Dear USFWS and Greg Siekaniec, Regional Director for the Alaska Region,
To rush the leasing process and allow the associated preparatory steps, such as seismic testing, to move forward is patently wrong, misguided, and unfair to the public and management agencies, both of which need time to consider the natural history, geology and biology of the ecosystems at risk. To conclude, as USFWS apparently intends to conclude, that the seismic program will not have a significant impact to polar bears is unsupported and wrong.
The USFWS has a solemn obligation to protect the Arctic Refuge and the polar bear is one of the USFWS trust species. In considering the Incidental Harassment Authorization (IHA) application, USFWS must take the necessary time to review, measure, and ensure scientific integrity, including the preparation of an in-depth analysis of potential direct, indirect, and cumulative impacts rather than the cursory analysis undertaken to date.
An objective, non-rushed, scientifically based decision process is necessary. The proposed seismic operations will risk significant harm to polar bears and therefore, it is our recommendation the USFWS deny an incidental harassment authorization for the proposed seismic program.
[Your Name]
