U.S. DEPARTMENT OF THE INTERIOR BUREAU OF LAND MANAGEMENT Anchorage Field Office 4700 BLM Road Anchorage, Alaska 99507

Iditarod Trail-based Special Recreation Permits and Trail Facility Maintenance Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA

Case File: AA-57929

Table of Contents ACRONYMS 3 1.0 Introduction 3 1.1 Summary of Proposed Project 3 1.2 Background 3 1.3 Purpose and Need 4 1.3.1 Decision to be Made 4 1.4 Land Use Plan Conformance 4 1.5 Other Applicable Laws, Regulations, Policies, etc. 4 1.6 Summary of Public Involvement 4 1.7 Issues Identified 5 2.0 ALTERNATIVES 8 2.1 Alternative 1 - No Action Alternative 8 2.2 Alternative 2 – Maintain Current Number of Trail Users and Events 8 2.3 Alternative 3 - Increase Permitted Users or Races (Preferred Alternative) 9 2.4 Design Features Common to All Action Alternatives 10 3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 16 3.1 Physical or Visual effects to Iditarod Trail, setting, or facilities 16 3.1.1 Affected Environment 16 3.1.2 Direct and Indirect Effects from Alternative 1 22 3.1.3 Direct and Indirect Effects from Alternative 2 23 3.1.4 Direct and Indirect Effects from Alternative 3 27 3.1.5 Cumulative Effects 30 3.1.6 Recommended Mitigation 30

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3.2 Vegetation and Soil 30 3.2.1 Affected Environment 30 3.2.2 Direct and Indirect Effects from Alternative 1 - No Action Alternative 31 3.2.3 Direct and Indirect Effects from Alternative 2 32 3.2.4 Direct and Indirect Effects from Alternative 3 (Preferred Alternative) 32 3.2.5 Cumulative Effects 33 3.2.6 Recommended Mitigation 33 3.2.7 Residual Impacts 33 3.3 Cultural Resources 34 3.3.1 Affected Environment 34 3.3.2 Direct and Indirect Effects from Alternative 1: No Action Alternative 37 3.3.3 Direct and Indirect Effects from Alternative 2 37 3.3.4 Direct and Indirect Effects from Alternative 3 37 3.3.5 Cumulative Impacts 38 3.4 User Conflicts 38 3.4.1 Affected Environment 39 3.4.2 Direct and Indirect Effects from Alternative 1 - No Action Alternative 40 3.4.3 Direct and Indirect Effects from Alternative 2 41 3.4.4 Direct and Indirect Effects from Alternative 3 41 3.4.5 Cumulative Effects 42 3.4.6 Recommended Mitigation 42 3.5 Socio-Economic Effects 42 3.5.1 Affected Environment 42 3.5.2 Direct and Indirect Effects from Alternative 1 - No Action Alternative 43 3.5.3 Direct and Indirect Effects from Alternative 2 43 3.5.4 Direct and Indirect Effects from Alternative 3 43 3.5.5 Cumulative Effects 43 3.5.6 Recommended Mitigation 43 3.6 Decreased Length of Winter Trail Travel Season 44 3.6.1 Affected Environment 44 3.5.2 Direct and Indirect Effects from Alternative 1 - No Action Alternative 44 3.5.3 Direct and Indirect Effects from Alternative 2 44 3.5.4 Direct and Indirect Effects from Alternative 3 44 Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 2

3.5.5 Cumulative Effects 45 3.5.6 Recommended Mitigation 45 3.7 Residual Impacts 45 4.0 CONSULTATION AND COORDINATION 45 5.0 LIST OF PREPARERS 45 6.0 REFERENCES CITED 46 7.0 APPENDICES / ATTACHMENTS 46 APPENDIX A: 46 Appendix B 46 APPENDIX C: 46

ACRONYMS ARC Alaska Road Commission AHRS Alaska Heritage Resource Survey BLM Bureau of Land Management BMP Best Management Practices INHT Iditarod National Historic Trail NRHP National Register of Historic Places SRP Special Recreation Permit

1.0 Introduction 1.1 Summary of Proposed Project The Bureau of Land Management (BLM) is completing a programmatic Environmental Assessment to analyze the potential impacts of issuing new Special Recreation Permits (SRPs) for the use of BLM- managed public lands in conjunction with the Iditarod Trail (Trail). This includes but is not limited to the Iditarod Trail Sled Dog Race, the Iron Dog snowmobile race, human powered races, and eco-tourism events.

1.2 Background The Iditarod Trail Sled Dog Race and Iron Dog snowmobile race have made use of the Trail between Anchorage and Nome since the early 1970’s. Long-distance human powered races began joining these endeavors on the Trail in the 1980’s. In order to manage these activities BLM authorizes the events with SRPs. The current SRPs were issued for 10-years in 2008.

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1.3 Purpose and Need The purpose of conducting this analysis is to document the current conditions of the Trail and forecast potential impacts from any future SRP uses. The BLM anticipates that the events that have been held for the past 40-years will continue to be held and possibly have increases in competitor and spectator participant numbers over the next 10-year period.

In order to issue SRPs to applicants for trail-based events, BLM needs to analyze potential impacts to the resources potentially affected by the events. There is also a need to upgrade public facilities associated with the Trail in order to meet anticipated future uses.

1.3.1 Decision to be Made Whether to issue 10-year SRPs for permitted commercial activities in 2018, and authorize facility maintenance and improvement projects on BLM-managed lands.

1.4 Land Use Plan Conformance The activity described in this document is not currently covered under a Land Use Plan. It will however, be covered under the BLM Bering Sea/Western Interior Land Use Plan currently under development.

1.5 Other Applicable Laws, Regulations, Policies, etc. All SRPs would be subject to various laws, regulations, and acts, including but not limited to the following Federal laws:

● Endangered Species Act of 1973 (as amended) (16 U.S.C. 1531 – 1544) ● National Trails System Act (PL-90-543) as amended by the National Parks and Recreation Act (PL 96-625) ● National Historic Preservation Act of 1966 (as amended (16 U.S.C 470 et seq.) ● Executive Order 11644 – Use of Off-Road Vehicles on the Public Lands (February 1972) ● Executive Order 11989 – Off-Road Vehicles on Public Lands (May 1977) ● National Historic Preservation Act of 1966, P.L. 89-655, 80 Stat 915, 16 USC 470, 1966 U.S. Code Cong. And Ad. News 3855; amended; P.L.s 91-243, 93-54, 94-422, 94-458, 96-244 and 96-515 ● Fish and Wildlife Coordination Act of 1934 (16 U.S.C. 661 – 666c) ● Federal Subsistence Hunting Regulations (Title 36 CFR Part 242) ● Federal Clean Air Act of 1970/1977 as Amended ● Resource Conservation and Recovery Act (RCRA) of 1976 (40 CFR 239 -282) ● National Trails System Act of 1968 as amended ( 16 U.S.C. 1241-1251)

1.6 Summary of Public Involvement A public scoping period was opened on May 31, 2017 for thirty days. Two comments were received during that time. The concerns that were presented involved the continued opportunities for commercially permitted activities on the Trail and access to the trial for use by individuals in nearby communities. By analyzing the two action alternatives that would allow for continued or increased commercially permitted activities, these issues are being addressed.

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1.7 Issues Identified This analysis considers the no action alternative, which would allow all permits to expire. In this alternative, each permit would be analyzed in accordance with FLPMA and NEPA and a decision made at a future date. Alternative 2 would continue with current permit levels of authorized SRP entrants, Alternative 3 (Preferred Alternative) would allow for increased number of permits and entrants to utilize the Trail.

Issues to be analyzed:

Vegetation What impacts could trail-based activities by SRP-authorized users have on vegetation and soil?

Recreation Will the proposed activities have significant negative physical and visual effects on the Trail, adjacent setting, and associated facilities?

The BLM recommended establishing Areas of Critical Environmental Concern (ACEC’s) in the 1981 Southwest Management Framework Plan. The Iditarod Trail crosses several of these proposed ACEC’s. How will the proposals affect the area or resource within the boundaries of the ACEC?

Will the Preferred Alternative create significant conflicts between casual users and permittees?

Cultural Resources Will cultural resources be significantly negatively affected by the proposed activities?

Social-Economic Will the proposed activities have a disproportionately high and adverse effect on low income or minority populations?

Length of Winter What are the effects of the changing length and intensity of seasonal winter weather on winter-specific trail use?

Issues Eliminated from Further Analysis

Impacts to air quality The Preferred Alternative is not expected to have a noticeable effect on air quality from emissions caused by aircraft use and wood smoke, in proportion to existing emissions from casual use. The Preferred Alternative is not expected to have a significant effect on air quality from the use of snowmobiles, in proportion to existing emissions from casual use. Improved emission standards for snowmobiles have resulted in significant decreases in emissions for the fleet of snowmobiles operating in the United States, in Alaska, and on the Iditarod Trail. Annual Trail usage has remained approximately the same for the past decade. If more snowmobiles are operated on the Trail as a result of

Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 5 additional permitted events, the overall quality of the air will likely remain the same due to decreases in snowmobile fleet emissions.

Water Quality Airborne contaminants associated with snowmobile emissions settle on the snow and may migrate into surface and/or groundwater. However, the level of contamination associated with the races is a small fraction of the total amount generated by casual, non-permitted Trail users, and is not expected to have a significant effect on the environment.

The alignment of waterway crossings for the Trail often use short, steep river and creek banks. Ascending or descending these banks repeatedly with a snowmobile can lead to vegetation stripping and ground disturbance, which can cause sedimentation in waterways. Compared to the high level of natural bankside erosion that takes place in the waterways crossed by the Trail, the effects of these Trail crossings are virtually indiscernible.

Aquatic Life Because Iditarod Trail-based events take place during winter when rivers and streams are frozen, impacts directly to fish and aquatic life are minimal.

Area of Critical Environmental Concern The BLM recommended establishing Areas of Critical Environmental Concern (ACEC’s) in the 1981 Southwest Management Framework Plan. The Iditarod Trail crosses several of these proposed ACEC’s. How will the proposals affect the area or resource within the boundaries of the ACEC?

In 1981, the drainages of the Unalakleet River system were identified as important for the Unalakleet Wild River, the Kaltag Portage of the Iditarod National Historic Trail, sport and subsistence fisheries, winter moose range, and grizzly/brown bear concentrations. Although recommended in the 1981 Southwest MFP, an ACEC to protect peregrine falcon habitat has not been implemented (SWMFP 1981). Many of the ACECs that were recommended in 1981 were for species once found on the endangered spices list that have since been removed. No ACEC management plans were ever created as a result of the 1981 recommendations.

In 1986, the watershed of the Unalakleet River was designated an ACEC, within the Central Yukon RMP planning boundary, in order to provide a higher level of protection to salmon and sheefish spawning and rearing habitat than would otherwise exist without the ACEC designation. These areas contain that portion of the watershed (including all lands within the linear river withdrawals) to minimize potential impacts of land usage on important fish production rivers. These fisheries have been identified as having high commercial, sport and subsistence economic values.

The current ACEC policy from 1988 requires that all existing ACECs be evaluated during the land use planning process. The current planning effort, Bering Sea-Western Interior Resource Management Plan, is currently under development and a report evaluating ACECs has been completed with Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 6 recommendations to consider when the plan is presented for a decision. They include the Sheefish ACEC, Drainages of the Unalakleet River ACEC, Unalakleet ACEC, Unalakleet River Watershed ACEC, Tenmile River Watershed ACEC.

Each of these ACECs is designed to provide additional protection for the listed rivers and watersheds associated with them. Continued winter Trail use is not expected to have an adverse effect to the quality or quantity of the water resource, fish, or other related habitat in the area.

Hazardous Materials or Other Waste Materials Permit stipulations require permittees to observe and practice all state and federal requirements for fuel handling, storage, and removal, with BLM providing regular monitoring of such practices. Monitoring of such practices for the past decade has shown that these sources do not have a significant effect on the environment.

Permit stipulations also require that event sponsors remove all solid waste generated by the each event. Monitoring of such requirements for the past decade has shown that these sources do not have a significant effect on the environment. The proposed alternatives should not have a significant effect on the environment when the stipulations are followed.

Human use of the Trail for SRP-authorized events is a small proportion of the total use of the Trail, and is not expected to generate significant amounts of human waste along the Trail. To prevent impacts from human waste at popular public shelter cabins, BLM maintains pit privies. BLM may also require SRP holders to remove human waste as part of permit stipulations.

Dispersion of canine fecal material over the length of the Trail may result in short-term, localized effects to water quality. Water quality would return to background levels several months after any effect may be noticed, and this effect is not considered significant.

Wildlife Threatened and Endangered Species: Throughout the length of the Trail, the only area that could provide potential habitat for threatened and endangered species involve the portion of the Trail adjacent to coastal areas along Norton Sound. Both Steller’s and Spectacled Eiders may frequent marine waters within Norton Sound during spring and fall migrations to breeding areas on the northern coast of the state. Use of the Trail and permitted activities would occur only during the winter, and therefore would not affect eiders that would potentially use marine waters along coastal areas of Norton Sound only in the ice-free season in spring (April/May) and fall (September/October).

The impact of all alternatives on threatened and endangered plants and animals and their habitats has been evaluated in accordance with the Endangered Species Act of 1973, as amended. Based on currently available information, they would not affect any threatened or endangered species or their habitats. Therefore, no consultation with the U. S. Fish and Wildlife Service is considered necessary pursuant to Section 7 of the Act and none will be undertaken.

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Subsistence Approximately 78 miles of the entire Trail route traverse unencumbered BLM owned lands. These segments of the route are Federal Public Lands as defined in ANILCA Section 102(3) and fall under the regulatory authority of the Federal Subsistence Board and Subsistence Management Regulations for the harvest of wildlife, fish, and shellfish on Federal Public Lands in Alaska. These lands are used by subsistence users within game management units (GMU) 19D, 21E (south route) 22A and 22B. These lands are also within subsistence resource region 6 (Western Interior) and region 7 (Seward Peninsula).

