Protecting the Arctic
Written evidence submitted by Greenpeace
• The Arctic is a unique and uniquely vulnerable environment. As well as being home to scores of species not found anywhere else on Earth, the region also plays a critical role in regulating the global climate. The Arctic ice-sheet acts a huge mirror which reflects the sun’s heat back into space and helps to keep the planet cool.
• But the Arctic is under threat – from climate change from industrial expansion, in particular by oil companies looking to drill in the dangerous waters of the Arctic Ocean, but also from industrial fishing.
• The impacts of climate change can be seen more starkly in the Arctic than anywhere else. 2011 witnessed sea-ice levels plummet to the second lowest level since records began. In 30 years we have lost 75% of the Arctic sea ice. 
• Corporations and politicians see the melting ice as a business opportunity. As the ice melts, companies are moving in to exploit the oil, precious metals and some of the world’s largest fisheries. Nothing better illustrates our current blindness to the risks of climate change than the rush to exploit the region’s fossil fuels, releasing more of the greenhouse gases that caused the sea-ice to melt in the first place.
• The drilling conditions facing oil companies operating in the Arctic are some of the most challenging on Earth. The hostile weather, freezing conditions and remote location present unprecedented challenges for oil companies dealing with a spill in the region. Techniques for containing a spill and cleaning up after it are inadequate or untested in Arctic conditions. Conventional oil spill response techniques, such as booms and skimmers, are ineffectual in ice, and capping a well in ice has never been tested. As the respected Pew Environment Trust has observed the oil industry is: "not prepared for the Arctic, the spill plans are thoroughly inadequate."  The risks of Arctic drilling cannot be adequately managed and drilling should not go forward in this fragile location.
• To protect the Arctic from rising temperatures and the threat from oil drilling we need to reduce our reliance on oil. The USGS (United States Geological Survey) estimate that the Arctic may hold around 90 billion barrels of oil, enough oil to meet global oil consumption for just three years.
• The UK government must champion the deployment of existing technology so that we use less oil in the first place, for example by ensuring strong new European car efficiency laws are put in place. Greenpeace is calling for a European car efficiency target of 95gCO2/km by 2020, and a target of at least 60gCO2/km by 2025. Greenpeace research shows that an efficiency target of 80gCO2/km by 2020 is technically possible. 
• The receding sea ice is also opening up Arctic fisheries. The Barents whitefish fleet is already venturing further north than it ever has before, and Sir David Attenborough has voiced his concern that the opening up of Arctic fisheries could lead to the decimation of polar fish stocks.
• Arctic fisheries management is currently fragmented, based on bilateral arrangements between Arctic states and Regional Fisheries Management Organisations (RFMOs). This situation must be addressed if we are serious about preventing over-fishing in the region.
• The melting Arctic ice is opening up new shipping routes, such as the Northwest and Northeast Passages. New access for shipping brings with it the risk of environmentally damaging impacts, the most obvious danger being an oil spill from a tanker. Poor mapping, insufficient search and rescue capacity and the fact that there are no resources to deal with any form of spill mean that these new shipping routes are putting the Arctic Ocean, its wildlife, and the people who depend on them at risk.
• In light of these increased risks, we urgently need to improve governance of the Arctic, if we are to ensure that this unique region is protected. At present, resource management and environmental protection in the Arctic is almost exclusively determined by the group of Arctic nations, often in the interests of extractive industries, and with very little in the way of binding multilateral rules to ensure stability or enforce minimum standards.
1. The Arctic is both an ecosystem under critical stress and an arena of great geo-political significance and sensitivity. The loss of extent and thickness of Summer Arctic sea ice indicates more than just the scale of climate change impacts on natural systems: it also delivers a warning of changes in the climate system, which represents a grave risk to human well-being across the planet. Recent modelling has suggested that the Arctic may be ice-free in summer within less than a decade  , rather than the 30 - 90 years previously estimated. As the ices melts, the ice-albedo positive feedback loop risks accelerating warming, leading to a potential a ‘death spiral’ for the ice and risking additional releases of large volumes of methane trapped in the region’s permafrost. These changes will not just have regional impacts but could also have knock-on effects for the global climate, though the extent and significance of these is still under debate.  The Arctic is a bellwether for the rest of the world and provides a graphic illustration of the risks humanity is taking by failing to tackle the crisis of climate change.
2. Within the Arctic region lie a vast wealth of resources – oil, gas, precious and rare metals as well as some of the world’s largest fisheries, which until now have been largely inaccessible to human exploitation because of the Arctic ice. However, as the ice melts, these riches are becoming easier to reach, and politicians and companies are increasingly setting their sights on the region. Nothing better illustrates our current blindness to the risks of climate change, or our apparent unconcern for the future of the Arctic than the rush by companies and politicians to exploit the region’s fossil fuels; releasing more of the greenhouse gases that caused the sea-ice to melt in the first place.
3. The lure of these resources, especially to nations struggling to achieve energy security and competing for technological and economic competitiveness, is now being reflected in the territorial claims and military posturing reported with increasing frequency across the world’s media,  and revealed graphic detail in the recently released Wikileaks data  .
4. Many countries are also anticipating a significant shift in patterns of global trade and transport, as routes in and around the Arctic open up to shipping.  In response, they are constructing new vessels to navigate these routes, and businesses are adjusting their supply chains to take advantage of them. With more shipping comes the risk of local emissions of large quantities of black carbon (which have the potential to accelerate still further the warming process already engulfing the region  ); not to mention the potential risk of oil spills from container ships.
5. Already under strain from climate change, the Arctic is particularly poorly placed to withstand the impacts of industrial development, which will bring with them pollution, disturbance and habitat loss.
THE ARCTIC: WHAT’S AT STAKE?
6. The ecosystem confronting these threats is rich, vulnerable and unique due to the fact that it has evolved independently, and is one of the last places on Earth where largely (though not entirely) natural conditions prevail.
7. Despite the harsh Arctic environment, the region supports some of the world’s best known mammals, millions of resident and migratory birds (15% of all the world’s species spend their breeding season in the Arctic) and a rich and diverse marine life, including some of the world’s major ocean fisheries.
8. The Arctic region is home to narwhals, as well as blue whales, polar bears, seals, golden eagles and bowhead and beluga whales; more than 100 species of fish, including Arctic cod, capelin, herring and saffron cod are found there, and many species of bird and whale pass through the Arctic on their global migrations.
