow units is based upon a synthesis of proprietary seismic mapping that 

defines the shape of a capture volume, or trap, which is assumed to be completely filled with oil. The 

seismic mapping locates and measures the point of the maximum vertical thickness of the capture 

volume, which is where the VLOS well is sited. Therefore, the exact location of the VLOS well 

represents proprietary information and is not disclosed. The vertical thickness of the oil-filled capture 

volume is reduced to an aggregate flow unit thickness by the expected ratio of porous flow units to 

overall formation thickness as forecast from analog fields and well penetrations. 

The area drained by the blowout event is assumed to be 160 acres (equivalent radius [re] surrounding 

well = 1,490 ft). The oil saturation model is based on the porosity and permeability models, 

assumptions about the texture (sorting, particle size) of the porous units in the reservoir formation, 

and reference to analog fields. 

The oil discharged from the Chukchi Sea VLOS well is assumed to be low-sulfur 35° API crude oil 

like that recovered at the Klondike 1 well, here informally termed the “Klondike oil.” The Klondike 

oil was recovered when the drill string was pulled out of the well to repair a plugged jet in the bit. 

The lifting of the drill string reduced wellbore pressure in the lower part of the well and thereby drew 

the oil out of the formation and into the wellbore. At the time of the bit repair trip, the part of the 

wellbore that was uncased or “open” extended from 9,093 ft to 9,916 ft md. This “swabbed” oil was 

subsequently circulated to the surface with drilling fluids and an unspecified quantity was collected as 

samples. The Klondike oil had a gravity of 35.3°API, a sulfur content of 0.18%, a ratio of 

saturates:aromatics:non-hydrocarbons = 66.2:26.1:7.7, a ratio of normal paraffins:isoalkanes + 

cycloalkanes:aromatics:non-hydrocarbons = 22.4:43.8::26.1:7.7 (Klondike 1 well, 1989) and would 

be classified as a paraffinic-naphthenic oil (Tissot and Welte, Table IV.2.2, p. 418). The low-sulfur 

and high-gravity qualities of the Klondike oil resemble the Simpson, Umiat, Tarn, and Alpine oils of 

the North Slope of Alaska (Figure D-2a). However, unlike the Simpson, Umiat, and Tarn oils, the 

Klondike oil is isotopically “light” (or deficient [relatively more negative value for ΔC13] in the 

content of the heavier carbon isotope C13 relative to C12). The isotopic composition of the Klondike 

oil most resembles the Jurassic (Kingak Formation)-sourced oils of Alpine field and at the Kavearak 

Point well (Figure D-2b). However, the ratio of C29 Terpane/Hopane for the Klondike oil is 0.77; 

values exceeding 0.75 suggest contribution from marine carbonate (Peters et al., 2007, tbl. 3, p. 883 & 

893), possibly pointing to the carbonates of the Triassic Shublik Formation as a second contributing 

source. The Klondike oil is assumed to represent the dominant (Triassic/Jurassic-sourced) petroleum 

system in the central Chukchi Sea because of its composition and because it was extracted from a 

sequence of rocks that includes very rich oil source rocks of the Shublik (Upper Triassic) and Fire 

Creek (Lower Triassic) Formations. No oil source rocks of Jurassic age were penetrated in the 

Klondike 1 well but such rocks are probably preserved in nearby areas flanking the Klondike 

structure. 
Sale 193 Revised Draft SEIS BOEMRE 

Appendix D D5 

The oil in the VLOS reservoir is assumed to be initially saturated (contains the maximum amount of 

dissolved gas possible at the inferred reservoir temperature and pressure). Therefore, the bubblepoint pressure (pressure at which dissolved gas breaks out of solution and forms bubbles in the oil) is 

assumed to equal the initial reservoir pressure (pi). No significant gas cap is assumed to be present in 

order to maximize the vertical thickness of the oil column. The pressure-temperature model, the oil 

gravity, and the assumption of saturation then lead through various correlations and calculations to 

estimates for Boi (oil volume factor, in reservoir barrels [rb] per surface or “stock tank” barrel [stb]), 

Rsi (dissolved gas content, in surface or standard cubic ft [scf] per stock tank barrel [stb]), μo (oil 

viscosity, in centipoise [cp]), reservoir oil density (g/cm3

), and static pressure gradient for reservoir 

oil (in psi/ft). In some basins, these types of data are sometimes available through laboratory “PVT” 

(pressure-volume tests at constant temperature) studies of oil recovered in nearby wells. However, 

for the Chukchi Sea VLOS well, no relevant PVT studies are available and many key fluid and rock 

parameters were of necessity obtained through estimates for pressure and temperature and use of 

industry-accepted correlations as published by many sources including Craft and Hawkins (1959), 

Standing (1977, and other references therein), McCain (1973, and references therein), and Ahmed 

(2010, and many references therein). 

