Seismic EA Update 3 messages LaMarr, Sarah -- Thur Se 13' 2015 al1:24 PM TO: Mall Whitman -- Slacev Frill -- Debora ngfo Hello Seismic Exploraiion Team oil, we'd like lo inank everyone ior your diligence and hard work on inis EA Ailnougn ll has been a iasl paced and, alien limes, conlusing process ano allhough you all nao many olner you lolks managed lo gel il compleleo! Kudos! And, Thanks! We greally appreciale all your hard work. The preliminary EA ls ready lo be uploaded in ePlanning. We're juslwalling lo gel lne final approval lrorn lne Slale heime ll gels posted (nopeiuily lomolmwl Theve will be a so day puoiic commeni penoo |hzl slans onca ine EA is posieo. Tnere will also be a public meeling ln Ulqiagvlk on onoaers, Feel tree (0 leviaw the preliminary EA located ai: V:l010 Aicllc Disllicl Offibel04 Plain Seismlc Emma" EA Revlsionlerafl Coaslal Plain Seismic EA 9.13.2018 But do not make any Chang's to this document. Please be aware that lhele have been numerous edits based on sollcilo! and Stale Ollice Ievlew. You may see some changes to you! secllons based on lhese edils. Please contact Donna or me ll you'd like In discuss any Changes (ha! have been made. Please iel us know llyou find any errors. Again, Thanks! saran Sarah La Marr Bureau ol Land Managemenl Arelic Dislricl omee Frii 599142018 al12.00 PM From: thro, Deanna Date: Fri, Sep14,2018 at11:13AM Subject Re' Seismic EA Update Mlnorerr in Imi EA- Table ateontents 3.3,4 and Seenie Rivers is listed in aitierent tent Page 17, last sentanee "2.3 Alternative Addition of Required Operating Proceduras" should be In a new paragraph Alternative 5 - PolarEear- Suggested text changes are in red "Although disturbances to polar bears would he reduced from procedures outlined in the Wildlife Interaction Plan (Appendix H), FLIR surveys. den site buffets Ind other required FWS Terms and Conditions which are determined from the ESA consultation, there could be unforeseen disturbances to polar beers that could result in a "may affect, likely to adversely affect" determination under the ESA With the application of the ROPs described above and required FWS ESA Biological Opinion Terms and Conditions, however, no biologically significant impacts to polar bears would be anticipat Last paragraph in Chapter 5 Polar Bear section. Space needs to be deleted an: Chapter 5 polar bears last paragraph has been changed significantly from what I wrote. I do not agree with these changes as they completely change my conclusion for the cumulative section. I know there is likely nothing that can be done but I would like it to be in the admin record that I do not agree with this wording change or witlt the new conclusion My original paragraph is below with the sections removed underlined Next paragraph is what is in the final Given the limited temporal and spatial framework of the current proposed activity, ng Given the limited temporal and spatial framework of the current proposed activity, cumulative effects to polar bears and their habitats would be less than significant from the incremental addition of winter seismic exploration in the Coastal Plain Debbie Fritz. Stacey-- Fri, Sep 14. 2018mm" PM set.-- I am troubled by numerous omission; from my sections In the tlnal EA reallxe that some or these changes were made throughout the review process. and I tor not being able to respond adequately before but there was a great deal of version contusion and changes to other sections that I could not review belore mine and other Issues associated with the review that complicated rrvy ability to respond. I can see that much language was omitted to comply with streamlining and page limits. However, I think it should have been considered thatl already sbeamllned and removed redundancy to a great extent: there was no Economy or Sociocultural systems I rolled any econ and socioculbural Into EJ, and furthermore mllad much at what would be in Chapters Into chapter to reduce redundancy. Therefore, a longer EJ sedlon. Irl ChapleN only. should have been fine as It was still much shorter than treating all those resources separately. It was decided there should not be an economy section bemuse it wasn't a resource that would be substantially Impacted. An economist should have made that determination and determined whether a specialists report would have been appropriate. I am not an economist but I think that a spndullsl's repon would have been appropriate and it should have Included a subsection on non-market values and that report should have been briefly section only brletly discussed Ioml economic Impacts as they relate to Ed. Even though an economy section was deemed not necessary. meet or the economy language in the Ed section has not been omitted. Instead. what was omitted was the EJ context or the proposed action ior tire two communities (I streamlined substantially by limiting my discussion to two communities. when In fact than is a far larger collection cl North Slop. and communities that would be Impar):ted - residents from several communities have testiiled about this in the Coastal Plain Lansing EIS meetingr. The llnel omitted the entire section otthe EJ discussion that discussed the Ed context for Kaklovlk and Arctic Village and that summarized the main reasons that residents or Kaktovlk support or do not support exploration In the Coastal Plain. We have already pone against ED 12898 by not conducting meaningful consultation with these EJ populations (that I am aware ct). but I tell Ihntl had based that discussion on solid research that acwreteh represented the views of the main EJ populations. Normally. we would discuss those impacts with than people to determine how eignitleent the Impacts might be and how best We Build mitigate them. I should note that we normally conduct govemmem--tc--goveinrnerlt consultation for large seismic projects In the NPR-A. theretore doing so would not have been extraordlnary. I removed the section on consultation that norrnelly Include In the ANILCA B10 