Audubon Alaska • Oceana • Ocean Conservancy • Pew Environment Group
______________________________________________________________________________
May 5, 2010
The Honorable Ken Salazar
Secretary of the Interior
Office of the Secretary
Department of the Interior
1849 C Street, N.W.
Washington, D.C. 20240
Dear Secretary Salazar,
We write to request that you reconsider the Minerals Management Service’s (MMS) approval of
Shell Oil’s plans to drill exploration wells in the Chukchi and Beaufort this summer. The blowout on
BP’s Deepwater Horizon rig and the ongoing oil spill in the Gulf of Mexico makes it unambiguously
clear that the oil industry has only limited capacity to respond to large oil spills once they occur, even in
the Gulf with its abundant infrastructure and support. If a similar blowout occurred in remote Arctic
waters, in mixed ice and harsh weather conditions, effective response would be impossible. The oil
industry’s repeated public assurances regarding response capabilities in the Arctic simply do not
withstand serious scrutiny.
The Arctic is home to vibrant human communities and healthy, functioning ecosystems. Many
Arctic peoples make extensive use of the marine environment to support their subsistence way of life, and
subsistence hunting is a mainstay of the economy and culture in the region. The Arctic also provides vital
habitat for iconic wildlife, such as bowhead whales, walruses, bearded seals, Arctic cod, eiders, and polar
bears, as well as other whale, seal, bird, and fish species. An oil spill in this pristine Arctic environment
would have catastrophic consequences.
The BP Deepwater Horizon blowout and spill fundamentally calls into question the
credibility of the oil industry’s representations regarding safe operations and effective spill
response. We urge you to immediately suspend operations on Shell’s Chukchi and Beaufort leases.
There should be no exploration drilling on Outer Continental Shelf (OCS) leases in the Arctic
until, at a minimum, (1) there is a definitive understanding of the events and circumstances that led to the
Deepwater Horizon blowout and confidence that other OCS operators are not vulnerable to similar
blowout events; (2) the U.S. Geological Survey (USGS) conducts its science and oil spill gap analysis,
there is an independent analysis of science and response capacity, and we have a better understanding of
the impacts of oil and gas activity on Arctic marine ecosystems and how to effectively prevent and
respond to a spill; (3) MMS addresses shortcomings in its assessment of Shell’s exploration plans; and (4)
there is a comprehensive and coordinated management structure to guide decision-making in the region.
(1)
Drilling activities in the Arctic Ocean should be halted until investigations by the Coast
Guard and other appropriate agencies have documented the cause of the Deepwater Horizon
blowout and there is confidence that similar accidents will not occur in the future.
Shell’s operations in the Arctic Ocean should be halted until the cause of the Deepwater Horizon
blowout is determined and there is an ability to ensure that new drilling operations will not experience
similar problems. As BP did in the case of the Deepwater Horizon, Shell has essentially dismissed the
risk of a blowout in the Arctic Ocean. The Gulf disaster clearly shows, however, that the supposedly “fail
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safe” technology cited by industry can and does fail. At this point, there is no clarity regarding the cause
of the blowout; this information is essential before allowing new frontier drilling in the Arctic.
(2)
Exploration drilling in the Beaufort and Chukchi seas should be suspended until the USGS
has finished its review of Arctic science and identified additional research needs, and until
there is an independent analysis of the science and response capacity that is necessary for
effective and reliable oil spill response in ice-covered regions.
In announcing the Administration’s comprehensive strategy for offshore oil and gas development
and exploration on March 31, you tasked USGS with assessing, by October 1, information about
resources, risks, and environmental sensitivities in Arctic areas. Among other things, you asked USGS to
“determine what research is needed for an effective and reliable oil spill response in ice-covered regions.”
There should be no exploration drilling in the Arctic until USGS has completed its report, and until there
is an independent analysis of science and response capacity and a demonstrated capability to contain and
clean up to a spill in harsh Arctic conditions.
The efforts to contain and clean up the oil spilled from BP’s Deepwater Horizon show that oil
spill response is extremely challenging, even in the industrialized environment of the Gulf of Mexico—an
area with significant resources, infrastructure, vessels, and personnel available to support a spill response.
In contrast, Shell’s Chukchi Sea leases are in a remote frontier region with almost no infrastructure to
support spill response. Moreover, Arctic waters are susceptible to severe storms, darkness, subzero
temperatures, heavy fog, and moving pack ice. Instead of allowing Shell to proceed with exploration
drilling in a severe environment, far from response infrastructure and resources, and without information
about the cause of the Deepwater Horizon blowout or the research that is required for “effective and
reliable oil spill response in ice-covered regions,” MMS should suspend operations, allow USGS to
complete its report, assess relevant independent science reviews, and revise its environmental analyses in
light of new information.
(3)
Exploration drilling in the Beaufort and Chukchi seas should be suspended until MMS has
addressed shortcomings in its assessment of Shell’s exploration plans.
The BP Deepwater Horizon blowout and oil spill highlight critical flaws in MMS’s assessment of
Shell’s Beaufort and Chukchi exploration plans. MMS should suspend Shell’s operations and revise its
environmental documents to remedy those flaws.
In its environmental assessments of Shell’s exploration plans, MMS did not analyze the potential
impacts of a blowout in the Chukchi and Beaufort seas because the agency felt that a blowout was too
remote a possibility. The BP Deepwater Horizon blowout demonstrates that the risk of mechanical
failure or human error is very real, and that those failures or errors can have catastrophic consequences.
