Comment from David Dickson

July 27, 2009 Ms. Sue Salveson Assistant Administrator Sustainable Fisheries Division, Alaska Region National Marine Fisheries Service Attn: Ellen Sebastian Dear Assistant Administrator Salveson, I write on behalf of the Alaska Wilderness League to urge Secretary of Commerce Locke to approve the proposed rule for the implementation of the Fishery Management Plan for Fish Resources of the Arctic Management Area and Amendment 29 to the Fishery Management Plan for Bering Sea/Aleutian Islands King and Tanner Crab (Arctic FMP) as noticed in the Federal Register/Vol. 74, No. 110/Wednesday, June 10, 2009. I also write to convey the attached comments of support for the Arctic FMP of approximately 1,500 of our members and supporters. Alaska Wilderness League is a non-profit 501(c)(3) corporation founded in 1993 to further the protection of Alaska’s amazing public lands and waters. The League is the only Washington, D.C.-based environmental group devoted full-time to protecting the Arctic National Wildlife Refuge and other wilderness-quality lands and waters in Alaska. The Alaska Wilderness League’s mission is to lead the effort to preserve Alaska’s wilderness by engaging citizens, sharing resources, collaborating with other organizations, educating the public and providing a courageous, constant, and victorious voice for Alaska in the nation’s capital. The Arctic Ocean faces changes unparalleled on the planet. Over the last 100 years, the Arctic has warmed twice as fast as the rest of the Earth. Since the 1950s, an area of sea ice almost half the size of the continental United States has melted. Many species that rely on this ice-based ecosystem, such as polar bears, walrus, spectacled eiders, bowhead whales and ribbon seals face significant environmental stress; some are already listed for protection under the Endangered Species Act. This marine ecosystem is also of vital importance to the survival of the subsistence cultures of the Alaska Native peoples of the North Slope. The bowhead whale is of particular importance to the subsistence culture of the Inupiat communities of Alaska’s North Slope. The Arctic FMP offers the President Obama and the Department of Commerce the opportunity to change the direction of federal management of this unique and troubled marine ecosystem. Thanks to the initiative shown by the North Pacific Management Council, Secretary of Commerce Lock has the opportunity to take a precautionary, science-based approach to fisheries management in the Arctic Management Area. This approach would be an extremely welcome change to the way the previous administration managed America’s Arctic Ocean. In recent years the Arctic Ocean has been the subject of a push to open the Beaufort and Chukchi Seas to massive oil and gas leasing, exploration, and development by the Bush administration. The Bush administration undertook this effort despite the fact that very little is known about the marine ecosystems of the Arctic Ocean. In almost every Environmental Impact Analysis document over the last several years relating to oil and gas leasing, exploration, and development activities the Minerals Management Service has admitted it lack of fundamental knowledge regarding the biology of the these waters and thus an inability to predict potential environmental impacts. Despite this lack of fundamental biological baseline knowledge, and regardless of the concerns raised by the National Marine Fisheries Service, the Fish and Wildlife Service, and the U.S. Environmental Protection Agency, MMS pushed ahead with its plans for massive industrial development in U.S. Arctic Waters. The proposed Arctic FMP, which will close the Arctic waters to commercial fishing until or unless science shows that these activities will not harm the fragile ecosystem or the people, who rely on it for subsistence, represents a tremendous precedent for how the federal government, and other countries, should proceed with industrial activities in the in the Arctic Ocean. Sincerely yours, David Dickson Western Arctic and Oceans Program Director, Alaska Wilderness League 122 C St. NW, Suite 240 Washington, DC 20001