April 9, 2007
Dr. Rosa Meehan
U.S. Fish & Wildlife Service
Marine Mammals Management Office
1011 East Tudor Road
Anchorage, AK 99503
Attention: Polar Bear Finding
Dear Dr. Meehan:
These comments are submitted on behalf of the Resource Development Council for Alaska, Inc., (RDC) in response to the U.S. Fish and Wildlife Service’s (FWS) request for public comments on the proposed rule to list polar bears as threatened under the Endangered Species Act (ESA). RDC strongly opposes the proposed rule as the polar bear is clearly not a species in need of recovery, given its healthy population status and extensive protections now in place.
RDC is a statewide, non-profit business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, tourism and fisheries industries. RDC’s membership includes Alaska Native corporations, local communities, organized labor and industry support firms. Our purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through responsible resource development.
RDC and its members support ongoing polar bear research, management and conservation. A number of our members include major industry stakeholders operating within the historic and current range of the polar bear. These stakeholders have been major contributors to the extensive research conducted on polar bears and have played a significant role in advancing the scientific community’s understanding of the polar bear and its habitat.
While the matter of global warming requires continued monitoring, a proposed listing of the polar bear under the ESA is not warranted, for a number of reasons, including the following:
- Polar bears are abundant and their population in Alaska is healthy in size and distribution. The polar bear continues to occupy its entire historical range and it is extremely adaptive to change.
- The listing is premised on the presumption that sea ice is the most important factor for survival of polar bears, but models relied upon to justify the listing do not consider key population factors which show the bears are highly resilient and adaptable to change.
- Polar bears and their habitats are sufficiently managed and protected by international and domestic agreements, conservation programs, regulatory mechanisms and laws, including the Marine Mammal Protection Act.
- The proposed rule is based on highly-speculative risks outlined in highly uncertain carbon emission scenarios and climate change models.
In addition, RDC is concerned about a polar bear listing for a number of reasons, including:
- A listing of polar bears under the ESA could result in severe unintended economic consequences to both the national and Alaska economies and significantly impact U.S. energy production.
- The listing could jeopardize the Alaska Natural Gas Pipeline.
- The proposed action could lead to scores of other listings of species that might be impacted by climate change, overwhelming the FWS and adversely impacting local economies.
- The listing would have a disproportionate and adverse impact on arctic residents and industries that operate in the region.
- It is not clear how or if a listing would help polar bears. Given the limitations of the ESA itself, the listing will not stop sea ice from melting.
These factors and concerns place this species in a position where an ESA listing cannot be justified.
Population is healthy in size and distribution
The proposed rule is unprecedented in that it would invoke the ESA to list a species whose population worldwide has more than doubled over the past 40 years, a strong indication protections in place today are effective in protecting polar bears and their habitat.
No species has ever been listed under the ESA where the scientific consensus indicated the species continued to occupy its entire historical range at sustaining population levels. In Alaska, polar bears are abundant and are near historic population highs. Worldwide, the population has increased from 8,000-10,000 between 1965-1970 to as many as 25,000 today. Of all the animals and plants currently listed, no listings occurred when the animal or plant was at the level of health the polar bear finds itself in today.
In its petition to list the polar bear under the ESA, the Center for Biological Diversity (CBD) claims that the species’ current health is irrelevant. It argues that climate change will threaten polar bears in the future. However, the leading indicators of a species risk in ESA listings are current population, trend and the range of the species. Because of their healthy status in these leading indicators, a listing of the polar bear would be unprecedented.
In Alaska, many Inupiat Eskimos, who have life-long experience with arctic sea ice and polar bears, do not believe the bears are in danger of extinction. In fact, arctic coastal residents continue to see many of the great white bears and have not observed a decline in numbers or range.
Any analysis about the healthy status of polar bear populations should include the traditional and historical knowledge of arctic residents. This knowledge clearly demonstrates that polar bears continue to occupy their entire historical range at healthy and sustaining levels. Additionally, traditional knowledge has taught local residents that polar bears are extremely adaptive and opportunistic.
Beyond Alaska, in the Canadian far north, Nunavut has or shares 12 of 19 polar bear populations numbering about 15,000 of the world total of approximately 25,000. Most of these populations are abundant, productive and sustaining at current harvest levels. Only one, Western Hudson Bay, has been identified as having been reduced by the effects of climate change and other factors. The study that provided this result was one that did not search the entire summer-retreat area used by this population in open water season. In 2006, the Canadian Polar Bear Technical Committee agreed the area missed needed to be surveyed before the results could be accepted as final. Inuit hunters in this area have reported significant numbers of polar bears in the areas not searched. According to the study, the population has only been reduced by 250. Is the reduction due to population decline or a shift in distribution?
