A great sigh of relief could be heard all across Alaska's North Slope as word spread of Shell's decision to end its Chukchi drilling efforts.
The summer of 2015 has been filled with worry as Native Iñupiat across Alaska's North Slope faced an uncertain future as Shell drilled the Burger J exploration well at the edge of Hanna Shoal, a sensitive marine ecosystem and source of life-sustaining subsistence food for many.
"There are a lotta happy faces here in Barrow. Peace to the Ocean!!!", declared Gilford Mongoyak III from the North Slope village of Barrow, Alaska this morning. Mongoyak recently created the "No To Shell" Facebook group that rapidly gained over a thousand members and served to give voice and hope to Native Alaskans opposed to Shell's drilling campaign across the North Slope.
Mae Hank from the village of Point Hope, an outspoken advocate of Arctic Ocean protection for decades, pronounced, "Yes, mission accomplished from all the Warriors nationwide, united we stand we win one by one!" when asked about Shell's announcement to pull out of its Arctic drilling campaign earlier today.
Shell's operations interrupted daily life across the slope this summer serving as a stark reminder of the intense impacts that Village communities could expect from continued oil and gas development.
"We've seen a marked rise in opposition to Shell in front line Village communities, despite intense pressure from within to keep quiet", said Ceal Smith, co-founder of Chukchi Sea Watch. "People in Barrow are irate because Shell's helicopters scared caribou away from subsistence hunters gathering meat for the coming winter. Worries about toxic discharges surrounding the drill site and seismic testing disturbing the fall Bowhead whale hunt were widespread" said Smith. "Intense pressure and fear of reprisals kept people from speaking openly, but that changed as the season wore on and people realized they couldn't live under the Shell shadow".
Carl Jennings from Kotzebue summed up the feelings of many that, "Living
in the Arctic shows me daily why there shouldn't
be oil development that endangers our true sustainable resources, the
marine mammals and animals that have fed and clothed us for thousands of
years. We as a global community need to work towards clean renewable
energy".
Mark Gutman from Chukchi Sea Watch noted that, "Shell's 7 billion dollar gamble for its unproductive exploratory effort, along with unknown millions spent by permitting Federal agencies, are overshadowed by the extraordinary cost of oil spills and no proven ability to clean them up. The toxic discharge and harmful harassment of marine life, coupled with no capacity to clean or rescue animals once they become injured or contaminated along with the disruption of Native subsistence are all additional costs which should not be paid on Shell's behalf. We are glad to see Shell go."
"This pivot point is an ideal opportunity for the United States, as Chair of the U.N. Arctic Council, to advance renewable energy and a rapid transition away from fossil fuels as a priority among Arctic nations in addressing climate change", said Gutman.
Monday, September 28, 2015
Monday, September 21, 2015
FWS Polar Bear Draft Conservation Plan Comments
Chukchi Sea Watch commented on the US Fish and Wildlife Service Draft Polar Bear Conservation Plan filed with Fish and Wildlife Service this week...
Dear Ms. Colligan:
Please accept the following comments on behalf of Chukchi Sea Watch and our Associates. The mission of Chukchi Sea Watch is to protect communities and ecosystems of the Chukchi Sea and surrounding areas from potential threats, including but not limited to, climate change, industrial development and increased shipping. Chukchi Sea Watch is a collaborative of Iñupiat residents from North Slope communities, Alaskan citizens, scientists and others who value the biological richness and climate stabilizing capacity of the Chukchi Sea.
Loss of sea ice resulting from increased atmospheric green house gases (GHG) has been shown to effect polar bear survival in the southern Beaufort Sea[1] but polar bears do not appear to be declining in response to changes in sea ice in the Chukchi Sea[2]. More research is needed to understand differences in population responses to declining sea ice. We urge FWS to make a strong call for more research in the CMP and continue your work with US Geological Survey, North Slope Borough and other independent research institutions to further our understanding.
In the meantime, we agree that FWS should work with EPA and other Federal Agencies with the authority to provide clear, strong, rapid science-based guidance on the GHG cuts likely needed to sustain and recover polar bears[3].
