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United States Department of the Interior Bureau of Land Management Eastern Interior Field Office 222 University Avenue Fairbanks, AK 99709 Phone: 907-474-2200

NOAA Parcel G Relinquishment Environmental Assessment (EA) DOI-BLM-AK-F020-2017-0016 Serial Number F-025943

July 26, 2017

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Table of Contents

1.0 INTRODUCTION AND BACKGROUND ...... 5 1.1 PURPOSE AND NEED FOR THE PROPOSED ACTION...... 6 1.2 DECISION TO BE MADE ...... 6 1.3 CONFORMANCE WITH BLM MANAGEMENT PLAN(S)...... 6 1.4 CONSISTENCY WITH LAWS, REGULATIONS, AND POLICIES ...... 7 1.5 SCOPING AND IDENTIFICATION OF ISSUES ...... 8 2.0 PROPOSED ACTION AND ALTERNATIVES ...... 11 2.1 Alternative A: Proposed Action ...... 11 2.2 Alternative B: No Action Alternative ...... 11 2.3 Alternatives Considered but Eliminated From Detailed Analysis ...... 12 3.0 AFFECTED ENVIRONMENT and ENVIRONMENTAL CONSEQUENCES ...... 12 3.1 Realty and Land Status ...... 13 3.2 Vegetation ...... 14 3.3 Recreation ...... 15 3.4 Wastes, Hazardous or Solid ...... 16 4.0 PUBLIC INVOLVEMENT ...... 17 4.1 Public Notice ...... 17 4.2 Public Meeting ...... 17 4.3 Comments ...... 18 5.0 CUMULATIVE IMPACTS ...... 19 5.1 Geographic Scope and Timeframe ...... 19 5.2 Past and Present Actions ...... 19 5.3 Reasonably Foreseeable Future Actions ...... 20 5.4 Cumulative Impacts for the Proposed Action ...... 20 6.0 LIST OF PREPARERS...... 21 7.0 REFERENCES ...... 21

3 List of Appendices

Appendix A Figures and Photos Appendix B Notice of Intent to Relinquish Letter from NOAA Appendix C Cultural, Essential Fish Habitat, and Subsistence Reports Appendix D Environmental Site Assessment Appendix E State of Letter – De-energized Power Line Appendix F Land Surveyor Report

4 NOAA Parcel G Relinquishment Environmental Assessment DOI-BLM-AK-2017-0016-EA Serial Number F-025943

1.0 INTRODUCTION AND BACKGROUND The Fairbanks Command and Data Acquisition Station (FCDAS), also known as the Gilmore Satellite Tracking Station, is located east of Fox, Alaska in a valley within an 8,855 acre federal land withdrawal. In 1965, Public Land Order (PLO) 3708 established the withdrawal for the FCDAS, which was administered by NASA until 1989 when PLO 6709 transferred control of the withdrawal to the National Oceanic and Atmospheric Administration (NOAA). In 2008, BLM issued PLO 7710 to extend the withdrawal through 2029. The FCDAS facilities are concentrated along Eisele Road in the western portion of the withdrawal. The remainder of the withdrawal is predominantly unimproved forested land that serves as a buffer zone to block external radio interference from hindering the FCDAS mission. NOAA filed a Notice of Intent to Relinquish (NOI) a 709.17 acre portion of the withdrawal with the BLM Alaska State Office on October 18, 2016, stating that they have determined that the subject lands, identified as Parcel G (Figure 1), are no longer needed to fulfill their mission.

The subject lands are included in the General Purposes Grant selection application F-029454 pursuant to Sec. 6(b) of the Alaska Statehood Act as amended (PL 85-508). Two previous partial relinquishments of the withdrawal, covered under this same selection grant, were tentatively approved for conveyance to the State of Alaska in 2008 and 2011.

The current land uses related to Parcel G are:

• The site has three State of Alaska identified RS2477 designated trails, which cross through Parcel G: RST 650 Gilmore Trail/Fairbanks Creek Connector Trail, RST 644 Cleary Summit – Gilmore Dome Trail, and RST 1931 Gilmore Hill Road.