The worst-case scenario for reduction in ice cover from the International Intergovernmental Panel on Climate Change (IPCC) still shows summer ice in the Canadian Arctic Archipelago and winter sea ice for most of the current range of polar bears within their 50-year projections. (The time frame for ESA status determination is three generations – which for polar bears is about 45 years.) Even if the Hudson Bay population disappeared, there would still be more than half of the world’s polar bears inhabiting areas that are not predicted to go ice free in the summer, under worst-case projections. Even with the total loss of summer sea ice, the bears are likely to survive the current warming period, as they have other past warming and cooling cycles.
Consistent with the healthy status of the polar bear population worldwide and recognizing the extensive protections already in place, there is no nation that has listed the polar bear or any of its prey species as endangered or threatened. With 55 to 65 percent of the world’s polar bears and home for 14 of 19 identified populations, Canada has been closely studying and monitoring polar bears. Polar bears have been evaluated under Canada’s Species At Risk Act (SARA) and the most recent status review put polar bears in the “Not at Risk” category. Canada’s assessment of the polar bear is particularly relevant, given the number of polar bears in Canada and their extensive range across the northern territories.
Models used to justify the listing do not consider other key factors that show polar bears are highly resilient and adaptable to change
The proposed rule was based on models depicting the loss of arctic sea ice and did not include modeling of polar bear population factors such as terrestrial habitat use and food sources for the month or so of potential ice-free conditions along the coast in late summer. Modeling should more fully address the adaptability of polar bears to alternative sources of food and denning options. Considering the fact that polar bears are highly adaptable, have survived at least two major warming periods in their existence and are currently at historic high population levels, it is highly unlikely sea ice loss will cause a devastating decline in polar bear numbers or critical habitat. Therefore, further modeling of population data and other parameters must be conducted.
Based upon the best available science and commercial information, the FWS must evaluate the species’ population size, distribution and health, as well as its proven ability to adapt to changes in its habitat. These factors, measured over time, are the best available indicators that a species is not threatened. The FWS should not ignore or discount the current health and distribution of polar bears in deciding whether or not to list.
Richard Glenn, an Inupiat Eskimo who has studied the polar bear in many ice environments, offered his personal observations in testimony presented at a public hearing in Barrow, Alaska on March 7, 2007. His observations are particularly relevant because they represent valuable historical and traditional knowledge from one who is familiar with sea ice environments and polar bear behavior.
Mr. Glenn spoke of the importance of the marginal ice zone (near-shore) to polar bears, as well as their onshore habitats, where he said the bears are known to travel more than 60 miles inland, even when ice conditions would have allowed them to roam offshore. Mr. Glenn noted polar bears not only thrive in the marginal ice zone, but spend considerable time onshore in summer months feeding on walrus, seals, and dead grey whales washed up on to beaches. The remains are simply a part of their natural feeding cycle, Mr. Glenn said. He emphasized, “There is a yearlong and varied cycle of habitat, ice environment, prey animals and food sources for polar bears in our region, including marginal ice zones, shorelines, inland areas, leads and multi-year ice. A polar bear is at home in the water, on the ice, and on the land. Polar bears have adapted, and adapt each year to changing habitat, prey and other food sources.”
Mr. Glenn’s observations are important because the models used to justify the proposed listing are based heavily on the loss of summer arctic sea ice. In fact, the loss of sea ice was used as the only important factor for survival of polar bears.
The State of Alaska in its preliminary comments on the proposed rule took exception to the presumption that sea ice is the most important factor for the survival of polar bears. The State agreed with the Inupiats that polar bears do not use the majority of the ice cap, but favor near-shore ice, and that any warming of the arctic may create new near-shore ice or other suitable habitat for the bears. The State also noted polar bears are adaptable to use land for hunting and to den. Data from several areas indicate that bears are already adapting to alternative food sources, including some that may be expanding. Polar bear survival may in fact be more dependent upon snow for denning than on the presence of sea ice.