Subsistence hunters and trappers generally take advantage of hunting and trapping seasons along the trail during winter. Trapping for furbearers is open through the winter and the trail may be used to access trap lines on and off Federal Public Lands. There is a federal subsistence priority for black bears, brown bears, caribou, Dall Sheep (GMU 19D), Muskox (GMU 22B), furbearers and upland game birds on Federal Public Lands managed by BLM along the trail route. Hunting seasons for these species may be open during the winter when the trail is in use, depending on population levels, migration patterns and changes in Federal subsistence hunting regulations. Brown and black bears are denning and unavailable in winter, although caribou, moose, and muskox have open winter seasons on Federal lands along the trail. Hunters may travel the trail on snow machine during these seasons to access these lands.

There is an annual open hunting season for an introduced herd of Plains Bison along the Farewell Burn segments of the route, however it is a state managed hunt rather than a subsistence harvest and managed by the State through a lottery for permits.

Approximately 100 wood bison were introduced in the Innoko bottoms area near the village of Shageluk in March 2015. This herd has dispersed onto BLM lands in the region, including areas along the trail, and is considered a subsistence species. The herd is currently closed to all harvest until the population increases to a level that can sustain a limited annual subsistence harvest.

The actions proposed in all three alternatives will not result in a significant restriction in subsistence resources and uses.

2.0 ALTERNATIVES 2.1 Alternative 1 - No Action Alternative The No Action Alternative would allow the current permit holders to continue with their permits until such time as they expire, at which time they will be required to re-apply for new permits. Each permit application would then be analyzed as received, and would be approved or denied at that time.

2.2 Alternative 2 – Maintain Current Number of Trail Users and Events This alternative would allow for the continued use of BLM managed public lands for the competitive events at the 2008 permitted level. No additional users or races above the 2008 entrant numbers would be permitted under this alternative.

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2.3 Alternative 3 - Increase Permitted Users or Races (Preferred Alternative) This alternative would provide for anticipated increase in interest and use of the Trail over the next 10- year period. This alternative would allow for the potential increase in individual participants in permitted races, new similar designed races, and guided tours.

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Figure 2-1 Location Map

2.4 Design Features Common to All Action Alternatives All events would take place on BLM lands traversed by sections of Trail commonly known as “the Iditarod Trail” (see Figure 2-1). Events commonly follow one of two routes between Ophir and the Yukon River valley: One route runs north from Ophir to Ruby, and then west on the Yukon River to Kaltag, where it rejoins the Trail to Unalakleet. This route is sometimes referred to as “the north race route”. The other alternate race route (used by sled dog races and human-powered marathons only) turns south at Ophir and travels to the ghost town of Iditarod, then to Anvik, and north to Kaltag on the Yukon River. This route is sometimes referred to as “the southern race route”.

All events are scheduled to occur in February and March, as lengthening days provide for warmer temperatures and extended daylight conducive to Trail travel. Event starts are separated by time (typically by a week), with the shortest duration events (motorized) being scheduled earliest in the season, human-powered marathons being scheduled next as they are the longest duration (up to 20 plus days for events traveling to Nome), and finishing with the long-distance sled dog race, (which is completed within 14 days).

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Table 2.0.1 Alternative Comparison: Proposed number of participants Event Type Alternative 1: Alternative 2: Alternative 3: No Action Preferred Alternative Sled Dog Race 1 0 100 100 Snowmobile Race 1 0 125 120 Snowmobile / Snow Bike Race 2 0 0 120 Human-powered Marathon 1 0 50 75 Human-powered Marathon 2 0 0 75 Human-powered Marathon 3 0 0 75 Guided Winter Overland Tours (Dogsled, 90 snowmobile, etc.) 0 0 Total 0 275 655 (Note: The overland tours include all support staff and participants.)

Checkpoints All events establish temporary checkpoints at selected intervals (dictated by the event, with most in existing communities), staffed by volunteers for the purpose of providing fuel and supply pickup, animal and entrant health and safety support, and participant shelter. Event participants may or may not be required to stop at each checkpoint according to the rules of the event.

Checkpoints are typically located where access and supply of provisions and fuel can be provided by small or large plane (on either maintained runways at communities or unmaintained snow covered airstrips in remote locations).

One checkpoint is usually established on BLM lands at Rohn, a BLM Air Navigation Site, a short airstrip, and location of the historic Rohn Public Shelter Cabin. Rohn has historically been used as a checkpoint, and is the first checkpoint on the north side of the Alaska Range. All events typically use this location for a checkpoint.

Trailbreakers Each event uses trailbreakers to prepare the Trail prior to participants passing, although with differing levels and/or location of preparation. The trailbreakers typically precedes the event, packing the route by snowmobile, or on some segments, with the use of drag-behind trail groomers, removing fallen trees from the Trail, and marking critical turns on the Trail with 3-foot pieces of survey lathe. They install temporary trail markers (survey lathe, flagging and reflective tape) stuck in the snow or drilled into the ice.

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The human powered races participants who go on past McGrath are required to break trail as no additional trailbreakers are provided for this endurance race.

Snowmobile Race The current snowmobile race typically starts in the Matanuska-Susitna Borough, and travels to Nome on the north race route only. Then from Nome it travels east to Fairbanks via the Iditarod Trail through Unalakleet, Kaltag, and Ruby, and then on the Yukon River and other waterways and trails to Fairbanks. (No BLM land is crossed east of Kaltag).

Participants include a professional class of riders, representing competitive riders, and a recreational class of riders, representing a non-competitive group that travel one-way only, from the Mat-Su to Nome. Between 2008 and 2017, BLM permitted up to 119 riders but the average participation has been approximately 70 pro-class riders and 16 to 24 recreation class riders.

Race organizers transport snowmobile fuel by small plane to the Rohn airstrip, and volunteers from local communities serves as timekeepers and provide other support necessary to operate the checkpoint.

Up to six checkpoint volunteers typically drive snowmobiles to the site from McGrath and/or Nikolai, and staff the site for two to three days.

Fuel handling requirements and other stipulations that protect the site, the Trail, and/or associated resources are included with the permit, and permittees are monitored for compliance. (See Appendix A). Race organizers and volunteers are expected to remove all solid waste, remove all empty fuel drums, and leave the site in good shape.

Snowmobile race participants typically bypass other public shelter cabins found on BLM lands along the Trail, instead opting to overnight in regional communities along the race route. This includes Rohn, where event participants usually stay long enough to fuel their machines, make minor adjustments, and eat before continuing north.

Human-powered Races Human-powered marathon events typically start approximately a week after the long-distance snowmobile race begins, to take advantage of the snow-packed trail. The marathons are frequently broken into shorter-distance and longer-distance races.

The shorter-distance races travel approximately 350 miles and conclude in McGrath in the Kuskokwim River valley, and are the more popular of these events, typically with three quarters of the permitted entrants participating in this event. The longer distance race travels approximately 1,000 miles to Nome, and usually attracts a quarter or less of all entrants due to the commitment of time and resources.

A number of on-foot (and running-style snowshoes) participants pull small sleds with camping gear, and take a week or more to finish the shorter race, and up to 20-days or more to finish the trek to Nome.

The route for the human-powered marathons typically follow the route used by the long-distance sled dog race, with the shorter distance marathon being completed before the sled dog race begins, and then Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 12 the small number of foot and bike racers being passed by, and being able to make use of the trail packed for the sled dog race.

The human-powered marathon(s) typically use Rohn as a checkpoint, setting up a small wall-tent to provide sleeping quarters for racers, along with providing a few volunteers to staff the site. Operational stipulations are listed in the permit for the site, which encourages protection of the site, the Trail, and/or associated resources, and permittees are monitored for compliance. (See Appendix A). Race organizers and volunteers are expected to remove all solid waste, and leave the site in good shape.

Racers can and do occasionally use the BLM public shelter cabins at other locations along the Trail to take a break from the rigors of winter camping, although this is typically only a handful of persons, as most are focused on completing the shorter venue to McGrath rather than spending time along the Trail.

Sled dog Race The sled dog race travels in one direction only (north), usually alternating annually from the north race route to the south race route. The event takes approximately two weeks from start to finish.

Race organizers transport straw for bedding dogs, fuel, and supplies for checkpoint volunteers and race participants by small plane to the Rohn airstrip. Race organizers recruit and provide volunteers to serve as timekeepers and provide other support necessary to operate the checkpoint.

Sled dog race entrants occasionally take an extended rest and/or feeding break for their dog team along the Trail, including on BLM lands, and sometimes at BLM public shelter cabins. The breaks are typically less than 12 hours, and are most likely to occur on the BLM segment of the Trail between Kaltag and Unalakleet. If a public cabin is located conveniently for a mushers “run-rest” schedule, they may use that cabin; otherwise, they camp along the Trail. Camping typically involved melting water and heating food carried in their sled for the dog team. Campfires are usually not made, as each musher carries a large stove fueled by methanol, to heat dogfood.

Trail Facility Improvements Alternatives 2 and 3 will consist of Trail facility improvements necessary to respond to changing use patterns and keep the Trail and facilities in safe, working condition. (Alternative 1 will continue regular facility maintenance without the following improvements.) The location of, and specific actions are as follows: Rohn Air Navigation Site (includes Rohn Public Shelter Cabin) ● Excavate 1-privy replacement hole (double occupancy), 6’ x 4’ x 6’ = ~5.3 cubic yards (cy) ● Excavate 2 privy holes for 2-new privies, 2 x 2 cy apiece = 4 cy. Develop 2 new roofed privies. To be located in vicinity of airstrip. ● Install 8 concrete sonotubes, 12” diameter x 4’ deep (for new interpretive / orientation kiosk, and new woodshed). Total excavation = 1 cy ● Install one interpretive / orientation kiosk. ● Install one roofed open-sided woodshed.

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Structure design and location would be consistent with requirements for maintaining site eligibility for the National Register of Historic Places.

Other BLM Public Shelter Cabins on Iditarod Trail (Bear Creek, Tripod Flat, Old Woman, Foothill Summit) ● Excavate 4 privy replacement holes (one at each cabin) approximately 2 cy each: 4-holes x 2 cy apiece = 8 cy total

Trail Corridor ● Reroute Trail as necessary to avoid maintenance problems and/or resource degradation issues resulting from current Trail locations. This would include removal of trees and brush, cut flush with the ground, within three feet of either side of the centerline. Ground cover would not typically be disturbed.

● Install short bridges over open water crossings, made of native materials, or import other materials as necessary such as wood, steel, or fiberglass. This may require excavation and placement of abutments, typically no more than 10’ wide, with 12”x12” timbers or equivalent.

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Table 2.0.2 Comparison of Alternatives Action: Alternative 1: Alternative 2: Alternative 3: No Action Iditarod Trail-based Issue permits on a Authorize 3 Authorize up to 6 events, SRP Authorizations case-by-case basis events, 275 total 655 entrants entrants Authorize multiple guided No guided trips trail trips: total for all trips authorized - 90 staff and clients

Cultural Resources - Decreased use may No significant Same as Alternative 2 Trail use result in decreased adverse effects trail brushing, to the trail have affecting the been observed cultural integrity of between 2008 sections of the and 2017, and no trail. adverse effects are anticipated.

Facility Continue at Rohn: relocate Same as Alternative 2 maintenance and previous levels pit privy, develop improvements 2 new pit privies, Add 1 roofed woodshed, 1 kiosk Other Cabins: relocate existing pit privies Trail: install short bridges, relocate short sections of trail User conflict Decreases in SRP- The potential for The potential for conflicts at generated trail use user conflict is BLM cabins could increase, and visits to BLM anticipated to but permit stipulations on lands could result remain the same SRP events are expected to in a decrease in as current levels. prevent and/or reduce user potential user conflict to current levels. conflicts.

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3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 3.1 Physical or Visual effects to Iditarod Trail, setting, or facilities Issue: Will the proposed activities have significant negative physical or visual effects on the trail, adjacent setting, or associated facilities?

3.1.1 Affected Environment The affected environment for this analysis mainly involves the corridor traversed by the Trail, and associated facilities and the developed footprint for those facilities. The SRP events being considered would use the Trail to traverse approximately 94-miles of BLM managed public lands between the Alaska Range and Nome. These 94-miles are located in five distinct areas that are described in the following sections.

Rohn Air Navigation Site (Map 1, Appendix C) The easterly parcel of BLM lands affected by SRP events is the Rohn Air Navigation Site. For the past century, Rohn has been the site of the only habitable public shelter between Rainy Pass Lodge, 50 trail- miles to the east, and Nikolai 70 trail-miles to the north. The site consists of a 400-acre BLM parcel of upland forest at the confluence of the South Fork Kuskokwim River and the Tatina River. Built facilities include a 1,200-foot unmaintained gravel airstrip, the main Iditarod Trail and other connecting trails, and the historic Rohn Public Shelter Cabin. The public shelter cabin is the oldest historically intact structure open for public use and managed by the BLM on the entire Trail. The 400-acre site also houses a set of real time, Internet-broadcast weather monitoring cameras, installed and maintained by the Federal Aviation Administration (FAA).

The first roadhouse was established at Rohn in 1910. It was used throughout the Iditarod gold rush until it burned down in 1924. Subsequently, a new cabin was built and it survived until it was washed away by the Tatina River in 1984. In the late 1930s, the site was “withdrawn” for public use by the Department of Interior for the development of an emergency airstrip and shelter cabin by the Civil Aeronautical Administration. At that time, the Civilian Conservation Corps (CCC) built what is today known as the Rohn Public Shelter Cabin.

The Rohn Public Shelter Cabin is one of the most well known cabins, and sites on the Iditarod Trail, having been used for over 40 years as the first checkpoint north of the Alaska Range for competitors in the Iditarod Trail Sled Dog Race. The shelter cabin and airstrip are also used as a checkpoint on the Iron Dog snowmobile Race, muscle-powered races such as the Iditarod Invitational Ultramarathon, and frequently as a base camp in late summer for sheep hunters. Most use of the cabin and site is for SRP- authorized events, with only a fraction of use by recreationists as casual use.