9. Whilst it is widely acknowledged that the region is one of the most world’s most diverse and rich ecosystems, the depth of our understanding of this region, its ecology and how it will interact with a changing climate and creeping industrialization is very limited. The respected environmental charity, the Pew Trust, recently noted that the Arctic Ocean is among the least understood places on Earth. 
10. On the surface, however, we are already witnessing signs of the impacts of climate change in the Arctic, where warming is happening twice as fast as anywhere else on the planet, with an average temperature rise of approximately two degrees Celsius. The Arctic sea ice is receding year on year. 2011 saw the second lowest ever sea-ice minimum,  and scientists estimate that we have lost around 75% of the Arctic sea-ice cap in the last 30 years. 
11. The loss of sea-ice is already having serious consequences for wildlife, impacting on migration, feeding and mating patterns. For example, the declining sea-ice is jeopardising the ability of polar bears to hunt for food and as a result some polar bear populations are declining. In 2009, the IUCN Polar Bear Specialist Group (PBSG) cited climate change as the greatest challenge to the conservation of polar bears. Of the 19 polar bear populations, 8 populations were declining, 3 were stable, 1 increasing and for the remaining for 7 there was not enough information to determine their population status  . Other ice dependant species are also being impacted by these major changes in their habitat. For example, the walrus is also being impacted by the receding sea ice.  In areas where the sea ice is retreating walruses are forced to hunt for food in even deeper water, where access to food is much more difficult.
12. The Arctic is not just home to this rich and diverse wildlife, it also plays a critical role in regulating global climate, and it is here that the changes in the region could have serious implications for the rest of the planet. Air and water interactions in the region influence ocean circulation patterns and the reflectivity of polar snow and ice limits the amount of sunlight and heat absorbed by the Earth, acting like a global air conditioner.  The layers of peat and permafrost in the Arctic also store vast amounts of carbon.
OIL EXPLORATION AND PRODUCTION
THE IMPACT OF THE ARCTIC OIL RUSH
13. The Arctic is already feeling the impacts of climate change, and as a result is even less able to withstand the impacts of industrialisation, such as that resulting from oil exploration and production.
14. Exploratory drilling and full-scale production have serious routine consequences for the natural environment. Firstly, as a consequence of drilling, chemicals are released into the marine environment. For example, the liquid and solid waste volumes may be as high as 5000 m^3 for every well sunk. 
15. In addition, the fragile Arctic is acutely vulnerable to large oil spills. The freezing temperatures, thick ice cover and lack of sunlight inhibits the breakdown of oil through biological processes and physical weathering, meaning that toxic oil lingers, leaving the ecosystem contaminated for decades rather than years.  At the same time, the long life span and slow reproductive rates, as well as the dwelling habits, of a number of key species mean that they are particularly threatened by pollution.
16. The Pew Trust, which has analysed in detail the likely impacts of spill on the different components of the Arctic ecosystem, concludes that these could wipe out local populations of walrus, seal and polar bear, at the same time destroying the isolated indigenous communities that depend on hunting to survive.  The US Geological Survey (USGS) warned that the long-term impact of oil development on Indigenous communities is unknown because "additional information" is required to "determine the potential hazard to native subsistence livelihoods." 
17. The oil industry itself recognises that a spill would have significant environmental impacts. In Cairn Energy’s oil spill response plan for its operations off Greenland, the company acknowledges the ‘significant long-term impacts on narwhals and breeding colonies of Atlantic puffins and razorbills, whilst populations of cormorants and king eiders would be significantly depleted.’ 
18. The continuing deep-seated impacts of the 1989 Exxon Valdez spill in the Gulf of Alaska, provide evidence of what a future oil spill in the Arctic could mean to the ecosystem. After the tanker Exxon Valdez ran aground in March 1989, 2000 km of pristine Alaskan shoreline was contaminated and the effects continue to be felt in marine and coastal environments two decades on. A study of the long-term impacts on the ecosystem concluded that oil has persisted in surprising amounts and in toxic forms and had long-term impacts at the population level,  and that pockets of oil remained in sediment under gravel beaches  
19. The immediate impact of Exxon Valdez on marine mammals and sea birds was devastating. Mass mortalities of both were recorded, including between 1000-2800 sea otters and 250,000 seabird deaths documented in the days after the spill. 
20. The long-term impacts on wildlife have also been apparent over the following decades. Populations of sea otters, whose numbers were cut in half, have yet to fully recover,  and sea otters born after the spill had a higher mortality  Harlequin duck populations showed signs of still being exposed to oil 9 years after the spill.  In addition other marine birds showed evidence of persistent exposure to residual oil after the spill, such as Barrow’s golden eye sea duck whose population has declined dramatically. Some salmon populations have been reported with stunted growth and lower survival rates.  Finally, local populations of marine mammal species, with toxins incorporated into their blubber,  are nearing extinction. Populations of killer whales were reduced by 40%  and their survival in Prince William Sound remains uncertain. 
21. Indigenous communities also risk being devastated by an oil spill. These communities depend on the region’s hunting and fishing grounds to survive and they are the ones that will be most directly impacted by the consequences of an Arctic oil rush. It makes no sense for those directly impacted to be excluded from the decision-making process.
OIL INDUSTRY PLANS IN THE ARCTIC
22. According to the USGS up to 90 billion barrels of oil may lie under the entire Arctic.  As easy-to-find sources of oil become less productive and/or accessible to international oil companies,, these companies are squeezed into developing increasingly marginal or environmentally challenging areas, including unconventional sources of oil such as tar sands, or technically challenging deep water reserves. The far North, with its promise of potentially vast untapped resources, is emerging as an attractive new frontier for the oil industry as other options recede.
23. Some oil exploration and production has taken place in the last decade in the Russian and Canadian Arctic, primarily onshore or in shallow waters. In addition in the last two years, wildcat firms, like Cairn Energy, have undertaken exploratory operations off places like Greenland, and now the industry’s major players are now lining up behind them and planning drilling programmes of their own.
24. Current industry plans:
· Shell plans to begin exploratory drilling in the Chukchi and Beaufort Sea between July and October this year.