Polar bears and their habitats are well managed and protected
Polar bears and their habitat are well managed and protected by numerous international and domestic agreements, regulatory mechanisms and laws, including the Marine Mammal Protection Act (MMPA), the National Environmental Policy Act, the Outer Continental Shelf Lands Act and coastal zone management programs at the federal, state and local levels. These extensive legal authorities and agreements make the polar bear one of the most protected species in the world, and provide more than adequate basis for addressing realistic threats. In fact, these regulatory mechanisms have resulted in the successful conservation and management of polar bears on a global scale. One only needs to look at population levels today and compare them to 30 years ago.
Historically, there has been virtually no impact on polar bears from oil and gas activities in Alaska. In fact, the sustained and continuing growth of the polar bear population for the past 30 years has coincided with the development of the oil and gas industry on the North Slope. Mitigation measures, existing regulatory mechanisms and conservation programs can continue to offset the effects of oil and gas development in the arctic.
Planning and training requirements set forth in current regulations have increased polar bear awareness among industry personnel and have minimized human-bear encounters. No lethal take associated with North Slope industrial activities has occurred during the period covered by incidental harassment regulations, which include measures that minimize impacts to the species.
The proposed rule is premised on the impact of global climate change on arctic summer sea ice and it partly justifies a listing by concluding there are no adequate regulatory mechanisms to control sea ice recession. The latter point is often used by proponents of the rule who claim current laws and regulations are insufficient in addressing sea ice recession. Yet the proposed rule provides no discussion on of the causes of climate change, the role of carbon emissions or the highly-acknowledged uncertainties regarding the timing and extent of climate impacts. The FWS has even conceded its lack of expertise in these issues and has said it does not intend to address carbon emissions or other issues of global climate change.
RDC strongly opposes using the ESA as a mechanism to regulate sea ice recession. The law gives the FWS virtually no room to address the broader issues that may be causing receding ice. Moreover, the FWS cannot regulate sea ice recession without a conclusive cause and effect analysis linking reliably predictable facts to future changes in climate and its effects on summer sea ice. While climate change deserves close monitoring and attention, the broader issues of legislating and regulating carbon emissions should play out through Congress, and not the back door of the ESA.
Proposed listing is based on speculation and highly uncertain modeling
The Proposed Rule is unprecedented in that it is based on highly-speculative risks outlined in carbon-emission scenarios and various climate change models. Moreover, there is a current lack of science demonstrating in a reliable manner that polar bears are likely to become extinct in the foreseeable future. A key principal issue in this debate is whether the extent and pace of summer sea ice decline in the Arctic over the next century is reliably predictable and, if so, is likely to threaten the polar bear with extinction.
Under the ESA, a species is considered “threatened” if it is likely to become endangered within the foreseeable future throughout all or a significant portion of its range. The terms “likely” and “foreseeable future” create a statutory requirement that the best scientific and commercial data reliably demonstrate that endangerment of the species is probable, not merely possible. An ESA listing cannot be based on the mere existence of a risk factor – in this case the very uncertain risk posed by possible future scenarios of global climate change.
The CBD petition and proposed listing are both based on selective use of carbon-emission scenarios and climate change modeling projections. In fact, they primarily used models that predict more rapid loss of summer sea ice than other probable models. Additionally, the modeling does not consider the polar bear’s ability to adapt to changing conditions as it has in at least two previous warming cycles.
It is important to note there is no consensus on whether any one of the scenarios or models is more likely to occur over another. Both the IPCC and the Arctic Climate Impact Assessment did not intend for the emission scenarios to be predictive, but to present a broad and full range of potential futures to assist in understanding how climate change might occur if a set of complex assumptions ultimately prove true. In fact, the IPCC disclaims any contention that the climate change scenarios presented are “likely” to occur. As a result, the use of any one scenario as the scientific basis to justify a listing is just plain wrong. Moreover, key uncertainties in both the emission scenarios and the climate response models make it impossible to reach reliable conclusions so as to support a listing. Given the highly-speculative nature of climate models and emission scenarios, it is virtually impossible to say with any certainty that polar bears are likely to become extinct in the foreseeable future.
A decision on whether or not to list polar bear should be based on what we do know: the fact the species’ is healthy in population size and distribution, existing laws and regulatory mechanisms are working, polar bears are highly adaptive to change (as history has proven) and they are one of the most protected species in the world.
