March 22, 2011

Ms. Kaja Brix, Assistant Regional Administrator
Protected Resources Division
Alaska Region, NMFS
Attn.: Ellen Sebastian
P.O. Box 21668
Juneau, AK 99802

Re: RIN 0648-­-XZ58 – Bearded Seal and RIN 0648-­-XZ59 – Ringed Seal

Dear Ms. Brix:

The Resource Development Council for Alaska (RDC) is writing to oppose the proposed threatened listing for the Beringia and Okhotsk distinct population segments of the bearded seal and the proposed threatened listing for the Arctic, Okhotsk, Baltic, and Ladoga subspecies of the ringed seal (seals).

RDC is a statewide 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. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.

The listing of the seals under the Endangered Species Act (ESA) is not warranted. The proposal is based on uncertain and unreliable forecast models, not any actual scientific evidence that the seal populations are decreasing or being adversely impacted by climate change. While climate change is an important issue, the ESA was not intended as a means to regulate potential impacts from climate change. RDC believes the listing of the seals under the ESA is not warranted, for reasons including:

• The seal populations are abundant with a large distribution, occupying their entire historic range.
• The proposed listing is “primarily due to concern about threats to the species’ habitat from climate warming and diminishing ice and snow cover,” which is a based on unclear and uncertain science projections.
• The seals and their habitat are well managed and protected by existing agreements, conservation programs, and laws.

The seals are not threatened under any of the factors set forth in the ESA for the listing of a species, other than projected/modeled threats from climate change, including sea ice loss, and therefore should not be considered for an ESA listing. The ESA should not be used to control greenhouse gases, as it will likely negatively impact Alaska’s economy, with little or no added benefit to the seals. Listing the seals will not make the sea ice grow.

The proposed listing could negatively impact the economy and projects both on and offshore Alaska. The arctic communities’ economies would be disproportionately impacted with no added benefit to the seals. The listing of the animals would impact an area of national significance because of its critical importance to domestic oil and gas production and development. Fisheries, transportation, community development, and access to potential mineral resources may be impeded as well. These activities have not resulted in a decline in species abundance, but will be significantly and disproportionately impacted by an ESA listing.

The seals are sufficiently protected by international agreements, conservation programs, and laws, including the Marine Mammal Protection Act. RDC supports continued efforts under these measures. These and other measures are working, and the seals are in abundance.

In addition, RDC endorses the joint comments submitted by the Alaska Oil and Gas Association and the American Petroleum Institute. RDC appreciates the opportunity to comment on the proposed listing.

Sincerely,
Resource Development Council for Alaska, Inc.