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Oil Spill Response and Cleanup Impossible in Alaska’s Beaufort and Chukchi Seas We must not move forward with the existing drilling proposals in the Arctic Ocean. There is currently too little sound scientific information about this unique marine ecosystem given the rate of rapid climate change. The threat of a catastrophic oil spill, like the one in the Gulf of Mexico, presents too great a risk to Arctic resources that support wildlife and Alaska Native subsistence way of life. Beaufort Sea oil drilling threatens the fall bowhead whale migration corridor, polar bear habitats, and the Arctic National Wildlife Refuge coast. In the Chukchi, open-water leads provide unique yearround feeding grounds and pathways for migrating bowhead and beluga whales, fish, and birds along the Chukchi coast. Oil spills and noise disruption threaten vital subsistence resources and wild coasts. Oil spills are an inevitable part of oil drilling, production and transportation. As the Deepwater Horizon demonstrates, oil spill response, containment and “cleanup” are challenging at best, even in the milder mid-latitudes of the Gulf of Mexico where industry has oil spill response infrastructure and technology on hand. Despite recent federal assertions that “the vast majority” of oil is no longer a threat to the gulf ecosystem, 1 prominent marine scientists analyzing the same data conclude that nearly 80 percent of the oil spilled into the Gulf of Mexico has not been recovered and remains a threat to the ecosystem. 2 The bottom line is that it is impossible to effectively “clean up” a major marine oil spill anywhere. And as challenging as it has been to respond to the Deepwater Horizon disaster, it would be much more challenging off the coasts of Alaska’s Beaufort and Chukchi seas. As NOAA recently noted, “[r]ecovery rates of spilled oil in optimum situations (calm weather, in a harbor, rapid response) rarely exceed 20 percent, and response to spills in ice in remote areas is substantially more challenging. On-scene response efforts may take days to weeks to implement, and are rarely effective.” 3 Even once response efforts are launched, it could take up to three years to cap a blown-out well in the Arctic. 4 If a large oil spill happened in the Chukchi or Beaufort seas, industry could not effectively contain or recover the oil, putting Alaska’s Arctic Ocean and the people and species that depend on it at risk. Here’s why: 1. Alaska’s Chukchi and Beaufort seas experience some of the harshest weather on earth. Summers are characterized by week-long storms, high winds, heavy fog that restricts visibility and temperatures in the 40s. Winter brings months of darkness, extreme cold, wind, intense storms and moving pack ice.                                                          1 3 NOAA Comments to Draft Proposed Five Year OCS Lands Act Program, 2010-2015 (Sept. 21, 2009) at 6. 4 2

2. There is no proven technology to remove spilled oil from Arctic waters. The sea ice that persists for most of the year in the Beaufort and Chukchi seas renders the proposed methods for removing oil from the marine environment – mechanical response 5 and in-situ burning 6 – ineffective. Recent research in oil spill recovery in ice-covered waters has not been tested outside of a very controlled setting and in the wide-ranging conditions that might be present in the Beaufort and Chukchi Seas. 7 The inability to detect oil spilled in and under ice in the most common Arctic conditions remains a major technical challenge. 8 For a more detailed analysis of the inadequacies of oil spill response technologies in Arctic offshore conditions, please refer to the World Wildlife Fund report, “Not So Fast: Some Progress in Spill Response, but US Still Ill-Prepared for Arctic Offshore Development,” at 3. The Beaufort and Chukchi seas lack sufficient response assets and infrastructure. The Deepwater Horizon spill occurred in the Gulf of Mexico where there is a significant cache of equipment, personnel, resources and onshore infrastructure to respond to a spill. No such infrastructure exists in Alaska’s Beaufort and Chukchi seas, which are in remote parts of the state with very little to no onshore infrastructure to support spill response. There is one road leading to Prudhoe Bay on the Beaufort Sea coast, and no roads or large airports on the Chukchi Sea coast. The nearest Coast Guard station is more than 1,000 miles away in Kodiak, AK; indeed, the U.S. Coast Guard has acknowledged that it lacks adequate response capability to contain and clean up an oil spill in sea ice. 9 Industry lacks adequate equipment for responding to a large spill off the Beaufort and Chukchi coasts, and much of its spill response equipment is more than 20 years old. Ice class tugs and barges are not available in Alaska at this time 4. Industry is overselling its ability to respond, contain and clean up an oil spill in Alaska’s Beaufort and Chukchi Seas. The last test of industry’s preparedness for an offshore oil spill in Alaska’s Arctic took place ten years ago on the Beaufort Sea coast.                                                          5

National Research Council (NRC). (2003). Board on Environmental Studies and Toxicology and Polar Research (BESTPR).Cumulative environmental effects of oil and gas activities on Alaska’s North Slope. The National Academies Press. Washington, DC. at 218 (noting that in the 2000 Beaufort Sea trials in broken ice, ice coverage of over 1% during freeze-up actually jammed up the equipment.) 6 "In-situ burning has not been demonstrated in actual field tests to be effective in ice coverage above 30% or below 70%. Above 70% coverage, sea ice may provide natural containment, although the sea ice may transport oil great distances so that it is unavailable for response once spring break up occurs. At higher ice concentrations, significant logistical, technical, and safety challenges remain in tracking, accessing, and igniting the oil slicks and recovering burn residues. " (DeCola, Robertson, Fletcher, Harvey 2006). 7 Sorstrom, S.E., P. J. Brandvik, E. Buist, P. Daling, D. Dickins, L-G. Faksness, S. Potter, J.F. Rasmussen, and I. Singsaas. 2010. Joint industry program on oil spill contingency for Arctic and ice-covered waters. Report No. 32. Sintef A14181. ISBN-nr: 978-82-14-04759-2. 40p. 8, “Arctic Oil Spill Response Research and Development Program, A Decade of Achievement,” MMS, page 10. 9 Senate Hearing 111-259, “Strategic Importance of the Arctic in U.S. Policy”. U.S. Senate Subcommittee of the Committee on Appropriations. August 20, 2009, Anchorage, AK.

BP had major problems responding to a mock oil spill, yet that was the last time the state required BP or any other oil company to test oil spill response capabilities in the Beaufort or Chukchi seas. Since then, industry has funded its own studies, using them as the basis for asserting it can respond and “clean up” an oil spill in Arctic waters. Shell claims it can effectively remove oil from the icy waters of Alaska’s Beaufort and Chukchi seas based on interim findings from tests conducted off the coast of Norway in favorable spring conditions. The findings are limited in scope, have not been peer reviewed, and do not prove oil can be removed from the icy waters of the Beaufort or Chukchi seas under normal conditions. In fact, the overwhelming body of evidence supports the consensus from Arctic nations that oil spill response, containment and recovery in Arctic offshore conditions is “extremely challenging,” “limited,” and “unreliable and untested.” 10 Additional Resources Oil response capabilities in the Arctic fact sheet – _Response_Fact_Sheet.pdf Arctic Values Map (shows important wildlife use areas on land and in the Chukchi and Beaufort seas) – Audubon Arctic Marine Atlas maps (background info on wildlife, ocean and ice characteristics, and human use) –


“Arctic Marine Shipping Assessment 2009 Report,” Arctic Council, page 138.