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United States Department of the Interior
U.S. FISH AND WILDLIFE SERVICE
Northern Alaska Field Office
101 12th Avenue, Room 110
Fairbanks, Alaska 99701
January 21, 2022
Memorandum
To: Nichelle Jones, Arctic District Manager, Bureau of Land Management
From: Kaithryn Ott, Lead Section 7 Biologist, U.S. Fish and Wildlife Service
KAITHRYN OTT Digitally signed by KAITHRYN OTT
Date: 2022.01.21 09:53:23 -09'00'
Subject: Request for concurrence on a not likely to adversely affect determination for
spectacled and Steller’s eider, and polar bear, and a no effect determination for
polar bear critical habitat for the Emerald House Peregrine Exploration Program.
This memorandum is in response to your concurrence request for effects of the Proposed Action
on endangered and threatened species and designated critical habitat pursuant to section 7 of the
Endangered Species Act (ESA) of 1973, as amended. The U.S. Fish and Wildlife Service
(Service) previously consulted on the Bureau of Land Management’s (BLM) issuance of a 5-yr
Right of Way (ROW) authorization to Emerald House Peregrine Exploration’s (Emerald House)
exploratory drilling program in the National Petroleum Reserve – Alaska (NPR-A) in a letter
dated November 5, 2020, regarding effects of the Action on listed spectacled eiders (Somateria
fischeri), Alaska-breeding Steller’s eiders (Polysticta stelleri), and polar bears (Ursus
maritimus). We understand Emerald House has proposed an amendment to the ROW for
modified access to an additional exploratory well. To ensure continued section 7 compliance
related to Emerald House’s Exploration Program, on January 11, 2022 BLM requested the
Service to re-affirm its concurrence with BLM determinations regarding Emerald House’s
ongoing and proposed activities. Therefore, the Service has reviewed the Peregrine Exploration
Program, as amended, to determine if it would adversely affect listed species or designated
critical habitat under our jurisdiction. Although the Proposed Action would not occur within
designated polar bear critical habitat, it is proximal to designated terrestrial denning habitat.
THE PROPOSED ACTION
Emerald House proposed an amendment to their existing 5-yr ROW authorization to continue an
exploration and drilling program from 2022 through 2025. The existing ROW includes access,
exploratory drilling, testing and associated activities (camp, fuel storage, etc.) for the program.
The 2022 exploration activities would be a component of the five-year oil and gas exploration
program within Emerald’s Peregrine Oil and Gas Lease Block southwest of Nuiqsut in the NPR-
A. The proposed amendment would include modified access to an additional exploration well
(Merlin 2) within the same lease block (Figure 1).
Access to the project would start through the Prudhoe Bay oil fields with controlled security
checkpoints. Access would be along gravel roads on State of Alaska lands to an existing
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permanent gravel pad (2P) (Figure 1). At the 2P pad, the access route would continue across the
seasonal North Slope Borough (NSB) Community Winter (Snow) Access Trail (CWAT) on
state lands for approximately 27 miles before entering the NPR-A at Ocean Point along the
Colville River. Once west of the Colville River, Emerald House would construct a snow road to
the Merlin 2 drill site and to Umiat (approximately 80 miles). The snow road would be built to
accommodate the drill rig, camp move, and associated activities.
Winter infrastructure
A process of “prepacking” snow would occur along the snow roads and at the ice
pad locations (well site pad and four staging ice pads). Prepacking would be used to
compact snow to hold it in place, remove the snow’s insulating properties to drive frost
down, mound up snow at stream crossings to protect streambanks, create ramps, and cover
willows.
Prepacking would be implemented using snow machines, Tucker SnoCats, Pisten Bully’s or
similar all terrain smooth-tracked vehicles that are approved for summer off road tundra
travel and would result in a minimum of 6 inches of compacted snow for the base of the
snow roads and ice pads.