· Cairn have drilled a total of eight exploratory wells in Baffin Bay, west of Greenland in 2010 and 2011 but have made no commercial discovery of oil. The company have now partnered with Statoil to finance the remainder of their exploratory programme.
· ExxonMobil and Rosneft are developing a joint operations plan to carry out exploratory drilling in the Kara Sea, although there is no specific timeline for these activities.
· Gazprom’s Prirazlomnaya platform located in the Pechora Sea will begin commercial production in early 2012.
· Chevron, Conocophillips and Statoil all hold licences and developing plans for exploratory drilling in several areas of the Arctic.
· The Norwegian government plans to open up the Barents Sea North for seismic activities in the former disputed area.
· Later this year, the Greenland government will open up a new licence round for blocks in the North East Greenland.
THE RISKS OF DRILLING IN THE ARCTIC
25. Freezing conditions and severe weather in the Arctic pose unprecedented challenges to spill response.
26. Severe storms are common in the fall and early winter in the US Arctic Ocean.  In the Chuckhi and Beaufort Seas, strong winds can hamper operations. Gale force winds are prevalent (max daily average wind speed in Barrow is 44 mph in October, and 40 mph in November). Cairn Energy’s oil spill response plan notes that strong winds frequently occur along the shores of west Greenland in the winter, meaning that if a spill were to happen towards the end of the drilling season, it would make it even more challenging to clean up. 
27. Fog is a major component of the Arctic Ocean climate and is a major hindrance to any prospective clean-up operation. Point Barrow, Alaska averages 12 days of fog per month from May- September,  which can significantly restrict visibility during the drilling season, and this could impact on spill response. For example, oil is more difficult to observe on the water surface when fog is present.
28. Freezing temperatures prevail with an average temperature range between 4 and -20 degrees Celsius during the Arctic summer (June through to November), in the Alaskan Arctic.
29. The reduction in daylight hours is also a problem as the winter approaches because if an oil spill were to occur towards the end of the season, shorter days would seriously hamper spill response. In Cairn Energy’s spill response plan, the admission is made that - "during the winter months, there are very few hours of daylight which can cause serious operational complications."  In Shell’s plan, the company estimate an average of 15 hours of daylight during September dropping to just 11 in October. 
30. Finally, the presence of sea ice and icebergs during the drilling window can pose serious challenges to both drilling and spill response. Sea-ice cover in the US Arctic Ocean can vary considerably but is typically present from October – June. During the summer, the Beaufort and Chukchi experience a period of open water for 3-4 months, though scattered sea ice may still be present. Off the shores of Greenland, ice formation can vary considerably according to weather conditions.
31. Cairn Energy uses ‘Ice management’ techniques to tow icebergs or water cannon them out of the way. However, these techniques are ineffective against the largest icebergs and in extreme cases rigs themselves might have to be moved to prevent collisions. Cairn Energy operates in an area of Baffin Bay known locally as ‘iceberg alley’, and during the drilling months of June and July the area sees the highest concentrations of icebergs.
32. Icing on infrastructure poses a major problem in these conditions and may have been a contributory factor in the sinking of the Kolskaya in the Sea of Okhotsk  .
INDUSTRY ATTITUDES TO SPILL RISK
33. The industry is alarmingly unprepared across its operations for ‘black swan’ events – events which they deem to be unlikely, but which once they have occurred, have devastating consequences. Last year, the Energy and Climate Select Committee’s inquiry into deep water drilling in the UK raised concerns that – "the offshore oil and gas industry is responding to disasters, rather than anticipating worst-case scenarios and planning for high-consequence, low-probability events". 
34. This is particularly worrying in a situation where they are operating in more and more hazardous, challenging and environmentally vulnerable environments – where in reality, such events are becoming MORE likely, and their consequences MORE serious. For example, the Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) estimated that a one in five chance of a major spill occurring over the lifetime of activity in just one block of leases in the Alaskan Arctic.  The Pew Trust’s analysis also suggests that the industry has significantly underestimated the risk of a blowout. 
35. Despite the devastating impacts of the Gulf of Mexico spill, the industry has done very little to ensure that such a spill does not happen again, or to put in place credible measures to manage the consequences. . The risk of human error can never be mitigated away completely, and incidents continue to occur post-Deepwater Horizon which show that lessons have not been learnt. For example Shell’s North Sea oil spill in August 2011 which initial findings suggest was due to an inadequate risk assessment of an ageing pipe conducted by the company. 
36. Whilst the industry claims to be reviewing and tightening procedures that will avoid a repeat of Deepwater Horizon, behind the scenes, they have continued to lobby against regulatory measures which would help reduce the likelihood of a spill or manage its potential consequences. For example, Shell strongly lobbied the Canadian government to relax rules which stipulate that a relief well must be drilled at the same time as the main well (known as dual drilling). More recently, last month Shell is reportedly opposing a proposal by BOEMRE to ensure that drilling stops 38 days before the first ice encroachment onto the drill site.  Cairn Energy last year resisted intense pressure to publish their Oil Spill Response plan despite it being the industry norm to do, and despite the fact that this is recommended by the Arctic Council’s guidelines on offshore oil exploration.
‘THOROUGHLY INADEQUATE’ SPILL RESPONSE PLANS
37. The industry’s claim that it is prepared to manage a spill in the Arctic is seriously undermined by gaps and inadequacies in their spill response plans.
38. The Pew Environment Group recently examined  oil spill response plans for operations in the Arctic and concluded that the industry is "not prepared for the Arctic, the spill plans are thoroughly inadequate,"  adding that Arctic spill plans "underestimate the probability and consequence of catastrophic blowouts, particularly for frontier offshore drilling in the U.S. Arctic Ocean."  Analysis for WWF found that industry proposals for assessing the risks of a spill in the Arctic were inaccurate, describing it as "imagineering, not engineering." 
39. For example, Cairn Energy’s oil spill response plan contains little detail on how Cairn would control a blow-out in deep water; it mentions capping the well but does not specify exactly what capping equipment will be used and how.  The plan claims that its operations meet various design standards and requirements for oil well control  However, the lack of detail makes it difficult to ascertain which standards Cairn has actually met and to what extent. It also omits critical technical information including the exact BOP (Blow Out Preventer) design, the number of centralisers (which help during cementing operations to provide a constant space around the casing rather than having the casing lying against the borehole wall) that will be used, and the precise formation of cement slurry. 