The drive mechanism for the blowout flow is assumed to be pressure depletion and expansion of 

exsolved solution gas. The estimate for specific gas gravity is based on analyses of gas samples 

obtained by tests at the Burger 1 and Popcorn 1 wells on the Chukchi shelf. Estimates for fluid and 

rock compressibility are based upon assumptions about rock consolidation, porosity, pressure, 

temperature, dissolved gas content, relative fluid saturations, and brine composition. The brine 

salinity is assumed to be similar to seawater and that assumption is supported by analyses of connate 

water recovered at the Burger 1 well. The estimate for brine viscosity is based upon the salinity 

assumption and reservoir temperature. The model-implied in-place oil volume (reduced to surface 

barrels) is calculated as 869 bbls/acre-ft, as shown at the bottom of Table D-2. Joining the implied inplace oil volume with thickness (h) and a 160-acre assumed drainage area indicates an in-place 

volume of 25,722,400 bbls of oil within the model drainage area. Probably less than half of this inplace oil could be recovered by a single well, even over decades of carefully-engineered production 

and enhanced recovery techniques. Only a very small fraction of this in-place oil will reach the 

surface during the hypothetical VLOS. 

9. Discharge Model Results for the Chukchi Sea VLOS Well 

Table D-3 and Figure D-3 summarize the results of the discharge model for the Chukchi Sea VLOS 

Well. Following the blowout, the oil discharge climbs rapidly to a maximum of 61,672 bbls/d during 

day 1. After peaking in day 1, Figure D-3 shows that the oil discharge rate declines rapidly through 

the first 40 days of flow as the reservoir is depressurized by approximately 1,400 psi (Table D-3). 

The decline in the flow rate flattens somewhat after day 40, finally falling to 20,479 bbls/d (33% of 

the day 1 peak rate) by day 74 when the near-wellbore reservoir pressure has fallen to 58% of the 

initial reservoir pressure (4,392 psi). As shown at the bottom of Table D-3, the cumulative oil 

discharge over the 74-day discharge period is 2,160,200 bbls. As shown in Table D-3, water 

production over the 74-day period is quite small (cumulative water: 28.8 bbls). The water discharge 

is limited because in the oil-saturated reservoir the small amount of water is bound to the walls of 

pores and because the relative permeability to oil is much higher. In addition, the model is designed 

to preclude any brine-saturated reservoir from direct contact with the wellbore. 

10. Patterns of Fluid Discharges from the Chukchi Sea VLOS Well 

The decline in discharge rates of both oil and gas during the early part of the flow period are on the 

order of 99% per year and reflect rapid de-pressurization of the reservoir near the wellbore. The oil 

discharge rate declines throughout the entire 74-day period. However, the gas discharge rate declines 

to a minimum of 19,513 Mcf/d on day 45 and then, despite continuing reservoir depressurization, 
BOEMRE Sale 193 Revised Draft SEIS 

D6 Appendix D 

reverses the decline and rises to 24,608 Mcf/d by the end of the 74-day period. This behavior is 

caused by the evolving compositions of the fluids that remain in the reservoir pore system as oil is 

withdrawn. One clue to how the reservoir contents are changing is the change in produced gas-oil 

ratio through the 74-day flow period, as discussed below. 

The oil in the VLOS reservoir is estimated to be originally saturated with 930 scf/stb of dissolved 