• There are two existing BLM Rights-of-Way (R/W) in the parcel, the first being FF90548, for a 138 KV power transmission line, containing approximately 5 acres, crossing through sections 7 and 8 in the northern portion of the proposed relinquishment. The second R/W is FF097267, which is for a fiber optic line wholly within the same R/W corridor.

• Fairbanks Inc., (FGMI) is currently conducting exploratory drilling within the proposed relinquishment under BLM permit FF096399, issued in 2014, and set to expire in September of 2017.

• There are 2 current Special Recreation Permits in the area, FF096999 permitting a running race held by Running Club North and FF097214, a year round motorized tour guide operation.

5 Land Description and acreage:

Parcel G (Photos 1, 2a & 2b) consists of 709.17 acres and is located approximately 6.5 miles north and east of Fairbanks and is within the PLO 3708 boundaries, as amended.

Legal Description:

Fairbanks Meridian, Alaska T. 2N., R. 2E., sec, 7, SE1/4SE1/4 sec. 8, SW1/4SW1/4 sec. 17, W1/2 (portion of), sec. 18, E1/2 (portion of), sec. 19, NE1/4 (portion of), sec. 20, NW1/4 and portions of S1/2 The areas described aggregate 709.17 acres.

1.1 PURPOSE AND NEED FOR THE PROPOSED ACTION Purpose: The purpose of the action is to determine if the NOAA notice of intent to relinquish a 709.17 acre portion of a public land withdrawal, under PLO 3708 as amended, meets the requirements listed in 43 CFR 2372.1-3 and whether or not the lands are suitable for return to the public domain for disposition under the general public land laws.

Need: The need for the action is established by the BLM’s withdrawal authority under FLPMA (Pub. Law 94-579) §204 and responsibility under 43 CFR 2370 to respond to withdrawal relinquishment requests from holding agencies.

1.2 DECISION TO BE MADE Based on the information provided in this EA, the BLM Eastern Interior Field Manager will recommend to the Secretary of Interior whether or not the lands included in the notice of intent to relinquish (Parcel G) are suitable for return to the public domain for disposition under the general public land laws. The Finding of No Significant Impact (FONSI) will describe the Field Manager’s recommendation and rationale for the recommendation. Those findings and recommendations will be forwarded to the Secretary of the Interior, through the Alaska State Director, for consideration and final decision on the revocation of the withdrawal.

1.3 CONFORMANCE WITH BLM MANAGEMENT PLAN(S) The Fortymile Resource Management Plan (2016) specifically addresses the BLM’s role and responsibilities for withdrawal relinquishments on pages 64-65 under 2.2.17.4 Withdrawals:

Goals Where the BLM determines withdrawals from the public lands laws are not necessary, those lands would be open to the public land laws.

6 Lands-35: Recommend retaining federal agency withdrawals (e.g., NOAA, military, GSA, FAA) until no longer required by the agency. Regulations in 43 CFR 2370 and following will govern the process for an agency to relinquish lands or interest in lands, in whole or in part, when no longer needed. Once an agency has filed a complete notice of intent to relinquish to the BLM and appropriate General Services Administration (GSA) regional office the BLM will follow the appropriate regulations and the Authorized Officer will make a determination as to suitability of the lands or interest in lands for return to the public domain. If the lands or interest in lands are determined suitable for return to the public domain the Authorized Officer will notify the holding agency that the Department of the Interior accepts accountability and responsibility for the property in accordance with procedures found in 43 CFR 2374. If the lands or interest in lands are determined to be unsuitable for return to the public domain the Authorized Officer will request concurrence from the appropriate officer of the GSA and upon receipt of the concurrence will notify the holding agency to report as excess property the lands and improvements or interest in lands to the General Service Administration in accordance with procedures found in 43 CFR 2374. (Table 3.3b, “Existing Withdrawals to Other Agencies in the Planning Area” Eastern Interior Proposed RMP/Final EIS)

1.4 CONSISTENCY WITH LAWS, REGULATIONS, AND POLICIES The Proposed Action and No Action Alternatives are consistent with federal, state, and local laws, regulations, and plans.