40. One of the most consistent problems with spill response plans is that oil company assumptions used to plan for worst case scenarios do not in fact reflect the worst case. For example, Cairn outlines a worst case spill of 5000 barrels a day for 37 days.  The Macondo well , in contrast, released around 60,000 barrels a day for 84 days.
41. Shell’s spill plan for the Alaskan Beaufort Sea claims that oil would only "be released to a relatively small area on the water," even though US regulators have estimated some of the wells it wants to drill in 2012 could gush at a rate of over 60,000 barrels a day. 
42. Cairn’s estimates for how effective the clean-up will be are wildly optimistic. Cairn claims it can clean 8,793 barrels of oil a day. Professor Richard Steiner changed Cairn’s over-optimistic assumptions about oil to water ratio at the surface and emulsification, and concluded that a more realistic figure would be 650 barrels a day. 
43. Some of the diagrams from the spill plan, described by Shell as "the best oil-spill response plan anywhere in the world,"  are graphic illustrations of the inadequacy of the industry’s preparations. Its description of "the physical removal of oil and oiled debris on beaches" is as follows:
4 4 . Cairn’s plan includes proposals that a "section of oiled ice can be cut out and allow the ice to thaw in a heated warehouse and then separating the oil from its water".  The company offers absolutely no proof that auguring for oil under ice actually works or that oiled ice can be successfully located and cut out, how it would be transported, or where the warehouse would be situated.
RELIEF WELLS, CAPPING AND CONTAINMENT:
45. Relief wells and capping and containment systems are a key element of the industry’s oil spill response plans. Yet oil companies appear to have done little credible or detailed work to estimate how long it would take to drill a relief well in Arctic conditions. Cairn’s plan estimates 34 days to drill a relief well for any well in Greenland, despite the wells being of greatly varying depths and hundreds of miles apart. Tellingly, Cairn admits that this figure is drawn from another large operator’s relief well plan for the Arctic, rather than being based on Cairn’s specific Arctic projects. 
46. Cairn’s estimate also seems to be extremely optimistic; working on a best, not worst case scenario. BP took over 80 days to drill a relief well which finally stopped oil flowing from the Macondo well in the Gulf of Mexico. The company were forced to stop several times due to poor weather conditions. The potentially extreme Arctic weather conditions also could delay the drilling of a relief well.
47. Most significantly of all, if a blow-out were to happen at the end of the drilling season, it is in fact unlikely a relief well could be drilled before the ice encroaches, and it would be extremely unlikely that it would be possible to drill a relief well once ice was present over the drill site. This could leave oil gushing from the wellhead under the ice for up to 7 months over winter, until drilling could resume again in the Spring.
48. Oil companies also often cite capping and containment systems as the other means by which they would deal with a spill, but provide little detail, or evidence of how these would work in Arctic conditions. . For example Cairn’s plan fails to specify what capping equipment will be used and how, and whether it has been tested in Arctic conditions.
49. Shell are developing a ‘containment structure’ to cap a ruptured well, yet they have so far refused to release information on how, where and when it will be built and it has not been tested in-situ  while similar constructions used by BP during Deepwater Horizon were notably unsuccessful. The International Association of Oil and Gas Producers recently announced a four year research project to improve techniques to respond to oil spills in ice.  This acknowledges the unique challenges that operating in Arctic conditions presents , including - "prolonged periods of darkness, extreme cold, distant infrastructure, presence of sea ice offshore and a higher cost of doing business." Each oil company will contribute around $2.4 million to fund the research, yet this is dwarfed by the $4 billion that Shell has already invested in its Alaskan exploratory drilling programme.
CLEANING UP AN OIL SPILL
50 . The Arctic Ocean is a unique operating environment - its remote location, extreme climate and dynamic sea ice make containing and cleaning up an oil spill extremely difficult and in some cases arguably impossible.
51. The basis of Shell’s clean-up plan for Alaska depends on getting large amounts of material on-site very rapidly and assumes that the necessary infrastructure already exists in Alaska to do this. This is far from the case. BP’s response to the Gulf of Mexico spill needed 6,500 vessels, tens of thousands of staff and the costs lead to one of the world’s wealthiest and best resourced companies having a near-death experience.  A similar sized response would be impossible in the Arctic. The US Coast Guard has admitted that almost no infrastructure exists in the region, with Admiral Robert Papp, Jr. saying that, "there is nothing up there to operate from at present...no way we could deploy several thousand people as we did in the Deepwater Horizon spill."  The USA currently has only one operational ice-breaker  and the nearest town to Shell’s drill sites was described by the US Coast Guard as having "limited access and no ability to support large-scale operations."  It concluded that these logistical problems created a "significant impediment not only to oil spill response but to search and rescue."  It is tempting to conclude that oil companies imagine that a spill in the Arctic would be ‘out of sight and out of mind – and that for this reason they will not have to mount a clean-up operation of the scale needed to deal with the Deepwater Horizon disaster.
THE PROBLEM OF ICE
52 . The USGS conclude that "there is no comprehensive method for clean-up of spilled oil in sea ice" and that recovery systems normally used to collect oil faced "severe limitations" due to extreme conditions in Alaska. 
53. Similarly, according to a senior official at a Canadian firm that specializes in oil-spill response "there is really no solution or method today that we’re aware of that can actually recover [spilt] oil from the Arctic." 
54. Cairn admits that any clean-up response will grind to a halt during the freezing Arctic winter: "during ice conditions the response may be limited to monitoring the spill with recovery operations resuming once the thaw is complete." 
5 5 . Shell note that "as these [ice] conditions develop, the efficiency of physical containment and recovery tactics will be reduced." The company goes so far as to say that "all physical removal tactics will cease" if conditions deteriorate too far because "it may be impractical and unsafe to access the oiled zone because of its movement and extensive ridging and rafting of the ice." 
5 6 . The presence of ice not only renders conventional oil spill techniques ineffective, the moving ice presents unique challenges to spill response.