Carbon dioxide and global climate change
The world is warming and sea ice is retreating, but the key question is, “What truly is causing global warming?” We do not know with any certainty the cause behind our warming climate. Given the limited information at hand, it takes a leap of faith to conclude CO2 emissions are a significant factor in global warming or that humans can truly influence it. While the current popular hypothesis links increasing CO2 concentrations in the atmosphere with the rise in global temperatures, some scientists do not attribute the CO2 increase to the use of fossil fuels. While not the prevailing view, they believe it is unlikely that future increases in CO2 content will produce any significant global warming.
A position paper written by C.D. Idso and K.E. Idso of the Center for the Study of Carbon Dioxide and Global Change notes correlation between CO2 and temperature proves nothing about causation. The paper stated:
“Proponents of the notion that increases in the air’s CO2 content lead to global warming point to the past century’s weak correlation between atmospheric CO2 concentration and global air temperature as proof of their contention. However, they typically gloss over the fact that correlation does not imply causation, and that a hundred years is not enough time to establish the validity of such a relationship when it comes to earth’s temperature history.
“The observation that two things have risen together for a period of time says nothing about one trend being the cause of the other. To establish a causal relationship it must be demonstrated that the presumed cause precedes the presumed effect. Furthermore, this relationship should be demonstrable over several cycles of increases and decreases in both parameters. And even when these criteria are met, as in the case of solar/climate relationships, many people are unwilling to acknowledge that variations in the presumed cause truly produced the observed analogous variations in the presumed effect.
“In thus considering the seven greatest temperature transitions of the past half-million years – three glacial terminations and four glacial inceptions – we note that increases and decreases in atmospheric CO2 concentration not only did not precede the changes in air temperature, they followed them, and by hundreds to thousands of years! There were also long periods of time when atmospheric CO2 remained unchanged, while air temperature dropped, as well as times when the air’s CO2 content dropped, while air temperature remained unchanged or actually rose. Hence, the climate history of the past half million years provides absolutely no evidence to suggest that the ongoing rise in the air’s CO2 concentration will lead to significant global warming.”
(Supporting references: References to the voluminous scientific literature that supports this position paper and the complete text of the paper may be found at www.co2science.org, which is updated weekly.)
This view differs sharply from those of others. However, it serves to point out that opinions vary greatly on the causes behind global climate change and sea ice retreat. Clearly, much more time and research is necessary to reduce the speculation factor. Some believe the sea ice retreat has more to do with warm water currents from the North Atlantic Ocean flowing into the Arctic Ocean. This phenomenon is caused by the North Atlantic Oscillation, a natural phenomenon. Others believe global warming itself is caused by factors beyond humankind’s use of fossil fuels.
Unintended economic consequences and impacts to energy production
If the FWS decides to list polar bears, all federal agencies must evaluate their actions to ensure that activities they authorize, fund, or carry out are not likely to jeopardize the continued existence of the bears or are not likely to result in adverse modifications to any critical habitat. Depending upon how a final listing is codified, requirements under Section 7 of the ESA could be expanded to include consultations with the FWS for any federal permitting and funding that involves air quality, transportation and emissions. Thus, a listing could make it difficult to obtain any federal or state permits that have the potential to affect polar bears and their habitat – directly or indirectly. This could discourage investment in new energy projects in Alaska and elsewhere, and at the very least, result in delays and higher costs with no corresponding benefit to polar bears.
Proponents of the proposed listing have openly called for the entire energy-rich North Slope of Alaska to be designated critical habitat and have admitted their goal is to force the U.S. government to address global climate change. Some have made it clear they intend to push the FWS to use the ESA to force consultations on power plants and other projects that could contribute to global warming, and therefore endanger polar bear habitat. They want to use the ESA to limit production of fossil fuels and impose mandatory controls and taxes on carbon emissions. As noted earlier in these comments, such actions would be an improper use of the law and well beyond its limitations.
RDC applauds the Interior Department for acknowledging that it does not intend to use an ESA listing to address carbon emissions or other issues of global climate change. The department has correctly assessed the law gives it no room to address the broader issues that may be causing receding ice. However, our concern is if a listing moves forward, “open season” will likely occur as any threat, whether it is perceived or real, would invite third-party litigants to challenge virtually any project that involves, directly or indirectly, carbon dioxide emissions.
For example, lawsuits, using the listing as a mechanism to address the broader issue of global climate change could target development of coal deposits and the construction of new coal plants. Plants that burn coal now supply more than 50 percent of the nation’s electricity. It is a low-cost and abundant fuel, but burning less of it would drive up the cost of electricity and impact all Americans. While Americans generally agree they should do their part to reduce greenhouse gases and limit the impacts of climate change, most are not aware they will personally have to pay for it.
