Here is the complaint in Arctic Slope Regional Corp. v. Salazar (D. Alaska):

Arctic Slope Polar Bear Complaint

The summary from the complaint:

1. When polar bears were recently listed as a “threatened” species under the Endangered Species Act (“ESA”), it triggered a statutory duty for the United States Fish and Wildlife Service (the “Service”) to designate critical habitat to the extent prudent and determinable. The Service recognized that no on-the-ground North Slope activities (e.g., subsistence uses, oil and gas exploration activities) posed a threat to the species. Instead, the Service forecast that climate change was likely to cause sea ice to recede in the coming decades and that this would have a negative impact on polar bears.

2. The polar bear critical habitat designation is unprecedented in important ways. First, it is far and away the largest designation in history – covering 187,157 square miles along the North Slope. Second, it is not expected to result in a single additional conservation measure to help polar bears. The Service does not have the tools to address climate change, so instead it mechanically applied the critical habitat designation even though this action provides little to no assistance to polar bears and risks crippling the North Slope villages and Alaska Native communities in its path.

3. Alaska Natives have been the Arctic’s primary conservation stewards for thousands of years, carefully balancing subsistence needs and cultural traditions with a profound respect for polar bears and the other wildlife that share their habitat. As repeatedly recognized by the Service, Alaska Natives and other residents of the North Slope Borough are the key partners for any conservation efforts directed at polar bears. Their voluntary conservation efforts have been vital to getting the polar bear population to its current healthy status.

4. The Service’s designation of 187,157 square miles of critical habitat will disproportionately harm Alaska Natives and other North Slope Borough residents, the people who share habitat with polar bears and whose livelihood depends on those lands. As the Service has acknowledged, the listing of polar bears as a “threatened” species and the resulting critical habitat designation are both driven entirely by impacts associated with climate change. Alaska Natives and Borough residents did not cause and cannot halt the climate change at issue. The imposition of added government regulation pursuant to this critical habitat designation will not address the primary threat to polar bears, the loss of sea ice due to climate change.

5. Alaska Natives living on the North Slope are heavily dependent on their natural resources for survival. In particular, Alaska Native Regional and Village corporations in the area are employers, landowners, lessors of subsurface rights, and business partners with oil and gas companies and others working in the region. As a result of the critical habitat designation, the consultation requirements under Section 7 are expected to impair the ability of Alaska Natives to benefit from their natural resources, leading to a loss of jobs, income, tax revenues, royalties, and dividends for Native shareholders. Even relatively modest economic impacts from a designation could force Alaska Natives to abandon their ancestral villages in search of work.