5 7 . Moving ice floes can trap spilt oil as they move over the drill site, and then float up to a thousand miles from the source of the spill during the course of the winter. Each floe would then have to be tracked and the oil recovered – yet there is no currently no method of remotely detecting oil trapped under ice. The oil would remain under the ice until the Spring, when as the floes thawed, the still highly toxic oil would be released into the environment at the beginning of the breeding season for many species.  The potential trans-boundary issues from ice impacting on several di fferent national territories have not yet been considered.
5 8 . The oil industry seeks to allay fears with assurances that drilling only takes place in open water. However, Shell’s plan for the Beaufort Sea admits, "ice incursions can occur at any time" during the summer drilling season.  Moreover, the company is currently lobbying to reverse a restriction on its drilling operations which would see them cease 38 days before ice-encroachment. Given that Shell itself recognizes the impracticality of dealing with an oil spill once sea-ice has formed, it is difficult to see how they can justify this position.
59. Article 234 of UNCLOS (below) clearly recognises the serious hazards to the protection of the marine environment posed by sea ice and the duty of Coastal States to put measures in place to prevent and reduce harm from potentially damaging activities within their EEZs. It says - "Coastal States have the right to adopt and enforce non-discriminatory laws and regulations for the prevention, reduction and control of marine pollution from vessels in ice-covered areas within the limits of the exclusive economic zone, where particularly severe climatic conditions and the presence of ice covering such areas for most of the year create obstructions or exceptional hazards to navigation, and pollution of the marine environment could cause major harm to or irreversible disturbance of the ecological balance. Such laws and regulations shall have due regard to navigation and the protection and preservation of the marine environment based on the best available scientific evidence."
60 . It is widely acknowledged that m echanically recovering oil using booms and skimmers would not be effective if ice cover is more than 25%.  Other research has suggested that 10 per cent ice coverage will render booms ineffective."  Even if conditions are ideal, oil companies estimate, at best, that only 10-20 per cent of the oil could actually be removed.  In most spill scenarios in the Arctic , offshore recovery will almost certainly not be anywhere that high.  For example, only 9% of oil was recovered from the Exxon Valdez spill. In addition, low temperatures cause the oil to solidify and make it very difficult, if not impossible to pump. 
61. The long-term eco-toxicological impacts of chemical dispersants are not well understood, and the inefficacy of dispersants in the Gulf of Mexico in dispersing the oil was widely reported.  Oil spill dispersants do not actually reduce the total amount of oil entering the environment, but change the properties of the oil, and therefore the oil’s fate and potential effects.  The US National Research Council notes that - "the mechanisms of both acute and sub-lethal toxicity from exposure to dispersed oil are not sufficiently understood," and that there are "many important, unanswered questions about how dispersed oil might be... passed through the food chain."  Worryingly, Cairn Energy’s plan recommended using dispersants near the shore in certain circumstances even though most countries to do not permit this.
62. The increased viscosity of the oil due to low Arctic temperatures can render dispersants less effective than in other environments, and the presence of sea-ice can inhibit mixing of the dispersant in water. 
63. In-situ burning cannot take place if ice cover is more than one third.  This is because the equipment, such as herders and booms, which is needed to ensure a high enough concentration of oil for in situ burning to take place, is only effective when the ice cover is below these levels. The oil also has to be of a minimum thickness to ignite, and has to be ignited within 2-3 days.  Dealing with the resulting residues and keeping wildlife away from the burn are both serious challenges. 
64. The side-effects of burning significant quantities of oil in the Arctic are unknown. The in situ burning guidelines for Alaska admit that "the potential effects of in situ burning in the marine environment and in inland and upland areas are not well known or understood, and will vary depending on the specifics of each accident". It goes on to say that "potential ecological impacts of in situ burning have not been extensively discussed or studied". 
65. Shell claims that by using in-situ burning they could recover 90% of oil spilled. This is a remarkable assumption when you consider that the USGS estimates  recovery levels of 1-20% in the Arctic. Only about 3% of oil was ever recovered after Deepwater Horizon, whilst the figure for Exxon Valdez was around 9%.
66. Cairn Energy’s plan to use in-situ burning as part of a spill response is hampered by the fact that some of the equipment that would be used for in situ burning has never been tested, nor approved for use in Greenland or by the Greenland government.
ECONOMICS OF ARCTIC OIL
67. In a period of rapid economic growth in emerging economies (particularly China, India and Latin America), characterised by growing awareness of resource constraints, there has been a strong assumption that there is significant oil (and gas) available for extraction in the Arctic, based on preliminary studies conducted by the United States Geographical Survey (USGS). 
68. The USGS concluded that about 30% of the world’s undiscovered gas and 13% of the world’s undiscovered oil may be found in the area north of the Arctic Circle, mostly offshore under less than 500 meters of water. This estimate for total undiscovered oil and gas in the Arctic exceeds the total discovered amount of Arctic oil and oil equivalent natural gas (240bn barrels) - which constitutes almost 10% of the world’s known conventional petroleum resources.
69. The published information contained in this survey however contains one significant caveat: "No economic considerations are included in these initial estimates; results are presented without reference to costs of exploration and development, which will be important in many of the assessed areas". However, without a consideration of the potential cost of exploiting this resource, the public discourse has neglected the potential alternatives to chasing supply, with a presumption that extraction will inevitably proceed, regardless of cost.
70. Unpublished but available information including costs for exploiting this resource, also from the USGS, suggests a potentially different outcome, at least in the East Greenland Rift Basins – a region in the Arctic considered particularly promising for oil and gas extraction, with an estimated resource of 7.5 billion barrels. The report  concludes extraction costs could be very high – from $100-$300 per barrel, implying that a high average oil price would be required. If the average oil price was $100 per barrel, only 2.5bn barrels of oil could be commercially extracted, with a 50% probability of success. Even with an average oil price of $300 a barrel, only 4.1bn barrels could be expected to be extracted, again with only a 50% chance of success. The high costs, as well as a high risk of failure, are significant deterrents to investment in the region, especially in the context of the potentially extremely high costs of responding to a major spill in the Arctic. Additionally there is the risk is of high cost, stranded assets, created by the development of alternatives to very highly priced oil, such as ultra- efficient internal combustion engines, hybrid and ultimately electric vehicles charged from renewable resources.
GOING BEYOND OIL
71. To protect the Arctic from rising temperatures and the threat from oil drilling we need to end our fossil fuel dependence and make a shift to clean and reliable technology which is safe, tried and reliable. The USGS (United States Geological Service) estimate that the Arctic may hold around 90 billion barrels of oil, enough to meet global oil consumption for just three years. This fact starkly illustrates the need to reduce our dependence on oil from an energy security perspective alone.