Due to the historic significance of Rohn, the site is eligible for, and per BLM policy, managed as if it were listed on the National Register of Historic Places, in order to protect its historic values.

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Farewell Burn segment (Map 1, Appendix C) The Farewell Burn segment, located approximately 30 miles north of Rohn, traverses a nearly straight 20-mile alignment laid out by Alaska Road Commission surveyors in 1911. The Farewell Burn segment, along with adjoining segments outside of BLM lands, is uninhabited. The nearest community is Nikolai, located approximately 10 trail-miles from the north boundary of this segment. The nearest community to the south is Knik, Alaska, and is approximately 200 trail-miles distant.

The Trail generally parallels the South Fork of the Kuskokwim River, and is located on a nearly level plain with frequent river, creek, bog, and lake crossings although they are hard to discern in winter due to snow coverage. A large wildland fire burned over much of this area in 1977, leading to its common name as the ‘Farewell Burn’.

Almost all of the area traversed by the trail has shallow soils and/or permafrost. Vegetation is made up of mosses, shrubs, wetland/bog plants, black spruce, and paper birch interspersed in a mosaic pattern in the area traversed by the trail. Much of the growth is relatively small, representing sub-Arctic regrowth since the 1977 wildfire in the area.

The Trail in the Farewell Burn is cleared of vegetation to an approximate width of 5 feet. Vegetation in the treadway is made up of low-growing shrubs that are mechanically pruned annually by the passage of winter traffic on the trail. The summer trail surface is otherwise undisturbed, grows vegetation between knee- and waist-height, and does not show any signs of the passage of summer OHVs such as rutting and erosion. In the winter, most of the vegetation disappears under the snow-packed trail treadway. Winter precipitation levels and the amount of snow found on the ground typically increases from the south to the north.

In the early 1990s, BLM built a new public shelter cabin near the east end of this segment, Bear Creek Public Shelter Cabin and installed a steel trail bridge over the year-round ice-free crossing at the Sullivan River. Between 2012 and 2014, BLM collaborated with local communities to install way- marking safety signs on this segment of trail that indicate the distances to the nearest shelter.

BLM also manages two very short segments of trail that total less than 2.5-miles, approximately 5 miles east of Takotna. This section is part of the main overland winter trail between Takotna and McGrath 18 miles to the east, and experiences frequent casual use for inter-village travel.

Iditarod town site to Anvik (Map 2, Appendix C) BLM manages 13 miles of the largely uninhabited 65 mile Iditarod Trail between the abandoned town site of Iditarod and the Yukon River community of Anvik. Use of the segment is very light, except on odd-numbered years, when SRP-permitted sled dog race and human powered marathons use this segment.

East of Shageluk the trail traverses snow-covered drainages and low, forested hills. West of Shageluk the trail traverses the flat Innoko Bottoms, which is a large wetlands complex that comprises all of the

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lands between the Innoko River and the Yukon River. The entire segment typically receives and holds a deep snowpack until mid-April.

In 1987, the Secretary of the Interior added the Anvik-Shageluk-Iditarod segment to the Iditarod NHT System, as it was used historically to drive reindeer herds from the Yukon River area to feed gold miners overwintering in Iditarod.

In 2009, BLM collaborated with a variety of local and State stakeholders and built a new shelter cabin on State lands approximately 10-miles east of BLM-managed lands, at the trail crossing of the Big Yetna River. Between 2012 and 2014, BLM partnered with local communities to install trail way- marking safety signage indicating the distances to the nearest shelter.

Kaltag to Unalakleet (Map 3, Appendix C) All SRP authorized events on the Trail use the 35-miles of BLM lands that lie between Kaltag and Unalakleet although those that include shorter events as part of their permit see only a quarter or less of total participants on this segment. The segment is sometimes known as the Kaltag Portage, as it provides the shortest overland route between the Bering Sea and the Yukon River.

Trail use on the Kaltag Portage segment is split between local and regional use for transportation, subsistence, trapping, and casual recreation and trail-based SRP authorized events. Among regional resident trail users, the BLM public shelter cabins are very heavily used, with three quarters of all reported trail users for this segment visiting one or more cabin (Fix, Peter J. 2011).

The physiographic province crossed by the Kaltag Portage segment is the Nulato Hills. Moderately steep, rounded mountains form a broad, U-shaped valley through which the route passes. Winter precipitation decreases from east to west, with the most snow falling between Tripod Flat and Old Woman Creek. Soils are shallow throughout the area, and in many cases underlain by permafrost. Due to the flat topography, the area is poorly drained and is often characterized as wetlands.

Between Tripod Flat, on the eastern edge of this segment, to Old Woman Creek the route is forested by black spruce and some tamarack, along with occasional bog and tussock-tundra grasses and sedges. Much of this segment of the trail was burnt over in the 2015 Old Woman Fire, which as a low- to medium-intensity fire appears to have killed most of the black spruce within the fire perimeter, but did not significantly affect the ground cover.

The trail between Tripod Flat and Old Woman is cleared of vegetation to an approximate width of 7- feet. Vegetation in the treadway is made up of low-growing shrubs and sedges that are “pruned” annually by the passage of winter traffic on the trail. The summer trail surface is otherwise undisturbed, growing between ankle and knee-height, and does not show any signs of the passage of summer OHVs such as rutting and erosion. In the winter, most of the vegetation disappears into the snow-packed trail treadway.

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From Old Woman Creek to the Chiroskey River (the west end of BLM’s Kaltag Portage segment), the width of the Unalakleet River valley increases significantly. The trail crosses broad, flat tundra and bogs of low-growing shrubs and tussocks, and intermittently makes perpendicular crossings of taller vegetation such as black and white spruce, tamarack, and willow along bands of riparian areas.

The distance between these riparian crossings and the intervening tundra is usually between 2 and 5 miles. The entire area is significantly affected by wind, with the snowpack typically transported and redeposited by the frequent winds in the area.

Where the trail crosses the tussock tundra west of Old Woman, repeated use of the trail has resulted in alteration of the vegetation within the treadway. Repeated snowmobile passage on a single alignment has resulted in a slight linear depression or rut along the trail, which is typically ‘in-filled’ by wind transported snow. Although providing some protection to underlying vegetation, the resulting snowpack, and altered thermal and moisture regimes are accompanied by changes in vegetation. Monitoring of a photo site by BLM on the trail near the Chiroskey River between 2007 and 2017 shows no changes in vegetation due to trail use (see Figure 3.3.3.4 and 3.3.3.5).

The summer trail alignment is otherwise undisturbed and does not show any signs of the passage of summer OHVs such as vegetation shearing, surface rutting, ground disturbance, or erosion, with vegetation growing between ankle and knee-height. The effects of trail use through the riparian vegetation in the western half of this segment are similar to the effects described for the eastern half.

Unalakleet to Nome This 220-mile section of the Trail contains approximately 10 miles of BLM managed Trail in four locations, with all segments less than 3 miles in length except for one. The Trail traverses sparsely vegetated, low, broad rolling hills surrounding Norton Sound. No trees grow west of Elim, with all vegetation comprised of either low-growing tundra vegetation, or clumps of short willows. Given the high-latitude location, topography, and lack of vegetation, this section experiences frequent high winds, which result in hard-packed snow surfaces throughout the area for much of the winter.

Analysis Methodology and Baseline Trail Use and Visits Estimates Due to logistical and technological constraints, BLM did not attempt electronic trail monitoring between 2008 and 2017. Therefore, this analysis estimates existing trail use and visits to BLM lands by both the casual user and SRP authorized users.

Two measurements are used in this environmental assessment: 1. a “trail-pass” and 2: a “visit to BLM lands” one “trail pass” represents the passage by one trail user over a point on the Trail. Estimates of the number of trail passes will be used to identify potential effects to the linear Trail and features in the immediate trail corridor.

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A “visit” is equal to any use of BLM-managed lands by one person in a 12-hour period. Estimates of the number of visits will be used to identify potential effects to sites along Trail, particularly BLM public shelter cabins.

Casual Trail Use and Visits Baseline Estimates The majority of casual use on BLM-managed segments of the Trail is by snowmobile (Fix, Peter J. 2011). BLM observations and survey research into trail use patterns indicate that casual use that occurs on one section of BLM-managed Trail does not typically extend into the other sections of BLM- managed Trail (Fix, Peter J. 2011), (By comparison, SRP-generated use uses all segments of BLM- managed Trail.)

Casual Trail use does not follow the east to west use patterns typical of Iditarod Trail-based SRP events. Casual use is typically between two communities, or “out-and-back” from the point of origin, unlike the one-way flow of SRP-authorized users.

Given that casual visits to BLM lands are fairly short in duration because of the speed of snowmobile travel by the majority of users, this analysis assumes that for casual users only, one trail pass is equivalent to one visit to BLM lands. (In contrast, estimates of visits for SRP-authorized use are based on typical event-use patterns observed by BLM, as detailed in Appendix B for all events.)

Table 3.1 Casual Trail Use Passes & Visits Per BLM Segment, Per Year (estimate) Site/Segment Casual Use Trail “Passes” & Visits Per Year Rohn 100 Farewell Burn 240 Iditarod-Anvik 1,200 Kaltag-Unalakleet 2,250 Unalakleet to Nome 4,500

Casual trail use by the public during the previous 10 years appears to be relatively steady. Therefore, this analysis assumes that casual trail use will remain relatively constant between 2018 and 2028. The total annual number of casual trail passes for all segments, per year, for the next ten years, is estimated at 8650.

2008 SRP Authorized Trail Use and Visits Baseline Estimates The 2008 authorization for Iditarod Trail-based events forms the basis for the projection of expected use and visits for the three alternatives considered in this EA. BLM estimates that the 2008 authorization for SRP permits for Iditarod Trail-based events generates approximately 382 event participant “passes” on the trail. (see Table 3.2) This 382 event participant “passes” include the 275 authorized event participants and support staff.

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Table 3.2 Estimated SRP User Trail ‘Passes’, Based on 2008 Authorization Alternative 2 # of Passes on Assumptions Authorized Event Iditarod Trail (Willow to Nome) Sled Dog Race 1 112 Based on 100 entrants and 12 trailbreakers / sweeps Snowmobile Race 1 220 Based on 100 pro class entrants who travel BLM trail to and from Nome and then to the finish at Fairbanks, and rec class who traverse BLM lands to a finish at Nome Human Powered 50 Up to and including McGrath; north of McGrath, Marathon 1 number of participants north of McGrath is assumed to be 15 Total SRP User 382 This includes support staff for each event. “Passes” On Trail

The 2008 SRP authorized 275 event participants. BLM estimates that these 275 participants generate approximately 1,803 visits to BLM lands over the course of their events.

Table 3.3 Estimated SRP Visits, based on 2008 Authorization Event Type 2008 Authorized 2008 Estimated Visits per Participants Annum Sled Dog Race 1 100 1,008 Snowmobile Race 1 120 704 Human-powered Marathon 1 50 191 Total 275 1,803

Baseline Trail Passes Analysis: Casual and SRP Use At 2008 levels, SRP-use makes up a fraction of the total use for trail segments that are popular transportation corridors (e.g., for Nome to Unalakleet, SRP passes make up 7 percent of passes). For segments of Trail not used as inter-village transportation corridors, SRP use comprises the majority of use (e.g., for the Farewell Burn).

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Table 3.4 SRP Passes Percentage of Total Passes, Per Segment, Based on 2008 Authorization Site/Segment Casual User Estimated SRP Total SRP Trail Passes Trail Passes Estimated Percentage Passes Rohn Airstrip 100 382 482 79 Farewell Burn 240 382 622 61 Iditarod-Anvik 1,200 127 1,327 10 Kaltag Portage 2,250 347 2,597 13 Unalakleet to Nome 4,500 347 4,487 7

Baseline Visits Analysis BLM estimates that of the approximately 10,000 visits made to BLM lands associated with the Iditarod Trail, almost 18 percent are visits associated with the SRP events permitted in 2008.

Table 3.5 Baseline Estimated Visits to BLM Lands Associated with the Iditarod Trail, Casual Visits and SRP-Visits, Based on 2008 SRP Authorization Event Type Estimated SRP- Estimated Casual Total Visits Visits Visits to BLM Sled Dog Race 1 1,008 0 1,008 Snowmobile Race 1 704 0 704 Human-powered Marathon 1 191 0 191 Overall Total 1,803 8,290 10,093

3.1.2 Direct and Indirect Effects from Alternative 1 For the No Action Alternative, given that SRP events would be permitted on an individual, case-by-case basis, it is expected that there could be a decrease in the number of events from Alternative 2. Corresponding decreases in SRP-generated trail passes and visits are anticipated, with the greatest decreases in trail passes and visits on remote segments not used as inter-village transportation corridors (Rohn, Farewell Burn, and east of Shageluk). The total percentage of trail passes could decrease between 7 percent and 79 percent depending on which segment of trail considered (see Table 3.4). Total visits to the Trail could decrease by up to 18 percent, if no events occurred (see Table 3.5)

Decreased trail passes and visits were observed with the cancellation of the Iditarod Trail Sled Dog Race southern route in 2015. A 2016 BLM visit to a State of Alaska winter safety cabin on the southern race route near the ghost town of Iditarod determined that no one had traveled the 150 mile trail segment between Ophir and Shageluk from 2013 to 2016. The last year the southern race route was used was 2013.

The effect of the No Action Alternative would be that the remote sections of trail might become overgrown and/or blocked by trailside vegetation that would otherwise be “pruned” by the passage of snowmobiles. Corresponding use of BLM facilities, primarily public shelter cabins on segments outside Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 22

of popular inter-village transportation routes would decrease, primarily for the Rohn and Bear Creek Public Shelter Cabins.

