Oil & Gas Exploration License in Katalla and Controller Bay

Thank you to all that sent in your public comments.

Click here to read EPC's comment letter.

Some Suggested Comment Points:

• The Preliminary Finding is not in the Best Interests of the State of Alaska.
• The Copper and Bering fishery is a yearly renewable resource. This past season, the processors value was $24,328,501. This does not include the price paid to the fishermen, nor does it include the financial value of the fishery to all resellers worldwide. The value of these fisheries expands into the many multiple millions, and supports the region and resellers and community businesses worldwide.
• The 10 year average income for the processors is over $22 million per year. Risking a renewable resource in favor of a $1 million work agreement shows ineptitude, mismanagement and a severe lack of critical thinking.
• The Preliminary Finding does not address the magnitude of loss an oil spill and subsequent fishery closure would bring.
• There are no mitigation measures provided for any of the 537 existing commercial stakeholders in the event of loss of income due to impacts in the commercial fishery from oil and gas exploration activities within or adjacent to active commercial fishing districts.
• There is no oil spill response plan for the requested License region: The Copper River Flats, Bering River, and Controller Bay regions are not currently included within the Prince William Sound Subarea Contingency Plan for oil spill response, and there are currently only two Geographic Response Strategies within the Copper River Delta Zone, neither of which are east of Boswell Bay and the entrance to Orca Inlet.
• The dangers of seismic and sonar exploration and mitigation measures are not sufficient in the Finding. In the ocean, the enormous vessels involved in sonar exploration could easily interfere with fishing vessels. This is not to mention the streamers that might be a few kilometers long. The streamers with attached hydrophones and air bombs are usually towed at a depth within ten feet of the ocean surface. Studies show that salmon usually remain within the top ten meters of the water column, meaning they could easily be in close proximity to the tremendous acoustic blasts that are characteristic of marine sonar exploration. According to the first-hand account from an anonymous ExxonMobil employee, "gas bombs detonated in the water may disable, stun, or kill fish – depending on their size and distance from the boat. Explosions involved in exploration may also threaten any sensitive marine mammal species present. Whales will try to stay away because their hearing is so sensitive. Seals will follow closely behind these ships because they are eating the fish that have been killed by the blasts."
• The impacts of exploration activities and seismic testing on salmon eggs are outlined in Chapter 8. Mitigation measures provide for adjusting timing of seismic tests accommodate bird species within the area, but do not address concerns to fish within the License Area. There are no measures that mitigate for potential impacts to herring within the area, and the Alaska Department of Fish and Game blast criteria referenced in the Best Interest Finding only address impacts to fish in freshwater systems, whereas the Alaska Department of Fish and Game Division of Habitat does not have jurisdiction over blast criteria within marine environments, where seismic activity is most likely to occur. Recent aerial surveys by local ADF&G biologists have documented increasing amounts of herring spawn within the License Area, and seismic exploration may impact this recovering species in a negative manner.
• There is no way to clean up oil spills on the water or in the sea, or save the harmed animals.
  https://www.smithsonianmag.com/science-nature/oil-spill-cleanup-illusion-180959783/
• All currently-available oil spill response techniques appear inadequate for cleaning up oil in such a complex environment. The limited range and effectiveness of mechanical skimmers and the documented toxicity of chemical dispersants to marine life are examples of the shortcomings of oil spill response mechanisms.
• Draft Finding does not prohibit offshore, directional drilling, or pipelines in navigable waters.
• Increased vessel traffic, drilling platforms, pipelines, and associated tanker traffic directly within an active commercial fishery has the potential to displace current stakeholders from their historical fishing grounds, which have been sustainably commercially fished for well over 100 years.
• The region hosts some of the largest storms in the Gulf of Alaska, and has wiped out several previous attempts for oil infrastructure and production in the Katalla License region. There is decaying infrastructure, oil pools and rusting equipment still on Katalla.
• This License Area is a highly dynamic region, and local geography within the area subject to significant change from year to year. Frequent winter storms, , severe weather events, unpredictable tidal activity, intense currents, shifting channels and sandbars, all present challenges for any oil spill response activity. Spill responders would have difficulty maintaining boom formations for proper deflection and containment. It is improbable that oil spill responders would succeed in protecting these sensitive and critical habitat areas.
• The finding has no mitigation measures for the effects of rising seas and climate change. It does state on 3-10 that there is an estimate that infrastructure "will be damaged by increasing temperatures and projected sea levels costing up to $270 million dollars annually for estimated repairs."
• License Area encompasses 65,773 acres of state-owned land and lies primarily within state waters, and the DNR map indication shows an overlap of the Copper River Delta State Critical Habitat Area.
• The Finding does not address the historical or cultural significance of the region, not does it state allowances for any respect or protections of cultural Indigenous sites. The Eyak had a village called qaataalah at what is now called Katallah. There are Eyak and Tlingit place names surrounding the License area including on Kayak Island and the other smaller islands in the License area.
• The ecological values of this area are staggering. The Controller Bay ecosystem provides important habitat for an abundance of wildlife species, including herring, hooligan, wild salmon and whales. Additionally, the Bering River is a sub-watershed within the larger Copper River basin, which contains hundreds of square miles of marshes, lakes and braided rivers.
• The greater watershed that includes the License area is an enormous sanctuary for migratory birds and countless other wildlife species. Every year, in one of the largest bird migrations in the world, twenty million shorebirds and waterfowl of the Pacific flyway pass through or nest on the Delta. This migration event alone attracts international attention, visitors, and revenue deriving from ecotourism. There is no mention of mitigation measures for the abundance of wildlife that would be effected by accidents (such as fires, explosions) and oil spills.