1. Principle federal laws and regulations pertaining to this analysis a. Federal Land Policy and Management Act of 1976 b. 43 CFR 2372 and 43 CFR 2374 c. Endangered Species Act of 1973, as amended d. National Historic Preservation Act of 1966, as amended e. Archaeological Resources Protection Act of 1979 f. The Clean Water Act of 1977, as amended g. Executive Order 11988 of 1977, as amended h. Alaska National Interest Lands Conservation Act (ANILCA) of 1980, as amended

2. State and Local Laws and Statutes This area is covered by the State of Alaska, Department of Natural Resources (DNR) Eastern Tanana Area Plan, adopted on August 28th, 2015. The land unit covering the area is Unit #F-16, Classification: Minerals and Wildlife Habitat and Designation: Minerals. The plan lists the Management Intent for this area as follows:

Unit is to be retained and is to be managed for its mineral resources and values. Recreation facilities may be accommodated to the extent that they do not interfere with mining activity. Mineral development must consider potential impacts upon recreational uses and habitat areas (moose wintering) and provide appropriate avoidance or minimization practices. RS 2477 routes and historic sites that do not conflict with current or future mining activity should be protected and retained in public ownership.

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1.5 SCOPING AND IDENTIFICATION OF ISSUES The following internal and external scoping was conducted by the BLM:

1.5.1 Internal

The EIFO, Interdisciplinary Team (IDT), reviewed the Proposed Action and No Action Alternative and completed the following Valued Environmental Component (VEC) Matrix:

Valued Identify Issues for Rationale and Specialist Sign Off Environmental Analysis Brief Description of Rationale Components (Refer to Section 6.4 of the BLM NEPA Handbook) YES or NO The subject area is a few miles outside of the north boundary of the Fairbanks North Star Borough (FNSB) Environmental Protection Agency particulate matter 2.5 Air Quality – Baxter NO non-attainment air quality area. There are no expected impacts to air quality from the proposed action. VAB 07-07-2017 Areas of Critical There are no ACECs within 35 miles of the proposed action. ACECs will not be Environmental NO affected. JDH 2017_7_20 Concern - Herriges Cultural Resources - There are no Cultural Resources concerns with the proposed action, see Appendix NO Mills C. ROM 6-23-17 Environmental The proposed action would have no impact upon the human health and Justice - Baxter NO environmental conditions in minority and low-income communities. VAB 07-07- 2017 Essential Fish There is no EFH in the vicinity of the proposed action – no affect. JP_7/18/17 NO Habitat - Post

Farm Lands - Baxter NO There are no farm lands in or adjacent to the subject area. VAB 07-07-2017

Fire Management - This area is within Full and/or Critical fire suppression designation. There are no NO Baxter expected impacts to fire management from the proposed action. VAB 07-07-2017 Floodplains - Post The formal, legal process of transferring 709 acres from NOAA, to the BLM, and then to the state of Alaska, will not affect floodplains. The state of Alaska intends NO to manage the 709 acres for mineral development. Impacts to floodplains have not been analyzed under management by the state of Alaska or for mineral development. JP_7/18/17 Invasive, Nonnative Site inspections performed of the exploratory drilling and rehabilitation areas in Species - Baxter April and June of 2017 found no extremely, highly, or moderately invasive plant NO species in the area. There would be no expected impacts to invasive or nonnative plants if the lands convey to the State. VAB 07/07/2017 Mineral Resources - There are no Mineral Resource concerns related to the proposed action. JDF NO Fennell 7/5/2017