While the No Action Alternative may result in a decrease in the number of SRP-authorized events and associated users, the levels of SRP-use of the Trail is a small fraction of the total overall use, and does not contribute significant negative visual effects to the trail and its setting. The current type of trail use, including physical limits on the size of snowmobiles and other over-snow vehicles, maintains a trail width and use pattern that is consistent with the intention of the National Historic Trail designation for the Iditarod Trail.

3.1.3 Direct and Indirect Effects from Alternative 2

Alternative 2 would be a continuation of the 2008 level of permitted SRP participants. SRP passes on the Trail, and number of visits, are anticipated to be the same as identified in Tables 3.4 and 3.5. SRP- generated trail passes would continue to be the highest proportion of passes on remote sections of BLM- managed Trail, while inter-village transportation would make up the majority of trail passes on northern sections of the Trail.

Long-term monitoring by BLM of selected points on Farewell Burn and Kaltag Portage segments of the Trail show no significant long-term effect from the passage of over-snow traffic, including foot, dogsled, bicycle, or snowmobile use. Compaction of snow on the trail treadway provides seasonal armoring to the underlying vegetation although protruding vegetation is removed by the passage of users. Figures 3.1.3.4 and 3.1.3.5 show the effects of 11 seasons of winter use on the Kaltag Portage segment of the Trail. BLM estimates that from 2007 to 2017, approximately 25,000 snowmobiles passed this photo-monitoring location east of the Chiroskey River, between Unalakleet and Kaltag.

There does appears to be some alteration to the variety of ground-covering vegetation under the trail treadway, likely due to the decrease of the insulation value of compacted snow, and resulting delayed thawing of vegetation and the underlying ground as shown in Figures 3.1.3.1 and 3.3.3.5.

No vegetation stripping from the ground surface, damage to roots, or widespread exposure of underlying soil has been observed on BLM segments of the trail in the past decade during repeated winter and summer visits. Therefore no significant effects are anticipated to the trail from implementation of Alternative 2.

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Figure 3.1.3.1 Compacted snow on the Farewell Burn trail treadway at the intersection of the main trail and the southern spur trail to the BLM Bear Creek Public Shelter Cabin, 2008. (BLM photo)

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Figure 3.1.3.2 View south on Farewell Burn section of the Iditarod Trail at the north intersection of the Bear Creek Shelter Cabin, 2013. This photo was taken one mile north of the previous photo. (BLM photo)

Figure 3.1.3.3 View west of the Iditarod Trail, approximately 7 miles west of the Old Woman Cabin, on a low snow year, 2016 (BLM photo, 2016)

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Figure 3.1.3.4 2007, Iditarod Trail photo monitoring site between Kaltag and Unalakleet, 1 mile east of Chiroskey River. View west. (BLM photo, 2007)

Figure 3.1.3.5. 2017, Iditarod Trail photo monitoring site Kaltag and Unalakleet, 1 mile east of Chiroskey River. View west. (BLM photo, 2017)

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While Alternative 2 would maintain the number of SRP-authorized events and associated users, the levels of SRP authorized use of the Trail is a small fraction of the total overall use of the trail and does not contribute significant negative physical or visual effects to the trail and its setting. The current type of trail use, including physical limits on the size of snowmobiles and other over-snow vehicles, maintains a trail width and use pattern that is consistent with the intention of National Historic Trail designation.

As visits to BLM lands are anticipated to be similar to those estimated for 2008 SRP authorization (Table 3.5) facility wear-and-tear is anticipated to continue at the rate observed in the previous ten- years. Proposed facility improvements such as an additional outhouse at Rohn, and the relocation of outhouses at other cabins are small in scale and are not anticipated to have significant negative effects on the resource.

3.1.4 Direct and Indirect Effects from Alternative 3 Under Alternative 3, the Preferred Alternative, additional events authorized would include one additional long-distance motorized event, two human-powered events, and up to 90 persons in supported guided overland tours, as compared to Alternative 2. The total number of event participants could increase from the current level of 275 to 655, representing a 138% increase.

Table 3.6 Number of SRP authorized participants, per alternative Event Type Alternative 1 Alternative 2 Alternative 3 (Proposed Action)

Sled Dog Race 1 0 100 100

Snowmobile Race 1 0 125 120

Snowmobile / Snow Bike Race 2 0 0 120

Human-powered Marathon 1 0 50 75

Human-powered Marathon 2 0 0 75

Human-powered Marathon 3 0 0 75

Guided Winter Overland Tours 0 90 (Dogsled, snowmobile, etc.)

Total 0 275 655 Overland Tours includes support staff

Alternative 3 Trail Passes Analysis Under the Preferred Alternative, the proportion of SRP-authorized trail passes could increase from 4.4 percent of all trail use (Alternative 2: 382 SRP passes out of 8,672 total trail passes) to 8.0 percent of all Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 27

trail use (Alternative 3: 730 SRP passes out of 9,020 total trail passes). Total trail use could increase up to 4 percent if the entire Preferred Alternative was implemented (see Table 3.7 following immediately).

Table 3.7 Projected Per Segment and Total Causal Trail Passes and SRP Passes, Alternative 2 and Alternative 3 (Preferred Alternative) Alternative 2 Alternative 3 SRP Authorizations SRP Authorizations Total Passes Segment Casual Use SRP % of SRP % of Passes Passes total Passes total Alt 2 Alt 3 passes passes Rohn Airstrip 100 382 79 565 85 482 665 Farewell Burn 600 382 61 565 70 622 805 Iditarod-Anvik 1,200 127 10 160 12 1,327 1,360 Kaltag-Unalakleet 2,250 347 13 730 24 2,597 2,980 Unalakleet - Nome 4,500 347 7.1 640 12 4,487 5,140

As a percentage of total trail use in these respective segments, SRP passes could increase slightly at Rohn from 79 percent to 85 percent of total use. The Farewell Burn segment could see an increase from 61 percent to 70 percent

Use on the Iditarod-Anvik segment may increase slightly with the Preferred Alternative by 2 percent in to the total number of trail passes. The small change is because the projected snowmobile races are assumed to only use the north route of the contemporary Trail, and the Iditarod-Anvik segment is on the south route. Also most human-powered marathon event entrants complete their event in McGrath, and do not travel onto this segment.

Under the Preferred Alternative, trail passes for the Kaltag-Unalakleet segment could increase 11 percent, and trail passes for the Unalakleet-Nome section could increase 5 percent.

Based on observations of the effects of trail passes on the trail between 2007 and 2017, including monitoring a site with an estimated 25,000 snowmobile passes with minimal physical effect, it is not anticipated that there will be substantial additional physical effects on the trail due to the implementation of the Preferred Alternative.

While Alternative 3 would increase the number of SRP-authorized events and associated users, the number of passes by SRP users are a small fraction of the total overall use of the Trail, and do not contribute significant negative visual effects to the trail and its setting. The current type of trail use, including physical limits on the size of snowmobiles and other over-snow vehicles, maintains a trail width and use pattern that is consistent with the intention of National Historic Trail designation.

Alternative 3 Visitation Up to 3,414 visits could be made to BLM-managed lands based on the Proposed Action, if all events were totally filled (see Table 3.8, which summarizes the estimated number of SRP visits from the

Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 28 proposed action, per event; detailed estimates for each event, are found in Appendix B.) Overall, an additional 1,600 SRP visits could be made to BLM lands, compared to Alternative 2. Table 3.8 Total maximum number of visits to BLM lands each year for all events Event Type Number of visits Sled Dog Race 1 908

Snowmobile Race 1 704

Snowmobile/Snowbike Race 2 704

Human-powered Marathon 1 246

Human-powered Marathon 2 246

Human-powered Marathon 3 246

Guided Overland Tours 360

TOTAL 3,414

Under the Preferred Alternative, SRP-authorized visits to the Iditarod Trail on BLM lands could increase the total visits to the Trail by 16 percent. The proportion of SRP visits to casual use visits for Alternative 2 would be 18 percent, while for Alternative 3 could be 29 percent, representing a potential 11 percent increase in the proportion of SRP users to casual users.

Table 3.9 Comparison of SRP visits, casual visits, and total visits, Alternative 2 and Alternative 3 (Proposed Action) Alt. 2 Estimated Alt. 2 Alt. 3 Estimated Alt. 3 Estimated Casual Visits Total Visits Estimated Casual Visits Total Visits SRP-Visits SRP-Visits 1,803 8,290 10,093 3,414 8,290 11,704

Effects to associated facilities from increased visitation, particularly BLM public shelter cabins, may include increased human use of pit privies. The Preferred Alternative includes the development of new and/or additional capacity of pit privies at BLM public shelter cabins, thereby preventing potential issues associated with inappropriate human waste disposal. BLM also has the authority to require SRP permittees to haul out all human waste generated from an event.

The Proposed Action could increase firewood use, and result in additional tree cutting in areas around the BLM public shelter cabins. In general, BLM prohibits live tree cutting for all cabin users. On a case-by-case basis for SRP permittees, stipulates the provision of firewood from off-BLM locations, and/or encourages the use of non-firewood stoves for heating. These actions are expected to minimize potential significant effects from firewood gathering. At Rohn, increased use of the site might result in

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the creation of additional fire pits. Potential increases in the number of fire pits can be prevented by permit stipulations requiring use of developed fire pits.

Facility wear-and-tear, and the associated cabin maintenance (that is a baseline activity), along with proposed improvements (additional outhouses at Rohn, relocation of outhouses at other cabins) are small in scale and not anticipated to have significant negative effects on the environment.

Discussion of effects on user experience and potential user conflicts can be found in Section 3.4.

3.1.5 Cumulative Effects The same cumulative effects would be anticipated in alternative 3 as described in alternative 2, but would be proportionately greater for alternative 3.

3.1.6 Recommended Mitigation No adverse residual effects are anticipated from the Preferred Alternative to the trail and associated facilities, therefore no mitigation is recommended.

3.2 Vegetation and Soil Issue: What impacts could trail-based activities by SRP-authorized users have on vegetation and soil?

3.2.1 Affected Environment Trail Segments: BLM segments of the Trail occur in five boreal ecoregions: the Tanana-Kuskokwim Lowlands, Kuskokwim Mountain, Yukon River Lowlands, Nulato Hills, and Seward Peninsula (see Appendix C for trail segment maps). Vegetation is generally comprised of white spruce (Picea glauca) and paper birch (Betula neoalaskana) woodlands, black spruce (Picea marianan) lowlands, tall and low scrub, dwarf shrub tundra, and tussock tundra interspersed in a mosaic pattern. Almost all of the areas traversed by the Trail have shallow soils that are underlain with permafrost and are usually characterized as wetland.

The trail segment in the Farewell Burn is cleared of vegetation to an approximate width of 5-feet. Vegetation in the treadway is made up of low-growing shrubs that are “mechanically pruned” annually by the passage of winter traffic on the trail. The summer trail surface is otherwise undisturbed, grows vegetation between knee- and waist-height, and does not show any signs of the passage of summer OHVs such as rutting and erosion. In the winter, most of the vegetation disappears under the snow- packed trail treadway.

The trail between Tripod Flat and Old Woman is cleared of vegetation to an approximate width of seven 7-feet. Between Tripod Flat on the eastern edge of this segment to Old Woman Creek, the route is mostly forested by black spruce and some tamarack, along with occasional bog and tussock-tundra grasses and sedges. Much of this segment of the trail was burnt over in the 2015 Old Woman Fire, which was a low to medium-intensity fire. It appears that the fire killed most of the black spruce within the fire perimeter, but did not significantly affect the ground cover.

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The trail segment between Old Woman Creek to the Chiroskey River on the west end of BLM’s Kaltag Portage segment crosses broad, flat tundra and bogs of low-growing shrubs and tussocks, and intermittently makes perpendicular crossings of taller vegetation such as black and white spruce, tamarack, and willow along bands of riparian areas.

BLM Public Shelter Cabins Five public shelter cabins are located on BLM segments of the trail. Most of the shelter cabins are surrounded by a zone cleared of vegetation to provide a defensible space in the event of a wildfire. These areas are now dominated by early successional species: tall and short shrubs and graminoids that are routinely trimmed. Rohn cabin is surrounded by short boreal ground cover species and limbed mature white spruce trees to allow an open area for sled dog mushers to rest dog teams.

A non-native invasive plant survey of the entire Iditarod National Historic Trail was conducted in 2009 (Flagstad and Cortés-Burns 2010) by the University of Alaska Natural Heritage Program. Seventeen non-native invasive plant species were found to be established at BLM public shelter cabins, mainly at the Rohn Air Navigation Site. The non-native invasives are suspected to have been introduced via historical use (travel between villages, mining towns, roadhouses) and more recently via aircraft, machinery, and the bedding straw used by mushers (Flagstad and Cortés-Burns 2010).

In 2009, fifteen invasive plant species were found at Rohn, two were found at Bear Creek cabin, and one was found at Old Woman Public Shelter Cabin. None were found at the Tripod Flats Public Shelter Cabin. The Foothills Public Shelter Cabin was built after this survey took place, therefore there is no information on this site. Invasive species occurrences are closely tied to disturbed ground, high visitor traffic, and storage of straw.

The Rohn checkpoint was the most infested remote site surveyed along the trail. Since 2009, BLM has engaged the Alaska Natural Heritage Program to visit the site annually and manually treat and monitor the status of infestations. By 2016, treatment has been successful in eradicating nine of the species originally found at Rohn. Only six non-native species persist. However, only two of these species (Bromus inermis ssp. inermis and Hordeum jubatum) are ranked moderately invasive (ranked 62 and 63 out of 100) by the University of Alaska’s Nature Heritage Program’s Invasiveness Ranking System. The other four species (Chenopodium album, Crepis tectorum, Galeopsis tetrahit, and Matricaria discoidea) are ranked modestly, weakly, or very weakly invasive (scores lower than 59).

Sensitive Plant Species BLM Sensitive Plant Species have not been found in close proximity to BLM segments of the trail or BLM public shelter cabins.

