Letter to the Hon. David Bernhardt, Secretary of the U.S. Department of the Interior - Huffman, Markey Lead House and Senate Members in Joint Letters to DOI Opposing Lame-Duck Oil and Gas Lease Sale and Seismic Exploration in Arctic Refuge

Letter

Date: Dec. 16, 2020
Location: Washington, DC

Dear Secretary Bernhardt,
We write in strong opposition to the Bureau of Land Management's (BLM) efforts to take the next steps
to hold a lease sale in the Arctic National Wildlife Refuge (Arctic Refuge), as well as to Kaktovik Inupiat
Corporation's (KIC) application to conduct seismic exploration on the Coastal Plain of the Arctic Refuge.
It is wholly unacceptable that the Trump administration is working to hold a lease sale as one of its final
actions. Following the results of the 2020 election, this decision should be left to the incoming Biden
administration. We oppose all oil and gas exploration and development activities on the Coastal Plain of
the Arctic Refuge. The Coastal Plain of the Arctic Refuge is a national treasure that is no place for oil and
gas development. It is also sacred to the Gwich'in, who call it the "sacred place where life begins" due to
its critical role as the calving grounds of the Porcupine Caribou Herd, on which they depend for their food
supply and their entire way of life.
The oil and gas leasing program was adopted in violation of numerous laws that protect the Coastal Plain
and ensure the integrity of the decision-making process. In its rush to lease, this administration has failed
to uphold the public trust, failed to protect the purposes of the Arctic Refuge, and cut corners in its
obligations to involve the public and engage in adequate consultation with the Gwich'in and other tribes.
As a result of these violations, BLM's actions to date are currently the subject of four separate lawsuits.
Before moving forward with these proposals, the BLM must remedy these legal deficiencies and ensure
full compliance with numerous federal laws -- including the Alaska National Interest Lands
Conservation Act, the National Environmental Policy Act, the National Historic Preservation Act, the
Wilderness Act, the Endangered Species Act, the Tax Act, and the National Wildlife Refuge System
Administration Act -- not run roughshod over them.
BLM's call for nominations and actions to hold a lease sale are ill-advised in light of current market
conditions, which do not warrant a lease sale. Any lease sale is likely to fall far short of the $2 billion in
revenue promised as part of the Tax Act. Additionally, nearly every major bank and investment firm has
committed to not develop in the Arctic because of the substantial risks involved, with many of those
banks pointing directly to the economic and reputational risk of drilling in the Arctic Refuge as a major
concern. Major oil and gas companies are reducing their exploration and development budgets, focusing
on core areas where resources are well defined and cost effective to develop, and leaving alone complex
and risky environments such as the Arctic. In addition, development poses large risks for communities,
species, and our planet and would undermine 60 years of conservation action at a time when the climate
crisis is on the brink of tipping past the point of no return.
BLM should also reject KIC's proposal to conduct seismic exploration on the Coastal Plain of the Arctic
Refuge. The risks of seismic exploration have not been adequately analyzed and threaten the Coastal
Plain and its resources, including denning polar bears. The cursory summary of the seismic proposal
released to the public raises serious concerns about the proposed activities and the significant impacts
likely to occur to the Coastal Plain. This woefully inadequate document makes it impossible for the public
to understand or comment on the full array of impacts from this seismic exploration proposal. Based on
the limited information provided to the public to date, the impacts are likely to be significant and longlasting. BLM must thoroughly and comprehensively analyze the impacts to all Coastal Plain resources
and ensure that it is meeting all legal obligations. The analysis should be completed through an
Environmental Impact Statement with significant and robust public involvement. BLM should not fasttrack or shortcut its review of this proposal. We believe that a proper analysis will indicate that the
proposal is likely to cause significant harm and should be rejected.
We urge the Trump administration to not hold a lease sale in the Arctic National Wildlife Refuge and to
reject KIC's application for seismic exploration. Moving forward with a lease sale now, in the remaining
few weeks of the Trump presidency, is crass and reckless political posturing, not thoughtful energy
policy. Instead, we ask the Trump administration to reverse course and fully consider the legal, fiscal,
cultural, social, economic and environmental impacts of these actions, and halt any authorizations for
exploration or development.


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