Kachemak Bay Conservation Society strongly urges BOEM to ensure the health of Cook Inlet and the communities who depend on it, now and in the future. Cook Inlet is a vast and vital ecosystem that has provided subsistence resources to Native Alaskans since about 500 A.D. and continues to sustain the residents of this region. Damages caused by poor management will be felt from Kodiak to Anchorage and will likely be irreversible. We urge the greatest caution as BOEM considers oil and gas leasing in the dangerous and extremely difficult conditions of Lower Cook Inlet. The forces of the tides, storms, ice, sediment, and dynamic conditions of our home cannot be underestimated. Every precaution is needed to prevent disasters and ban practices that will leave us without the ability to make a living from the wild resources we all love and depend on.

At a minimum our communities need:

1. A direct comparison of the costs and benefits of oil and gas vs. wind development in the lease sale area.
2. The institution of Ocean Observing System, such as that used in the Prince William Sound, Alaska.
3. No seismic work conducted during the entire period of the salmon run, from the early spring when salmon exit rivers, to the fall after they have gone upstream again.
4. Based on the location of the lease sales, impact analyses for the potential industrialization of Homer, Seldovia, Port Grahm, Anchor Point, and the west side of the Inlet is necessary.

Need and Purpose:

The premise of the lease-sales appears to be fundamentally flawed. The economic premise used to justify the lease sale as in the “national interest” must be carefully reviewed in light of the best available information. BOEM’s assumption that offshore oil and gas development in the Lower Cook Inlet is the best way to “enhance the energy security of the United States” is not a given and there are a number of reasons why that may not be the case, especially when risks to essential habitats and climate impacts are factored in.  A direct comparison of the costs and benefits of oil and gas vs. wind resource development is needed to assure the agency’s fulfillment of its mission to “manage development of U.S. Outer Continental Shelf energy and mineral resources in an environmentally and economically responsible way.” Offshore wind development—over a period of 40 to 70 years—in the region needs to be one of the alternatives assessed. This is particularly pressing at a time when the price of oil is hovering around $40/barrel and when regional natural gas and electricity costs have been rising for over 20 years. We do not need more oil. We need a more diversified grid.

The analysis of wind vs. oil and gas leasing in the OCS must include:

• An assessment of the impact of greenhouse gas emissions for the full lifecycle of activities resulting in the release of emissions, beginning with oil and gas exploration and production and ending with consumer use.
• A through analysis of the value of current economies and uses which rely on the resources of Lower Cook Inlet.
• An assessment of regional job creation under each scenario over a 40 to 70 year period.

As a point of reference, one analysis for the Atlantic coast estimated that the energy created by 20 years of offshore wind in the Atlantic could produce the equivalent of five billion barrels of oil—more than that of all the economically recoverable oil and gas in the same area. On top of that, Oceana estimates that for the next 20 years on the Atlantic Coast, offshore wind could create about 91,000 more jobs than offshore drilling, which is about double the job creation potential.

The National Center for Atmospheric Research has named shallower portions of the Lower Cook and Gulf Coast as some of the best potential locations for offshore wind in Alaska, due to the excellent wind resources available, as well as their proximity to population centers and existing Alaska Grid transmission lines.

Why would this region or our nation want to risk the unique natural resources of Lower Cook Inlet when there are better energy resources with a brighter future available to us?

Scope of Impact

All five species of Pacific salmon are harvested commercially in Cook Inlet. Commercial fisheries for halibut, groundfish, herring, and razor clams also occur in lower Cook Inlet and Kamishak Bay. Personal use fishing, an important source of food for many Alaskans, is prevalent in the area. Sport fishing is a major economic driver for residents in the Sale Area, adding more than $1 trillion of economic output most years.

The visitor industry is one of Alaska’s major economic drivers and, overall, the Southcentral region receives the highest economic impact from visitors. Estimated overall total visitor spending in the state in October 2014 to September 2015 was $1.94 billion.

