In the waning days of 2018, the U.S. Interior Department took a major step toward allowing oil drilling in the Arctic National Wildlife Refuge by releasing a draft environmental impact statement (DEIS) that downplays and underestimates the damage that would result from drilling one of the most wild places left on earth.* The review, required by law and conducted by a private contractor hired by the Interior Department, assesses the potential environmental impacts of auctioning off drilling rights on more than 1 million acres of the coastal plain in the Arctic Refuge.

A Center for American Progress review of the Interior Department’s environmental analysis finds that it dramatically underestimates and discounts the permanent, irreversible damage that would result from drilling in the Arctic Refuge. Even through the assessment’s rosy lens, it’s clear that drilling would have terrible consequences for the refuge, its wildlife, and the indigenous populations who rely on it for subsistence.

The Trump administration is hurrying this inadequate assessment in an attempt to sell off drilling rights before Congress or a future administration can intervene to block destruction of the Arctic Refuge. Significantly, no new scientific data were collected for the DEIS—though an independent 2018 U.S. Geological Survey report found that there are many data gaps and a significant amount of outdated information on coastal plain resources and the potential impacts of oil and gas development in the refuge.

This column discusses five of the many areas where the rushed assessment fails to capture the full impacts of drilling in the Arctic Refuge: oil spills; destruction of polar bear and caribou habitat; increased carbon pollution; surface disturbance; and water consumption.

Oil spills

Based on historical oil and gas activity on Alaska’s North Slope, the DEIS expects that development would result in up to 1,745 oil spills, including six large spills. Although these are striking numbers, the assessment downplays the risk, stating that the probability of a spill of more than 100,000 gallons is “low” because there were “only” three spills of that magnitude documented from 1985 to 2010.

If one examines oil spill data from across Alaska, however, the prospect of a major spill in the Arctic Refuge seems almost certain. From 1995 to 2005, North Slope oil fields averaged more than 400 oil spills per year. Across Alaska, there were 16 major spills from 2002 to 2016 that released at least 10,000 gallons of oil each into the environment; five of those released more than 100,000 gallons each. Most recently, in April 2017, a BP well in nearby Prudhoe Bay gushed oil and gas for three days before an emergency response team managed to kill the well.

Destruction of polar bear and caribou habitat

According to estimates used by the U.S. Fish and Wildlife Service, there are just 900 Southern Beaufort Sea polar bears left in the world—a stunning 50 percent decline from just 30 years ago. The DEIS tellingly fails to include an estimate of how many polar bears could be killed, injured, or displaced by drilling in the Arctic Refuge, but it does acknowledge that “the potential for injury or mortality could be high when developing new oil and gas projects.”

More than 77 percent of the coastal plain—the area of the refuge under consideration for leasing—serves as critical denning habitat for polar bears, with a concentration of maternal dens in areas the DEIS identifies as having high oil and gas potential. The DEIS suggests that infrared cameras are an “effective means of locating dens” in order to avoid disturbance. Independent polar bear experts note, however, that this method of locating dens is very unreliable and that surveyors could miss up to 50 percent of dens due to poor weather conditions, hilly terrain, snow depth, and failure of industry to apply best practices—errors that could result in deaths of or injuries to polar bears.

The DEIS also suggests that 49 percent of the coastal plain that could be offered for leasing is sensitive calving grounds for porcupine caribou, a herd whose long-term health is inextricably linked to the Arctic Refuge. This statistic, however, vastly undercounts the value of the coastal plain to the caribou, who use virtually 100 percent of the area during calving and post-calving seasons—a statement supported, in part, by the review’s own maps of the herd’s historic movements.

Even with the downplayed numbers, the assessment does acknowledge that activity that moves the herd away from the coastal plain would be detrimental, citing a study predicting an 8 percent decline in calf survival due to displacement. While the DEIS acknowledges that the potential for disturbance and displacement of caribou could cover up to 633,000 acres—40 percent of the coastal plain—it offers a wholly insufficient solution to mitigate the impact: suspension of “major construction activities”—but not drilling—for a single month of the year. This is particularly problematic given the National Oceanic and Atmospheric Administration’s 2018 Arctic Report Card, which found that overall, Arctic caribou populations have decreased by more than 50 percent in the past 20 years.