We are alarmed by the disturbingly high likelihood of extinction allowed in the CMP that is out of step with basic principals of conservation biology. According to the “fundamental criteria,” polar bears in each ecoregion can be considered recovered even if the ecoregion has a 10% chance of quasi-extinction in 100 years. In addition, demographic criterion 3 that assumes recovery at a global population reduction of 85% from levels at the time of listing is seriously flawed as it would allow for the loss of entire polar bear subpopulations, including those in Alaska. We urge FWS to revise their analysis to ensure a 95% survival rate for Alaska polar bear populations for a minimum of 60% of the southern Beaufort and Chukchi populations at the time of listing.
The CMP provides recovery criteria for threats from sea ice loss, human-caused removals, and disease and parasites, but fails to include recovery criteria for key threats from oil and gas development, contaminants, shipping, human-bear conflicts, and declines in seal prey as required by the Endangered Species Act. We recommend that FWS require meaningful recovery criteria and actions for these threats, including ecosystem and critical habitat designation and conservation and geographically representative recovery as required by the ESA.
The CMP does not ensure that polar bears will remain at their Optimum Sustainable Population (OSP) level as required by the Marine Mammal Protection Act (16 U.S.C. § 1361(2). Consistent with the structure and purpose of the MMPA, OSP is based on a population’s historical carrying capacity before human exploitation of the population. However, the Service proposes a new interpretation that reduces OSP as climate change increases. This allows for massive population declines that are in conflict with MMPA.
The failure of the CMP to consider ongoing and future impacts from oil and gas development in the Chukchi Sea and surrounding Arctic is particularly glaring. Agency findings that oil and gas activities have had and will continue to have only negligible effects on polar bear population numbers is unsubstantiated and reflects the potentially undermining influence of industry over Chukchi Sea science[4].
Bureau of Ocean Energy Management have hundreds of active lease sales and will soon be undertaking a new five-year lease sale plan[5]. Ongoing Prudhoe Bay oil and gas industrialization and Royal Dutch Shell’s current offshore exploratory operation are surely having multiple, real time significant impacts on polar bear that will only increase with future expected oil and gas development.
We urge FWS to include a full assessment of oil and gas industrialization in the CMP that accounts for the multitude of expected impacts including, but not limited to, visual, acoustic and noise pollution, icebreaking, ship channeling, dumped drill cuttings, carbon monoxide, NOx emissions, VOCs, particulate matter and sulfur dioxide, invasive species, changes in prey availability and increased human-polar bear conflicts The alarmingly high risk of small and large oil spills associated with Arctic drilling comprise a long-term, irreversible threat to polar bears that could have devastating consequences for polar bear health, reproduction and long-term survival[6], [7] and potentially lead to subpopulation level extinction. To dismiss this considerable threat is negligent and irresponsible. It’s imperative that the CMP objectively and fully assess impacts from oil and gas industrialization on present and future polar bear survival despite pressure from the oil and gas industry not to do so.
Lastly, we urge FWS to call for the establishment of critical habitat in the CMP. The FWS published a final rule to designate critical habitat for the polar bear in 2010. Because the ESA prohibits destruction or adverse modification of designated critical habitat, the CMP should again call for this designation of critical habitat that will benefit polar bear recovery by the additional level of legal protection under Section 7 of the ESA. The significance of implementing critical habitat is further justified by studies showing that endangered species with critical habitat are twice as likely to be improving as those without[8], [9]. The addition of critical habitat to the CMP Conservation/Recovery Actions will provide important mitigation to sustain polar bears until GHG emissions and warming climate are contained.
We appreciate your consideration of these comments and look forward to working with FWS regarding polar bear conservation in the future. If you have any questions, please do not hesitate to contact us.
