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

Mike Thrasher, Terminal Operations Manager

Good evening, My name is Mike Thrasher and I am the Anchorage Terminal Operations Manager 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. The vessels, M. V. Midnight Sun and M. V. North Star, each have the capacity to carry over 500, 28 to 53 foot highway trailers and 250 vehicles. TOTE’s Alaska operation employs 40 directly and contracts for mechanics, long shore, and local deliveries employing indirectly another 150+ people. Each vessel carries a crew of 24.

TOTE has provided transportation service to Alaska, using this trade lane, since 1975. During this time, we can safely state that TOTE has not experienced a whale strike or any other incident related to beluga whales in Cook Inlet. 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.

Freshwater ballast systems are utilized on both ORCA class vessels to avoid introducing marine species that are not indigenous to Alaskan waters. Both ships are double-hulled, twin-screwed, clean burning diesel electric propulsion systems. Ships’ trash and other waste are disposed of at onshore facilities. TOTE does not discharge into marine waters.

TOTE’s ORCA class vessels have a lower than average underwater acoustic signature due to their unique hulls and propulsion plants. The Orca Class vessels have a diesel electric propulsion plant. The propellers are only connected to quiet electric motors while the diesels providing the electrical generating power are supported on sound isolating rubber mounts. These features combined with our hydrodynamically efficient hull design combine to produce a low noise vessel. TOTE is confident the ORCA Class vessel sound signature is less than 120 dB.

Cook Inlet is a challenging maritime environment. Currents flow as fast as 8 knots with a tidal variation of as much as 35 feet. Large vessels arrive and depart on a flood tide, when there is adequate water depth to cross the Knik Arm Shoal. A very narrow window of opportunity exists for large cargo vessels to navigate Upper Cook Inlet, cross the Knik Arm Shoal, and dock at the Port of Anchorage. Any further limitations on speed, restrictions to hours of operation, or other actions threatening operations within this limited navigational time frame in Cook Inlet would result in additional fuel burn in order to maintain schedule, if it is even possible to maintain schedule at all.

Even less severe vessel operating restrictions that only affected transit times by a couple of hours in either direction, there would still have a significant cost. During average operating conditions adding one additional hour of voyage time in each direction would result in an increased annual cost of $600,000 in fuel. (200 Voyages, 40bbls per hour, $75 per barrel)

Another item that needs to be taken into consideration is the dangerous navigation conditions in Cook Inlet. Cook Inlet has many navigational hazards, including ice. Restricting a vessel’s ability to maneuver may have the unintended consequences of putting a vessel in harm’s way. Whatever restrictions are imposed must take this into account.

It has been stated that consultation is not required for vessels but would be for operational features such as dredging. Dredging in Cook Inlet and at the Port of Anchorage is essential to the ports functionality for large cargo vessels. If early spring dredging, or any dredging for that matter, is delayed due to a bureaucratic process, this could render TOTE’s berthing at the Port of Anchorage an impossibility. Without adequate dredging in Cook Inlet and at the Port of Anchorage, the risks of unintentional grounding due to siltation and uncharted shoals grow.

The completion of the Port of Anchorage Development Project is critical to TOTE’s operations. The project, in its current state, is rapidly becoming hazardous to operations due to continuous loss of bottom depth, and without completion puts TOTE’s operations at risk. Already TOTE has had to stop cargo discharge to leave the dock at extreme low tides due to silting. Dredging is necessary eight months of the year in order to maintain TOTE’s berth at the port. Should the POA project be slowed or stopped due to critical habitat TOTE’s operations will continue to be put at risk. Ultimately, this will negatively impact the many Alaskans who benefit from the cargo hauled by the carriers utilizing the port.

Decades of safe and environmentally responsible vessel transportation through Cook Inlet has taken place without harming Cook Inlet beluga whales. 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