As scientists from around the country come to Alaska for the Global Climate Change hearings, the Alaska Forum for Environmental Responsibility wishes to inform you that the Trans-Alaska Pipeline (TAPS) may be at risk due to warming temperatures. The Alaska Forum for Environmental Responsibility is a non-profit organization dedicated to holding industry and government accountable to the laws designed the safeguard Alaska's people and environment. The above-ground sections of TAPS, some 420 miles, rest on Vertical Support Members (VSMs), which resemble H-shaped pilings. Of the 78,000 total VSMs, we believe that some 25,000 are moving - either sinking into or jacking out of the ground due to permafrost changes, or leaning at some degree away from vertical. Additionally, we believe that slope stability along the pipeline, work pad shifting, and other permafrost degradation issues must be considered as TAPS ages and climate change continues. The VSMs on TAPS were originally drilled to depths of 15 to 70 feet. However, as permafrost conditions change, the VSMs may sink into the ground, jack up out of the ground, and/or tilt, bend, and lean. We have seen evidence of this most recently at Squirrel Creek where Alyeska last year had to replace some 38 VSMs that were moving significantly. While we commend Alyeska for their maintenance efforts, we remain concerned that this problem will continue unabated. As you are no doubt aware, the owners of TAPS recently filed applications to renew the state and federal Right-of-Way permits on the pipeline for another 30 years. We are concerned that they have provided no details and have outlined no plans for how they intend to guarantee VSM integrity for the next 30 years. Add to this the uncertainty of climate change over the life of TAPS and our concern is magnified. Thank you both for your consideration of this matter and for hosting the Global Climate Change hearings in Fairbanks. We respectfully request that you keep in mind the issues raised in this letter as you consider the important effects of climate change.

Sincerely,

Ross Coen
Executive Director