72. Later this year the European Commission will publish proposals on European car efficiency targets. It is these targets that will be the key driver for introduction of new technologies that will kick start a wholesale shift towards a low-carbon transport system.
73. Greenpeace is calling for a European car efficiency target of at least 60gCO2/km for cars and 100gCO2/km for vans by 2025. We are also asking the European Commission to reconsider the 2020 targets set in the existing legislation, in particular for vans.
74. The latest data shows that the EU’s van standard would achieve less than a 20% reduction in CO2 emissions from new vans between 2010 and 2020. With such a standard, the EU would do too little to drive technology improvements in the sector, and miss an important opportunity to reduce its oil consumption and CO2 emissions. In our view, an average of 120gCO2/km (not 147gCO2/km as currently planned) can and should be achieved by 2020.
75. A car standard of 95gCO2/km would achieve more than a 30% reduction between 2010 and 2020. However, recent developments indicate that faster reductions are possible, and EU research recommends a target in the range of 70-90gCO2/km.  Greenpeace believes that average CO2 emissions should be reduced to no more than 80gCO2/km by 2020. The UK government must champion strong new European car efficiency laws.
76. Once a de facto marine reserve protected by permanent sea ice, the Arctic Ocean is not only becoming accessible to the oil industry but also to industrial-scale fishing fleets. Arctic and sub-Arctic waters are among the most biologically productive in the world. The EU is of high relevance as an importer for the Arctic nations’ fish catches, with the UK a major importer of fish from both Canada and Iceland  .
77. At present, industrial activities in the Arctic Ocean are limited by the sea ice that exists for most or all of the year. Climate change is changing all this, with both the melting of the sea ice and changes in ocean currents which causes changes in sea temperatures, leading to fish stocks changing their distribution. It’s predicted that the North East Atlantic cod stock, the last of the big global cod stocks, will move North and East due to ocean changes.  Unsurprisingly with the opening up of these previously unexploited waters, the Barents whitefish fleet is already venturing further north than it ever has before.
78. In June 2010, the Greenpeace ship, Esperanza, documented this northward creep, encountering ten Russian trawlers at almost 80 degrees north on the northern west coast of Svalbard. Cod trawlers such as these drag their heavy gear across the seabed causing extensive damage to vulnerable marine habitats such as cold water corals and sponge fields. Such damage is known to have occurred further south in areas such as along the Egga Ridge and the sponge fields located on the Tromsø Bank. The marine habitats north of Svalbard are not well understood and poorly mapped and so it is not known what impact such fishing will have on the fragile and interlinked ecosystems of the Arctic Ocean. The Greenpeace expedition conducted a series of seabed surveys in the region using a drop camera and ROV and discovered that the seabed was not the lifeless muddy bottom suggested by some, but home to a myriad of marine life including sea urchins, sea stars, sea anemones, soft corals, sea squirts, tube worms, sponges, haddock, cod, red fish and shrimps  .
79. Spurred on by concerns over the impacts of climate change on fishing in the region, the North Pacific Fisheries Management Council made the sensible decision in February 2009 to establish a moratorium on commercial fishing in a vast zone off Alaska's northern coast. This move was applauded by Greenpeace, and will help give marine life in the Chukchi and Beaufort Seas a much better chance of surviving the loss of sea ice and the increasing ocean acidification that are predicted for Arctic waters in the coming decades.
80. The need to adopt a precautionary approach to the management of fish stocks and the wider marine environment of the Arctic Ocean, especially in the context of limited knowledge and huge uncertainty is widespread within the scientific community. In a speech earlier this year, Sir David Attenborough voiced his concern about polar fish stocks, warning that unless fishing levels are closely monitored and controlled the fish species found in Arctic and Antarctic waters might end up overfished in the same way as other stocks have been including the Clyde herring and the cod stocks that were once abundant over the Newfoundland Banks  .
81. Currently the Pew Environment Group’s Oceans North campaign is collecting signatures from scientists to an open letter urging Arctic governments to develop an international agreement to address fisheries in the central Arctic Ocean. At present, as is the case with most of the high seas, there are virtually no measures in place to protect the Arctic Ocean’s marine biodiversity.
82. The Parliamentary Office of Science and Technology has summarised the situation succinctly: " Arctic fisheries management is currently fragmented, being based on bilateral arrangements between Arctic states and Regional Fisheries Management Organisations (RFMOs), which include the North East Atlantic Fisheries Commission. Large parts of the Arctic Ocean, however, are not covered by RFMOs because they have not been needed to date. As Arctic marine ecosystems change, if fish stocks migrate out of their current geographical regions into high seas areas or territorial seas beyond current RFMO coverage, inadequate fish stock management and overfishing may result." 
83. The recent and unresolved mackerel conflict in the North Atlantic is a clear example of lack of international mechanisms to resolve conflicts over highly migratory fish stocks even among states that normally cooperate very well  .
84. As the decline in Arctic sea ice causes historically closed routes such as the Northwest and Northeast Passages to open up, serious questions arise regarding security and safety. New access to shipping routes brings with it the increasing risk of environmental degradation caused by these activities. Poor mapping, insufficient search and rescue capacity and the fact that there are virtually no resources to deal with any form of spill mean that the opening up of these routes are now putting the Arctic Ocean, its wildlife and the people who depend on them at risk.
85. Fuel oil spills and industrial accidents are one obvious cause for concern. The Arctic Ocean is both hazardous to shipping and highly sensitive to a range of harmful substances arising from vessels operating in these waters. It is clear from studies and experience that the effects of oil spills in a high-latitude, cold ocean environment last much longer and are far worse than in other areas. As indicated earlier, oil spill cleanup is rarely effective but in the Arctic conditions any clean-up attempt at all will be impossible for much of the year due to extreme darkness, temperature and solid or broken ice conditions.
86. In spite of the Arctic Council’s Search and Rescue agreement  , there is as yet no effective search and rescue system for the Northern Sea Route, so all arrangements need to be done on a vessel by vessel basis. Weather is challenging and will often delay passage. Icebreaker support is often needed and expensive. Poor mapping of the hydrographic conditions adds to the risks and there is a clear need for better navigational charts.
