April 3, 2015
Ms. Jolie Harrison
Office of Protected Resources
National Marine Fisheries Service
1315-East-West Highway
Silver Spring, MD 20910
Re: Authorization for Incidental take of marine mammals during seismic survey in Alaska’s Cook Inlet, March 1, 2015 to February 29, 2020
Dear Ms. Harrison:
The Resource Development Council for Alaska, Inc., (RDC) is writing to support the issuance of the proposed letter of authorization for the incidental take of marine mammals between March 1, 2015 to February 29, 2020 during Apache Corporation’s offshore seismic survey operation in Alaska’s Cook Inlet.
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 the need for new and sustainable natural gas energy supplies in Southcentral and Interior Alaska, the proposed seismic survey could ultimately lead to the development of much needed energy resources for Alaska’s most populous regions. 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, the state’s economy, and the quality of life of our residents.
Although oil and gas production has been occurring in Cook Inlet for more than 40 years, the potential for new significant discoveries is high. In the past five years, there has been a revival of industry activity in the region. In 2014, Cook Inlet oil production increased by 25 percent and has nearly doubled since 2010 to 16,288 barrels per day.
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 previous seismic programs resulted in hundreds of 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. Moreover, recent studies have shown that each single job in the oil and gas industry creates 20 other jobs through industry spending – nine in the private sector and 11 in government.
Apache has acquired over 850,000 acres of oil and gas leases in Cook Inlet since 2010 with the primary objective to explore for and develop oil and gas resources. Except for the location and the size of the survey area, the activities proposed for the upcoming surveys in the 2015-2020 seasons are essentially the same as those conducted during Apache’s previous surveys in 2012 and 2014. As shown during the 2012 and 2014 seismic surveys, the mitigation measures and operating standards imposed by the company were exceptional. Apache has consistently operated in full compliance of the previous incidental take permits. Since 2011, when Apache began conducting operations in Cook Inlet, no data indicates that the beluga whale population has been adversely affected by its activities.
Taking into account an analysis of the likely frequency of interactions between Cook Inlet marine mammals and Apache’s planned operations, and also considering factors such as the proposed mitigation measures, the National Marine Fisheries Service has concluded that the seismic surveys will only disturb small numbers of animals.
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. The number of takes that are anticipated and proposed to be authorized by the Service are expected to be limited to short-term behavioral disturbance. Animals are not expected to permanently abandon any area that is surveyed, and any behavior that could potentially be 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.
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.
The proposed five-year letter of authorization provides vital consistency and durability to Apache’s exploration program. Previously, a company conducting offshore surveys had to acquire an annual authorization for the unintended minor disturbance of marine mammals.
Apache obtained this type of authorization for its Cook Inlet surveys, filing an application each year, with the process involving a public review. In comparison, the newly proposed letter of authorization covers a five-year period, requires a longer application period, and is more complex than that for an incidental harassment authorization as it involves two public comment periods. However, once the authorization has been granted, no further applications and public reviews are required. As a result, the five-year authorization is more efficient over the long term for both the company and the regulatory agency.
RDC strongly supports Apache’s efforts to explore for potential oil and gas resources in the Cook Inlet basin. The company has worked closely with scientists, stakeholders, and tribes, as well as local, state, and federal agencies on its Cook Inlet program. It’s clear that Alaskans and our state’s economy would benefit from increased oil and gas development and production in Cook Inlet. In fact, the very concept of Alaska’s statehood is predicated on the development of our natural resources. Alaska was allowed to join the union because of the expectation that the development of natural resources would sustain our economy.
RDC is confident Apache will work diligently to insure a successful, environmentally-sound project. In 2013, the company received the Chairman’s Stewardship Award from the interstate Oil and Gas Compact Commission for its efforts to minimize environmental impact in Cook Inlet.
Given extensive mitigation measures and monitoring requirements, the survey is not likely to adversely affect Cook Inlet species or stock. RDC encourages the Service to issue the proposed letter of authorization covering the next five years.
Sincerely,
Resource Development Council for Alaska, Inc.