Sincerely,
Ceal Smith, MSci/Research Director
Mark Gutman, Biologist
Chukchi Sea Watch Anchorage, Alaska
[1] Bromaghin, J.F., McDonald T.L, et al. Polar bear population dynamics in the southern Beaufort Sea during a period of sea ice decline. Ecological Applications, 25(3), 2015, pp. 634-651
[2] Rode, K.D., Regehr, E.V, et al. Variation in the response of an Arctic top predator experiencing habitat loss: feeding and reproductive ecology of two polar bear populations. Global Change Biology, Vol 20, Issue I, pp 76-88, Jan 2014
[3] Amstrup S.C., et al., Greenhouse gas mitigation can reduce sea-ice loss and increase polar bear persistence. Nature. Vol 468, Dec 15, 2010. http://www.nature.com/nature/journal/v468/n7326/pdf/nature09653.pdf
[4] As Arctic drilling starts, Shell-funded researchers keep watch. Science 21 August 2015: Vol. 349 no. 6250 pp. 778DOI:10.1126/science.349.6250.778. http://policy.oceanleadership.org/as-arctic-drilling-starts-shell-funded-researchers-keep-watch/
[5] Bureau of Ocean Energy Management, Alaska OCS Region, August 10, 2015. Detailed Listing of Active Leases; http://www.boem.gov/Alaska-Detailed-Listing-of-Active-Leases/
[6] Kelkar, Kamala. How to de-oil a polar bear: Grim outlook for wildlife impacts from an Arctic spill. Arctic Newswire, Aug 15, 2015. http://www.adn.com/article/20150815/how-de-oil-polar-bear-grim-outlook-wildlife-impacts-arctic-spill
[7] Amstrup, et al. Estimating potential effects of hypothetical oil spills on polar bears. Alaska Science Center, US Department of Interior/US Geological Survey, March 2006. http://www.polarbearsinternational.org/sites/default/files/amstrup_et_al_mms_oil_spill_2006.pdf
[8] Taylor, M.F.J., et al. The effectiveness of the Endangered Species Act: A Quantitative Analysis. BioScience. 55(4): 360-367. 2005. http://www.bioone.org/doi/abs/10.1641/0006-3568%282005%29055%5B0360%3ATEOTES%5D2.0.CO%3B2
[9] Greenwald D.N., et al. Critical Habitat and the Role of Peer Review in Government Decisions. BioScience. 62(7): 686-690. 2012. http://www.bioone.org/doi/abs/10.1525/bio.2012.62.7.11
Dear Ms. Colligan:
Please accept the following comments on behalf of Chukchi Sea Watch and our Associates. The mission of Chukchi Sea Watch is to protect communities and ecosystems of the Chukchi Sea and surrounding areas from potential threats, including but not limited to, climate change, industrial development and increased shipping. Chukchi Sea Watch is a collaborative of Iñupiat residents from North Slope communities, Alaskan citizens, scientists and others who value the biological richness and climate stabilizing capacity of the Chukchi Sea.
Loss of sea ice resulting from increased atmospheric green house gases (GHG) has been shown to effect polar bear survival in the southern Beaufort Sea[1] but polar bears do not appear to be declining in response to changes in sea ice in the Chukchi Sea[2]. More research is needed to understand differences in population responses to declining sea ice. We urge FWS to make a strong call for more research in the CMP and continue your work with US Geological Survey, North Slope Borough and other independent research institutions to further our understanding.
In the meantime, we agree that FWS should work with EPA and other Federal Agencies with the authority to provide clear, strong, rapid science-based guidance on the GHG cuts likely needed to sustain and recover polar bears[3].
We are alarmed by the disturbingly high likelihood of extinction allowed in the CMP that is out of step with basic principals of conservation biology. According to the “fundamental criteria,” polar bears in each ecoregion can be considered recovered even if the ecoregion has a 10% chance of quasi-extinction in 100 years. In addition, demographic criterion 3 that assumes recovery at a global population reduction of 85% from levels at the time of listing is seriously flawed as it would allow for the loss of entire polar bear subpopulations, including those in Alaska. We urge FWS to revise their analysis to ensure a 95% survival rate for Alaska polar bear populations for a minimum of 60% of the southern Beaufort and Chukchi populations at the time of listing.
The CMP provides recovery criteria for threats from sea ice loss, human-caused removals, and disease and parasites, but fails to include recovery criteria for key threats from oil and gas development, contaminants, shipping, human-bear conflicts, and declines in seal prey as required by the Endangered Species Act. We recommend that FWS require meaningful recovery criteria and actions for these threats, including ecosystem and critical habitat designation and conservation and geographically representative recovery as required by the ESA.