In addition, it is highly probable that among the effects of a listing will be lawsuits to force the agency to designate large portions of Alaska’s arctic, including the entire coastal North Slope, Beaufort Sea and Chukchi Sea as critical habitat. These areas, which include the National Petroleum Reserve – Alaska, hold immense oil and gas potential and are the future for the oil and gas industry in the 49th state. Such development would greatly benefit Alaska and its residents, and would play a major role in boosting domestic energy production. However, once critical habitat designations are in place, more litigation challenging development in or near those designations would likely occur and have a negative effect on new energy exploration in highly prospective areas.
The potential economic implications to Alaska of a polar bear listing under the ESA are frightening. Ninety percent of the Alaska’s revenue base comes from North Slope oil production. An ESA listing and third-party lawsuits from litigants with a variety of motivations would, at a minimum, discourage investment, which would likely result in less exploration, translating into lower production, which in turn would constrict revenues to the state, compromising its ability to provide services to rural and urban Alaskans. A more dire outcome would likely occur if litigants were to challenge virtually every oil and gas lease sale and project near or in critical habitat areas. On a national scale, litigants could effectively hold the nation’s best onshore and offshore energy prospects hostage as they move to block virtually any new oil, gas and other fossil fuel development in the arctic. This could bring the economy, especially in Alaska, to its knees and sharply raise the cost of energy for all Americans.
One only needs to look at the impact third-party litigation has had on the forest products industry in Southeast Alaska. Timber sales in this region are routinely litigated by non-development interests. As a result, the U.S. Forest Service has been unable to supply adequate amounts of timber allowed by the current Tongass National Forest land management plan to the few surviving local saw mills. The industry is now a mere shadow of itself, losing thousands of jobs over the past ten years. Local communities have experienced severe economic downturns and the annual harvest from the Tongass has fallen beyond 50-year lows.
In response to those who claim an ESA listing of polar bears would have no negative impact on Alaska, the oil industry and local communities, the FWS should consider the severe impacts the forest products industry experienced from the listing of the Northern Spotted Owl under the ESA. Beginning in the late 1980s, lawsuits to protect the habitat of the spotted owl withdrew huge acreage of national forests from timber harvesting. President Clinton’s Northwest Forest Plan set aside 24.5 million acres for spotted owl recovery under the ESA. This caused an 80 percent drop in overall timber harvests in the Pacific Northwest, which must be considered an opportunity loss. The estimated losses alone resulting from the owl recovery plan ranged from a low of $33 billion to a high of $46 billion. Those losses were borne out by mill closures and job losses. Since 1989, when environmental lawsuits began, through 1994, 424 lumber mills closed in the Pacific Northwest alone. More than 27,000 loggers and mill workers lost their jobs. Furthermore, as logging communities across the Northwest lost direct timber-related jobs, the jobs of thousands of other employees – private and public – providing goods and services to local timber-dependent communities dried up.
Additionally, numerous local communities lost major revenues derived from the forest products industry. As mills closed and employees lost their jobs, the revenue base of many communities fell sharply. Lower revenues to state and federal governments also resulted when the sale of national forest timber products fell sharply. Even local school districts lost funding as timber-dependent counties lost tax income, population and commercial activity.
The economic costs of mill closures and lost jobs also had severe social consequences. As more logging families lost their incomes and became unable to pay their debts, the pressures within families increased, leading to alcohol and drug abuse, drunk driving arrests, school dropouts, domestic violence, and family breakups.
The unwarranted listing of polar bears could result in similar economic and social impacts, especially in Alaska, without any added benefit to the bear.
Listing could jeopardize Alaska Natural Gas Pipeline
A major concern of RDC is that an ESA polar bear listing could jeopardize the long-term economics of the proposed Alaska gas pipeline. The pipeline is a top national energy priority and is considered vital to Alaska’s future. The gas pipeline is projected to begin generating revenues to the state about the time oil production and corresponding revenues from such production falls below levels required to sustain state services to residents.
New natural gas discoveries beyond the North Slope’s 35 trillion cubic feet of known reserves are vital to ensuring the long-term profitability of any gas pipeline. But an ESA listing with its subsequent critical habitat designations and third-party lawsuits could potentially block access to highly prospective areas that may hold up to 200 trillion cubic feet of natural gas. If this were to happen, investors would simply direct their capital toward other opportunities in their global portfolios. Unfortunately, this would only serve to crimp domestic production and result in an increase in America’s reliance on foreign sources of energy. Moreover, since environmental laws and regulations tend to be weaker outside America, an increase in foreign energy production to satisfy America’s domestic energy needs would likely result in increased pollution abroad.
