16 MAY 1977
Hopson’s Testimony: The Environmental Impact Assessments Associated with Prudhoe Bay Gas Pipeline Proposals, Council
on Environmental Quality
Mr. Chairman, I am Eben Hopson. I am Mayor of the North Slope borough. Our’s is a regional, home rule municipality covering the entire Arctic Slope, and our jurisdiction includes Prudhoe Bay, and the entire Alaskan portion of the proposed Arctic Gas Pipeline route, as well as the Arctic portions of the other two routes.
We are in the middle of our spring whaling season in Barrow, but I felt these hearings to be sufficiently important to fly here today to talk to you about the adequacy of what I would like to call the “EIS process.” I would like to talk about our experience with it as it relates to the gas pipeline proposals with which you are dealing, but I would also like to help you understand the context and our point of view from which we observe the EIS process.
The North Slope borough was established in 1972 as the first home rule government in the North American Arctic. We Inupiat are proud of the North Slope borough because it represents major progress in the restoration of democratic self-determination to all Inupiat in Alaska, Canada, and Greenland.
Strangely, none of the competing pipeline companies bothered to contact the North Slope Borough directly to discuss their EIS programs with us. Our government has not been officially involved in the planning, research or writing of any of the environmental impact statements associated with any of the three routes. Some Borough employees may have been interviewed by EIS contractors, but no effort was made to involve the Borough in the planning or execution of environmental impact assessment within our jurisdiction. But this has been true for all environmental impact statements associated with oil and gas exploration and development projects within our jurisdiction. There have been many of these written in connection with NPR-4, and many are being prepared in connection with the Beaufort Sea OCS Program. Our Borough has been largely ignored in their preparation.
Recently, we organized a new Department of Conservation and Environmental Security to strengthen the Borough’s involvement in the EIS processes of other agencies, and to institute our own environmental impact assessment program. As part of my testimony, Mr. Chairman, I would like to include a copy of the recent memorandum to me from this new Department outlining our environmental protection policies and programs. I have reviewed this memorandum and feel it is a fair statement, one that I will submit to our Assembly with the hope that it will be incorporated in an official environmental policy statement from our Borough Assembly.
I feel that when other governmental agencies become aware of our active interest in all environmental impact assessment within our jurisdiction, through the work of our new Department of Conservation and Environmental Security, we will be able to overcome the lack of involvement of local government in EIS work on the Arctic Slope.
The North Slope borough first became closely involved in the EIS process when the Inuvialuit of Inuvik, in Canada’s Western Arctic, contacted me just over one year ago to ask me to intercede in the plans of the Canadian government to issue a drilling permit to DOME/CANMAR for the first Beaufort Sea OCS exploration project off the Tuktoyuktuk Peninsula in the Mackenzie Bay. I learned from Canadian government officials and from the Inuvialuit’s Committee for Original Peoples Entitlement (COPE) that the Canadian government had joined with the oil and gas industry to conduct a five year Beaufort Sea Study which produced three dozen reports that comprised a very comprehensive environmental impact assessment. At the invitation of our own Federal OCS Environmental Assessment Program officials, I attended a U.S./Canadian Beaufort Sea Conference in Seattle where I learned from Arctic environmental scientists involved in the Canadian Beaufort Sea Study that their study was concluded by a recommendation for the Canadian government to deny a final permit for the DOME/CANMAR Mackenzie Bay Project. This was the recommendation of Environment Canada.
The recommendation to delay Canadian Beaufort Sea OCS operations was based upon general perception that the industry lacked adequate proven technology able to safely operate in the Beaufort ice environment. This was particularly true with respect to extraction technology, and I began to question the wisdom of allowing OCS exploration in the Arctic ice environment where no existing technology could safely take oil out from under the ice.
However, as you know, the Canadian government chose to go ahead in spite of the conclusion of their comprehensive environmental impact statement, and I began to wonder about the entire EIS process. Since then, the DOME/CANMAR Beaufort Sea OCS wildcat operation has suffered two blowouts, one of which resulted in a methane explosion that killed a drilling ship crewman.
The implications about the ability of a Texas businessman, Lamar Hunt, to work through a small Canadian company, Dome Petroleum, and its subsidiary, Canadian Marine (CANMAR), to win permission to conduct Beaufort OCS operations which would never have been permitted on our side of the Beaufort Sea; the implications of this contravention of our own national Arctic environmental safeguards were too great to ignore. They posed a direct threat to the environmental security of the people of the North Slope borough. We at the North Slope Borough have gone to great pains to bring this problem to public attention.
A great deal has happened in the past 12 months. Motivated by what I had learned about the Canadian Beaufort OCS program, I worked to expose this problem to national attention through the use of the 1976 Congressional election campaign. I sought and won my party’s Congressional nomination in order to raise our national Arctic environmental security as an important national political problem. I felt so strongly about this problem that I decided to continue my political campaign in spite of serious illness from which I have only recently fully recovered.
Because of illness, I was not able to personally deliver my testimony before the Berger Commission, but I prepared my statement at the request of the Inuvialuit’s Committee for Original People’s Entitlement of Inuvik, Northwest Territories. I would like to enter my Berger commission testimony into your record of this hearing, Mr. Chairman, because it says what we would have said if any of the gas pipeline companies had asked. In my testimony before Justice Berger, I sought to tell the story of the North Slope Borough and of our experience with oil and gas operations on the Arctic Slope.