87. These problems need to be addressed in a comprehensive manner and Greenpeace together with various other environmental NGOs including the Antarctic and Southern Ocean Coalition (ASOC) and WWF supports the development and introduction of a mandatory Polar Code through the International Maritime Organisation (IMO) that addresses all forms of potential impact from all vessels operating in polar waters and ensures that the highest possible environmental standards are applied.
88. Greenpeace welcomes the heavy fuel ban that has been implemented in parts of Svalbard and would like to see such a ban expanded to cover more parts of the Arctic. Further information on the scope of the code can be found in the joint NGO briefing ‘Proposals for provisions for inclusion in an environmental protection chapter of the mandatory polar code’  .
89. Research to date has demonstrated the huge intrinsic value of the Arctic as a unique set of ecosystems as well as its importance as an indicator of impending and ongoing global change, including that resulting from climate change and ocean acidification as a consequence of rising atmospheric CO2 concentrations. Arctic research nonetheless remains logistically highly complex and resource intensive, relying as it does on limited access and infrastructure. All observations, measurements and samples collected in such a challenging environment are therefore extremely valuable in terms of building knowledge and understanding of ecosystem structures and dynamics, material and energy flows and the human impacts already realised or projected to occur and it is vital that governments maintain strong support for scientific programmes in the Arctic.
90. Although once considered a relatively pristine and inaccessible region, retreating ice has, as documented above, made possible a rapid increase in human activities in the Arctic which have the potential to cause substantial impacts on wildlife and habitats, including freight shipping, fishing and the exploration and exploitation of oil and seabed mineral resources. Despite what is known about the Arctic, these human developments are inevitably occurring against a background of incomplete scientific description and understanding of the species and natural systems which may ultimately be impacted. The collection of further baseline data should therefore be a priority, and perhaps be accelerated over the coming decade, in order to inform the subsequent detection of impacts and long-term trends in the quality of the Arctic environment.
91. Recognising the logistical complexities and restrictions in suitable research ship time which are frequent limitations in the planning and conduct of research in the Arctic, Greenpeace has in recent years made its vessels available as research platforms for a number of institutions and university research groups, thereby assisting in the collection of data relating to glacier movement and to sea ice thickness and structure, among others. One of the more intensive pieces of such collaborative work involved logistical and scientific support for a major programme of field research into impacts of ocean acidification conducted in the Kongsfjord (Svalbard) in the Arctic summer of 2012 by the German marine institute IFM-GEOMAR   . This research, focused on impacts on planktonic organisms exposed to a range of projected future CO2 concentrations, has already made a fundamental contribution to understanding of the responses of these organisms within an environment that is anticipated to be among the most susceptible to early acidification. The samples collected are also expected to underpin numerous other lines of research in the coming years.
92. Contribution to such research programmes by an organisation such as Greenpeace, though positive, is reliant on considerable allocation of very limited funds and as such can only ever be part of the solution to support on-going research in the Arctic. It is therefore vital that national governments, including the UK, continue to recognise the central importance of Arctic research to the documentation and prediction of regional and global change and to support such research institutionally and financially well in to the future.
93. At present, resource management and environmental protection in the Arctic is almost exclusively determined by the group of Arctic nations, often in the interests of extractive industries, and with very little in the way of binding multilateral rules to ensure stability or enforce minimum standards. Much of the region falls under the national jurisdiction of one of eight Arctic nations (Canada, Russia, Greenland, the US, Norway, Sweden, Finland and Iceland), all of whom apply their own regulatory control regimes affecting activities within their borders, territorial waters and continental shelves.
94. The Arctic Council, which describes itself as a ‘high-level intergovernmental forum to promote co-operation, co-ordination and interaction among the Arctic States’  draws up and issues guidance on some elements of environmental protection (for example on regulating offshore oil and gas activities), but this guidance has as yet no ‘hard’ legal status and is not necessarily followed by the Arctic nations or companies operating within the Arctic. For example, neither Cairn nor Greenland followed the guidance in making its spill response plan publicly available for scrutiny. In 2011, the first legally binding agreement of the Arctic council was signed (on Search and Rescue), which marks a potential new direction for the Arctic Council to become an active decision-making body. Presently there is a new agreement being negotiated on emergency prevention, preparedness and response with a planned signing at the next ministerial meeting in 2013. This new direction would entail enhanced influence and responsibility of permanent participants and observer states on issues concerning the entire Arctic Ocean. Clearly given the scale and importance of the issues that need to be addressed, and in order that it remains relevant, the Arctic Council must evolve.
95. The only part of the region currently subject to some form of international jurisdiction is the part of the Arctic Ocean around the North Pole, which falls under the regime of the high seas under the United Nations Convention on the Law of the Sea (UNCLOS). However, with no Implementing Agreement under UNCLOS to apply basic standards of marine protection to the high seas, there is in reality a governance vacuum which is likely to become more acute as the ice melts and it becomes more accessible. Moreover, the continental shelf region around the North Pole is now also subject to territorial claims by a number of the surrounding Arctic nations, meaning that the jurisdictional status of the Arctic Ocean is even more confused.
96. Under UNCLOS each coastal state has a 12-nautical mile territorial sea and an Exclusive Economic Zone (EEZ) from 12 to 200 nautical miles offshore. Beyond 200 nautical miles, coastal States may claim rights over an "extended continental shelf". Several Arctic States have already indicated their interest in extending their continental shelf up to and including the North Pole, raising the stakes for future conflict over the region. Other state territorial claims are ongoing and will be submitted in the coming years, with disputes expected across several boundaries.
97. Article 123 of UNCLOS addresses the cooperation of States bordering enclosed or semi-enclosed seas and requires co-operation and coordination by those states.
98. Given the current situation as outlined above it is clear that the high seas of the Arctic Ocean would benefit from the development of a new multi-lateral governance system that would protect the Arctic Ocean environment and ecosystems and the people that depend on them.