Increased carbon pollution

The DEIS significantly underestimates the greenhouse gas (GHG) emissions that would result from drilling the Arctic Refuge. Misleadingly, the analysis only calculates the fractional GHG emissions from the consumption and combustion of oil that would result from the net increase in oil demand that the analysis predicts would result from Arctic Refuge production. As a result, the Trump administration’s analysis suggests that the indirect GHG emissions from combustion and downstream use of the oil would amount to 0.7 million to 5 million metric tons annually.

But if one calculates the total GHG emissions that would result from combustion of all the oil and gas that the DEIS predicts will be extracted from the Arctic Refuge, this number is magnitudes higher. CAP estimates that closer to 62 million metric tons of CO2 equivalent would be released into the atmosphere from the oil that the DEIS predicts will be produced from the Arctic Refuge—equal to the annual emissions of approximately 16 coal-fired power plants or 13 million cars.

Surface disturbance

The Trump administration’s environmental assessment of drilling the Arctic Refuge performs some impressive twists in order to state that disturbance to land from oil and gas activity would be limited to fewer than 2,000 acres, as required by law. The DEIS creatively interprets the legislative language so that elevated pipelines and gravel pit mines do not count as surface disturbance; it also does not count the disturbance from other activities such as seismic exploration or ice road construction. More than 200 miles of elevated pipelines would be constructed in the refuge, but the analysis only considers the posts that touch the ground—a vast undercount of a pipeline’s footprint. Similarly, the analysis arbitrarily discounts the anticipated 325 acres of gravel pits.

Water consumption

The DEIS avoids providing a clear estimate of how much water will be required for energy development, but a CAP analysis of numbers scattered throughout the document finds the potential water consumption of drilling the Arctic Refuge to be staggering—billions of gallons per year—and inconsistent with the continued provision of clean water for fish and wildlife species in the area.

CAP estimates that up to 1.3 billion gallons of water—and perhaps far more—would be needed to drill the oil wells that the DEIS projects would be drilled. The DEIS states that drilling a single well requires 420,000 to 1.9 million gallons of water; all of the DEIS’ development scenarios contain at least 21 production and satellite pads, with approximately 30 wells per pad. Beyond that, the DEIS states that 1 million gallons of water are needed to construct every mile of ice road, and 500,000 gallons of water are needed for every ice pad.

Most striking is the water required once production starts. Using the numbers from the DEIS, CAP calculates that 5.7 billion gallons of water per year would be needed just to support oil production. The DEIS estimates that producing 50,000 barrels of oil would require 2 million gallons of water per day; it also assumes that up to 142 million barrels of oil could be produced each year, on average.

Over the life of oil production on the coastal plain—which the DEIS estimates could extend from 50 years to 100 years—this all quickly adds up to an unthinkable amount of water. Available fresh water in the coastal plain is scarce and growing scarcer, and the U.S. Fish and Wildlife Service, which manages the refuge, has flagged concerns about the “cumulative impacts of all stages of oil and gas development” on water and, subsequently, the “populations and habitats of fish and wildlife.”

Conclusion

The wild and rugged rivers, plains, and coastline of the Arctic National Wildlife Refuge have been carved and shaped by millions of years of ice, wind, sun, and geologic change. But the Trump administration is offering just 45 days for the public to comment on the draft environmental review of sacrificing these lands for oil drilling.

In the brief window before February 11, it is vital that the public—including Alaska Natives, scientists, and everyone who values the survival of America’s wildlife—call out the deceptive estimates, wishful thinking, and inadequate analysis that plagues the Trump administration’s environmental review. The flaws in this analysis reaffirm how fundamentally wrong it would be to drill the Arctic Refuge, and they underscore the need for Congress, the courts, or a future administration to stop this heedless rush and protect America’s last great wilderness.

* Authors’ note: Specific page numbers for this column’s references to the Interior Department’s draft environmental impact statement—and the U.S. Fish and Wildlife Service’s concerns about available fresh water on the coastal plain—are on file with the authors.

Kate Kelly is the director of Public Lands at the Center for American Progress. Matt Lee-Ashley is a senior fellow and the senior director of Environmental Strategy and Communications at the Center. Jenny Rowland-Shea is a senior policy analyst for Public Lands at the Center. Sally Hardin is a research analyst for the Energy and Environment War Room at the Center.