Water may be applied along the prepacked route and pads to form a thin crust and hold dry
snow in place. If the tundra opening criteria has not been met when operations are scheduled
to begin, Emerald House may request approval from the BLM and the Alaska Department of
Natural Resources (ADNR) Division of Mining, Land and Water (DMLW) to use half-
loaded water buffaloes (water trucks) to apply water along the prepacked snow road. Once
BLM and ADNR DMLW have confirmed that tundra opening criteria have been met along
the route, fully loaded water trucks would be used for watering.
Emerald House would construct both conventional (i.e., compacted snow) and armored (i.e.,
ice chips and water added to compacted snow) snow roads on the route between Ocean Point
and Umiat (Figure 1). Some changes in the route shown in Figure 1 may be necessary due to
terrain, water sources, wildlife dens, river crossings, or other field conditions at the time of
construction. Travel in the project area would avoid, as much as possible, traveling over any
terrain including bluffs and riverbanks which provide suitable habitat for denning bears. The
final route could be up to 1,500 feet different in either direction from the route shown in
Figure 1 and would be at least 100 feet from the 2020/2021 snow road location.
Snow roads would be constructed and maintained using accepted practices for the North
Slope and following the BLM NPR-A Integrated Activity Plan (IAP) Required Operating
Procedure (ROP) C-2 that requires soils to be frozen to a depth of 12 inches with a minimum
of 6 inches of snow cover. Additional snow cover or ice chips would be used to cover and
protect sensitive tussock tundra and willows during snow road and ice pad construction.
Four thermistors were installed along the snow road in September 2021. Once operations
begin, Emerald House would submit thermistor data to the BLM on a weekly basis.
River and stream crossings could require ice bridges and/or the construction of snow ramps
along the banks. Additional ice chip aggregate and/or water could be required at river and
2
stream crossings. Ice aggregate and water would come from permitted lakes adjacent to the
route. Upon completion of operations, snow road stream crossings would be slotted at a
minimum of two locations to facilitate water flow during spring break up, natural
hydrological regimes, and reduce potential in-stream barriers to migrating fish during spring
break up. Snow berms would also be constructed across the entrance to the snow road to bar
further use.
Both conventional and armored snow roads could accommodate loads up to 115,000 pounds.
Steigers and Pisten Bullys would operate on the conventional snow road but, to prevent
potential damage to the road surface or underlying tundra, heavier semi-tractor trailers and
heavy equipment would be required to stay on the armored snow road. Semi-tractor trailers
and all heavy equipment would be loaded on Steiger trailers at Drill Site 2P, transported over
the conventional snow road, and offloaded either at Dogbone Lake or at the Merlin 2 well
site. The modular drill rig would be transported by Steigers to the Merlin 2 well site.
The Merlin 2 exploratory well would require the construction of a 6-acre ice pad (500 feet by
500 feet) to support oil and gas drilling and testing of the well. Support facilities on the
Merlin 2 ice pad would include a safety station, Covid-19 quarantine rooms, satellite office,
camp for drill rig operators, and storage of fuel and equipment.
Up to 4 additional 6-acre ice pads would also be required for the camp, equipment and
materials, and support facilities (Figure 1). Support facilities on these pads would include
housing units for equipment operators and other staff, generators, fuel storage, and light
towers.
Each ice pad would be constructed by compacting snow and adding ice and water to armor
the pad. All ice pads would be constructed with no physical changes to surface topography
and would meet federal, state and NSB regulatory requirements, industry standards and arctic
oil field best practices. All fuel storage tanks on the pads would be located at least 500 feet
from lakes, rivers, and streams.
Camps
There would be 3 camps associated with operations (one at the Merlin 2 well pad and 2
located on staging ice pads). The Merlin 2 ice pad would house the camp for the drill rig
operators while the camps on the two supporting ice pads would house equipment operators
and other staff. The camps would include housing units, offices, restroom, kitchen, and
recreation areas. The camps would also have generators, fuel storage, and waste management
facilities.