3.2.2 Direct and Indirect Effects from Alternative 1 - No Action Alternative Given that SRP events would be permitted on an individual basis, decreases in SRP-generated trail use are anticipated, with the greatest decreases in trail use on segments outside of popular inter-village transportation corridors (Rohn, Farewell Burn, east of Shageluk). Therefore, it is expected that the

Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 31 potential for non-native invasive species to be introduced and spread in these areas of the trail would decrease.

Rohn checkpoint would likely experience less traffic, which would result in decreased potential for new species to be introduced (from planes, boots and other gear, etc.). Additionally, the introduction of non- native invasive plants harbored in straw being used as dog bedding during sled dog races would cease if sled dog racing SRP’s were not authorized.

Existing non-native invasive populations would continue to be treated in a similar fashion as the past eight years. The defensible space around each cabin would also continue to be maintained as it has been in the past.

Since BLM segments of the trail could experience less use due to potentially decreased SRP activity, native vegetation could increase along the trail corridor. However, this will neither positively nor negatively affect the populations of native vegetation in the area since all species affected are widespread, abundant, and have stable populations.

3.2.3 Direct and Indirect Effects from Alternative 2 Alternative 2 would be a continuation of the 2008 level of permitted SRP participants. Therefore, the potential for non-native invasive introduction and spread would continue at the same level observed on BLM trail segments and public shelter cabins since 2008. Existing non-native invasive populations would continue to be treated in a similar fashion as the past eight years. The defensible space around each cabin would also continue to be maintained as it has been in the past.

Excavation of privy holes and sonotubes will result in disturbed soil and piles of soil that will be susceptible to colonization by non-native invasive species. Any areas of disturbed soils resulting from these activities will be promptly seeded with an appropriate mix of native seed. If native grass or forbs are immediately established, there is a low risk for aggressive non-native invasive infestations.

BLM segments of the trail will experience a similar level of traffic due to the same SRP activity which will continue to keep vegetation short along the trail corridor. This alternative also includes trail maintenance activities and trail reroutes where necessary that could result in native vegetation removal. However, this amount of vegetation removal will not directly or indirectly affect the populations of native vegetation in the area since all species affected are widespread, abundant, and have stable populations.

3.2.4 Direct and Indirect Effects from Alternative 3 (Preferred Alternative) Under the Alternative 3, total SRP-related visitation days could increase. Therefore, this alternative has a slight potential to increase the spread of invasive species into adjacent uninfected areas with disturbed ground along the trail system and intact ecosystems, primarily due to the increase in individuals transporting gear and clothing that may hold seeds or other propagules. The potential for straw generated infestations can be prevented by permit stipulations that require the use of weed-free straw, and/or the removal of all straw from BLM lands after use.

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The risk of spreading invasive species that are ranked highly invasive are low if best management practices are implemented (which is a requirement of all permit stipulations proposed) and therefore pose only limited direct or indirect effect on vegetation over trail segments or public shelter cabins. However, more effort may be required from the BLM to respond to the possible introduction of new species and spread of existing infestation.

Excavation of privy holes and sonotubes will result in disturbed soil and piles of soil that will be susceptible to colonization by non-native invasive species. Any areas of disturbed soils resulting from these activities will be promptly seeded with an appropriate mix of native seed. If native grass or forbs are immediately established, there is a low risk for aggressive non-native invasive infestations.

BLM segments of the trail will experience an increased level of traffic due to the increase in SRP activity which will continue to keep vegetation short along the trail corridor, but would not likely increase native vegetation damage along the BLM trail segments. This alternative also includes additional trail maintenance activities and trail reroutes where necessary that will result in native vegetation removal. However, this amount of vegetation removal will not directly or indirectly affect the populations of native vegetation in the area since all species affected are widespread, abundant, and have stable populations.

The proposed activities would not require any change in managing the defensible space around each cabin.

3.2.5 Cumulative Effects There are no other current or proposed activities along BLM segments of the trail or BLM shelter cabins, therefore there are in cumulative effects to vegetation or increased risk of invasive plant infestations. The proposed Donlin Gold Mine plans to construct a natural gas pipeline that will intersect the Trail on segments of the Trail crossing State of Alaska managed land approximately 20 miles south of BLM’s Farewell Burn segment. The pipeline construction requires extensive movement of soil, and the use of large equipment. There is a possible risk to BLM segments of the trail and BLM public shelter cabins from non-native invasive species introduction due to their proximity to the pipeline crossings. However, an Invasive Plant Management Plan will be developed for this project, which will significantly decrease the potential for introduction and spread.

3.2.6 Recommended Mitigation To avoid direct effects to surrounding intact vegetation, Best Management Practices (BMP’s) to prevent the spread of invasive species would be implemented. These BMP’s are listed in the permit stipulations and focus on reducing the risk of introduction by keeping gear and equipment clean and using weed-free straw products to avoid spreading seeds and plant propagules.

3.2.7 Residual Impacts If BMPs are adopted, there should be no residual impacts on vegetation resources on BLM segments of the trail or surrounding BLM shelter cabins.

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3.3 Cultural Resources Issue: Will the Preferred Alternative have a significant effect on cultural resources?

3.3.1 Affected Environment Prehistoric Overview1 Centuries before the Iditarod Trail System was designated by the Alaska Road Commission (ARC) as an official winter transportation corridor in the late 18th century, Alaska Native groups utilized segments of the trail network for hunting, fishing, trade, and inter-village travel. The trails served as the main thoroughfare between the coastal communities of the Inupiaq and Yupik peoples (often referred to as “Eskimos”) and the interior villages of the Athabaskan speaking Tanaina and Ingalik Indians. They facilitated the exchange of not only goods, but also language, ideas, and cultural traits. A key feature of Native use of the trails was the development of special modes of travel for traversing the backcountry during Alaska’s cold, snowy winters. A popular means of winter transportation were long, narrow snowshoes with pointed or rounded toes. These were used for travelling in deep snow and carrying heavy loads. When transporting a particularly large or unwieldy loads, another popular method of conveyance, the dogsled, was used to pull goods.

It is estimated that Alaska Native populations began using dog sleds between 500 and 1,000 years ago. They appear to have borrowed the practice from Siberian Native groups located just across the Bering Sea. Traditionally, natives harnessed only one or two dogs to their sleds. Because dogs require a lot of food, it was inefficient to collect and store enough food to support more animals over the winter months. Archaeological evidence from the western coast of Alaska indicates that early sleds were typically locally made from birch and tied together with moose hide; however, other materials, including driftwood, walrus tusk, caribou antlers, and whale bone are said to have been used. Because of the smaller size and lighter weight of the traditional sleds, a person wearing snowshoes would walk out in advance of the dogsled to break a path. This process was slow but essential to traversing the arctic wilderness.

Historic Overview The ARC’s initial goal was to create a series of trails and roads that would provide access between the coastal ports in southcentral Alaska and the goldfields at Nome and Fairbanks. In addition to expediting overland travel and freight transport in the Alaskan wilderness, this network was intended to enable expedient, year-round mail service throughout the territory. Much of the ARC’s early work was concentrated in the region between the coastal port of Valdez and the city of Fairbanks to the north. This work was aimed at improving and updating existing routes, such as the Trans-Alaska Military Road (a trail blazed by the Army in 1899 between Valdez and Eagle), rather than the construction of new roads. In contrast, most of the work around the Nome area was dedicated to the construction of new roads and trails. According to the 1907 annual ARC report, by the end of the year, the Nome area had

1Excerpt from “Determinations of Eligibility for Cultural Resources Associated with the Iditarod National Historic Trail (INHT): Farewell Burn Segment (MCG-0124), Kaltag Portage Segment (UKT- 0044, NOB-0057, NUL-0065), Ten-mile Cabin Site (NOB-0033)” (Cecil / BLM, 2017). Reference this report for citations and information on primary sources.

Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 34 about 108 miles of wagon roads and 69 miles of staked trails between Nome and Unalakleet on the eastern edge of Norton Sound. These routes significantly reduced travel times throughout the region and alleviated many of the hardships faced by miners and entrepreneurs as they carried their equipment from settlement to settlement. However, despite such improvements, one major gap remained in Alaska’s transportation networks: a direct route between the Cook Inlet area and the mining areas around Nome.

In late 1907, Major Richardson called upon Walter L. Goodwin, then Superintendent of the ARC’s Nome District, to lead a reconnaissance party from Seward to Nome in order to assess the feasibility of a cross-territory trail. Goodwin, along with three other men and a team of dogs, set out from Seward in January 1908. In total, the journey covered approximately 875 miles. It took the crews 115 days to complete; however, this figure also included the time that the crews took to survey, mark the path, and clear areas for future access. It was presumed that a dog team travelling along an already improved trail would be able cross the landscape in less time. In his report to the ARC, Goodwin concluded that an overland winter trail between Seward and Nome was feasible, but there was, as of 1908, no pressing economic impetus to construct it. Although new gold strikes had recently been discovered along the drainages of the Innoko River (1907), Goodwin and his crews counted only about 200 people living in the district. Without significant population growth, trail construction and maintenance would be cost prohibitive. Ironically, about one year after Goodwin handed over his findings to the ARC, word spread that large gold deposits had been uncovered along Otter Creek, right in the middle of the proposed Seward to Nome route.

Following roughly the same route that he and his crew had staked out two years earlier, Goodwin set off from Nome in November 1910 to lay out a proper trail between Seward, Nome, and the new goldfields at the Iditarod and Innoko. The crew cleared trail and marked the winter path with metal stakes and wooden tripods. The tripods were designed so that a musher could tell where the turns in the trail were by following at right angles to a lone tie at the top of the structure. In places with thick vegetation and tree-cover, ax men worked to remove enough trees so that an eight foot-wide corridor could be established. Occasionally, the trail had to be resurveyed and adjusted to accommodate changes in the landscape, or to incorporate other existing trails into the network. For example, in the area between Kaltag and Dishkaket (in the center of what is today the Innoko National Wildlife Refuge), another ARC crew led by a Mr. Giddings, had cleared a wide and usable path, marking it with wooden tripods along the way. Goodwin adopted this length of the route into the Iditarod Trail system.

While Goodwin and his men worked along the northern end of the trail, another crew of ARC employees led by Superintendent Anton Eide was completing work at the southern end of the trail near Seward. Beginning in the summer of 1910, Eide and his men had worked towards improving the trail route along the edge of the railroad to Kern Creek and then over open ground to Indian Creek pass in the Chugach Range and beyond to Susitna. As this was one of the most used sections of the trail, the ARC desired to eventually make it into a road fit for travel using horse teams; however, given the treacherous nature of the mountain crossing, the trail remained suitable only for dog teams during the winter months. Goodwin ultimately elected to cross the Chugach Range at Crow Creek Pass rather than at Indian Pass, resulting in additional trail construction and maintenance the following summer; however, the hard work completed by Giddings, and his men remained integral to the rapid construction of the Iditarod Trail. Throughout the Goodwin work trip, an engineer with the crew took accurate mileage readings using a cyclometer. Somewhat resembling a unicycle, the cyclometer was used to accurately measure distances Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 35 along the trail route. With this tool, Goodwin discovered that there were several portions of the previously surveyed trail that could be repositioned to cut down on both distance and time between points. According to the 1911 annual work report published by the ARC, despite adding numerous new routes to the trail system that crisscrossed through the Iditarod and Innoko goldfields, at the end of the project the entire trail system totaled 958 miles; only 82 miles longer than the initially surveyed route. The total expense to build the trail was $8,132.53. For administrative purposes, the ARC broke up the length of the trail into several trail segments (e.g. Route 20A, 20B, 20C, 20D). It is referred to in these terms in the ARC’s annual report series.

In anticipation of increased traffic along the route, entrepreneurs from around the state and around the world moved into the region to develop businesses and roadhouses. The roadhouses were placed at intervals of about 30 miles: the approximate distance of a day’s travel. They served as waypoints for mail carriers and others travelling along the trails to rest, eat, and wait out particularly rough weather.

Although any roadhouse was preferred to making a “Siwash camp” for the night – i.e. an overnight camp without tents or other supplies – some roadhouses were better than others. Records suggest that there were an estimated 21 roadhouses between Seward and Knik, 85 roadhouses established along the trail between Knik and Kaltag, and another 16 between Kaltag and Nome.

With the trail improvements and shelter infrastructure in place, the trail system was transformed into a kind of rural, winter highway. Thousands of people – including miners, trappers, mail carriers, and others interested in accessing remote mining communities – and thousands of pounds of goods and glimmering gold traversed the hard packed snow each winter. In 1914, the postal service issued the first contract for regular mail service over the trail to “Colonel” Harry Revelle.

Because of advocacy work by trail advocates and sled dog enthusiasts, in November 1978, Public Law 95-625 (National Parks and Recreation Act) amended the National Trails System Act. Adding a new category called “National Historic Trails” and added four new historic trails to the system: the Lewis and Clark Trail, the Oregon Trail, the Mormon Pioneer Trail, and the Iditarod Trail. The National Trails System Act set forth the goal of national historic trail designation, stating, “National historic trails shall have as their purpose the identification and protection of the historic route and its historic remnants and artifacts for public use and enjoyment.”

The Rohn Air Navigation Site The Civilian Conservation Corps built the current public shelter cabin at the Rohn Air Navigation Site in 1939. It is listed in the Alaska Heritage Resource Survey (AHRS) as MCG-0019 and is currently listed as eligible to the National Register of Historic Places (NRHP). The BLM Anchorage Field Office Archaeologist visited the Rohn site (MCG-0019) on September 20, 2017 and surveyed the areas proposed for a woodshed and new privy holes, and confirmed that there were no cultural resources on the ground in those locations.

Other BLM Public Shelter Cabins The Bear Creek, Tripod Flat, Old Woman, and Foothill Summit public shelter cabins were surveyed for cultural resources prior to their construction and no cultural resources are known in their immediate Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 36

vicinity, aside from the INHT itself. The Old Woman public shelter cabin is built next to Old Woman Mountain, the most visible landmark along the Kaltag Portage, and a site that would likely be found NRHP eligible as a Traditional Cultural Property if the research was conducted.