99. Whilst the Arctic nations seek to extend and consolidate their authority, non-Arctic countries are trying to find alternative ways to gain influence, either through private sector players (for example, through independent oil companies such as BP securing exploration and extraction rights in Arctic countries), by proposing some form of quasi-protective/military role (for example NATO), or through arguing for observer status at the Arctic Council (for example, China and the EU). Such diplomatic encroachments have so far been met with hostility by the Arctic nations, who see no reason to allow other countries to establish a bridge-head in determining the region’s future. This increases international tensions, but also creates some dynamism in the dialogue around future governance arrangements. The UK, which is already an observer on the Arctic Council, has an active interest in the activities of international oil companies based in London, and arguably has neglected its interests in the fishing and shipping sectors as they relate to the region, could have a significant diplomatic role to play in securing a stable, multi-lateral governance regime for this highly contested and vulnerable area.
ARCTIC GOVERNANCE: A MULTI-LATERAL APPROACH
100. This current system of Arctic governance is ill-designed to secure protection of this unique ecosystem, reduce tensions, and manage the competing range of regional and global interests at stake. There are both global and local imperatives for facilitating a more ordered multinational approach. Greenpeace believes that an integrated, multilateral agreement is needed to address the various inter-connected challenges facing the Arctic.
101. A more open and inclusive dialogue about the risks of resource exploitation to the local environment, including local cultures and livelihoods, is clearly desirable, along with an exploration of other potential futures not focused exclusively on the need to access oil, fish, minerals and new transport routes as quickly and cheaply as possible.
102. At the same time, an international discussion should take place about the legitimate interests of the wider global community in protecting the Arctic environment, addressing climate change, and ensuring the sustainable management of scare resources.
103. In each of the areas of significant potential tension, some form of international co-operation, including binding rules, is needed to secure an outcome which is to the benefit of Arctic peoples and the wider global community. Specifically, Greenpeace believes that:
· International agreement is needed to ensure the conservation and sustainable management of high seas marine biodiversity, including around the North Pole.
· International agreement is needed to secure a moratorium on oil exploration and production in the waters of the Arctic Ocean, since this activity is demonstrably unsafe.
· International agreement is needed to ensure the safe and sustainable management of shipping routes in the Arctic.
· Measures need to be adopted to ensure that Arctic fish stocks are managed on a precautionary and ecosystem basis and associated impacts on the wider environment are taken into account.
104. International fora do exist which could arguably deliver an outcome around each of these issues (via the UN General Assembly, the Arctic Council, the IMO, the Polar Bear Treaty ); and given the urgency of the current crisis, the UK should seek every opportunity to secure progress through these. However, given the inter-related nature of each issue, and the common tensions and challenges which will arise in each case, there is also a strong case for seeking a unifying framework for such agreements, through a single international agreement or a treaty system covering the future of the Arctic region as a whole.
105. The lack of a unifying vision, along with competing or non-aligned interests of different government departments, has so far led to an incoherent approach to UK engagement in the Arctic.
106. For example, shipping and resource extraction are viewed as opportunities to promote British business interests (for example of UK oil companies), without any clear attempt to assess how this interacts with the UK’s advocacy of efforts to address dangerous climate change, protect ecosystems or promote advances of scientific understanding in the Arctic as exemplified by the work of the BASresearch station in Ny Ålesund on Svalbard.
107. The UK’s lags behind other EU permanent observers on the Arctic Council, such as Germany and France, who are already much more proactively engaged in thinking across the range of issues. For example, France has appointed a senior representative on the Polar regions, whilst Germany is engaging with non-littoral states to build alliances. To our knowledge, the only active diplomacy that the UK has undertaken at a senior level is in supporting BP’s ill-fated efforts to secure a deal to drill in the Arctic with Russian oil giant Rosneft . Freedom of Information Requests have revealed active engagement on this issue, and shown the limited thinking currently taking place about the risks of Arctic drilling, and the implications for climate change, of a continued ‘resource race’ in the region.
AN ALTERNATIVE APPROACH.
108. There are a number of ways through which the UK could promote a more rounded agenda for the Arctic, which recognised its full range of strategic interests, above and beyond those of international oil companies based in the UK.
109. Firstly, Greenpeace would like the Government to enter into a dialogue with civil society about the principles it adopts in its interactions in the Arctic. A number of UK NGOs have proposed a set of draft principles which could provide a starting point for this dialogue.  We would like an opportunity to engage in a cross-Whitehall discussion of their merits, and are actively pursuing this.
110. Secondly, the UK should actively pursue environmentally ambitious agreements to address the issues identified above, where we believe international agreement and co-operation are needed to secure the future of the Arctic. This includes ensuring that negotiations begin on:
A new Implementing Agreement under UNCLOS which would fill the current governance gap with regards to the conservation and sustainable use of marine biodiversity on the high-seas. Such an agreement has been supported by the EU for a number of years, with the UK government being an early champion of this approach. The demand for a new Implementing Agreement under UNCLOS is currently included in paragraph 80 of the zero outcomes draft for Rio  . The UK government should play an active role in supporting this outcome at Rio, not only as a huge step forward in biodiversity protection for the Arctic Ocean, but for the whole of the high seas.
- Adopting a precautionary approach to the management of Arctic fish stocks that takes into account the impacts on the wider ecosystem and exploring the options for achieving this.
- Securing binding rules on offshore oil and gas regulation under the auspices of the Arctic Council (which we believe should apply a moratorium to offshore drilling); and
- Leading the development of an international agreement to regulate polar shipping through the IMO;
111. Thirdly we would like the UK to review its current position and explore options for securing and integrating the various agreements outlined above, taking into consideration the experience gained from our involvement in the protection and management of Antarctica and the Southern Ocean. While there are clear differences between the two poles, there are also clear parallels. As with the Antarctic, a visionary approach needs to be adopted with respect to the Arctic environment that enshrines the ecosystem and precautionary approaches. Securing peace and enabling science must be founding principles of future Arctic policy. What happens in the Arctic is of consequence to us all, and the highest level of international cooperation is required in order to protect the region for this and future generations.
 http://news.bbc.co.uk/1/hi/programmes/newsnight/9483790.stm , BBC Newsnight, 12 th May 2011
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 http://www.greenpeace.org.uk/sites/files/gpuk/steiner-cairn-spill-response.pdf , p154
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 Cairn OSCP, p64
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 Cairn OSCP, p78
 Cairn OSCP, p78
 Cairn, OSCP, p78
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 Review of Cairn OSCP – Professor Rick Steiner p4
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 15 February 2012