The FWS needs to prepare a Statement of Energy Effects
Alaska accounts for approximately 17 percent of domestic oil production and a future gas pipeline could account for 25 percent or more of domestic gas production. As illustrated in these comments, the proposed rule could severely impact future oil and gas exploration, development and production in Alaska. If some supporters of the rule are successful in bootstrapping climate change regulations under the ESA, other fossil fuel production such as coal could be at risk. Clearly, the proposed rule could have severe unintended consequences, including much higher utility bills and gasoline pump prices. Americans need to know the full, potential economic costs and unintended consequences of a listing that will likely do very little to assist the polar bear.
RDC urges the FWS to comply with the requirements of the Executive Branch and prepare a Statement of Energy Effects. RDC strongly disagrees with the Proposed Rule’s finding that listing the polar bear is not a significant energy action and no Statement of Energy Effects is required under Executive Order 13211.
The proposed rule could result in scores of other listings
The CBD petition to list the polar bear under the ESA is an unprecedented attempt to use global climate change as a trigger for ESA listings. In order to list the polar bear as threatened, the FWS would have to premise such action on the mere existence of a single risk factor, without hard scientific data showing actual impacts to the species. The consequences of such a finding would likely lead to scores of species being listed under the ESA, overwhelming federal agencies and adversely impacting local economies.
The listing would have a disproportionate and adverse impact on arctic communities
A threatened listing for the polar bear under the ESA will do little for the polar bear. It will not create more ice cover. It will not change their ability to locate dens or prey. But it could negatively and disproportionately affect the lives of Alaskans, especially the Inupiats who coexist with the polar bear in the Alaska arctic.
Once the polar bear is listed under the ESA, any local community or business must enter into formal consultations with the FWS if any action they propose has the potential to affect the species or its critical habitat. This will likely increase the workload of our state and local agencies, cause delays to important projects and result in higher costs. These actions would negatively impact local economies.
Moreover, communities in northern Alaska will run the risk of becoming critical habitat zones and may be limited by the subjective process invoked by the ESA. Village infrastructure expansion, airfields, schools and traditional ways of living for local residents are likely to be impacted. Yet Americans elsewhere will continue to fly, drive cars and power their homes, falsely believing an ESA listing has assisted the bear.
These are valid concerns as landowners and businesses have known for decades that if one wants to stop or severely delay a development project, find a species on the land to protect and things will slow down or many times stop altogether. So may be the case of the polar bear listing and development in Alaska – whether community or industry related.
Conclusion
A decision on whether to list the polar bear should be based on what we do know: the fact the species is healthy in population size and distribution, existing laws and regulatory mechanisms are working and polar bears are highly adaptive to change. Population factors, measured over time, are the best available indicators that a species is not threatened. The FWS should not discount or ignore the current health and distribution of polar bears in deciding whether or not to list.
Moreover, the polar bears are not experiencing problems under any of the factors set forth in the ESA for the listing of a species, other than speculative risk of global climate change and sea ice loss. The listing is premised heavily on highly speculative sea ice recession models and does not include modeling of polar bear population factors, some of which show the bears to be highly resilient and adaptable to change.
Polar bears have survived other warming and cooling periods over thousands of years. Even with the total loss of summer sea ice, the bears are likely to survive the current warming period, given winter ice coverage and protections now in place. In addition, projections indicate that summer sea ice will remain in Canada’s Archipelago, and winter sea ice will continue across the arctic. The projections show that there would still be more than half of the world’s polar bears inhabiting areas not predicted to go ice free in the summer, even under the worst-case scenario.
The proposed listing appears to be more about the politics of global climate change, and the listing itself is likely to be used as a referendum on climate change. The potential ramifications to the economy and domestic energy production are frightening. The listing could jeopardize the proposed Alaska Natural Gas Pipeline. As a result of these potential impacts, the FWS should prepare a Statement of Energy Effects.
Third-party lawsuits typically follow listing decisions with significant delays and added costs. A listing based on the speculative risks associated with climate change could trigger scores of ESA listings elsewhere, overwhelming federal agencies and adversely impacting local economies, especially those in the arctic.
Thank you for the opportunity to comment on the proposed rule.
Sincerely,