The CMP does not ensure that polar bears will remain at their Optimum Sustainable Population (OSP) level as required by the Marine Mammal Protection Act (16 U.S.C. § 1361(2). Consistent with the structure and purpose of the MMPA, OSP is based on a population’s historical carrying capacity before human exploitation of the population. However, the Service proposes a new interpretation that reduces OSP as climate change increases. This allows for massive population declines that are in conflict with MMPA.
The failure of the CMP to consider ongoing and future impacts from oil and gas development in the Chukchi Sea and surrounding Arctic is particularly glaring. Agency findings that oil and gas activities have had and will continue to have only negligible effects on polar bear population numbers is unsubstantiated and reflects the potentially undermining influence of industry over Chukchi Sea science[4].
Bureau of Ocean Energy Management have hundreds of active lease sales and will soon be undertaking a new five-year lease sale plan[5]. Ongoing Prudhoe Bay oil and gas industrialization and Royal Dutch Shell’s current offshore exploratory operation are surely having multiple, real time significant impacts on polar bear that will only increase with future expected oil and gas development.
We urge FWS to include a full assessment of oil and gas industrialization in the CMP that accounts for the multitude of expected impacts including, but not limited to, visual, acoustic and noise pollution, icebreaking, ship channeling, dumped drill cuttings, carbon monoxide, NOx emissions, VOCs, particulate matter and sulfur dioxide, invasive species, changes in prey availability and increased human-polar bear conflicts The alarmingly high risk of small and large oil spills associated with Arctic drilling comprise a long-term, irreversible threat to polar bears that could have devastating consequences for polar bear health, reproduction and long-term survival[6], [7] and potentially lead to subpopulation level extinction. To dismiss this considerable threat is negligent and irresponsible. It’s imperative that the CMP objectively and fully assess impacts from oil and gas industrialization on present and future polar bear survival despite pressure from the oil and gas industry not to do so.
Lastly, we urge FWS to call for the establishment of critical habitat in the CMP. The FWS published a final rule to designate critical habitat for the polar bear in 2010. Because the ESA prohibits destruction or adverse modification of designated critical habitat, the CMP should again call for this designation of critical habitat that will benefit polar bear recovery by the additional level of legal protection under Section 7 of the ESA. The significance of implementing critical habitat is further justified by studies showing that endangered species with critical habitat are twice as likely to be improving as those without[8], [9]. The addition of critical habitat to the CMP Conservation/Recovery Actions will provide important mitigation to sustain polar bears until GHG emissions and warming climate are contained.
We appreciate your consideration of these comments and look forward to working with FWS regarding polar bear conservation in the future. If you have any questions, please do not hesitate to contact us.
Sincerely,
Ceal Smith, MSci/Research Director
Mark Gutman, Biologist
Chukchi Sea Watch Anchorage, Alaska
[1] Bromaghin, J.F., McDonald T.L, et al. Polar bear population dynamics in the southern Beaufort Sea during a period of sea ice decline. Ecological Applications, 25(3), 2015, pp. 634-651
[2] Rode, K.D., Regehr, E.V, et al. Variation in the response of an Arctic top predator experiencing habitat loss: feeding and reproductive ecology of two polar bear populations. Global Change Biology, Vol 20, Issue I, pp 76-88, Jan 2014
[3] Amstrup S.C., et al., Greenhouse gas mitigation can reduce sea-ice loss and increase polar bear persistence. Nature. Vol 468, Dec 15, 2010. http://www.nature.com/nature/journal/v468/n7326/pdf/nature09653.pdf
[4] As Arctic drilling starts, Shell-funded researchers keep watch. Science 21 August 2015: Vol. 349 no. 6250 pp. 778DOI:10.1126/science.349.6250.778. http://policy.oceanleadership.org/as-arctic-drilling-starts-shell-funded-researchers-keep-watch/