Generators would provide power to the camps, offices, and other facilities. Satellite phone
service and internet would be available at each field camp. Operational radio
communications would use fixed base stations and truck-mounted radio equipment. Potable
water may be transported to the staging ice pads and the Merlin 2 pad or provided on-site by
Potable Water Treatment. Domestic wastewater would be hauled off site for proper disposal
or treated with Wastewater Treatment Modules with an Alaska Department of Environmental
Conservation certified plant operator.
3
Vehicle plug-ins for engine warming systems (e.g., block heaters and oil pan heaters) would
be available at the camps and all staging pads. These would be available in bull rails in front
of camps as well as on mobile heaters or light towers found on the pads.
Airstrip
A temporary airstrip would be constructed to accommodate fixed wing aircraft for crew
changes. Fixed wing flights would also be used to inspect the snow road. There would be
approximately 2 round trip fixed wing flights per week from December 2021, through April
2022, totaling roughly 70 take offs and 70 landings. The temporary airstrip would be located
next to the Merlin 2 drill pad (Figure 1) and be oriented NE/SW to take advantage of
prevailing wind.
The airstrip would be constructed on tundra adjacent to the armored snow road and would be
constructed the same way as the armored snow road. The airstrip would be approximately 50
feet wide, 3,500 feet long and at least 1 foot thick (a minimum 6 inches of compacted snow
capped by a minimum 6 inches of ice) to accommodate an Otter and Pilatus N-12 fixed wing
aircraft.
Exploratory drilling
Drilling operations would be conducted using the Arctic Fox modular land drill rig operated
by Doyon Drilling Inc. The Arctic Fox is capable of being mobilized by all terrain tractor
tundra vehicles such as Pisten Bullys and Steigers. The Arctic Fox drill would be broken
down into 27 sections for overland transportation along the snow road. Once at the Merlin 2
drill ice pad, the rig would be placed on rig mats within a lined secondary containment area.
Rig operations at the Merlin 2 pad would be self-contained and powered by drill rig
generators.
Emerald House intends to gather well data including Measuring While Drilling, Parameters,
Logging While Drilling Data, Wireline Logs, Sidewall and/or Conventional cores, VSPs, and
check-shot information or Drill Stem Test data. Conventional well development and
completion, including hydraulically fracturing specific target zones, may follow.
Production tests could be performed at the well, as needed, after production casing is
set/cemented and the well is completed. Following completion, the well could be
hydraulically stimulated to facilitate testing. After testing, the oil would either be injected
into the same formation or transported offsite for processing and recycling at an approved
facility. Produced gas would be flared.
Emerald House has developed and would maintain a well control plan for drilling that
includes primary and secondary blowout prevention systems, a well capping program, and a
relief well plan designed for arctic conditions.
Upon completion of drilling and testing operations, the Merlin 2 well would either be plugged
(closed) and abandoned or suspended in accordance with BLM and Alaska Oil and Gas
Conservation Commission (AOGCC) regulations, and equipment and structures would be
removed from the project area by the end of April 2022. If the well is plugged and
4abandoned, the well location would be surveyed, and surface and intermediate casing
cemented back as directed by BLM and AOGCC.
Fuel storage and handling
During operations, onsite fuel and hazardous substance storage capacity would total 29,940
gallons and would be stored in double-walled tanks within secondary containment areas. These
fluids would be hauled by commercial carrier to ice pads where they would be stored in multiple
fuel containers. All containers would be stored in bermed/lined secondary containment capable
of holding 110 percent of the fluids stored, marked with product type, operator name, and affixed
with HAZMAT classification labels. The total amount of fuel required for the winter operations
would be approximately 643,320 gallons.