(solution) gas and this is reflected by the identical initial produced gas-oil ratio of 930 scf/stb in the 

flow model (time 0.1 days, Table D-3). As shown in Table D-3 and Figure D-3, the produced gas-oil 

ratio falls from the initial value of 930 scf/stb into a protracted minimum of approximately 757 scf/stb 

from day 15 to day 27, thereafter rising steadily to 1,202 scf/stb by day 74. This is a consequence of 

the increasing enrichment or “saturation” of the reservoir pore system with bubbles of free gas as 

pressure declines and dissolved gas breaks out of the oil and forms a separate phase in the centers of 

pores. At the onset of flow, and through the first 27 days of flow, gas bubbles are forming within the 

reservoir near the wellbore, but high oil saturation and correlative low relative permeability to gas 

blocks the movement of the gas bubbles through the pores in the reservoir and thence to the well. As 

oil flow continues, the oil saturation declines while gas saturation rises and gas eventually becomes 

the dominant phase. By day 27, a large volume of the reservoir near the wellbore hosts high free gas 

saturations and gas can easily flow to the wellbore. Thus, we observe that the gas rate and the 

produced gas-oil ratio both steadily rise, to 24,608 Mcf/d and 1,202 scf/stb respectively, by the end of 

the 74-day flow period. Essentially, the original VLOS oil reservoir is being converted to a gas 

reservoir. Ultimately, beyond the 74-day period shown in Figure D-3, gas production will peak and 

then decline as the reservoir drains to complete depletion of extractable oil and gas. 
 

APPENDIX D 

TABLES 
BOEMRE Sale 193 Revised Draft SEIS 

D8 Appendix D 

Table D-1. Estimates for time periods required to drill a relief well and to kill the discharge at the 

Chukchi Sea VLOS well (provided by BOEMRE AKOCSR Field Operations office). Model 3 

provides the largest and most protracted discharge and forms the basis for the present study. 

Relief Well Models for Chukchi Sea VLOS Well

Activity Time Estimate 

(days)

Cleanup and Re-Supply of Original Vessel 5

Construction of Relief Well Cellar * 7

Drilling of Relief Well 18

Killing of VLOS (Original) Well 5

Weather Downtime * 4

Total Required Time 39

Activity Time Estimate 

(days)

Plug and Temporarily Abandon Well Being Drilled by 

Second Drilling Platform 5

Cleanup and Re-Supply of Relief Well Vessel 5

Transport of Relief Well Rig to VLOS Well Site 2

Construction of Relief Well Cellar * 7

Drilling of Relief Well 18

Killing of VLOS (Original) Well 5

Weather Downtime * 4

Total Required Time 46

Activity Time Estimate 

(days)

Plug and Temporarily Abandon Well Being Drilled by 

Second (Relief Well) Drilling Platform 5

Cleanup of Relief Well Vessel (Performed En RouteNo Additional Time) 0

Transport of Relief Well Rig to VLOS Well Site 30

Re-Supply of Relief Well Vessel 5

Construction of Relief Well Cellar * 7

Drilling of Relief Well 18

Killing of VLOS (Original) Well 5

Weather Downtime * 4

Total Required Time 74

1. Use of Original Drilling Platform and Equipment to Drill Relief Well

2. Use of Second Drilling Platform and Equipment Pre-Positioned InTheater (Within Chukchi Sea) for Relief Well

3. Use of Second Drilling Platform and Equipment from Northern 

* estimates based upon previous operations in the area
Sale 193 Revised Draft SEIS BOEMRE 

 

Appendix D D9

 

 

Table D-2. Selected key input variables for reservoir inflow simulation element of Chukchi Sea VLOS 

well discharge model using AVALON/MERLIN software. 

Initial Reservoir Pressure (pi, psi) 4,392 Bubble Point Pressure (psi) 4,392

Flowing Bottom-Hole Pressure (pwf, psi) - 

Modeled by AVALON/MERLIN

1,853 - 

3,760 Oil Viscosity (μo, cp) 0.47

Reservoir Temperature, °F (°R) 176 (636) Skin Factor (S) 0

Reservoir Porosity (fraction of rock) 0.21 Reservoir Oil Density (g/cm3

) 0.68

Reservoir Permeability (ko, md) 400 Static Pressure Gradient of Reservoir Oil 

(psi/ft) 0.295

Aggregate Thickness Flow Units (h, ft) 185 Specific Gas Gravity (Air=1.0) 0.6

Drainage Radius (re, ft) 1,490 Formation Compressibility, Cf (v/v/psi*10-6) 3.6

Well Radius at Reservoir (rW, ft) 0.46 Oil Compressibility, Co (v/v/psi*10-6) 13.031

Initial Oil Saturation (fraction of porosity) 0.76 Brine Compressibility, Cw (v/v/psi*10-6) 3.25

Critical Oil Saturation (fraction of porosity) 0.2 Total Compressibility, Ct (v/v/psi*10-6) 14.284