[5] Bureau of Ocean Energy Management, Alaska OCS Region, August 10, 2015. Detailed Listing of Active Leases; http://www.boem.gov/Alaska-Detailed-Listing-of-Active-Leases/
[6] Kelkar, Kamala. How to de-oil a polar bear: Grim outlook for wildlife impacts from an Arctic spill. Arctic Newswire, Aug 15, 2015. http://www.adn.com/article/20150815/how-de-oil-polar-bear-grim-outlook-wildlife-impacts-arctic-spill
[7] Amstrup, et al. Estimating potential effects of hypothetical oil spills on polar bears. Alaska Science Center, US Department of Interior/US Geological Survey, March 2006. http://www.polarbearsinternational.org/sites/default/files/amstrup_et_al_mms_oil_spill_2006.pdf
[8] Taylor, M.F.J., et al. The effectiveness of the Endangered Species Act: A Quantitative Analysis. BioScience. 55(4): 360-367. 2005. http://www.bioone.org/doi/abs/10.1641/0006-3568%282005%29055%5B0360%3ATEOTES%5D2.0.CO%3B2
[9] Greenwald D.N., et al. Critical Habitat and the Role of Peer Review in Government Decisions. BioScience. 62(7): 686-690. 2012. http://www.bioone.org/doi/abs/10.1525/bio.2012.62.7.11
Labels:
Alaska,
Chukchi Sea,
draft conservation plan,
polar bear
Sunday, August 9, 2015
Drilling in the Chukchi Sea: Is Shallow Safer?
Shell's Fennica icebreaker on it's way to Burger J. Capping stack in front |
Shell's cavalier attitude towards Arctic drilling is reflected in the following remarks made by Shell's top Executive for the Arctic, Ann Pickard, in a recent interview with Bloomberg Business News:
"the Burger J prospect lies beneath only 140 feet of water, and its crude oil reservoir is under relatively low pressure as these things go.
In contrast, BP’s ill-fated Macondo well lay beneath a mile of ocean and was under extremely high pressure.
“The blowout scenario is quite different than the case of BP’s Macondo,” Pickard says. Burger J “is the kind of thing we’ve done all over the world for decades.”Of course the Gulf of Mexico is not prone to massive ice flows, fierce out of the blue storms or raging winds. Nor is it summer foraging ground and nursery to a large proportion of the planet's walrus, beluga and bowhead whale populations that have sustained Native Alaskans for millennia. Neither is it warming, according to various estimates, 2-4 times faster than the rest of the planet as a direct consequence of our overindulgence of fossil fuel.
Setting aside these apparently trival differences, we asked a very narrow question in terms of expected well pressures and Worse Case Discharge scenarios: is off shore drilling in the shallow Chukchi Sea really safer than drilling in the deep waters of the Gulf?
This is what we found.
Chukchi Sea Not a Low Pressure Field
To begin with, using depth of water as an indicator of wellhead pressure, as Shell's top Arctic Executive does, is backwards. Five thousand feet of water weighs much less than five thousand feet of compressed subsurface strata (rock and mud). For two equally deep wells, the one that has significantly deeper water but correspondingly less subsurface strata will have lower bottom-of-hole formation pressure, not higher, as Pickard implies.
It's not clear that the Burger J well will be shallower than the Macondo well since Shell declined to make their targeted well depth public, claiming it's Shell's "proprietary" information.
Shell's most recent Worst Case Discharge (WCD) estimate (see Table below) predicts an initial flow rate of 23,100 bbls/day; barely 37% of the initial Macondo flow rate of 62,000 bbls/day (1).
Table 2.g-1 from From Shells March 2015 Exploration Plan |
Assuming the WCD flow rate would be roughly proportional to the pressure difference between Macondo and Burger J, a more realistic WCD flow rate from Burger J would be between 50,200 and 92,400 bbls per day -- as compared to Shell's estimate of 23,100 bbls/day and of the Macondo's 62,000 bbls/day.
It should be noted that Shell's capping stack is only rated for 25,000 bbls/day maximum.
The Chukchi Sea is also thought to have a much greater proportion of gas to oil than the Gulf of Mexico where the gas pocket sank the Deepwater Horizon. It would follow that the Chukchi also has a greater risk of disaster than the Macondo prospect resulting in a greater magnitude WCD.
