Call For New Information

Cook Inlet Keeper is a citizen-based nonprofit organization dedicated to protecting the Cook Inlet watershed and the life it sustains. Please accept these comments on behalf of Keeper’s 600+ members living in the Cook Inlet watershed.

II. Comments

A. Seismic Data

New information suggests the Cook Inlet basin is more seismically active then previously understood.[1] In light of this new information, DNR must revise its previous Best Interest Finding for the Cook Inlet Areawide Oil & Gas Lease Sale, taking into account the elevated risk associated with platforms, pipelines and related facilities in a more seismically active area. At a minimum, mitigation measures must be incorporated which require infrastructure to withstand a worse case seismic event in Cook Inlet, and DNR must analyze the practicable mitigation of all seismic-related risks.

According to a new report from the Cook Inlet Regional Citizens Advisory Council, Cook Inlet contains over 156 miles of pipelines which carry crude oil, and unlike trends nationally, leaks from Cook Inlet pipelines are increasing.[2] Specifically, “[t]hese pipelines are approaching the end of their expected life span and need closer monitoring and testing.”[3] In fact, recent information regarding facility lines from Unocal’s Dillon platform indicates the pipeline wore from the outside-in, suggesting gross inadequacies in pipeline maintenance and oversight in Cook Inlet.[4] As a result of this new information, DNR must revise the BIF to more carefully consider the effects of outdated pipeline infrastructure in Cook Inlet, including a discussion how continued reliance on this antiquated system (and the concomitant risks of increased spills) can be found to be in the best interest of Alaskans, and how potential impacts have been mitigated to the extent practicable.

To date, no industry or agency has undertaken a legitimate effort to understand the effects of oil & gas exploration, development and production on the behavior or life cycle of the Cook Inlet beluga whale. In particular, there have been no studies to understand the effects of noise, drilling muds or produced waters on Cook Inlet beluga whales during migration, mating, birthing, or feeding activities. As a result, DNR lacks the information necessary to lease tracts in this area. In light of the decision in Cook Inlet Keeper v. DNR (case no. #AN-99-3343 CI), and DNR’s subsequent commitment to defer leasing on 124 tracts identified as important beluga whale habitat, please let me know whether DNR plans to offer the referenced tracts during the upcoming 2001 lease sale.

III. Conclusion

Thank you for the opportunity to provide comments on this important matter, and please feel free to contact me at (907) 235-4068 or bob@inletkeeper.org if you have any questions.

[1] Peter J. Haeussler, et al., Potential seismic hazards and tectonics of the upper Cook Inlet basin, Alaska, based on analysis of Pliocene and younger deformation, GSA Bulletin, v. 112, no. 9 (September 2000) (Available at: http://www.geosociety.org/pubs/bulletin/0900bul.htm#S6 ).

[2] Tim Robertson & Parker Horn Company, Overview of Pipeline Regulatory Requirements: Cook Inlet, Alaska (May 2000) (Prepared for the Cook Inlet Regional Citizens Advisory Council).

[3] Id. at p. 2.

[4] See Attachment A (showing picture of ruptured Dillon platform pipeline) (ADEC file photo).

I. Background

II. Comments

A. Seismic Data

III. Conclusion