Trail Segments There are numerous cultural resources located along, and associated with, the Iditarod Trail. Due to the remote nature of the segments, and the difficulty of navigating the areas in the summer, a complete inventory of all the BLM Trail segments has not been completed. Known cultural resource types vary from isolated artifacts and ephemeral camps to the remains of historic roadhouses.

All segments of the Iditarod Trail have been identified, and documented in the Alaska Heritage Resources Survey (AHRS) as cultural resources. Determinations of Eligibility for the NRHP for the Farewell Burn (MCG-0124) and the Kaltag Portage (UKT-0044, NOB-0057, NUL-0065) are currently in progress and will be submitted to the State Historic Preservation Office (SHPO) for review and concurrence in late 2017.

3.3.2 Direct and Indirect Effects from Alternative 1: No Action Alternative Under the No Action Alternative, no activities would be permitted. If there are no permitted activities, there would be no potential to affect cultural resources. There may be indirect effects to cultural resources from this alternative; if no activities are permitted, there may be less reason to do trail brushing and other maintenance activities, and over time, this may affect the integrity of the trail segments.

3.3.3 Direct and Indirect Effects from Alternative 2 Alternative 2 would be a continuation of the 2008 level of permitted SRP participants. Under Alternative 2, current levels of permitted SRP events would continue. Because no ground disturbance is authorized under the current SRPs, and all events take place during the winter when the ground is frozen, Alternative 2 would have no adverse effect on historic properties. The Rohn cabin would continue to be monitored for structural deterioration. Ground disturbance is proposed at Rohn and four modern BLM shelter cabins; see description in Direct/Indirect Effects, Preferred Alternative (following) for detailed description of effects from these projects.

3.3.4 Direct and Indirect Effects from Alternative 3 Under the Preferred Alternative, use of BLM-owned segments of the Trail and the Rohn ANS would increase. Ground disturbance is proposed at Rohn and four modern BLM shelter cabins.

Rohn Air Navigation Site Several ground-disturbing projects are proposed at Rohn, and proposed authorized use would increase. The BLM Anchorage Field Office Archaeologist visited the Rohn site (MCG-0019) on September 20, 2017 and surveyed the areas proposed for a woodshed and new privy holes, and confirmed that there were no cultural resources on the ground in those locations. The privy structure itself will be moved to the new location. It is rustic in character, and will continue to have no visual impact on the Rohn cabin. The new woodshed will be a pole structure, rustic in nature, and will be located in the trees behind the Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 37 main cabin, to avoid having a visual impact on the cabin. There are no cultural resources located on the ground in the vicinity of where the interpretive kiosk is currently proposed. If it is placed where currently proposed, on the edge of the airstrip, it will not be visible from the cabin clearing. It will be a log structure to blend in with the surrounding area. If it is proposed in a location that is visible from the cabin, SHPO consultation will be initiated to ensure that it does not have an adverse effect on the historic property. Continued, and increasing, use of the cabin may have the potential to affect the integrity of the cabin itself over time. Periodic monitoring, as well as SHPO consultation on any future proposed cabin repairs, will ensure that the integrity of the cabin is not impacted.

Other BLM public shelter cabins The BLM complied with Section 106 of the NHPA when the shelter cabins were originally constructed, and they were built on locations with no cultural resources present. Excavations to move the privies will be small and will have no historic properties affected. Old Woman Mountain would not be impacted, directly or indirectly, by an increase in people passing by on the Trail, nor by excavating a privy replacement hole.

Trail Segments All proposed commercial recreation activities would occur during the winter months, when the ground is frozen and there is snow cover. While several segments of the Trail are located in areas with significant winds that tend to blow snow off the Trail and accumulate in drifts, this has not been shown to result in additional impacts to the ground or the trail segments’ integrity. Because the proposed activities will take place on frozen ground, they will have no adverse effect on historic properties.

3.3.5 Cumulative Impacts Rohn Air Navigation Site The Rohn Air Navigation Site will see the most concentrated use on BLM land, and will see an increase in use under the Preferred Alternative. However, this increase is transitory and occurs during the winter, and the type of use is the same as currently under the No Action Alternative. Therefore, it is not anticipated that there will be cumulative effects to resources at Rohn.

Other BLM public shelter cabins Because there are no cultural resources present at these sites, there will be no cumulative impacts to resources. Regarding Old Woman Mountain, overall use of the Trail is low, and an increase in people traveling over the Trail in winter will not impact the view shed from the mountain, nor will a new privy hole.

Trail Segments Because the activities being analyzed are dispersed over a large geographic area, and the proposed SRPs are taking place in the winter when the ground is frozen, there will be no cumulative effects from the race activities to the historic resources associated with the Iditarod Trail.

3.4 User Conflicts Issue: Will the issuance of user permits create additional conflicts between casual users and permittees?

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3.4.1 Affected Environment For this analysis, conflict is defined as goal interference for an individual, attributed to the behavior of another individual, group, or permitted event (Nicolucci, Watson, Williams 1994). This analysis forecasts whether and to what extent the activities associated with SRP-authorized events have the potential to conflict with casual public users of BLM segments of the Iditarod Trail. Note that potential trail conflict is not limited to casual trail users and SRP-authorized uses, but may also potentially occur between different types of users (motorized and non-motorized users, etc.), within user groups (touring snowmobiles vs. racing snowmobiles) and between participants and/or sponsors of SRP authorized events.

Conflict can occur between users on a direct, face-to-face basis, or as a result of indirect, residual effects of one type of use on another type of use. Conflict may occur along the Trail, or at sites managed by BLM, such as public shelter cabins.

The Trail and BLM public shelter facilities are managed as shared-use, multiple use facilities that allow both winter motorized and non-motorized users. Therefore, this sets the stage for potential conflicts between different categories of users, but also sets user expectation in advance for a “shared-use” experience, as compared to the exclusive use and rental of public use cabins found in other locations in Alaska.

The likelihood for actual conflict appears to be further moderated by a number of factors including: the reliance of all trail users on snowmobile use to compact a snow treadway on the trail and make it passable for non-motorized users (on-foot users, sled dog teams, “fat-bikes”, cross-country skiers). Snowmobile-based volunteers for SRP authorized events are recognized by all users for clearing the trail of fallen trees, providing continuous marking of the trail, mobilizing supplies to event checkpoints, and providing the platform for emergency search-and-rescue.

One current source of conflict that nonetheless appears to be tolerated among users is the effect of snowmobiles on snow trail surfaces. The rotating belt track of snowmobiles, combined with their hydraulic suspension, the irregular surface of underlying vegetation and ground, and the dry, non- bonding continental snowpack, lead to a condition of ‘wash boarding’ or ‘moguls’ along the Trail. The wash boarding can create safety hazards for casual snowmobilers and others users, along with an unpleasant experience for all users who have to endure the closely spaced up-and-down snow trail surface over dozens of miles. Such conditions can be prevented by snow groomers dragged by snowmobiles that fill in the moguls, but currently little trail grooming is done except in association with the parts of the long-distance snowmobile race, usually only as far north as McGrath.

Another potential source of conflict from both snowmobile and sled dog team use is the creation of deep groves in the trail surface on steep hills. Narrow snowmobile tracks, when accelerated on an uphill stretch, can excavate a linear track into and along the otherwise flat trail treadway. Also, the ‘step- down’ brakes used dog sleds to slow descent on steep hills can also lead to deep gouging of the trail treadway. The result is that for other users relying on a flat trail surface to either climb a hill or descend a hill, such a surface is replaced by a linear groove that can impede safe hill climbing and/or descent. There are few if any segments of BLM managed Trail with hills that are subject to such effects.

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Collisions between trail users is a potential source of conflict. Contributing factors include the number of users on any given section of trail, the direction of travel of the users, the speed of trail users, and trail sight distances. Successful avoidance of collisions by users on narrow trails can also lead to snowmobiles getting stuck in unconsolidated snow, requiring the driver to shovel and/or tow their machine back onto the trail.

The potential for this conflict is currently prevented by BLM SRP permit stipulations that require event sponsors to publicize the dates events will be occurring in nearby communities. BLM has also prevented this issue on the Unalakleet to Kaltag section of the Trail by clearing the trail five to seven feet wide to provide extended sight distances and suitable areas for safe passes between users.

One type of collision that is possible source of conflict is drunken driving of snowmobiles, resulting in collisions with other trail users.

Uncourteous trail behavior by trail users can be a source of conflict. Entrants in competitive events may not want to pullover and let another user traveling at higher speeds pass.

Overcrowding at BLM public shelter cabins could be a potential source of conflict among all users, although current management practices may have prevented this over the past decade.

Start dates for Iditarod Trail-based events are currently separated by multiple days if not weeks. Crowded conditions at public shelter cabins, if they do occur as a result of SRP-related occupancy, are short-term, typically lasting only a day or two, as the bulk of a competitive field passes through a given area.

Conflict due to overcrowding at public shelter cabins has also been prevented to date by the designation of BLM public shelter cabins as open to all users at all times for non-exclusive use, widespread communication on the expected dates of events, and widespread community knowledge of event dates.

The Rohn Public Shelter Cabin sees the majority of its annual use as checkpoints for a long-distance snowmobile race and a long-distance sled dog race. For the snowmobile race, the cabin is used by race sponsors for a long weekend. For the sled dog race, the cabin is used for over a week. Due to a lack of available bunk space in the cabin, volunteers for the sled dog race are permitted to bring tents for sleeping outside of the cabin. Human powered marathons may also use Rohn at the same time as the sled dog race; when this occurs, race sponsors are authorized to set up a wall tent to provide shelter for participants.

3.4.2 Direct and Indirect Effects from Alternative 1 - No Action Alternative For the No Action Alternative, given that SRP events would be permitted on an individual, case-by-case basis, it is expected that there could be a decrease in the number of events from previous years. Corresponding decreases in SRP-generated trail use and visits are anticipated, with the greatest decreases in trail use and visits on segments outside of popular inter-village transportation corridors

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(Rohn, Farewell Burn, and east of Shageluk). As a result, the potential for all types of user conflict is expected to decrease.

3.4.3 Direct and Indirect Effects from Alternative 2 Alternative 2 would be a continuation of the 2008 level of permitted SRP participants. Therefore, the estimated amount of annual trail use and visits for the period between 2008 and 2017 (see Table 2.0.1) are considered to be valid for this analysis.

Potential conflicts between different categories of users could be expected to continue at the same level as currently experienced.

The high speeds and narrow belt tracks of the racer’s snowmobiles are sometimes implicated as causing miles of “washboards” or “moguls” from the compaction and deflection of the dry, continental snowpack along the trail between Kaltag and Unalakleet, mainly east of BLM-managed lands. Trail conflicts stemming from the condition of the Trail surface due to SRP-authorized snowmobile races are expected to continue at a similar level as observed in the previous decade. Overcrowding of public shelter cabins for SRP-authorized events are not expected to change from the previous decade, and not be a source of significant conflict.

3.4.4 Direct and Indirect Effects from Alternative 3 Under the Preferred Alternative, the additional SRP events authorized would include one additional long-distance motorized event, three human-powered events, and guided winter overland tours (see Appendix B for the formulas used in developing these estimates).

SRP authorized trail use could increase between 2 percent and 11 percent on segments of the Trail as shown in Table 3.7. The greatest increase would be seen in the Kaltag-Unalakleet segment. Therefore, the greatest potential for increased conflict would be on the Unalakleet to Kaltag segment of the trail.

As a result of the Preferred Alternative, SRP-authorized visits to the Iditarod Trail on BLM-managed lands could increase up to 11 percent, with SRP visits making up more than a quarter of all visits to BLM lands along the trail (see Table 3.8). Up to 1,600 new SRP-authorized visits could be made to BLM lands annually, with a total ranging between 3,200 visits to 3,400 visits, depending on which race route is used.

The result of the increased authorizations under the Preferred Alternative, without the implementation of permit stipulations by BLM, could be an increase in potential conflict between categories of users’ especially local residents and event participants, increased damage to trail snow surfaces, increased potential for collision, and public shelter cabin overcrowding. While this potential does exist, BLM has the ability to prevent such conflicts by a number of permit conditions (see Appendix A for example permit stipulations).

Given that future additional permits may be added, BLM will assess future applications and potential conflicts on a case-by-case basis. The BLM could implement permit stipulations, and event timing to separate event starting times, require trail grooming, and require avoidance of use of BLM public shelter Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 41

cabins. A number of other ‘adaptive management techniques’ that can respond directly to new or unanticipated impacts and/or conflicts resulting from SRP events will be reviewed and implemented as needed.

Commercially guided overnight winter tours on the Trail, when permitted have been required under permit stipulations to establish overnight camps at locations other than public shelter cabins. Commercial winter tours are allowed to otherwise stop and use the public shelter cabins for ‘breaks’ along the trail, and if extreme weather dictates, for participant and guide safety.

Because of required permit stipulations, a significant increase in user conflict due to authorization of additional SRP permits for Trail-based events is not anticipated.

Under the Preferred Alternative, the proportion of SRP-authorized trail use could increase by as much 17 percent over alternative 2.

3.4.5 Cumulative Effects There are no known cumulative effects from user conflicts on the trail at this time.

3.4.6 Recommended Mitigation With the implementation of SRP required permit stipulations, a significant increase in user conflict due to additional permits authorized for Trail-based events is not anticipated. Therefore, no mitigation is recommended at this time.

3.5 Socio-Economic Effects Will the proposed activities have a disproportionately high or adverse effect on low income or minority populations?

