16 2) Water Supply Fresh water resources are a major component of arctic oil production plans. Water is needed for exploratory drilling, ice road construction, development drilling, and human requirements. The Draft 1002 Report identified fresh water as the major engineering problem for development of the 1002 area: "the large quantities of water required for development drilling on the 1002 area are not available." However, in its Final Report DOI omits all reference to this statement, simply stating that the limited availability of fresh water is "not a problem unique to the area." Critics of full leasing believe Interior has not adequately addressed questions regarding the quality and site-specific sources of fresh water needed for development of ANWR. Oil development on the 1002 area may not even be possible due to the low availability of water. Moreover, fish and wildlife populations and natural processes could be affected if water cycles are disrupted. Interior lists the following possible solutions to the ANWR water shortage, but neglects to explain any of them in detail: desalinization of sea water, collection and melting of snow and ice, c) creation of water reservoirs through gravel excavation, 3) Gravel Supply If ANWR is developed, gravel will be required for roadways, airstrips, and for basal support of all buildings and structures. In the arctic environment, gravel generally is taken from stream channel and upland deposits. There is concern that the large amounts of gravel mined (several million cubic yards) will have a detrimental effect on stream ecosystems. According to the Final 1002 Report, disruption of stream flow, water siltation, blockage and entrapment of fish, and diminished fish populations could result from mining activities. As noted earlier, at a Kavik River gravel mine, removal of stream bank cover resulted in a reduction of juvenile arctic char as compared with control areas located downstream (Alaska Department of Fish and Game, 1987). Gravel mining from stream areas also could disrupt areas preferred by muskoxen. Important forage areas could be lost due 17 to displacement and habitat destruction (Interior Final Report, 1987). Reclamation of mined areas at Prudhoe Bay also has proven difficult (EPA Review Comments, 1987). If mitigation is to be effective, plans for gravel removal must include detailed procedures for the rehabilitation of the site and rehabilitation must be conducted concurrently with gravel removal (Alaska Department of Fish and Game, 1987). 4) Environmental Pollution a) Air pollution Air pollution will be generated by many activities associated with oil development, including air and vehicular traffic, electrical generation, and oil production activity. Of particular concern is flaring, the practice of burning off the heavy butanes and propanes on top of an oil deposit before the crude is removed (Mahoney, 1987). Although unproven, there is concern that the arctic may be more sensitive to these emissions than other regions due to its cool and arid climate and frequent thermal inversions. Some researchers contend that the arctic already experiences a haze from drifting industrial pollution originating in the U.S.S.R. and Europe; they feel a study of the cumulative impacts of circumpolar arctic development should be undertaken before further industrialization occurs (National Wildlife Federation, 1987; Udall, 1987). There also is concern that the vegetation of the arctic is especially sensitive to air pollution. Acidification of the tundra could result from low-level emissions even if temperate standards are met (EPA Review Comments, 1987). DOI's view is that the current U.S. Environmental Protection Agency and State of Alaska air pollution control regulations are adequate to ensure no significant deterioration of air quality in the coastal plain. This applies to both emissions generated in the 1002 area and from related activities elsewhere. Even so, in its Final Report Interior acknowledges that "limited data available for the Prudhoe Bay area do not allow prediction of air-quality consequences of oil development within the 1002 area." However, on the next page the Department states: "any emissions generated in the 1002 area (or from related activities elsewhere) will not cause a significant deterioration of air quality." Interior has been criticized for predicting air quality conditions with limited data. 18 b) Drilling wastes Drilling muds are another source of concern. When an exploratory or production well is drilled, a special slurry is used to lubricate the drill bit and remove material cut out by the drill. These drilling muds are disposed of in gravel-lined reserve pits near the drilling pad. Discharge of toxic fluids from these pits (including brines, hydrocarbons, corrosives, and heavy metals) has occurred at Prudhoe Bay (Alaska Department of Fish and Game, 1987). There is evidence that these reserve pit discharges kill invertebrates in nearby ponds and wetlands (West and SnyderConn, 1986). In situ studies of aquatic invertebrates have shown significant mortality, prolonged