American Whitewater provided Scoping Comments this week on the Coastal Plain Oil and Gas Leasing
Program Environmental Impact Statement (EIS). In December of 2017, Congress Passed the Tax Act of
115th Congress. Section 20001 of the Tax Act directs the Secretary of Interior to establish and
administer a competitive oil and gas program for the leasing, development, production, and
transportation of oil and gas in and from the Coastal Plain within the Arctic National Wildlife
Refuge. Congress directed the Secretary of Interior to offer for lease not fewer than 400,000
acres area-wide in each of two lease sales within the next ten years; these sales are to occur in
areas that have the highest potential for the discovery of hydrocarbons. Receipts derived from
this program will be split between the State of Alaska and the Federal Treasury.
The Bureau of Land Management has now initiated environmental review and solicited Scoping
Comments. Scoping is the first step in an environmental review under the National Environmental
Policy Act where issues related to a proposed action that require further analysis are
In our comments we highlighted the fact that the Arctic National Wildlife Refuge, and
specifically the Coastal Plain, is one of the last truly wild landscapes in the United States.
Oil and gas development activities that impact the unique visual and aesthetic values of the
landscape and opportunities for an unparalleled wilderness-quality backcountry recreation
experience—that includes unique wildlife-viewing opportunities—are of concern. We
noted that the U.S. Fish and Wildlife Service identified the following rivers, and their
associated outstandingly remarkable values, as eligible for designation under the Wild and Scenic
Rivers Act: Canning River (wildlife, fish, cultural), Hulahula River (recreational and cultural),
Okpilak River (scenic, geologic), and Jago River (wildlife). Of these rivers, the Hulahula was
recommended for designation under the Wild and Scenic Rivers Act in the Record of Decision for
the Revised Comprehensive Conservation Plan Arctic National Wildlife Refuge.
We supported analysis of a no-action alternative and analysis of complete site clean up and
restoration following surface-disturbing activities. The full cost of bonded ecological
restoration should be core to the economic analysis of any action alternatives. In response to a
request for information on technologies to consider, we requested an analysis of options that
would result in no surface-disturbing activities within the Coastal Plain.
We will continue to monitor the progress of the environmental review and advocate for a complete
review of impacts affecting the backcountry recreation experience for paddlers in the Arctic
National Wildlife Refuge.