8 Valued Identify Issues for Rationale and Specialist Sign Off Environmental Analysis Brief Description of Rationale Components (Refer to Section 6.4 of the BLM NEPA Handbook) YES or NO Native American There are no known Native American Religious Concerns in the area of the Religious Concerns NO proposed action. ROM 6-23-17 - Mills Paleontological - There are no Paleontological Resources concerns with the proposed action. See NO Mills Appendix C. ROM 6-23-17 Realty/Land Status - Recommendation to relinquish the lands and subsequent revocation of the Baxter YES withdrawal will allow state selection to apply and land may be conveyed to State of Alaska. Existing R/W permits will be affected by transfer. VAB 07-07-2017 Recreation - Yeager The affected area does not have a current recreation activity management plan. However, the project area does contain an existing trail system that provides recreation opportunities year round for both motorized and non-motorized uses. There are 2 BLM Special Recreation Permits that occur on a portion of the YES proposed relinquishment. Conveyance to the State would lessen the percentage of trail that the permit operates on Federal lands. Conveyance to the State would also require permittees to apply to the state for authorization to operate in the area. EY 7/18/2017 Socioeconomic - There are no socioeconomic effects on determining suitability to return the lands Baxter to the public domain. Conveyance of the lands to the State may result in the BLM NO permittees and R/W holders to seek authorizations from the state. Fees associated with State authorizations are lower than those charged by BLM, resulting in no adverse economic impacts. VAB 07-07-2017 Soils - Baxter The Natural Resources Conservation Service mapped soils units in the area. Soils on north facing slopes consist of Ester and Saulich peats, which are poorly drained with shallow depth to permafrost and are subject to solifluction. Soils on NO the south-facing slopes consist of well drained Steese and Gilmore silt loams. There are no expected direct or indirect impacts to soils from the proposed action. VAB 07-07-2017 Subsistence - The proposed action will have no direct effect on harvestable resources. Indirect Herriges and cumulative effects will be negligible. The NOAA withdrawal is entirely within the Fairbanks North Star Borough where residents are considered non- NO rural. Subsistence resources are not currently available for harvest in the NOAA withdrawal. Following relinquishment of the withdrawal, state selections will apply and the lands will continue to be unavailable for subsistence use. JDH 2017/7/20 Threatened or No threatened, endangered, or candidate species occur in the area of the proposed Endangered Species NO action. BLM-sensitive species will not be affected by the proposed transfer of - Herriges 709 acres from NOAA to BLM. JDH 2017/7/20 Travel Management This area is not currently covered by a travel management plan and travel - Yeager management restrictions do not exist. There are current year round motorized and non-motorized uses on the existing trails and 2 special recreation permits NO authorizing a running race and a tour operation. There are no expected adverse impacts to travel management if the withdrawal is revoked and the lands are conveyed to the state. . EY 7/18/2017 Tribal Notification – The proposed action is not in the area of concern stated by the tribal governments Ft. Yukon & NO of Ft. Yukon and Chalkyitsik. ROM 6-23-17 Chalkyitsik - Mills

9 Valued Identify Issues for Rationale and Specialist Sign Off Environmental Analysis Brief Description of Rationale Components (Refer to Section 6.4 of the BLM NEPA Handbook) YES or NO Vegetation - The drilling activity has changed the surface vegetation characteristics on 40 Herriges acres of Parcel G which may affect suitability. Vegetation will not be affected by YES the proposed transfer of 709 acres from NOAA to BLM. Reasonably foreseeable indirect and cumulative impacts include loss of vegetation due to mining, with eventual post-mining vegetation dependent on reclamation. JDH 2017_7_20 Visual Resources - This area has been identified as a Class IV visual resource. The objective of Class Baxter IV is to provide for management activities that would result in major modification of the existing character of the landscape. Changes may attract NO attention and be dominant landscape features, but should reflect the basic elements of the existing landscape. Visual resources will not be affected by the proposed action. Wastes, Hazardous An Environmental Site Assessment (ESA) must be completed according to 43 or Solid – YES CFR 2372. There were improvements on the land consisting of a tower, fence, Baxter/Beck de-energized power line, and a transformer on a power pole. VAB 07-07-2017 Water Quality – There would be no effect to surface or ground water quality from the proposed Surface or Ground - NO action. VAB 07-07-2017 Baxter Wetlands / Riparian The formal, legal process of transferring 709 acres from NOAA, to the BLM, and NO Zones - Post then to the state of Alaska, will not affect wetland/riparian zones. JP_7/18/17 Wild and Scenic There are no wild, scenic, or recreation rivers in the proposed action area, nor do NO Rivers - Yeager any tributaries flow into any wild, scenic, or recreation river. EY 7/18/2017 Wilderness An inventory for wilderness characteristics was completed for the Central Yukon Characteristics - Resource Management Plan (CYRMP) November 2014 and it included the lands DuPont NO that are being analyzed under this EA. It was determined that the lands being analyzed do not possess wilderness characteristics because they do not meet the natural appearance criteria. TD 7/18/2017 Wildlife/Aquatic - The formal, legal process of transferring 709 acres from NOAA, to the BLM, and NO Post then to the state of Alaska, will not affect fish and aquatic resources. JP_7/18/17 Wildlife/Terrestrial - Terrestrial wildlife resources will not be affected by the proposed transfer of 709 Herriges acres from NOAA to BLM. It is reasonably foreseeable that mining of much of NO the site may occur, potentially resulting in loss of habitats as indirect and cumulative impacts. JDH 2017_7_24