The Deepwater Horizon in flames before it sank. |
Math Geek Alert: Our Calculations
The formation pressure is roughly dependent on depth and how heavy everything above it is (as well as a number of geological factors which can affect the pressure, but generally...).
We can calculate and compare the minimum expected formation pressures of the Deepwater Macondo and Burger J by adding the pressure of the water plus the pressure of the subsurface strata for each (sea water weighs .44 pounds per square inch (psi) per foot of depth, and subsurface strata (layered zones of sandstone/slate/shale, etc) weighs around 1.15 psi per foot of depth).
The Deepwater/Macondo Well
The Deepwater Horizon was in 5,067 feet of water, and the well was bored through an additional 13,293 feet into the subsurface strata below the bottom of the ocean. Therefore, the well went to a total depth of 18,360 ft.
Therefore, the formation pressure at the bottom of the Macondo well was ~17,516 psi
The math: (5,067 ft x .44 psi) + (13,293 ft x 1.15 psi) = 17,516 psi
The rate of discharge at the wellhead is roughly proportional to net formation pressure at the wellhead (all else being equal). To get that number, we subtract the ocean bottom water pressure and the weight of the column of oil (let's assume .40 psi per foot of depth) in the well from the formation pressure at the well bottom.
Therefore, net formation pressure at the Macondo wellhead was ~9,969 psi
The math: 17,516 psi - [(5,067 ft x .44 psi) + (13,293 ft x .40 psi)] = 9,969 psi
The Chukchi Sea/Burger J Well
Shell is drilling the Burger J well as we write. It can't drill into the zone where oil and gas is expected to be encountered until the famed Fennica arrives with the capping stack (a second-tier emergency device intended to stop an oil spill in case the blowout preventor fails).
The ocean is 140 feet deep at the Burger J site. We can estimate that Shell will drill to at least 11,000 ft and not more than 20,000 ft -- the rating limit of both of Shell's drill rigs (although Shell hasn't publicly revealed the maximum depth they intend to drill -- this information is tagged "proprietary").
Therefore, the minimum net formation pressure at the Burger J wellhead is ~8,083 psi
The math:
(140 ft x .44psi) + (10,860 x 1.15 psi) = 12,489 psi
12,489 psi - [(140 ft x .44 psi) + (10,860 ft x .40 psi)] = 8,083 psi
This turns out to be around 81% of the wellhead pressure at Maconda.
The maximum net formation pressure at the Burger J wellhead is ~14,895 psi
The math:
(140 ft x .44 psi) + (19,860 ft x 1.15 psi) = 22,900 psi
22,900 psi - [(140 ft x .44 psi) + (19,860 psi x .40)] = 14,895 psi
This turns out to be about 149% of the wellhead pressure at Maconda.
Taking the relative formation pressures as a rough measure of relative initial flow rates, we get a potential Chukchi WCD flow rate of between 50,220 and 92,380 bbls/day. Compare this to Macondo's initial flow rate of 62,000 bbls/day.
The math:
62,000 bbls/day x 81% = 50,220 bbls/day
62,000 bbls/day x 149% = 92,380 bbls/day
The math on how many days it would take Shell to shut off a blown out well-head from a large, high pressure reservoir is anybodies guess.
If, like with the Deep Water Horizon, a random spark ignites the gas causing the entire rig to explode and sink, the shallow ocean turns out to have a vastly different consequence.
Shell's Noble Discoverer Drilling Rig (drilling Burger J now) |
The math:
Add the regulators (BOEMs) own calculation of a 75% probability of a catastrophic oil spill (should the Alaskan Arctic lease fields be fully developed) with the hard scientific fact that Arctic hydrocarbons must stay in the ground if we are to avoid 2 degrees Fahrenheit of planetary warming, and you get 100% chance of undoing Alaska's subsistence-based coastal village cultures and ensuing global chaos.
References
(1) Assessment of Flow Rate Estimates for the Deep Water Horizon/Macondo Well Oil Spill, National Incident Command, Interagency Solutions Group, Flow Rate Technical Group.
Labels:
Alaska,
Arctic drilling,
Burger J,
Chukchi Sea,
Royal Dutch Shell,
Shell
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