Comments submitted electronically 3/2/2010 Receipt #80ab21aa

Totem Ocean Trailer Express, Inc.
2511 Tidewater Road
Anchorage, AK 99501

National Oceanographic and Atmospheric Administration: National Marine Fisheries Service Docket # 090224232-91321-03
Endangered and Threatened Species: Designation of Critical Habitat for Cook Inlet Beluga Whale
Anchorage, Alaska 2/12/2010

Greg Kessler, Alaska Commercial Director

Good evening, My name is Greg Kessler and I am the Alaska Commercial Director for Totem Ocean Trailer Express. TOTE operates two ORCA class Roll on/Roll off cargo ships providing twice-weekly service between the Ports of Tacoma and the Port of Anchorage. TOTE is a major carrier calling on the Port of Anchorage.

Today, Alaska’s grocery and retail businesses depend on just-in-time shipping methods and are able to utilize this economic system of inventory control because of the service levels provided by the ocean cargo transportation carriers calling at the Port of Anchorage. This fast reliable ocean cargo transport is a vital transportation link for the companies providing goods and services in the Alaska market.

TOTE’s customers rank Customer Service and Reliability of highest importance. The most critical component of Reliability is the protection of scheduled arrivals and departures of the ships.

The designation of critical habitat and the implications for commerce are of great concern. Any restrictions in the Cook Inlet commerce corridor routes or at the Port of Anchorage will only lead to higher costs for residents of both urban and rural Alaska because restrictions that increase the cost of operations will ultimately be passed through to the public leading to higher costs for most residents of Alaska.

The potential impact would have implications for almost all Alaskans as they could result in increased costs to the consumer along with slower or less reliable service.

The Port of Anchorage has been designated as a strategic port by the U.S. military and is essential to our national security. The port is one of only 19 strategic seaports. The Port’s selection is based on Anchorage playing a critical role in the deployment by sea, including those forces stationed at Ft. Richardson and Ft. Wainwright or traveling to Alaska to train. The military also plays an important role as an economic engine in our economy. For TOTE an estimated annual load factor of 12% is attributed to military related supplies and equipment.

Activities likely to be negatively affected by critical habitat designation in Cook Inlet include shipping, oil and gas exploration, development, and production, renewable energy projects, wastewater utility discharges, commercial and industrial coastal development, commercial and sport fishing, mining, tourism, military operations, and community infrastructure development, including Port of Anchorage expansion, the Knik Arm Bridge, Port MacKenzie, and much more, all with no added benefit to the whales.

All these industries are critical to Alaska economic growth and prosperity. The designation of such broad areas of municipal, commercial, and industrial interests, without any known or identifiable link between these activities and the conservation status of the Cook Inlet beluga whale is contrary to the public interest.

TOTE has long term demonstrated experience safely navigating in Cook Inlet and believes that any restrictions to large cargo vessels would only add cost into the supply chain, costs that will be borne by end consumer, increase risks, and provide no corresponding benefit to the beluga whales.

For the reasons stated above TOTE believes that there is no need for restrictions in the commercial commerce corridors of Cook Inlet and supports an exemption from critical habitat for the commercial corridors and the Port of Anchorage.

Thank you.