analysis and In the subsistence end/or EJ sections. I contend that removing all at the language that I did submit on the Issues Is not In with the E0, which requires that tedersl apencler Identity and address Impacts activides on EJ populations. I realize that there Is little to be done atthla point and that my name will not appear as a preparer tor this document, however I do want It to be on the record that I oppose these omissions and am concerned that the BLM is not complying with guidance on tribal consultation and 50 12393. I am providing language I had provided in my tetest version below. Thank you very much tor the opportunity to provide my thoughts on the tlrtal EA Stacey As described in Chapter 3. the majority of residents in the communities that could be impacted by the proposed activity are uibnl members and therefore considered FJ populations. Broader analysis of El issuesessociated with seismic exploration ofthc area is complex because two different groups of Arctic indigenous residents (El populations) would be impacted differently. Cultural impacts tensions and distress associated with the political and environmental significance of the proposed activity being permitted, feelings of loss and distrust) would vary widely between them because the Arctic Rcfugc region is the focus of long-ninning and highly controversial indigenous-led struggles both against and for oil exploration and development. Following Council of Environmental Quality guidance on evaluating environmentaljusn'cc within NEPA (1997), the analysis should recognize if the question of whether agency action raises cuvironmerttaljusticc issues is highly sensitive to the history or circumstances of a particular community or population (CEQ, 1997, pg. 8) ELM therefore considers the following factors in determining whether the environmental effects of the proposed seismic survey would be disproportionately high and adverse: Whether there would be an impact on the natural environment that would significantly and adversely affects Native residents of Kaktovilr and/or Arctic Village. Such effects could include subsistence, ecological, cultural, human health, economic, or social impacts to Tribal members when these impacts are intcnelatcd to impacts on the natural and physical environment. A - Emmi" Aging Knktovilr The historical context within which environmental justice issues are considered for the Ifiupiat of the North Slope is discussed in the 2012 NPR-A Integrated Activity (Section 4.4.5). The history of the out because Kaktovik has been subjected to considerably greater adverse impacts from Federal actions than other North Slope communities. In summary, Kalrtovlk has been to: a Three forced village relocations, the first (1947) involving the bulldozing and loss of homes and ice cellars (Mikow, 2010; NSB 2015) I Military commandeering of Batter Island resulting in extensive environmental degradation of its land and water and dramatic and rapid transformation of the social, cultural, and economic traditions of the indigenous community (Chance 1990). I Decades of negotiating the processes of cleaning up contaminants and debris. 0 Failed efforts to seek compensation for the relocation: and environmental damage due to both ANCSA's cxtinguishment of previous land claims and an expired statute of limitations. 0 Limited land selection opportunities due to the establishment of the Arctic NWR, rota-lotions on some subsistence pracn'ces in the Arctic NWR, and public and political opposition to allowing the Qaslmigvigmiut to develop resources on its 1002 lands due to their location within Arctic NWR. Some Kaktovikmiut perceive themselves as refugees' whose right to economic development is unjustly thwarted by outside interest groups (cht'ord 2017). The seismic survey itself would not provide substantial economic benefits to local people because it is an investment to ascertain the oil and gas resumes in the area in anticipation of development. Kaktovilr rcsidenm could see some minor increased economic activity in their community due to the seismic operation (increased demand for local services and a few local jobs). According to the 2010 census, the median income in Kaktcvik is $53,750 and 3.8% of the population lives below the poverty line. These statistics are misleading in the context of remote Alaska communities, where the cost of living is significantly higher than in urban areas, Most food is flown in and is generally 146 percent higher. and can be double the cost, than in urban communities 2018). Subsistence foods, therefore, constitute a critical component of the economy. The Alaska Department of Labor and Workforce Development maintains a database of Alaskan communities that are economically distressedm, and approximately half of all Alaskan communities qualify as distressed by the standards used. Despite the high cost of living and the fact that a greater percentage of residens live in poverty reflected by census data, Kakalovik does not qualify as economically (Denali Commission 2017). If the proposed seismic survcy results in development of Native owned oil, most North Slope Inupiat. as shareholders in their Native corporations, would see economic benefits. This information is discussed within the scope of the El analysis for the proposed seismic survey to establish that the action does not a present a typical El situation wherein a project is imposed by outside industry near a minority population For those Inupiaq-led corporations, Kalnovik leadership entities. and residents who support the proposed action, it represents long overduejustice for the community. EJ evaluations also recognize sub-populations within FJ communities who perceive or would experience potential impacts differently. Some Kaktovik residents do not support the seismic survey. One assertion is that the ccnununily is essentially evenly divided (City of Kakiovik 2018), another is that the majority of Kaktovik adults who voted in the last election signed a