An in-field fuel tanker truck or fuel sleigh would fuel the drill rig, camp, and ancillary equipment
such as heaters, light plants, and heavy equipment. Refueling and fluid transfer would be
performed by two trained operators and would follow the Emerald House fluid transfer methods
in its Oil Discharge Prevention and Contingency Plan (approved by Alaska Department of
Environmental Conservation), North Slope Environmental Handbook, and Alaska Safety
Handbook procedures. Emerald House enforces the use of “duck ponds” (drip pans) for all
parked running or plugged-in vehicles and equipment. Spills of fuels, hydrocarbons, or
chemicals on ice pads and snow roads would be cleaned up immediately.
Fuel storage of more than 1,320 gallons also requires that a Spill Prevention and Countermeasure
Control (SPCC) Plan be developed and maintained on site, and Emerald House has an SPCC
Plan Facility Response Plan for exploration activities. Emerald House and contractor personnel
conducting fluids transfer would undergo training.
Light plants would be placed next to pump houses and road intersections for safety and be
refueled daily. On-site generators would be refueled every 24 to 72 hours. All light plants and
pump houses would have 110 percent containment for fuel.
Waste management
Emerald House has prepared and submitted to BLM a project-specific, comprehensive Waste
Management Plan and would implement it during operations to provide waste management
guidance required by the Alaska Department of Environmental Conservation pursuant to 18
AAC 60 and the 2020 NPR-A IAP ROPs. Emerald House adopted the latest versions of the
Alaska Safety Handbook, the North Slope Environmental Field Handbook, and the Alaska Waste
Disposal and Reuse Guide as guidance, reference, and as standard operating procedures for
workplace safety and for environmental and waste management practices.
Drilling wastes would not be discharged into lakes, streams, rivers, or wetlands and would be
disposed of prior to completion of winter operations. Drill wastes would be properly stored until
removed for disposal. Visual site inspections would be conducted following removal of the
drilling waste to ensure all waste has been removed and photographs would be taken for
reporting documentation.
5Up to 19,000 barrels of drill waste fluids may be generated at a rate of up to 1,000 barrels per day that would require temporary on-site handling and storage and offsite disposal. Drilling fluids (including muds) would either be loaded directly into 168-barrel Arctic Cutting Boxes and hauled by all terrain tundra tractors (Pisten Bullys or Steigers) as soon as possible for disposal (preferred) or would be temporarily stored at the Merlin 2 drill pad in a 288-barrel cuttings bin or 400-barrel steel tank within secondary containment. Solid, non-burnable waste would be deposited in large dumpsters located at each site. These containers would be backhauled to the NSB landfill at Prudhoe Bay daily. Any food waste that could attract wildlife would be stored in secured wildlife proof containers while awaiting transport. Domestic wastewater (including human waste) would average 5,000 gallons per day from envirovacs (restroom facilities) and camps. These wastes would be treated on site and disposed of, or hauled offsite, treated, and disposed of in the permitted Kuparuk River Unit or NSB Deadhorse Service Area 10 disposal facilities. All snow roads, ice pads, work areas, drill site, and camp locations would be inspected during the summer (July 2022) to ensure no debris or materials were left on the landscape after winter exploration activities. The snow roads, pads, and work areas would be flown with a helicopter at low elevation (
3. Continuous monitoring of any bear dens found and limiting travel within 1 mile of dens.
4. Provide U.S. Geologic Survey denning habitat maps to field crews for awareness prior to
field activities.
5. Store food inside buildings or containers to minimize odors.
6. Store hazardous materials in drums or other secure containers.
7. Position structures to maximize visibility and minimize potential areas that a bear could
crawl into or otherwise be hidden from view.
8. Instruct project personnel not to feed wildlife of any type.
Additionally, the following project-specific operating procedures would be required by BLM for
the 2022 activities:
1. Emerald House and its designees will cooperate with the U.S Fish and Wildlife Service
(Service) and other federal, state, or local agencies designated to represent the Service to
monitor impacts of project activities on polar bears. For example, Service personnel will
be allowed access to the activity site upon request.
