Comment from Sierra Club
Sierra ClubOpposeAdvocacy
Summary: The Sierra Club opposes the proposed Incidental Take Regulations (ITR) for seismic exploration by SAExploration, Inc. in the Southern Beaufort Sea. They argue that the U.S. Fish and Wildlife Service (FWS) failed to adequately account for the likelihood of lethal take of polar bear cubs and has unlawfully segmented the analysis of cumulative impacts.
The attached files present the comments of the Sierra Club on the proposed SAExploration ITR and findings, and associated Draft Environmental Assessment. The attached files include a pdf of the main comment letter and expert report attachments (Sierra Club Main Comment Letter and Attachments.pdf), and seven additional pdfs that present the materials cited in the comment letter and in the expert reports cited in the comment letter, for inclusion in the administrative record (Sierra Club Cited Materials 1.pdf, Sierra Club Citied Materials 2.pdf, Sierra Club Cited Materials 3.pdf, Sierra Club Cited Materials 4.pdf, Sierra Club Cited Materials 5.pdf, Sierra Club Cited Materials 6.pdf, and Sierra Club Cited Materials 6B.pdf).