Comment from Towers Saint Amand, TerryAnn

I am writing to oppose the proposed authorization of incidental take of Southern Beaufort Sea polar bears associated with SAExploration's seismic exploration activities on Alaska's North Slope. My primary concern is the disconnect between the Service's findings and its conclusions. The proposed rule acknowledges that disturbance of maternal dens can result in den abandonment, premature den emergence, separation of mothers and cubs, and cub mortality. It acknowledges limitations in den detection and monitoring, a measurable probability of lethal take during the authorization period, and ongoing stress to the Southern Beaufort Sea population from climate-driven habitat loss and environmental change. Yet despite these findings, the Service concludes that authorization is appropriate and that a more comprehensive environmental review is unnecessary. The record does not adequately explain how those conclusions follow from the evidence presented. The proposal relies heavily on mitigation measures, but mitigation cannot eliminate risks that depend on detecting something that may not always be detected. The Service acknowledges that den detection methods have limitations and that uncertainty remains. When dealing with a threatened species, uncertainty should weigh in favor of greater protection, not greater exposure to risk. If a maternal den is disturbed and cubs are lost, that outcome cannot be undone. The Service also appears to evaluate this seismic exploration program largely as an isolated activity. However, seismic exploration exists to identify and characterize subsurface resources that may support future oil and gas development. The foreseeable sequence is clear: exploration may lead to future leasing, drilling, infrastructure construction, transportation, and production. Evaluating the impacts of the first step while minimizing the cumulative impacts of the activities it is designed to facilitate understates the significance of the proposal. A more robust cumulative impacts analysis is warranted. I am also concerned by the lack of transparency regarding consultation with Alaska Native communities and organizations. The public record should clearly identify which Tribal governments, Native organizations, subsistence users, and local communities were consulted, what concerns they raised, and how those concerns influenced the proposed authorization. Given ongoing public controversy and litigation involving Arctic wildlife, subsistence resources, and North Slope development, a transparent record is essential. Ultimately, the Service's own findings raise serious questions. The proposal acknowledges denning risks, the possibility of lethal outcomes, limitations in detection and monitoring, ongoing population stress, and substantial uncertainty. Given those findings, the Service has not adequately explained why five years of recurring industrial disturbance is consistent with its conservation responsibilities. I urge the Service to deny the proposed authorization or, at minimum, prepare a full Environmental Impact Statement, conduct a more robust cumulative impacts analysis, provide greater transparency regarding Tribal consultation, and adopt substantially stronger protections for denning polar bears and their cubs before proceeding.