"Overall, the state of Alaska has completely lost any credibility it might have had on this issue by submitting this outrageous letter," Siegel said.

Deborah Williams, a former Interior Department special assistant for Alaska and now president of Alaska Conservation Solutions, a group aimed at pursuing solutions for climate change, called the state response misguided and regrettable.

"This is the state of Alaska," she said. "They ought to be speaking from the most complete set of scientific evidence they have, and they ought to speak to it fairly."

The state's submission fails to counter or even address recent Alaska polar bear research showing fewer Beaufort Sea cubs surviving, smaller body weights and skull sizes, plus drownings, cannibalism and starvation, she said. That's in contrast to the Fish and Wildlife Service's own initial review published Jan. 9 in the Federal Register.

The agency is sifting through more than more than 400,000 electronic comments plus boxes of written comment lining a wall in an Anchorage office. Interior Secretary Dirk Kempthorne is required to render his decision by January.