Resource Development Council

RDC Comment Letter:
Proposed Incidental Harassment Authorization
to Apache in Cook Inlet

January 22, 2014

Ms. Jolie Harrison
Office of Protected Resources
National Marine Fisheries Service
1315-East-West Highway
Silver Spring, MD 20910

Re: Proposed Incidental Harassment Authorization to Apache in Cook Inlet

Dear Ms. Harrison:

The Resource Development Council for Alaska, Inc., (RDC) is writing to support the issuance of the proposed Incidental Harassment Authorization for Apache Corporation’s proposed seismic survey in Cook Inlet between March 1 and December 31, 2014. Given extensive mitigation measures and monitoring requirements, the survey is not likely to adversely affect Cook Inlet species or stock.

RDC is an Alaskan business association comprised of individuals and companies from Alaska's oil and gas, mining, forest products, tourism, and fisheries industries. Our membership includes all of the Alaska Native Regional Corporations, local communities, organized labor, and industry support firms. RDC's purpose is to expand the state's economic base through the responsible development of our natural resources.

Given tight energy supplies in Southcentral Alaska, the proposed seismic survey could ultimately lead to the development of much needed energy resources for Alaska’s most populous region. The survey is clearly in the public interest as it could give Apache the information it needs to potentially secure a stable source of energy for local communities and utilize a valuable resource for Alaskans.

More than half of the state’s population depends on natural gas from the Cook Inlet region for home heating, electricity and commercial enterprise. Continued development of Alaska’s natural resources is critical to local communities and the state’s economy and the quality of life of our residents.

Development of potential energy resources in the Cook Inlet basin will provide new jobs in the region and revenues to the State of Alaska. Operation of Apache’s 2011-12 seismic program resulted in some 225 direct, indirect, and induced jobs resulting in more than $22.5 million a year in payroll. Because of Apache’s local hire policies, 60 percent of these jobs went to Alaska residents.

Apache has acquired over 800,000 acres of oil and gas leases in Cook Inlet since 2010 with the primary objective to explore for and develop oil and gas resources in Cook Inlet. Except for the location and the size of the survey area, the activities proposed for the 2014 survey season are essentially the same as those conducted during Apache’s first survey season in 2012. As shown during the 2012 seismic survey, which resulted in no takes of Beluga Whales, the mitigation measures and operating standards imposed by the company were exceptional.

Given Apache’s proposed measures, as well as other actions considered by the Service, the proposed mitigation measures would result in the least practicable impact on marine mammals species or stocks and their habitat. With the proposed mitigation and related monitoring, no injuries or mortalities to marine mammals are anticipated to occur as a result of Apache’s proposed seismic survey in Cook Inlet. Additionally, the animals in the area are not expected to incur hearing impairment or non-auditory physiological effects. The number of takes that are anticipated and proposed to be authorized by the Service are expected to be limited to short-term behavioral harassment. Animals are not expected to permanently abandon any area that is surveyed, and any behavioral that are interrupted during the activity are expected to resume once the activity ceases. Only a small portion of marine mammal habitat may be affected at any time, and other areas within Cook Inlet will be available for necessary biological functions. In addition, the area where the survey will take place is not known to be an important location where beluga whales congregate for feeding, calving, or nursing.

Mitigation measures such as controlled vessel speed, dedicated marine mammal observers, non-pursuit, and shutdowns or power downs when marine mammals are seen within defined ranges will further reduce short-term reactions and minimize any effects. In all cases, the effects of the seismic survey are expected to be short term, with no lasting biological consequence.

RDC supports Apache’s efforts to explore for potential oil and gas resources in the Cook Inlet basin based on its continued community outreach efforts, economic support, and efforts to work with local, state, and federal agencies on their Cook Inlet program. Moreover, development of potential resources is clearly in the public’s interest, as noted above.

RDC is confident Apache will work diligently to insure a successful, environmentally-sound project. We urge the Service to clearly recognize the many benefits of seismic surveys and subsequent development of energy resources to Alaskans and the local economy.

RDC encourages the Service to issue this Incidental Harassment Authorization in a timely manner.

Resource Development Council for Alaska, Inc.