2. All field crews will follow a Wildlife Interaction Plan prepared by Emerald House
detailing how crews will manage wildlife attractants (food and non-food materials) and
respond to human-polar bear interactions. The interaction plan must include all
guidelines for safely and non-lethally deterring polar bears from damaging property and
endangering the public as found in the Final Rule of the Marine Mammal Protection Act
(MMPA) Deterrence Guidelines (attached). Other methods of deterring polar bears
require authorization by the Service’s Marine Mammals Management office.
3. If a polar bear interaction escalates into a life-threatening situation, section 101(c) of the
MMPA allows, without specific authorization, persons to take (including lethal take) a
polar bear. Any injury or lethal take of a polar bear must be reported to the Service (907-
786-3844) and BLM (907-474-2310) within 48 hours.
4. Emerald House or its designee shall submit copies of the following documents to the
BLM at the time they are sent to the Service: 1) polar bear observation forms; and 2) an
annual monitoring report, if required by the Service.
5. Each year, at least 60 days prior to the start of each year’s winter activity, Emerald House
will notify BLM of their plans for the season on BLM managed lands. After the
requested information is received BLM will determine, in consultation with the Service’s
Marine Mammals Management office, if an Incidental Harassment Authorization (IHA)
for take of polar bears pursuant to the MMPA are available. If an applicant obtains an
IHA, relevant documents must be submitted to the BLM prior to work starting in NPR-A.
EFFECTS OF THE ACTION ON LISTED SPECIES
This section includes an analysis of the effects of the Proposed Action on listed species. Effects
of the Action are all consequences to listed species or critical habitat that are caused by the
proposed Action, including the consequences of other activities that are caused by the Proposed
Action. A consequence is caused by the Proposed Action if it would not occur but for the
7Proposed Action and it is reasonably certain to occur. Effects of the Action may occur later in
time and may include consequences occurring outside the immediate area involved in the Action.
Project effects on listed eiders
The Service listed the spectacled eider as threatened on May 10, 1993 (58 FR 27474), and the
Alaska-breeding population of the Steller’s eider as threatened on June 11, 1997 (62 FR 31748).
Spectacled eiders occur and nest in northern part of the project area between May and September
at very low density (Figure 3). Although Steller’s eiders may also occur in the Action Area, they
have been observed in northeast NPR-A very infrequently in recent decades and are not known
to nest within the Action Area. Direct effects are those that occur when there is an immediate
effect on listed species or habitat (e.g., disturbance resulting in nest abandonment). However,
direct effects to eiders from disturbance associated with winter transportation and exploration are
not anticipated because listed eiders are absent from the Action Area during winter.
Nesting spectacled eiders could be subject to disturbance from summer site visits and cleanup
activities (e.g., helicopter takeoffs and landings). However, nesting density of spectacled eiders
is extremely low and limited to the northern portion of the Action Area (Figure 3). Furthermore,
cleanup activities would be limited to a narrow linear route following the previous season’s snow
road and helicopters and cleanup crews would likely make a single pass as they move through an
area. Given the extremely low density of spectacled eiders, the small geographic area impacted
and temporary nature of disturbance from summer site visits, we do not anticipate impacts of
disturbance to nesting spectacled eiders would have the potential to result in injury or death of
any bird. Therefore, direct disturbance to spectacled eiders would be insignificant.
The proposed program could indirectly affect listed eider nesting habitat by damaging tundra
vegetation through compaction and scarring from tundra travel. However, several studies
investigating the effects of snow trails and ice roads on tundra vegetation found impacts to be
low, with occasional areas of moderate level impacts (Jorgenson et al. 1996; Pullman et al. 2003;
Yokel and Ver Hoef 2012). Furthermore, these impacts were limited to higher, drier habitat (e.g.,
tussock tundra) where listed eiders do not nest. Given the limited extent of snow roads and ice
pads, coupled with BLM’s requirements for construction and operation which aim to prevent
long-term damage to the underlying tundra, measurable impacts to eider nesting habitat are not
anticipated. Although the potential exists for contamination of nesting habitat from small fuel
spills, given the low density of listed eiders in the action area, and spill prevention and response
measures identified in the Project Description, impacts from fuel spills on listed eiders would be
extremely unlikely and therefore, would be discountable.