In my opinion, however, the EIS process must be improved in the Arctic if it is to have any significant role in the defense of our national Arctic environmental security. both the questions of Beaufort Sea OCS operations and a Prudhoe Bay gas pipeline routing have enabled us to see that there can be no reliable Arctic environmental security until Canada and the United States negotiates a single set of rules to govern all Arctic energy resource development. The United States is bound with Canada in an inevitable Arctic energy partnership. Decisions reached through this partnership will be executed by an oil and gas industry controlled by U.S. corporations. Regional Arctic environmental impact assessment must be treated as a matter for international cooperation. Because we Inupiat are the indigenous people of the North American Arctic, we have a right to be a party to all Arctic environmental impact or risk assessment. Our rights are based upon our aboriginal land rights, which include our right to protect our land from harm. None of the EIS reports prepared by any of the competing pipeline companies have adequately involved any part of our circumpolar Inupiat community in environmental impact assessment.
Mr. Chairman, the biggest deficiency in the environmental impact assessment connected with the gas pipeline proposals is that they fail to take adequate account of the larger ecological context of the proposed corridors. Therefore, they fail to deal adequately with the relationship between the pipelines and the Beaufort Sea OCS program. It is our position that this program has begun prematurely in the MacKenzie Bay with the expectation that Nixon administration support of the Arctic Gas Mackenzie Valley Pipeline would enable the marketing of gas and oil that would otherwise be uneconomic reserves. It remains to be seen whether or not Arctic Gas has been able to maintain its support in these new political days. As we know, one of the Canadian Beaufort Sea blowouts last fall was a gas blowout. When I was in Washington D.C. in March to testify before Congressional gas pipeline route selection oversight hearings, our Senator Ted Stevens told me that Arctic Gas had begun to justify its route on the basis of Beaufort Sea OCS reserves. Therefore, I don’t feel that a single-project EIS statement can adequately assess potential Arctic impact. There is a solid, non-deferrable connection between the Arctic Gas Pipeline and the pressures for premature Beaufort Sea OCS operations. Yet, this indirect impact is not adequately assessed in any work that I have seen.
The potential for the Arctic Gas Pipeline to tempt the industry to overextend itself in the Beaufort Sea OCS environment is a serious threat to our national Arctic environmental security, and it is this, more than any other environmental risk, that we find objectionable about the Arctic Gas Mackenzie Valley route.
Next month, during the week of June 13th, leaders of our circumpolar Inupiat community, from throughout Alaska, Canada and Greenland, will come to Barrow to participate in our Whale Festival, and to conduct the First Inuit Circumpolar Conference. WE are meeting to organize the Inupiat Circumpolar Assembly. The purpose of this Assembly will be to establish international Inupiat Arctic offshore jurisdiction. Part of this jurisdiction will be the evaluation of all Arctic coastal zone energy resource development plans in terms of our traditional use values, and to enable the entire circumpolar Inupiat community to work with the multi-national oil industry to enable safe and responsible Arctic energy resource development, both onshore and offshore. The North Slope Borough will be working with our Inupiat Circumpolar Assembly to organize an international Arctic Coastal Zone Management Program which will be responsible for making the EIS process work in the Arctic, and for the people of the Arctic.
Mr. Chairman, the CEQ has been given the task of evaluating the adequacy of assessing the environmental impacts necessitated by the marketing of Prudhoe Bay gas to the Lower 48 states. You do so when the EIS reports is under widespread attack in the United States and Canada. EIS reports tend to irritate rather than inform. They commit information overkill. They reveal nothing by talking about everything. They are usually poorly written and hard to read. They are poorly organized, and over-generalized. They are seldom site-specific, so they seldom make useful reference texts for our land use planners. And, they are often inconclusive about the balance of risk to our people and our land. They constitute an undisciplined discipline, and I feel that our environmental scientists who write them do all of us a disservice.
I am told that the CEQ regularly evaluates the effectiveness of our national environmental safeguards. In my opinion, the EIS process does not work well in the Arctic. The biggest reason for this is that the process is controlled by the resource development corporations which are led by men who have chosen to ignore or oppose the knowledge of those of us who live across the North American Arctic coast. Any EIS process that fails to reflect our knowledge of the Arctic to protect our traditional use values is of no use in the protection of our environmental security.
Successful protection of our national Arctic environmental values depends upon the protection of our Inupiat traditional land use values. Obviously, we need to make an effort at cross-cultural environmental impact assessment. The multi-cultural strength of American society can be realized only through good will efforts that reach as far as the EIS process in the Arctic. For our part, we intent to make this effort. That is why I am here today.
From our point of view, those who are licensed to profitably exploit our land for its subsurface wealth should regard themselves as very privileged, and privilege carries heavy responsibility. We do not think that the EIS process employed in the Arctic by either private enterprise or government agencies lives up to this responsibility. Through democratic home rule all across the Arctic, we Inupiat hope to be able to help improve the EIS process from the state in which we find it today.