Oil Gravity (°API) 35 Brine Salinity (ppm NaCl) 35,000

Initial Boi or FVF (rb/stb) 1.425 Brine Viscosity (cp) 0.37

Initial Rsi or GOR (scf/stb) 930 Implied In-Place Oil Volume (bbls/acre-ft at 1 

atm. and 60°F) 869

psi, pounds per square inch; °R, °Rankine (=°F+460); Boi, oil volume factor (aka FVF or formation volume factor); rb/stb, reservoir barrels per 

stock-tank barrel of oil (at 1 atm. and 60°F); Rsi, gas saturation (aka GOR or gas-oil ratio); scf/stb, standard cubic feet of gas per stock-tank 

barrel of oil (at 1 atm. and 60°F); cp, centipoise; model-implied in-place oil=7,758.38 bbls/acre-ft*(0.21*(0.76)/1.425). Highlighted variables 

appear in the Darcy radial flow equation.
BOEMRE Sale 193 Revised Draft SEIS 

D10 Appendix D 

Table D-3. Results of AVALON/MERLIN discharge model for Chukchi Sea VLOS well over maximum 

(74-day) time period estimated for mobilization, drilling, and completion of a relief well. 

Time 

(days)

Oil Discharge 

Rate (bbls/d)

Gas 

Discharge 

Rate (Mcf/d)

Producing 

Rsi (GOR) 

Gas-Oil Ratio 

(scf/stb)

Water 

Discharge 

Rate (bbls/d)

Cumulative 

Oil Discharge 

(Mbbls)

Cumulative 

Gas 

Discharge 

(MMcf)

Cumulative 

Water 

Discharge 

(bbls)

NearWellbore 

Reservoir 

Pressure 

(psi)

