Dear Sir, Prince William Soundkeeper, a 501c(3) organization, was established in 2004 by residents and stakeholders from the five communities in the Sound: Valdez, Cordova, Whittier, and the Native Villages of Chenega Bay and Tatitlek. Our Mission: Grass roots advocacy for preserving water quality in Prince William Sound, Alaska for all users. As you know, Prince William Sound (PWS) was the location of the 1989 Exxon-Valdez Oil Spill (EVOS). It’s been over 25 years since that tragedy and the Sound is still dealing with lingering oil, and the issues that arose with the clean-up and remediation choices made during and after that event. Therefore, PWSK felt it necessary to comment on the Alaska Regional Response Team’s Proposed Revision to the 1989 Oil Dispersant Guidelines.
Dispersant usage on a major oil spill is a very contentious subject. What we don’t want to do is take a terrible situation and make it exponentially worse by adding chemicals of unknown toxicity and persistence to the marine ecosystem. For Alaska’s cold waters in particular, the effectiveness and long term effects of chemical dispersants is unproven and unknown. The U.S. Government Accountability Office found that “….[The] experts generally agreed that there is a basic understanding of the processes that influence where and how oil travels through the water, but that more research was needed to quantify the actual rate at which dispersants biodegrade. In addition, all the experts GAO spoke with said that little is known about the application and effects of dispersants applied subsurface, noting that specific environmental conditions, such as higher pressures, may influence dispersants’ effectiveness. Knowledge about the use and effectiveness of dispersants in the Arctic is also limited, with less research conducted on dispersant use there than in temperate or tropical climates.For example, one expert noted that more research is needed on biodegradation rates for oil in the Arctic because the cold temperature may slow the process down.”Oil Dispersants: Additional Research Needed, Particularly on Subsurface and Arctic Applications, GAO-12-585: Published: May 30, 2012. Publicly Released: Jun 29, 2012 (http://www.gao.gov/products/GAO-12-585)
The Center for Biodiversity states that dispersants such as Corexit 9527A used in the BP Gulf Oil Spill pose significant human health risks. Corexit 9527A, contains the toxin 2-Butoxyethanol which “may cause injury to red blood cells (hemolysis), kidney or the liver” with “repeated or excessive exposure,” according to the manufacturer’s safety data sheet. Corexit 9527 was sprayed on the 11-million gallon oil slick created by the Exxon Valdez spill, and cleanup workers reportedly suffered health problems afterward, including blood in their urine as well as kidney and liver disorders, attributed to 2-Butoxyethanol. (http://www.biologicaldiversity.org/programs/public_lands/energy/dirty_energy_development/oil_and_gas/gulf_oil_spill/dispersants.html)
Besides the human health concerns raised by the usage of potentially toxic chemicals to disperse oil, gaining expected results from the use of petroleum oil dispersant chemicals (breaking up oil, removing it from surface and distributing it through the subsurface water column) raises serious concerns for the ramifications of it use throughout the marine ecosystem over the long-term. (http://www.restorethegulf.gov/release/2011/07/29/osat-summary-report-sub-sea-and-sub-surface-oil-and-dispersant-detection-ecotoxic)
The really interesting part in the choice to use Corexit by BP during the Gulf of Mexico spill was that there were other, MORE effective and LESS toxic, dispersants that could have been used. Instead, BP chose to use a chemical that has been banned from being used in Great Britain since 1998 due to the chemical’s toxicity to marine life near rocky shores. Such a choice made here in Alaska would be disastrous to our rocky coastal ecosystem.
Our the concern for the way the Pre-Authorization strategy choice is presented include: the size and extent of the proposed preauthorization area, the policies and procedures for dispersant applications, the stakeholder input process, and the autonomy of the FOSC (USCG) in decision making authority.
Pre-authorization of use raises serious concerns for the long-term, and irreversible, ramifications of such actions. Communities and people in Prince William Sound continue to suffer psychologically, economically, and environmentally with the lingering effects from the EVOS. Much of that damage was inflicted by the choices made by the entities in power in the heat of the moment, and without due consideration and discussion, with the local communities and people most affected. Quick decisions were made without proper consideration to the ramifications and long-term damage that would occur as a direct result of those decisions.
Alaska and Alaskans deserve a long-term Oil Spill Response Strategy that takes into account both the viability of our communities, our irreplaceable and unique marine ecosystem, and environment.
Sincerely, Kate McLaughlin, President and Executive Director