3.5.1 Affected Environment With the exception of Nome, all of the communities along the Iditarod Trail west of the Matanuska- Susitna Borough are primarily populated by Alaska Natives. Trail-based SRP competitive events bring a significant infusion of resources mainly through non-cash means into trailside communities whenever such events are held. Community visitors, including event participants and non-resident volunteers, need a place to sleep and shelter from winter weather. Commercial lodging is scarce or non-existent in most trailside communities. Additional flights are made into communities to provide resources, such as food and a variety of supplies for the particular event, such as dog bedding straw, fuel, and other supplies.

The trail-based events leverage a significant amount of community resources that are used by community members, event participants and event followers, both in terms of volunteer hours, public buildings opened for lodging, donated food, and basic necessities such as a variety of fuel types for heating and cooking.

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Long-distance sled dog racing brings the largest infusion of resources into communities, along with leveraging the largest amount of community in-kind support, such races typically take between 5 and 7 days to pass through a community, therefore requiring resources to be available in that time period.

Long-distance snowmobile races bring fewer resources, with most focused in layover communities near BLM segments of the trail such as McGrath, and Unalakleet, and most layovers lasting only one night. Human-powered marathons bring a small fraction of the total amount of resources into communities, as entrants are expected to be almost entirely self-supported, and are widely distributed along the trail. Guided winter trips on the Trail could also provide an infusion of resources, but more typically through the acquisition of goods and services from local communities and/or residents.

3.5.2 Direct and Indirect Effects from Alternative 1 - No Action Alternative The No Action Alternative, which would result in events being permitted on an individual basis, could result in a decrease in the number of Trail-based events, and therefore decrease the infusion of event- supporting resources to trailside communities. As the impacts are shared among community residents, there are not expected to be disproportionately high and adverse effect on low income or minority populations.

3.5.3 Direct and Indirect Effects from Alternative 2 Alternative 2, which would permit events at the levels permitted in BLM’s 2008 SRP authorization, would result in similar socio-economic effects in trailside communities as experienced between 2008 and 2017. Based on these observations, this alternative is not expected to have a disproportionately high and adverse effect on low income or minority populations.

3.5.4 Direct and Indirect Effects from Alternative 3 Alternative 3, the Preferred Alternative may result in an increase in the infusion of event-supporting resources into trailside communities. Based on BLM observations of the effect of previous SRP permits, this alternative is not expected to have a disproportionately high and adverse effect on low income or minority populations.

3.5.5 Cumulative Effects The Preferred Alternative may result in an increase in the infusion of event-supporting resources into trailside communities. There are other events related to the Trail that would contribute to the use of resources in these areas.

3.5.6 Recommended Mitigation None recommended, as adverse residual effects are not anticipated, based on observations of the effects of permitting for similar events between 2008 and 2017.

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3.6 Decreased Length of Winter Trail Travel Season Issue: What are the effects of the changing length and intensity of winter weather on winter-specific trail use?

3.6.1 Affected Environment

A significant shortening of the winter travel season on the Trail appears to have occurred in the last fifteen years. Typically, the winter trail travel season requires enough below freezing days to freeze waterways for snowmobile use, and provide enough precipitation in the form of snow to support over- snow travel. In the late 20th century, these conditions typically began in November of each winter, and extend through mid-April. Frozen waterways provide solid winter bridges and routes through country that otherwise requires a boat or isolated other segments of the Trail.

In recent years, late freeze-ups have become more common, with larger rivers (i.e., Yukon, Kuskokwim) freezing and then thawing late in the year, or remaining unfrozen in some places throughout the winter. In response, other non-Iditarod trails have been rerouted onto land routes, travel on, and use of segments of the Trail has been delayed, and a number of trail-dependent sled dog races and snowmobile races have been postponed, rerouted, or canceled.

Mid-winter rain events have also become more common, along with significant decreases in precipitation in the form of snow. The diminished snowpack melts quicker than typical snowpacks in the lengthening days of spring. Unalakleet receives 13.5 hours of daylight, not including twilight, on March 30. As a result, the winter trail travel season has been ending by late March, as compared to the more typical “break-up” of winter conditions in mid-April.

3.5.2 Direct and Indirect Effects from Alternative 1 - No Action Alternative The No Action Alternative, which would result in events being permitted on an individual basis, could result in a decrease in the number of Trail-based events, and therefore decrease the traffic and wear on the Trail surface. The shorter snow coverage period brought on by the change in weather condition would have minimal effects on these events.

3.5.3 Direct and Indirect Effects from Alternative 2 Alternative 2, which would permit events at the levels permitted in BLM’s 2008 SRP authorization, would result in similar effects experienced between 2008 and 2017 due to changing weather patterns and conditions.

3.5.4 Direct and Indirect Effects from Alternative 3 Alternative 3, the Preferred Alternative may result in an increase in the number of permitted events. Changing conditions and weather patterns would require earlier start dates than have historically been used. The daylight conditions that event participants prefer would not be available as daylight would be limited during the earlier periods of February. Additional snowmobile races would have a minimal

Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 44 impact on the overall greenhouse gas levels due to the additional race participants or trail groomers. These users would most likely be utilizing other venues for planned events if not utilizing the Trail for their activities.

3.5.5 Cumulative Effects The additional use of snowmobiles to groom trails, additional gasoline, and other fuel and heating materials to include support aircraft for additional races would contribute to the overall greenhouse gas levels in the area. The total accumulation of effects would be similar to all other activities happening in the area. When compared to the overall use of the trail the cumulative increase. However, until specific races are permitted the increase in greenhouse gas emissions can only be expected to increase by no more than an estimated amount of 17 percent if all additional races are permitted. As it has not been determined at this time which additional events may be permitted this is not assured.

3.5.6 Recommended Mitigation Standard stipulations should be put in place for each permit issued. The reduction of idle time for combustion engines could be enforced to reduce greenhouse gas emissions at checkpoints on BLM- managed lands.

3.7 Residual Impacts As demonstrated by previous Trail use there are no adverse residual impacts from continued Trail use. Should the Trail not be utilized in the future, the natural vegetation would return within a few years eliminating any evidence of use in heavily vegetated areas.

4.0 CONSULTATION AND COORDINATION The BLM provided a public notice of the development of this Environmental Assessment to all affected communities along the Trail. The BLM did not receive any requests for formal consultation with the tribal groups affected. The BLM consulted with the State Historic Preservation Officer as part of this review.

5.0 LIST OF PREPARERS Kevin Keeler Iditarod National Historic Trail Administrator Jenny Blanchard Archeologist Stephanie Kuhns Outdoor Recreation Planner Merlyn Schelske Fisheries Biologist Bruce Seppi Subsistence/Wildlife Biologist Aliza Segal Ecologist Ben Stratton Hydrologist Larry Beck Environmental Protection Specialist Bruce Loranger Planning and Environmental Coordinator

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6.0 REFERENCES CITED BLM / C. Cecil. Determinations of Eligibility for Cultural Resources Associated with the Iditarod National Historic Trail (INHT): Farewell Burn Segment (MCG-0124), Kaltag Portage Segment (UKT- 0044, NOB-0057, NUL-0065), Ten-mile Cabin Site (NOB-0033). 2017

Fix, P.J. Iditarod National Historic Trail Travel Analysis (#MP2011-04), University of Alaska, Fairbanks (2011).

L. Flagstad and H. Cortéz-Burns. Tracking weeds along the Iditarod National Historic Trail. Alaska Natural Heritage Program. University of Alaska, Anchorage. 2010.

M. Niccolucci, A. Watson, D. Williams. The Nature of Conflicts between Hikers and Recreational Stock Users in John Muir Wilderness. Journal of Leisure Research. 1994

7.0 APPENDICES / ATTACHMENTS Appendix A: IDITAROD TRAIL, SPECIAL RECREATION PERMIT: SPECIAL STIPULATIONS FOR 2018 – 2028

Appendix B [ANALYSIS #4.2.1] PREFERRED ALTERNATIVE AND PROJECTED #’S OF PARTICIPANT VISITS TO BLM LANDS FOR PROGRAMMATIC EA ON ISSUANCE OF SRP PERMITS FOR IDITAROD TRAIL BASED EVENTS

Appendix C: Affected Area Maps

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APPENDIX A: IDITAROD TRAIL SPECIAL RECREATION PERMIT: SPECIAL STIPULATIONS FOR 201_

In addition to the terms included on the back of the enclosed Special Recreation Application and Permit (SRP) (Form 2930-1), the following special stipulations are a part of this permit and are applicable to BLM-managed lands and water, including State and Native selected areas. Failure to comply with any of these conditions or stipulations constitutes a knowing and willful violation of 43 CFR 2932.57, punishable by up to a $100,000 fine and/or a year in jail.

Safety 1. Permittee shall provide a copy of this permit with stipulations to each Lead Volunteer and event Official working on BLM lands and shall ensure compliance by all volunteers, participants, or spectators under the permittee’s supervision.

2. At least two weeks prior, the permittee shall notify the residents of the communities along the event route, including village councils and village police safety officers, of the start and ending of the event. Within seven days of the start, the permittee shall issue a press release informing the general public about the timing of the event and recommended safety precautions of spectators and other trail users potentially affected by the event.

3. The permittee must initiate appropriate search and rescue procedures by contacting the Alaska State Troopers in the event of any lost or injured event participants.

4. Participants must be equipped with adequate safety and survival equipment, and be advised by event officials of any natural or man-made hazards along the event route. It is recommended that each racer be equipped with sufficient reflective materials or other apparatus to be effectively visible in the dark.

Use Conditions 5. Report wildland fires in Alaska at 1-800-237-3633.

6. All campsites, checkpoints, and staging areas will be kept in a neat and sanitary condition at all times. Only the use of dead trees for campfires and wood stoves at BLM public shelter cabins is permitted. This permit does not authorize the cutting of live trees, including spruce boughs in the vicinity of public safety shelter cabins. Permittee shall make their volunteers and event participants aware of responsible low-impact practices and techniques, as outlined in the enclosed Alaska Wildlands Leave No Trace Skills and Ethics booklet.

7. The permittee accepts responsibility for the existing condition of the Iditarod winter trail, camp site; cabin and aircraft landing area used and will be liable for all site damages which occur as a result of the activity. Writing, carving, and other defacement of the interior or exterior of shelter cabins, outhouses and other public structure walls is prohibited.

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8. Installation of memorials, signs, photographs, etc. on the interior or exterior of shelter cabins, outhouses and other public structure walls is prohibited.

9. The maximum number race participants is____.

10. Authorizations shall terminate two days prior to any approved conveyance of Native or State selected lands which involve your permitted operating area.

11. Storage of gear or equipment on BLM lands is prohibited without approval from the authorized officer (AO).

Vehicle Use 12. Each event and support vehicle on the trail shall not exceed a gross vehicle weight rating of 1,000 pounds and a maximum width of 60 inches.

13. On BLM lands, all snow machines shall travel only within the cleared vegetation limits of the established Iditarod Winter Trail.

14. While on BLM, snow machines shall run over ground with sufficient snow cover and/or ground frost as to avoid long-term damage to tundra or wetland vegetation and soils.

Fuel and Waste Management 15. Waste water, non-hazardous solid waste, hazardous substance storage containers, and spills shall be managed in accordance with Title 18 Alaska Administrative Code Chapter 72-Wastewater Disposal and Chapter 75-Oil & Hazardous Substances Pollution Control (refer to Attachment 1).

16. Dumping of fuel in pits, outhouse, or on the ground is prohibited.

17. Within seven (7) days from the passage of the last participant crossing each section of BLM lands, all trash shall be hauled out by the permittee. Trash shall be disposed of in a proper landfill, dumpster, or trash can. Cans, glass, plastics (including bags and packaging), batteries and other non- combustible/non-degradable materials shall not be burned. Do not bury refuse. Gray water and human waste shall be disposed of at least 100 feet beyond the ordinary high water mark of any water body. When possible, bury all gray water and human waste.

18. Within seven (7) days after completion of the 201__ Iditarod Trail Sled Dog Race, visible straw shall be removed from BLM lands and taken to an approved landfill or completely burned at one location per site.

19. A second and final sweep of use areas shall be completed by May 15, 201 , in order to remove or burn recent and accumulated loose straw and straw bales created by your event. If straw or any other debris created by your event is not eliminated by this date the BLM may use some or your entire $5,000 bond to pay for the cost of cleanup and removal and you will be required to submit an additional bond.

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20. Only Certified Weed-Free Straw is authorized for transport, storage, and use on BLM lands, including the Campbell Tract Facility. Every straw bale shall have an attached numbered Alaska Weed-Free Forage Certification tag. If shipped in from out of state, each individual bale or container shall be marked with a specialty band of blue and orange twine and marked as weed or weed seed-free, under the North American Weed Management Association (NAWMA) standards.

Historic Rohn Cabin and Air Navigation Site 21. Storage of 55-gallon fuel drums and associated refueling of snow machines is only authorized adjacent to the Rohn airstrip. Drum storage and use is prohibited at the Rohn cabin. A maximum of 22 fifty-five gallon steel drums containing gasoline is permitted.

It is understood that the Iditarod Trail Sweep Crew may require the use of stored fuel at Rohn during post cleanup activities. Therefore BLM and race officials shall coordinate a reasonable timeframe for removal of remaining fuel and drums from the area.

All small-size gasoline cans, oil, and other flammable fuels and gases, such as camp stove fuel and propane, shall be stored and used a minimum of 50 feet from the Rohn Cabin, active campfires in designated fire rings, tent sites, and under overhanging trees.

The use of rubber fuel bladders is prohibited.

All fuel containers shall be clearly marked with the contents, date, and event name. The fifty-five gallon gasoline drums used specifically for pumping fuel shall be placed within fuel catchment tank traps, provided by the permittee.

Fueling will be performed on snow adjacent to the airstrip so small spills can be easily shoveled and properly disposed of using absorbent pads. Absorbent pads sufficient to cleanup at least one spilled drum, shovels, and heavy gauge plastic bags or containers shall be positioned where gasoline is stored and used.

When not in use, small flammable fuel and gas containers shall be stored within the onsite yellow- colored flammable storage locker. Storage of flammables within or immediately outside of the Rohn Cabin is strictly prohibited.

