Comment on FR Doc # 2010-10512

Per Bruce Woods, U.S. Fish and Wildlife “critical habitat does not restrict public access.” I beg to differ. You will put responsible oil and gas activities within this area at a standstill. Oil and gas activity has not in the past posed a danger to the polar bear nor to it’s habitat. It is unlikely that it will be a future threat. There has been practically no impact on polar bears from oil and gas activities in Alaska and the Arctic regions of the World. The sustained and continuing growth of polar bear population for the past 40 years has coincided with the development of the oil and gas industry on the North Slope. The Polar Bear Specialist group estimates that the total number of polar bears is somewhere between 20,000 and 25,000. Estimates of the population during the 1950s and 1960s, before harvest quotas were enacted, range from 5,000 to 10,000. The proposed critical habitat designations for polar bears are unwarranted. The idea that these models can make predictions 50 to 100 years into the future is illogical. Polar bears and their habitat are well managed and protected by numerous international agreements, regulatory mechanisms, and laws including the Marine Mammal Protections Act (MMPA). Extensive legal authorities make the polar bear one of the most protected species in the world, and provide more than adequate basis for addressing realistic threats. Polar bears are very intelligent. They have adapted through many climate changes for thousands of years. They are not going to wait around for the ice to freeze to start hunting. They hunt in the floe-edge areas, on newly formed ice, and in the fiords in search of baby seals. They don’t hunt in the glaciers and they live on more than just baby seals. The Endangered Species Act requires protections to be balanced against their costs. This economic analysis is lopsided. It must also take into consideration the potential impacts to the nation, region and state economy. Impacts from the potential loss of energy production, and secondary impacts from no economic activity resulting from lost or delayed tax revenue, royalties revenue, employment and income, as well as community development infrastructure must be considered. If this does get approved, then current and proposed oil and gas exploration, development and production areas should be excluded from restrictions. The exclusions should include transportation corridors, as well as all active and proposed lease sale areas. Exclusions should be granted for public access for local community lands, including the North Slope and Northwest Arctic Boroughs, Alaska Native corporation lands, proposed mining sites and the 1002 area of ANWR. Bottom line: For once, Listen to the Native people of Alaska, Look at the Big Picture instead of just honing in on “facts” that sell your point of view and Learn from Your Past Mistakes here in Our Great State. Alaska is nothing like the lower-48 – please don’t tie our hands, once again, with bear-ocratic bull. Dave Cruz Cruz Construction, Inc. Palmer, Alaska