immobility, and reduced fecundity and growth when exposed to various concentrations of reserve pit supernatant (Alaska Department of Fish and Game, 1987). Invertebrates are key components of the arctic food web, and any damages to them could have consequences throughout the ecosystem. For example, aquatic invertebrates are a major source of food for snow geese and waterfowl; habitat values for these birds would be decreased if invertebrate populations decline. Moreover, at Prudhoe Bay the oil industry frequently waters roads with reserve pit fluids to suppress dust. When the application eventually dries, the metals in the fluids lead to contaminated dust that can be detected up to a half a mile away from roads (Interior Final Report, 1987). Contaminated dust also causes increased alkalinity and salinity (Interior Final Report, 1987). According to Interior, adverse impacts on invertebrates and acid-loving plants could result. This could eventually affect grazing mammals (caribou and muskoxen) and waterfowl (Interior Final Report, 1987). Nevertheless, at ANWR, "it is more likely that reserve pit fluids could be used on roads because other local water sources are limited" (Interior Final Report, 1987). c) Oil and gas spills A third pollution source is the mined crude oil and its derivatives. In 1985, the first full year of records of oilspill data at Prudhoe Bay, there were over 500 spills totalling 82,216 gallons (Interior Final Report, 1987). Spills of diesel fuel also were common. Similar to reserve pit discharges, an experimental spill of Prudhoe Bay crude oil on a tundra pond was found to eliminate several invertebrate species from the pond for at least 6 years (Barsdate et al, 1980). Direct effects of oil and fuel spills on vegetation have lasted more than 4 years (Interior Final Report, 1987). Prompt containment procedures could minimize effects on 19 the environment, states Interior. 5) Regulatory Compliance The U.S. Environmental Protection Agency criticized the Final Report's emissions monitoring plan. Robie Russell, Regional Administrator for EPA Region 10, found Interior vague in its description of how development would relate to existing environmental laws. Interior merely states that "a leasing program might require compliance with the National Environmental Protection Act, the Clean Water Act, and the Clean Air Act" (EPA Review Comments, 1987). 6) Canadian Objection Canada responded to the Interior Draft Report with alarm. Because several species of wildlife migrate between Canada and the U.S., each nation has "obligations to conserve these stocks and their habitats so the value of the wildlife to the other country is not unacceptably reduced" (Government of Canada Position Paper, 1987). In a February 1987 Position Paper, Canada accordingly urged the U.S. Government not to develop the 1002 area: [p]etroleum development of the 1002 area the 1002 area by establishing it as wilderness. In July of 1987, however, the two nations reached a nonbinding agreement to conserve the PCH and its habitat. An International Porcupine Caribou Board made up of 4 members from each country will make recommendations on how to accomplish this goal. Written justification is required if either country chooses to ignore the board's advice. Proponents of ANWR development argue that Canada has more than just wildlife and subsistence cultures at stake. The U.S. imports 5% of its total oil consumption from Canada (Long, 1987), and production on the coastal plain could reduce U.S. oil purchases from Canada. It is unlikely, however, that this would occur, since the U.S. probably would reduce OPEC imports first. 20 RESEARCH NEEDS Critics of Interior's analysis do not believe that a sufficient data base exists to make accurate predictions about the impacts of development in the 1002 area on fish and wildlife. In their evaluations of the Draft 1002 Report, the EPA and Congressional Research Service made note of this. Their concerns, however, were still not addressed in the Final 1002 Report (EPA Review Comments, 1987). Interior's Final Report is clouded with the words may, might, could, apparently, unknown, inconclusive, seemingly, likely, possibly, probably. It is difficult for the objective reader to agree with Interior's estimates. More information is needed on the following topics: 1) Porcupine and Central Arctic Caribou Herds Biologists do not understand why caribou prefer some b) Caribou movements Radio-collared caribou must be monitored for relatively provide better information for facility siting and c) Reaction to barriers Research must be undertaken to determine how large 2) Muskox A reliable simulation model that predicts impacts of a) Habitat requirements and displacement Research is needed to determine the components of b) Winter energetics and disturbance It is unknown how disturbances will affect muskox winter energetics. Muskox overwintering strategy involves reduced activity--disturbances during this period could reduce survival. c) Impacts from development According to the Interior Draft Report, no information Research is from gravel ト |