22. An assigned site for commercial recreation use of the Rohn Cabin, not the site or area, by your event is approved. The fee for an assigned site in 201_ is $_____. This authorizes use of the cabin for the period of five days from the start of the race to five after the last participant passes. Assignment of a site does not preclude (prevent) public use of the cabin. Use of the assigned site shall be temporary in nature, and any temporary structures or improvements shall be removed immediately upon the conclusion of the event. Unless expressly stated, the SRP does not create an exclusive right of use of an area by the permittee. The permittee shall not interfere with other valid uses of the federal land by other users. The United States reserves the right to use any part of the area for any purpose. 23. All used and unused dog and/or human food shall be flown or packed out before Rohn volunteers leave the area. Disposing of used and unused dog and/or human food on public lands shall be prohibited. Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 49

24. Removal of spruce boughs from trees at Rohn Air Navigation Site (limbing) is prohibited.

25. Campfires are restricted to only within the BLM-provided fire rings, excluding the burning of straw.

26. Burning of straw shall not take place within 300 feet of the Rohn Public Shelter Cabin, which is the distance from airstrip to the cabin. All straw shall be burnt at the west end of the airstrip approach, within the previously cleared area, in the vicinity of the top of the bluff above the South Fork of Kuskokwim River.

27. Burning of straw shall take place after the majority of aircraft traffic associated with the event has concluded, and smoke will have minimal effect on airstrip use.

28. The permittee shall have persons at the straw burn pile throughout the time the burning is occurring, and ensure that fires are completely extinguished before leaving the site.

29. Persons working the straw burn pile shall use fire tools such as rakes and shovels to prevent ignition of adjacent vegetation, and to ensure the pile is completely extinguished before departure.

30. Persons burning the straw should not burn the straw in the case that the combination of high winds and negligible snowpack can enable blown embers to ignite nearby fuel sources. Burning is allowed in light wind situations where a continuous snowpack prevents the spread of embers.

31. Due to the historic significance of the Rohn Cabin, modifications to the structure is strictly prohibited. This includes the drilling of new holes for electrical cords.

32. Snow machine use shall be limited to the vegetation clearing limits of the Rohn Cabin site.

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Appendix B Preferred Alternative Estimated Number of SRP Participant Visits to BLM Lands, Per Event

Sled Dog Race 1: Assume 100 race entrants (# does not include trail crew and checkpoint crew) Notes: ● 1 visit = use of BLM lands for any time less than, or equal to 12 hours ● The words ‘entrant’ and ‘participant’ are used interchangeably. ● The projected number of visits is higher than the expected actual number of visits, due to the portion of event participants that “scratch” every year before reaching BLM lands on the north portion of each event. No attempt is made to determine the proportion of participants who scratch every year, and their location relative to BLM lands.

Estimated musher visits on BLM lands (south race route, odd years): 1 visit Rohn 1 visit Farewell Burn (FB) segment 1 visit Iditarod-Anvik (IA) segment 2 or 4 visits Kaltag Portage (KP) segment2 1 visit segments north of UNK

Estimated musher visits on BLM lands (north race route, odd years): 1 visit Rohn 1 visit Farewell Burn (FB) segment 2 or 4 visits Kaltag Portage (KP) segment3 1 visit segments north of UNK

Musher visits South Route North Route

50 mushers x 6 visits = 300 50 mushers x 5 visits = 250

50 mushers x 8 visits = 400 50 mushers x 7 visits = 350

SUBTOTALS 700 visits 600 visits

Estimated Trail Crew visits (based on 12 trail crew members total) ● South route: assume 8 visits per person for 12 Trailbreakers or Trail Sweeps. ● North route: assume 7 visits per person for 12 Trailbreakers/Trail Sweeps

2 [Assumes average run time Kaltag to UNK 11 hours, without rest stops (7 mph), or 1 visit. Further assumes ½ of all mushers take 1 rest stop of up to 4 hours (resulting in 2 total visits for KP traverse), and ½ of all mushers take 1 rest stop of over 12 hours at one shelter cabin, resulting in 4 total visits for KP traverse] 3 [assume average run time Kaltag to UNK 11 hours, without rest stops (7 mph). Add following: Assume ½ of all mushers take 1 rest stop up to 4 hours, ½ of all mushers take 1 rest stop of over 12 hours at one shelter cabin] Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 51

South North Trail Crew Visits 12 persons x 8 visits = 96 visits 12 persons x 7 visits = 84 visits

Estimated Rohn checkpoint crew visits (based on 8 checkpoint crew members total) Rohn is used both years therefore calculation is the same. Assume 14 visits per person (7 days x 2 visits over 24 hr period) for an 8 person checkpoint crew:

Rohn Checkpoint Crew Visits 14 visits / person x 8 persons = 112 visits

Total estimated # of Sled Dog Race 1 visits to BLM lands:

Participant type South Route North Route

Musher 700 600

Trail Crew / Sweep 96 84

Rohn checkpoint 112 112

SUBTOTALS 908 visits 796 visits

[Note: Snowmobile race 1 and 2 entries are assumed to be the same at 100 pro class and 25 rec class entrants, and have the same # of visits, and same amount of checkpoint visits.]

Snowmobile Race 1: Assume 20 rec class entrants and 100 pro class entrants (not including checkpoint crew) Notes: ● The pro class crosses BLM KP and BLM ‘north of UNK’ lands twice, while the rec class crosses once. ● Both classes follow a north route every year, and do not cross Iditarod-Anvik segment. ● Rec class riders ride as individuals, while pro class riders are typically referred to by current event sponsors as a team of two riders. The number used below for pro class riders refers to number of participants, not teams. ● The number of estimated visits is higher than actual visits, as a decreasing percentage of starting participants drop out along the trail due to mechanical problems or other issues. (For example, of the 100 Pro class participants who start, perhaps only 80 make it to Nome, with even less returning to Fairbanks. Due to the unreliability of estimated annual ‘drop-outs’, it is assumed all starters finish their respective event.) ● 1 visit = use of BLM lands for any time less than, or equal to 12 hours ● The words ‘entrant’ and ‘participant’ are used interchangeably.

Estimated Pro class participant visits 1 visit Rohn 1 visit FB 2 visits KP 2 visits north of UNK Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 52

6 visits / entrant X 100 entrants= 600 visits by Pro class entrants

Rec class participant visits 1 visit Rohn 1 visit FB 1 visit KP 1 visit N of UNK 4 visits / entrant x 20 entrants = 80 visits by Rec class entrants

Estimated Rohn checkpoint crew visits [assume 4 visits at Rohn per pax for 6 pax crew] 4 x 6= 24 visits by Rohn checkpoint crew

Total estimated # of Snowmobile Race 1 visits to BLM lands Participant type # of visits to BLM land

Pro class 600

Rec class 80

Rohn checkpoint crew 24

Subtotal 704

[Note: Snowmobile race 1 and 2 entries are assumed to be the same at 100 pro class and 25 rec class entrants, and have the same # of visits, and same amount of checkpoint visits.]

Snowmobile / Snowbike Race 1: Assume 20 rec class entrants and 100 pro class entrants (not including checkpoint crew) Notes: ● While there are currently no long-distance motorized snowbike races proposed for the Iditarod Trail on BLM lands, this emergent class of use may be proposed within the life of this permit and therefore is considered as part of this analysis. ● The pro class crosses BLM KP and BLM ‘north of UNK’ lands twice, while the rec class crosses once. ● Both classes are assumed to follow a north route every year, and do not cross the Iditarod-Anvik segment. ● Rec class riders ride as individuals, while pro class riders are typically referred to by current event sponsors as a team of two riders. The number used below for pro class riders refers to number of participants, not teams. ● The number of estimated visits is higher than actual visits, as a decreasing percentage of starting participants drop out along the trail due to mechanical problems or other issues. ● 1 visit = use of BLM lands for any time less than, or equal to 12 hours ● The words ‘entrant’ and ‘participant’ are used interchangeably.

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Estimated pro class participant visits 1 visit Rohn 1 visit FB 2 visits KP 2 visits north of UNK 6 visits / entrant X 100 entrants= 600 visits by Pro class entrants

Rec class participant visits 1 visit Rohn 1 visit FB 1 visit KP 1 visit N of UNK 4 visits / entrant x 20 entrants = 80 visits by Rec class entrants

Estimated Rohn checkpoint crew visits [assume 4 visits at Rohn per pax for 6 pax crew] 4 x 6= 24 visits by Rohn checkpoint crew

Total estimated # of Snowmobile Race 1 visits to BLM lands Participant type # of visits to BLM land

Pro class 600

Rec class 80

Rohn checkpoint crew 24

Subtotal 704 [Note: Human powered winter marathon events 1, 2 and 3 entries are assumed to be the same at 75 / event, and have the same # of visits, and same amount of checkpoint visits.]

Human-powered Long Distance Winter Marathon 1: Assume 75 total race entrants (not including checkpoint crew) [350 mile and 1000 mile racers only]

350 mile participants (figures are for both north and south routes) 1 visit Rohn 1 visit FB 2 visits total X 55 entrants = 110 visits by 350 mile entrants

1,000 mile participants (figures are for south race route; for north race route, assume 1 less visit) 1 visit Rohn 1 visit FB Programmatic Environmental Assessment DOI-BLM-AK-A010-2017-0012-EA 54

1 visit IA 2 visits KP [assume 11 hr. traverse time @ 7 mph + 1 overnite camping] 1 visit north of UNK 6 visits X 20 entrants = 120 visits by 1,000 mile entrants

Estimated Rohn checkpoint crew visits [assume 8 visits at Rohn x 2 pax Rohn checkpoint crew) 8 x 2= 16 visits by checkpoint crew

Total estimated # of visits to BLM lands

Participant type South Race Route: North Race Route: # of visits to BLM land # of visits to BLM land

350 mile participants 110 110

1000 mile participants 120 100

Rohn checkpoint crew 16 16

Subtotal 246 226

[Note: Human powered winter marathon events 1, 2 and 3 entries are assumed to be the same at 75 / event, and have the same # of visits, and same amount of checkpoint visits.]

Human-powered Long-Distance Winter Marathon 2: Assume 75 total race entrants (not including checkpoint crew) [350 mile and 1000 mile racers only]

350 mile participants (figures are for both north and south routes) 1 visit Rohn 1 visit FB 2 visits total X 55 entrants = 110 visits by 350 mile entrants

1,000 mile participants (figures are for south race route; for north race route, assume 1 less visit) 1 visit Rohn 1 visit FB 1 visit IA 2 visits KP [assume 11 hr. traverse time @ 7 mph + 1 overnite camping] 1 visit north of UNK 6 visits X 20 entrants = 120 visits by 1,000 mile entrants

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Estimated IS Rohn checkpoint crew visits [assume 8 visits at Rohn x 2 pax Rohn checkpoint crew) 8 x 2= 16 visits by checkpoint crew

Total estimated # of visits to BLM lands

Participant type South Race Route: North Race Route: # of visits to BLM land # of visits to BLM land

350 mile participants 110 110

1000 mile participants 120 100

Rohn checkpoint crew 16 16

Subtotal 246 226

[Note: Human powered winter marathon events 1, 2 and 3 entries are assumed to be the same at 75 / event, and have the same # of visits, and same amount of checkpoint visits.]

Human-powered Long-Distance Winter Marathon 3: Assume 75 total race entrants (not including checkpoint crew) [350 mile and 1000 mile racers only]

350 mile participants (figures are for both north and south routes) 1 visit Rohn 1 visit FB 2 visits total X 55 entrants = 110 visits by 350 mile entrants

1,000 mile participants (figures are for south race route; for north race route, assume 1 less visit) 1 visit Rohn 1 visit FB 1 visit IA 2 visits KP [assume 11 hr. traverse time @ 7 mph + 1 overnite camping] 1 visit north of UNK 6 visits X 20 entrants = 120 visits by 1,000 mile entrants

Estimated IS Rohn checkpoint crew visits [assume 8 visits at Rohn x 2 pax Rohn checkpoint crew) 8 x 2= 16 visits by checkpoint crew

Total estimated # of visits to BLM lands

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Participant type South Race Route: North Race Route: # of visits to BLM land # of visits to BLM land

350 mile participants 110 110

1000 mile participants 120 100

Rohn checkpoint crew 16 16

Subtotal 246 226

Guided Overnight Winter Dogsledding/Camping Trips: Assumes same itinerary (5 nites total), approx. client- guide/support staff ratio, and general aviation support as permitted to a private operator in 2017, which included 2 nights camping on BLM lands, or 48 hours on BLM lands, which equals 4 visits. Also assumes 2:1 client-guide ratio, and 2 aircraft landings per 24 hour period on BLM lands. Assumed trip size is 10 clients, for 5 trips annually. Assumes itinerary of Galena to Unalakleet.

APPROX. NUMBER OF USER VISITS OBSERVED IN 2017 21 support staff x 4 visits to BLM lands = 84 visits 9 clients x 4 visits to BLM lands = 36 visits 1 aircraft x 16 landings (over 48 hrs) = 16 visits Total estimated # of AK Private Tour visits to BLM lands: 136 visits Therefore, analysis assumes 30 users (20 staff, 10 clients) at 4 BLM visits (2-24 hour periods)=120 visits / trip Proposed Action: Authorize 3 trips of up to 30 users/trip: 120 visits x 3 trips = 360 visits

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APPENDIX C: AFFECTED AREA MAPS [these maps and/or the pages will be rotated to a landscape format]

Overview Map

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MAP 1: ROHN TO TAKOTNA

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MAP 2: SHAGELUK - ANVIK VICINITY

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MAP 3: KALTAG TO SHAKTOOLIK

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MAP 4: SHAKTOOLIK TO GOLOVIN

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MAP 5: WHITE MOUNTAIN TO NOME

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MAP 6: FAIRBANKS ALTERNATE ROUTE: IDITAROD SLED DOG RACE

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