community petition opposing oil development in the Coastal Plain (Thompson 2017). These residents may oppose the activity duo to concerns that include. but are not limited to: - Disruptions tn the Kektovik cultural landscape. The project's potential impact to subsistence use areas (the air, water. and land). Reduced access to and user avoidance of badltional subsistence use areas. Reduced value of traditional subsistence use areas. Potential disruption and deflection of subsistence resources (resource availability). Potential decreascd community participation and transmission of knowledge about the area. - Seismic exploration could lead to onshore oil development infrastructure which would facilitate offshore oil development in the Beaufort Sen. I 1ndusn-ial activity in the Refuge may endanger ecu-tourism and local wildlife viewing businesses that are increasingly prevalent in Kaktovikr Arctic Village Arctic Village Gwich'in have organized and led strong opposition to exploration and development in the Coastal Plain for several decades, usually in coordination with residents of other Gwicb'in communities that rely caribou from the Refuge. The Gwich'in Nation has passed numerous resolutions opposing oil exploration and development in the Arctic Refuge and they see the subject as a food security and human rights issue. Arctic Village residents depend heavily on harvesting animals from the Porcupine Caribou Herd (see Subsistence section). and the Gwicb'in people consider the hcrd's calving pounds on the Coastal Plain as sacred ground (Gwich'in Nation 1983). Their central concern is that industrial activity in the Coastal Plain will affect the abundance and/or migration patterns of the caribou. Arctic Village residents also produce numerous caribou products vests, parkns, slippers, etc.) for use. barter, customary trade, and sale. Residents In Arctic Wlage would not likely experience direct impacts from the seismic survey. however some believe that the movement or the seismic camp units across ihe tundra would result In damage to the land (habitat lor the Porcupine Caribou Herd) (John 2018). Residents have also expressed concerns about oil spills, air quality. and potential impacts to wolves and small mammals (John 2018). Many Gwich'in are experiencing socas. frtun'ation. and fear over the provisions of the Tax Act that require leaning in the region and that are compelling the proposed seismic survey: they see this as a struggle for their culture and way of life (Gamctt 2018). for the Gwich'in have described the permitting process itself an injustice, noting that many tribal leaders have spent their entire adult lives defending their people and their culture . The current permitting process is exacerbating long-held feelings of and disenfranchisemcnt for some residents. Rceidcnu of Arctic Village and other Gwich'in communities are not positioned to benefit economically from any increased local economic opportunities that may result from the proposed action. According to the 2010 census, the median income in Arctic Village is $25,000 and 46.7% of the residents live below the poverty line. As described above, these statistics are misleading in the context of remote Alaska communities. where the cost of living is significantly higher than in urban breast Arctic Village. according to the Alaska Department of Labor and Workforce Development, qualifies as economically distressed (Denali Commission 2017) The BMPs that would be established under may result in better communication with of Kaktovik about subsistence used and across and would avoid impacts ncer allotments. camps, and cabins on Federal lands within the proposed seismic survey area. For residents of Arctic thlagc and other Gwich'in communities. there would not be any difference regarding environmental justice issues under Alternative B. lithe seismic survey were not psnnitted, none of the anticipated impacts to El populations would occur. Oil companies would be less likely to lease and develop land owned by KIC and Public Land within the Coastal Plain. Many North Slope residents, leadership entities, and lnupiaq-led corporations would perceive the no action alternative as a continuation of injustice in that it would deny thorn their right to take necessary steps to develop their land, increase economic development in their communities, and maintain or increase dividends to shareholders. The no action altcmeiivc would alloy the current environmental justice concerns of Arctic Village and other Gwicb'in communities because no habitat for the Porcupine caribou would be and the no action altcmativc would likely oil development in the region. Data available on population. employment. and turning: is usctl to identify those Alaska communion: considmd "distressed". distressed rlalln is determined by comparing average income ol'a community to full-time minimum caminp, the percentage oftlic population earning full-time minimum wage earnings. and rte-sure ofthc percentage ofthc population engaged in year-round we" and salary employment (Denali Commission 2017 [duet-d leIi Vim) sucoy Fm. r=no uninvolved/subatomic. soon-tat Bureau crLend inmate Matt" 5 mei Mafl' -- Sent: 889 14 2018 09 44'44 (MDTD To: 'LaMarr. Sarah' -- -- -- Subject: (IMPORTANT - PLEASE READ EARLY) Re SEISMIC EA Update SEISMIC EA docx There are some lundamental Inaccuracxes In the se-smm EA now that some 01 the lush and water resources text has been moved around and changed lrom what I submmed These are 'errors" and not Simply things that I don't Ilke how Ihe wording has been changed It these things are not fixed to the DUDIIC release. the DUDIIC Will be bolh conlused and mislead about these Items And we also no doubt get comments back about these errors and have to spend substantral time re-explalmng and hung I also have a lew general comments that are not necessanly needing Immediate attentlon but should be looked at. Del-eve, Please see the attached document these EHOIS and comments. Thanks, Matthew