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
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