When preparing the Environmental Impact Statement for the proposed Lease Sale 258, please consider the issues listed below for all phases of exploration, development, production and abandonment:

• How will halibut, cod, crab, salmon, scallops and clams be impacted by the lease sale?
• How will zooplankton and primary productivity be impacted?
• What will be the impacts to benthic invertebrates?
• How will the commercial, subsistence, and recreational fisheries in the Lease Sale 258 area be changed, altered or impacted?
• How will these changes or alterations impact the economic, cultural, recreational or subsistence uses by commercial, sport and subsistence users and their families?
• How will marine mammals, their habitats, and food sources be altered or impacted?
• What will be the impacts to the commercial fishing areas?
• What will be the impacts to the sport fishing areas?
• What compensation methods will be in place to make whole an injured party? What bonds will be required to hold responsible parties accountable?
  

Additionally, based on the location of the lease sales, impact analyses for the potential industrialization of Homer, Seldovia, Port Grahm, Anchor Point, and the west side of the Inlet is necessary. This analysis must include cumulative impacts to water resources, essential habitat for fishes, and harm to the existing tourism and fishing industries, net population impacts, as well as impacts to subsistence practices of residents, especially Alaska Native Tribal Members.  In all these analyses, please consider that most of our natural systems are already under strain due to a warming climate and increased population pressure.

Baselines and Basic Science

We cannot repeat mistakes and lessons learned from past problems with oil and gas extraction. Any plan for oil and gas development in the Lower Inlet must include comprehensive monitoring to ensure that the ecosystems of Cook Inlet and all the people who depend on them now and in the future will be safeguarded from harm. Please review the following gaps in information and address them directly in the EIS:

• An important data type that is lacking in Cook Inlet is wave height. This is due to the extreme weather, mainly heavy freezing spray and sea ice, which have destroyed previous buoys placed near the area.
• Macrophytes are a major food source supporting both commercial and noncommercial resources yet little is known of their biomass or productivity in Lower Cook Inlet.
• No data are presently available concerning the possible role of ice in either accelerating or restricting the dispersion of possible oil spills or other pollutants in Cook Inlet.
• In the past, spill models have not done well in Upper Cook Inlet due to the fact that currents that fed the modeling program did not resolve the strong convergence zones in the center of the Inlet that collect the oil and pull it below the surface. Previous modeling attempts have shown that a simple tide model with moderate sized grids will not do the job.
• We need baselines for petroleum contamination in the Inlet.
• There is a considerable lack of benthic habitat data regarding extent and distribution of marine species. Nearshore benthic habitat mapping is required to understand the distribution and extent of marine habitat types serving as nursery grounds and foraging grounds for coastal marine species of the region.
  

Please carefully review and address point by point the above as well as all the other research needs and information gaps listed in “Assessment of nearshore communities and habitats: Lower Cook Inlet Nearshore Ecosystem 2015-2018,” Cook Inlet Physical Oceanography Workshop Proceedings, as well as NOAA’s 1977 Environmental Assessment. It is essential that BOEM act responsibly when issuing permits; BOEM must work with other agencies to fill in the gaps in knowledge cited in these documents in a timely manner.‍

Mitigation

The following precautions and mitigation measures are necessary:

• As has been recommended by various agencies, the expansion of Cook Inlet Oil and Gas operations necessitates an Ocean Observing System, such as that used in the Prince William Sound, Alaska.  
• BOEM’s Nearshore Ecosystem Assessment Team recommends funding decadal-scale long-term studies on the unique shoreline along Western Cook Inlet, in and around Kamishak Bay.
• There can be no seismic work conducted during the entire period of the salmon run, from the early spring when salmon exit rivers to the fall, after they have gone upstream again.
• No seismic work can be conducted without first conducting surveys for Beluga whales; no seismic work can be done at night, when observers will be unable to see whales.
• The behavior of oil around the tidal convergence zone must be understood before permits are issued.
• Seismic surveys have been shown to harm zooplankton populations, “there is a significant and unacknowledged potential for ocean ecosystem function and productivity to be negatively impacted by present seismic technology.” Seismic testing must be kept to a minimum to avoid significant harms to the integrity of the zooplankton populations: harms to these populations will ripple across the entire food web. Impacts in Cook Inlet productivity must be monitored closely and data collected must be used to modify permits to ensure primary productivity.
• A Regional Ocean Modeling System (ROMS) was recently developed as part of the Prince William Sound Ocean Observing System (PWSOOS) to develop an operational modeling, data assimilation, and forecasting system that can deliver both physical and biological real-time data products to research and application users. Such a system is necessary for timely and effective spill response.  

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