Up to this point, the environmental assessment had received a level of attention reserved for only the most sensitive internal documents, according to two BLM employees. “That EA—every word of it—was the most scrutinized, politicized and controversial thing any of us had ever seen,” one of those BLM employees told me.

On the eve of publication, members of the BLM seismic team were given one last chance to review their respective sections but also instructed “to not make any changes to this document.” After thanking the team for its diligence and hard work, LaMarr wrote, “Please be aware that there have been numerous edits based on solicitor and State Office review. You may see some changes to your sections based on these edits.”

In some cases, the changes were deeply troubling to those who had originally drafted the document. At least two BLM employees took the unusual step of submitting complaints, which become part of the administrative record, an internal way of documenting the decision-making process for NEPA reviews. This sort of forceful condemnation of changes made by higher-ups within the department is rare, though not unheard of, according to Klein, who served at DOI under Obama.

In one instance a fisheries biologist wrote in an email to the project managers that, as a result of changes to his text, there were “fundamental inaccuracies in the seismic EA.” Another career employee was surprised to find that entire paragraphs on potential impacts to native communities, including environmental justice concerns, had been scrubbed from her analysis. “I am troubled by numerous omissions from my sections,” the employee wrote. She also warned that BLM might not be complying with guidance on tribal consultation for the EA. “[BLM] normally conduct government-to-government consultation for large seismic projects in the NPR-A, therefore doing so would not have been extraordinary,” she wrote.

Perhaps the most dramatic change was the reversal of a conclusion reached by Debbie Nigro, a BLM wildlife biologist, who found that seismic activity could have a negative cumulative impact on the southern Beaufort Sea polar bear population. Nigro, a long time BLM biologist who has received recognition for her work to protect threatened waterfowl, wrote the section in consultation with marine mammal experts at the FWS.

Polar bears are an important regional predator, as well as one of the best-known symbols of Arctic wildlife, and they’re considered a threatened species: The southern Beaufort Sea population has declined by more than 40 percent to just 900 bears in the past few decades. Based on SAExploration’s initial proposal, Nigro and FWS concluded there was a real possibility that polar bears and their critical denning habitat would be harmed by winter seismic exploration. According to Nigro’s assessment, “It is unknown to what extent, but possible that cumulative effects to polar bears and their habitats would result from the incremental addition of winter seismic exploration in the Coastal Plain.” Yet after undergoing “solicitor and State Office review,” according to the email from the assistant manager of the Arctic District Office, the section was changed to say the opposite. The draft version stated that if seismic exploration moved forward, “Cumulative effects to polar bears and their habitats would be less than significant.”

In her comments submitted as part of the administrative record, Nigro described the textual change as “significant” and included a copy of her original paragraph alongside the new version. “I know there is likely nothing that can be done,” she wrote, “but I would like it to be in the admin record that I do not agree with this wording change or with the new conclusion.”

The Department of the Interior says the draft environmental assessment was not reviewed by the department’s lawyers in Washington, D.C., or by Bernhardt. Nor was Bernhardt aware of the changes made to the document, according to DOI. In addition, the department said BLM’s “approach was predicated and dependent on the presumption that the applicant would be able to” receive the necessary approvals from the FWS. “This never came to fruition and thus the BLM could not move forward.”

Asked whether Balash had reviewed the draft analysis and was aware of the changes made to the document, DOI did not provide a yes or no response. His calendars show he was very much engaged with ANWR issues. Between August 23 and September 13, when Sarah LaMarr sent out her email to the seismic team, Balash had no fewer than nine meetings related to the Arctic Wildlife Refuge. He was also traveling in Alaska in late August and, according to his calendars, had a meeting with regional solicitors to discuss coastal plain matters.

Klein said the documents raise “significant questions about interference with scientific integrity processes at Interior and with the expert conclusions of the department’s own staff. Their work has been changed in ways they don’t agree with. That’s unusual and very troubling.”