Therefore, we expect collective effects of the Proposed Action on listed eiders would be
insignificant and/or discountable because, 1) listed eider density in the Action Area is very low,
2) disturbance of nesting eiders from winter activities would not occur, 3) disturbance of nesting
or brood-rearing listed eiders from summer site visits would be minor, temporary, limited to a
small geographic area, and would not have the potential to result in injury or death of any bird, 4)
measurable effects to eider nesting habitat from tundra travel are not anticipated, and 5) given
spill prevention and response measures in place, effects to eider nesting habitat from fuel spills
would be extremely unlikely (i.e., discountable).
8Polar Bears
The Service listed the polar bear as a threatened species under the ESA on May 15, 2008
(73 FR 28212). Polar bears may occasionally pass through or den in the Action Area, although
their density is very low (MMM pers comm.), and encounters are expected to be infrequent.
Disturbance to transient (non-denning) bears would be minor (i.e., limited to changes in behavior
that would not be biologically significant) and temporary because bears would be able to respond
to human presence or disturbance by departing the area. Furthermore, measures required by
BLM’s stipulation package and Emerald House’s proactive minimization measures (including
management of attractants and siting of structures), would minimize potential impacts in the
unlikely event a transient polar bear is encountered. Given the very low density of transient
polar bears and minor, temporary nature of disturbance from the proposed activities, we would
not anticipate impacts of disturbance to non-denning polar bears would have the potential to
result in injury or death of a bear. Therefore, disturbance to non-denning polar bears would be
insignificant.
Although the potential exists for polar bears to encounter contamination from small fuel spills,
given the very low density of polar bears in the Action Area, and spill prevention precautions
identified in the Project Description, the probability of impacts from fuel spills on polar bears
would be extremely unlikely and therefore, would be discountable.
On the Beaufort Sea coastline between the Kavik River and Utqiaġvik, 95% of detected polar
bear dens are within 5 miles (8 km) of the Beaufort Sea coastline (75 FR 76086). Therefore, due
to its inland location, ~ 20 miles (33 km) at the start of the snow road at Ocean Point, and ~ 64
miles (103 km) inland at Merlin 2, it would be highly unlikely, although possible that female
polar bears may den within the Action Area. However, prior to initiating on-the-ground
activities, Emerald House conducted den detection surveys of the Action Area using Aerial
Infrared and no suspected dens were detected (MMM pers comm). In the unlikely event that an
undetected den was encountered, denning bears would be susceptible to disturbance, potentially
causing females to abandon dens before cubs are able to survive. However, given 1) the location
of the program area, which is outside the area we would anticipate polar bears to den, 2) the
results of multiple FLIR surveys which failed to detect any dens, and 3) MMM separately
concluded the probability of encountering, much less, taking, any polar bears would be very low,
such that an incidental take authorization under the MMPA for Emerald House is not warranted
(MMM pers comm); effects of the proposed action on denning polar bears would be extremely
unlikely (i.e., discountable).
Therefore, we expect collective effects of the proposed action on polar bears would be
insignificant and/or discountable because: 1) the density of polar bears in the Action Area is very
low and hence it is unlikely project activities would encounter a polar bear, 2) in the unlikely
event a transient bear was encountered, behavioral effects would be minor and temporary and
would not have the potential to result in injury or death of a bear, 3) the Action Area is well
inland (> 20 miles) of the 5-mile coastal zone where 95% of terrestrial polar bear dens occur
such that the probability of encountering a denning bear would be extremely unlikely (i.e.,
discountable), and 4) Emerald House’s Minimization Measures and BLM’s stipulation package,
including den detection surveys, hand-held infrared cameras, denning habitat avoidance, and
9exclusion zones for any detected den, further serve to avoid and minimize potential impacts in
the unlikely event transient or denning polar bears are encountered.