The blowout preventer on BP’s Deepwater Horizon failed. Shell’s drilling operations in the Arctic will
rely upon blowout preventers, and they, too, could fail. MMS should suspend operations on the Chukchi
and Beaufort leases and until it has completed an analysis of the potential impacts of a blowout and large
oil spill in Arctic waters.
MMS should also reassess Shell’s ability to stop a blowout in the Arctic Ocean. In the event of a
loss of well control and if other measures prove ineffective, Shell’s exploration plans call for the company
to use its drillship—the Frontier Discoverer—to drill a relief well. The exploration plans fail to explain
what Shell would do if the Frontier Discoverer is disabled or lost in the course of the incident. In both
the Timor Sea Montara platform blowout and the ongoing BP Deepwater Horizon blowout, drill rigs were
burned and/or sunk, rendering them inoperable and incapable of drilling a relief well. MMS should
suspend operations on the Beaufort and Chukchi leases until Shell explains what it will do if there is a
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loss of well control and the Frontier Discoverer is lost or disabled and cannot be used to drill a relief
well.
In addition, MMS should reconsider Shell’s contingency and response plans. As noted above,
BP’s Deepwater Horizon spill occurred in an area with significant infrastructure and resources available
to assist in response efforts. Response and cleanup in the Arctic would be much more difficult. Shell’s
drill sites are in a remote frontier area where infrastructure and response resources are limited. Shell’s
exploration plans do not provide sufficient capacity to deal with an incident similar to BP’s Deepwater
Horizon blowout and spill. For example, Shell’s Chukchi Sea oil spill response plan provides for just a
fraction of the fire-fighting and oil skimming capacity that has been used to combat BP’s Deepwater
Horizon fire and oil spill. MMS should suspend operations on Shell’s Beaufort and Chukchi leases until
Shell develops and implements a credible and demonstrably effective contingency and response plan.
(4)
Exploration drilling in the Beaufort and Chukchi seas should be suspended until there is a
comprehensive and coordinated management structure to guide decision-making in the
region.
The BP Deepwater Horizon blowout and oil spill make clear that offshore oil and gas drilling can
have devastating impacts that affect or preclude many other activities in and uses of the ocean. Before
risking these kinds of impacts in the vulnerable Arctic Ocean, there should be a comprehensive planning
process, with meaningful input from local communities, to guide decision-making in the region.
President Obama has called for stronger and more comprehensive management of our oceans.
Last year, he created the Interagency Ocean Policy Task Force and charged it with developing a national
ocean policy and a framework for coastal and marine spatial planning. The Task Force recognized
changing conditions in the Arctic as a priority objective and recommended the development of a strategic
action plan for the Arctic. The Task Force also recommended the initiation of coastal and marine spatial
planning in Alaska, including in the Arctic. We expect the Administration to finalize both the national
ocean policy and framework for coastal and marine spatial planning in the near future. Once finalized,
the proposed National Ocean Council should begin drafting a strategic action plan for the Arctic, and
should take the first steps toward coastal and marine spatial planning in the region.
The national ocean policy and framework for coastal and marine spatial planning should guide
decisions about offshore activities, such as oil and gas leasing, under the discretion provided in existing
law. Exploration drilling in the Arctic Ocean should be suspended until the proposed National Ocean
Council has completed its Arctic strategic action plan and coastal and marine spatial plan. If MMS allows
exploration drilling to go forward this summer, it risks a blowout, spill, or other incident that could
compromise the Administration’s ability to achieve the objectives of those plans.
(5)
Conclusion
BP’s Deepwater Horizon blowout and oil spill have tragically demonstrated the risks of oil and
gas drilling and the enormous difficulties inherent in responding to and cleaning up a large oil spill. In
the fragile Arctic, where the remote and harsh environment would make response and cleanup effort far
more difficult, if not impossible, the consequences of a large spill would be catastrophic.
MMS regulations provide for the suspension of offshore oil and gas operations. 30 C.F.R. §
250.168; see also id. § 250.172. In light of the BP Deepwater Horizon incident, we urge you to
exercise this authority and suspend operations on Shell’s Chukchi and Beaufort leases. There
should be no exploration drilling on OCS leases in the Arctic until, at a minimum, (1) The Coast Guard
and other appropriate investigative authorities determine definitively the cause of the Gulf blowout and
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the MMS can take action to assure that drilling in the Arctic Ocean will not experience similar events; (2)
the USGS conducts its science and oil spill gap analysis, there is an independent analysis of science and
response capacity, and we have a better understanding of the impacts of oil and gas activity on Arctic
marine ecosystems and how to effectively prevent and respond to a spill; (3) MMS addresses
shortcomings in its assessment of Shell’s exploration plans; and (4) there is a comprehensive and
coordinated management structure to guide decision-making in the region.
Sincerely,
___________________________________
Eric F. Myers
Senior Policy Representative
Audubon Alaska
___________________________________
Janis Searles Jones
Vice President, Legal Affairs and
General Counsel
Ocean Conservancy
___________________________________
Jim Ayers
Vice President
Oceana
___________________________________
Marilyn Heiman
Director, U.S. Arctic Program
The Pew Environment Group
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