0 0 0 930 0 0 0.0 0 4,392

0.1 50,671 47,124 930 0.06 5.1 4.7 0.0 4,168

1 61,672 50,677 822 0.16 61.8 52.2 0.1 3,937

2 57,485 46,357 806 0.18 120.5 99.8 0.3 3,875

3 53,987 43,035 797 0.20 175.1 143.5 0.5 3,827

4 52,246 41,030 785 0.23 226.1 183.9 0.7 3,777

5 48,669 38,101 783 0.23 274.8 222.0 1.0 3,747

6 46,581 36,312 780 0.25 321.4 258.4 1.2 3,707

7 45,036 34,931 776 0.26 366.4 293.3 1.5 3,666

8 43,596 33,607 771 0.27 410.0 326.9 1.7 3,627

9 42,239 32,343 766 0.28 452.2 359.2 2.0 3,591

10 40,889 31,100 761 0.29 493.1 390.3 2.3 3,558

11 39,529 29,923 757 0.29 532.6 420.3 2.6 3,528

12 38,306 28,974 756 0.30 570.9 449.2 2.9 3,499

13 37,219 28,148 756 0.30 608.2 477.4 3.2 3,473

14 36,364 27,583 759 0.31 644.5 505.0 3.5 3,445

15 35,580 27,035 760 0.32 680.1 532.0 3.8 3,420

16 34,930 26,628 762 0.33 715.0 558.6 4.2 3,394

17 34,316 26,178 763 0.33 749.4 584.8 4.5 3,370

18 33,750 25,767 763 0.34 783.1 610.6 4.8 3,347

19 33,199 25,330 763 0.34 816.3 635.9 5.2 3,325

20 32,662 24,885 762 0.35 849.0 660.8 5.5 3,304

21 32,130 24,436 761 0.35 881.1 685.2 5.9 3,284

22 31,608 23,995 759 0.35 912.7 709.2 6.2 3,265

23 31,094 23,577 758 0.35 943.8 732.8 6.6 3,247

24 30,596 23,178 758 0.36 974.4 756.0 6.9 3,230

25 30,115 22,800 757 0.36 1,004.5 778.8 7.3 3,213

26 29,648 22,443 757 0.36 1,034.2 801.2 7.7 3,197

27 29,200 22,110 757 0.36 1,063.4 823.3 8.0 3,181

28 28,750 21,788 758 0.36 1,092.1 845.1 8.4 3,165

29 28,319 21,499 759 0.36 1,120.4 866.6 8.7 3,150

30 27,917 21,245 761 0.37 1,148.3 887.9 9.1 3,136

31 27,539 21,029 764 0.37 1,175.9 908.9 9.5 3,121

32 27,166 20,806 766 0.37 1,203.0 929.7 9.9 3,106

33 26,805 20,599 768 0.37 1,229.9 950.3 10.2 3,092

34 26,452 20,415 772 0.37 1,256.3 970.7 10.6 3,079

35 26,124 20,256 775 0.38 1,282.4 991.0 11.0 3,065

36 25,817 20,115 779 0.38 1,308.2 1011.1 11.4 3,052

37 25,534 20,006 784 0.38 1,333.8 1031.1 11.7 3,038

38 25,250 19,886 788 0.38 1,359.0 1051.0 12.1 3,025

39 24,974 19,787 792 0.39 1,384.0 1070.8 12.5 3,012

40 24,719 19,707 797 0.39 1,408.7 1090.5 12.9 2,999

41 24,474 19,637 802 0.39 1,433.2 1110.1 13.3 2,986

42 24,251 19,595 808 0.39 1,457.4 1129.7 13.7 2,973

43 24,034 19,552 814 0.40 1,481.5 1149.2 14.1 2,961

44 23,821 19,522 820 0.40 1,505.3 1168.8 14.5 2,948

45 23,620 19,513 826 0.40 1,528.9 1188.3 14.9 2,936

46 23,434 19,518 833 0.41 1,552.4 1207.8 15.3 2,923

47 23,259 19,531 840 0.41 1,575.6 1227.3 15.7 2,911

48 23,110 19,579 847 0.42 1,598.7 1246.9 16.1 2,898

49 22,946 19,617 855 0.42 1,621.7 1266.5 16.5 2,885

50 22,797 19,682 863 0.42 1,644.5 1286.2 17.0 2,873

51 22,665 19,765 872 0.43 1,667.1 1306.0 17.4 2,860

52 22,543 19,856 881 0.43 1,689.7 1325.8 17.8 2,847

53 22,434 19,972 890 0.44 1,712.1 1345.8 18.3 2,835

54 22,325 20,098 900 0.44 1,734.4 1365.9 18.7 2,822

55 22,228 20,252 911 0.45 1,756.7 1386.2 19.2 2,809

56 22,150 20,425 922 0.46 1,778.8 1406.6 19.6 2,795

57 22,042 20,566 933 0.46 1,800.9 1427.1 20.1 2,783

58 21,918 20,699 944 0.47 1,822.8 1447.8 20.6 2,770

59 21,807 20,869 957 0.47 1,844.6 1468.7 21.0 2,758

60 21,688 21,030 970 0.48 1,866.3 1489.7 21.5 2,745

61 21,580 21,203 983 0.48 1,887.8 1510.9 22.0 2,733

62 21,475 21,381 996 0.49 1,909.3 1532.3 22.5 2,720

63 21,369 21,566 1,009 0.49 1,930.7 1553.9 23.0 2,708

64 21,284 21,804 1,024 0.50 1,952.0 1575.7 23.5 2,695

65 21,193 22,032 1,040 0.51 1,973.2 1597.7 24.0 2,683

66 21,112 22,276 1,055 0.51 1,994.3 1620.0 24.5 2,670

67 21,033 22,532 1,071 0.52 2,015.3 1642.5 25.0 2,657

68 20,955 22,799 1,088 0.53 2,036.3 1665.3 25.5 2,644

69 20,868 23,078 1,106 0.53 2,057.1 1688.4 26.1 2,632

70 20,777 23,350 1,124 0.54 2,077.9 1711.8 26.6 2,619

71 20,693 23,637 1,142 0.55 2,098.6 1735.4 27.2 2,606

72 20,615 23,934 1,161 0.55 2,119.2 1759.3 27.7 2,594

73 20,539 24,248 1,181 0.56 2,139.8 1783.6 28.3 2,581

74 20,479 24,608 1,202 0.57 2,160.2 1808.2 28.8 2,567

Mcf/d, thousands of cubic feet per day; scf/stb, standard cubic feet or gas per stock-tank barrel of oil at 1 atmosphere (101.6 kilopascals) and 60 °F (15.6 °C) or surface 

conditions; Mbbls, thousands of barrels; MMcf, millions of cubic feet; psi, pounds per square inch (6.895 kiloipascals). "Near-Wellbore Reservoir Pressure" represents 

the formation pressure in the cell penetrated by the well.
 

APPENDIX D 

FIGURES
BOEMRE Sale 193 Revised Draft SEIS 

D12 Appendix D 

WALAKPAGAS FIELD

AKULIK 

SKULL

KUGRUA

CLIFF

EAGLE CREEK 

TUNALIK

TUNGAK CREEK

KAOLAK

PEARD

BRONTOSAURUS

Ipewik

Kukpuk

Pitmegea

R.