Project effects to polar bear critical habitat
On October 29, 2009, the Service proposed critical habitat for polar bears (74 FR 56058) and
a final rule designating critical habitat was issued on December 7, 2010 (75 FR 76086). We note
that although the Action Area is within approximately 15 miles of designated critical habitat,
there is no overlap between the Action Area and designated polar bear critical habitat (Figure 3).
Accordingly, BLM has concluded there would be “no effect” to polar bear critical habitat for the
Proposed Action. Although BLM has requested concurrence with that determination, the
regulations implementing section 7(a)(2) of the ESA (50 CFR 402) do not require the Service’s
concurrence with a “no effect” determination made by a Federal agency. Consequently, we
decline to concur with BLM’s “no effect” determination regarding the proposed Action.
However, as described at 50 CFR 402.14(a), the Service may request that a Federal agency
“enter into consultation if (the Service) identifies any action of that agency that may affect listed
species or critical habitat and for which there has been no consultation. Based on BLM’s
determination that the proposed project would have "no effect" on designated critical habitat, the
obligations of section 7(a)(2) have been met.
CONCLUSION
Because effects of disturbance on listed eiders would not have the potential to result in injury or
death to any birds, and measurable effects to nesting habitat would be extremely unlikely,
collective effects of the proposed exploration program on listed eiders would be insignificant
and/or discountable. Additionally, although the proposed activities could temporarily disturb
polar bears in the Action Area, because this species occurs at low density, minimization
measures would be in place, and the effects of disturbance would not have the potential to result
in injury or death of a bear, we expect the effects of disturbance to be insignificant. Finally,
given the inland location of the proposed activities, very low density of denning polar bears, and
minimization measures including den detection surveys, denning habitat avoidance, and
exclusion zones, we anticipate impacts to denning polar bears would be discountable.
Therefore, the Service’s 2020 concurrence with BLM’s determinations remains valid, and we
concur the Proposed Action is not likely to adversely affect spectacled or Alaska-breeding
Steller’s eiders, or polar bears. This letter acknowledges the proposed ROW modification
and amends the Service's November 5, 2020, consultation pursuant to section 7 of the ESA of
1973, as amended. Thank you for the opportunity to comment on this project. If you need
further assistance, please contact Kaithryn Ott at (Kaithryn_Ott@fws.gov).
10LITERATURE CITED
Jorgenson, J. C., B. E. Reitz, and M. K. Reynolds. 1996. Tundra disturbance and recovery nine
years after winter seismic exploration in northern Alaska. Unpublished report. U.S.
Department of the Interior, U.S. Fish and Wildlife Service, Fairbanks, Alaska.
Pullman, E. R., M. T. Jorgenson, T. C. Cater, W. A. Davis, and J. E. Roth. 2003. Assessment of
ecological effects of the 2002–2003 ice road demonstration project. Final report prepared
for ConocoPhillips Alaska, Inc., by ABR, Inc., Fairbanks, Alaska.
Yokel, D., and J. Ver Hoef. 2012. Impacts to, and recovery of, tundra vegetation from winter
seismic exploration and ice road construction. Unpublished report. U.S. Department of the
Interior, Bureau of Land Management, Fairbanks, Alaska.
Figure 1. Emerald House’s proposed 2022 exploration program area within the Peregrine Lease Block,
including snow and ice roads, ice pads, the Merlin 2 well site southwest of Nuiqsut, Alaska.
11Figure 2. Emerald House’s proposed 2022 exploration program inland of designated polar bear critical habitat
(blue hatch).
12Figure 3. Density distribution of spectacled eiders observed on aerial transects of wetland tundra on the North
Slope of Alaska during breeding pair surveys in June, 2012–2015, and the location of the proposed Action
(USFWS 2015).
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