R.

R. Kukpowruk R.

KukR.

R.

R.

Meade Inaru

Lisburne

Cape

Bay

Ledyard

Kasegaluk

Lagoon

Icy Cape

Point Franklin

Peard

Bay

Point Barrow

Point Hope

Atqasuk

Wainwright

Point Lay

Barrow

169° 168° 165°

68°

156°

70°

72°

74°

162° 75°

ALASKA

CHUKCHI

SEA

RUSSIAN

CHUKCHI SHELF

Beaufort Sea PlanningArea

Chukchi SeaPal nningArea

Chukchi SeaPlanningAre

N

a

CRACKERJACK BURGER 

KLONDIKE 

POPCORN 

DIAMOND

Chukchi Sea Very-Large-Oil-Spill (VLOS) Area

Leases Issued on Chukchi Shelf 

in 2008 (Sale 193)

Explanation

0 50 Kilometers

0

0 50 Nautical Miles

50 Statute Miles

2007-2012 Chukchi

Sea Program Area and

Area of Potential Very

Large Oil Spill

Figure D-1. Map of Chukchi Sea planning area with Sale 193 leased acreage. 
Sale 193 Revised Draft SEIS BOEMRE 

 

Appendix D D13

 

Kuparuk-PrudhoeBarrow Oils

Burger

Condensate Burger

Condensates,

Oil Extracts

Klondike

Oil

Klondike

Oil

Modified after Magoon & Bird (1985, fig. 9) and 

Masterson (2001, fig. 1.12)

SOFER’S LINE (1984)

Umiat Oil

Simpson

& Tarn

Oils

Pebble Shale

Kuparuk- Oil

PrudhoeBarrow Oils

Kavearak Pt

Kingak Oil

Alpine Oil

Geochemistry of Chukchi Oils & Condensates and North Slope Oil Families

(API Gravity vs Sulfur, Carbon Isotopes)

Modified after Magoon & Claypool (1981, fig. 3) 

Masterson (2001, tbl. 3.3)

and 

Alp

Tn Simpson-UmiatAlpine-Tarn Oils

Explanation

Burger RFT 4, 5,586 ft

Klondike, Swabbed 9,088-9,916 ft

Barrow-Prudhoe Oil Types

Simpson-Umiat Oil Types (Wells)

Simpson-Umiat Oil Types (Seeps)

A B

Figure D-2. A) Klondike oil gravity and sulfur content as compared to Burger condensates and North 

Slope oil types (Tn = Tarn oil; Alp = Alpine oil); B) Isotopic composition of Klondike oil as 

compared to Burger condensates and extracted oils and North Slope oil types 
BOEMRE Sale 193 Revised Draft SEIS 

D14 Appendix D 

74-Day Discharge History for Chukchi Sea VLOS Well

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

1 11 21 31 41 51 61 71

Days of Discharge

Oil Discharge Rate (bbls/d) and Gas 

Discharge Rate (Mcf/d)

0

500

1,000

1,500

2,000

2,500

Cumulative Oil Discharge (*1,000 bbls) 

and Producing Gas-Oil Ratio (scf/stb)

Oil Discharge Rate

Gas Discharge Rate

Cumulative Oil Discharge

Producing Gas-Oil Ratio

Maximum Oil Discharge Rate=61,672 bbl/d

Day 74 Oil Discharge Rate=20,479 bbl/d

Total Oil Discharge=2,160,200 bbls

Oil Saturation Declines

Gas Saturation Rises

Figure D-3. Graph profiling daily oil and gas discharge rates, producing gas-oil ratio, and cumulative oil 

discharge over 74-day period of discharge from the Chukchi Sea VLOS well. 

As the Nation’s principal conservation 

agency, the Department of the Interior 

has responsibility for most of our 

nationally-owned public lands and 

natural resources. This includes 

fostering the wisest use of our land and 

water resources, protecting our fish and 

wildlife, preserving the environmental 

and cultural values of our national parks 

and historical places, and providing for 

the enjoyment of life through outdoor 

recreation. The Department assesses 

our energy and mineral resources and 

works to assure that their development 

is in the best interest of all our people. 

The Department also has a major 

responsibility for American Indian 

reservation communities and for people 

who live in Island Territories under U.S. 

Administration.