1.5.2 External

1.5.2.1 Public and Agency Scoping

The BLM opened a 37 day public and agency scoping period on April 21, 2017, with the publication of maps and the purpose and need statement of this EA on the BLM National NEPA Register. BLM held a public meeting on May 18th, in Fairbanks, where 22 people were in attendance. During the scoping period, 15

10 comments were received from individuals, recreational groups, the Alaska Space Grant Program, and the Northern Alaska Environmental Center. The majority of the comments expressed a desire to maintain access to the public trails that cross this parcel. There were also comments related to potential radio frequency impacts to the site if the topography of Parcel G were altered through future actions. Additional concerns were expressed about the possible expansion of the Fort Knox mine. The main issues identified by the public were:

1. Access to and preservation of trails. 2. Potential for radio frequency interference impacting NOAA’s activities. 3. Potential expansion of the existing Fort Knox mine.

No comments from agencies were received.

2.0 PROPOSED ACTION AND ALTERNATIVES 2.1 Alternative A: Proposed Action The proposed action alternative is to recommend that the lands and minerals within Parcel G are suitable for return to the public domain and disposition under the general land laws. NOAA will be notified that BLM will assume accountability and responsibility for the lands and the recommendation for revocation of the withdrawal for Parcel G will be forwarded to the Secretary of Interior for final decision and publication in the Federal Register.

Top filing selection of Parcel G by the State of Alaska is allowable under Section 906(e) of the ANILCA and such selection becomes an effective selection without further action by the State upon the date the lands included in such application become available. The lands become available for selection on the date the withdrawal, PLO 3708, as amended, is revoked for Parcel G through publication of a new PLO in the Federal Register. Once the state selection is effective, the lands are considered segregated, or removed from the public domain, and the conveyance process starts immediately. The conveyance of Parcel G to the state of Alaska is a connected action to the revocation of the withdrawal and the potential impacts to resources from that conveyance are considered alongside the suitability determination.

2.2 Alternative B: No Action Alternative

NOAA filed their intent to relinquish the lands within Parcel G in October of 2016. That notice was deemed complete by BLM and the process for determining whether or not the land is suitable for return to the public domain was started in accordance of 43 CFR 2370. There is no alternative to consideration and evaluation of suitability once a Notice of Intent to Relinquish is received and determined complete.

11 The Alaska Statehood Act of July 7, 1958, provides that upon revocation of any order of withdrawal in Alaska, the order of revocation shall provide for State selection of the land (43 CFR 2627.4). The only alternative to opening the land to the general land laws and allowing the state selection to apply is to transfer reservation to another Federal agency (ANILCA, Sec. 906(e)). No other federal agencies have expressed an interest in these lands to date and the State has indicated that these lands are a high priority selection.

Thus, the No Action Alternative under BLM jurisdiction is limited. However, for the purposes of analysis, a No Action Alternative provides a baseline for comparison in the EA. For the purpose of impact analysis, the No Action Alternative is defined as federal retention of Parcel G.

2.3 Alternatives Considered but Eliminated From Detailed Analysis

During public scoping, the majority of the comments received indicated concern over continued access to and use of existing trails within Parcel G. BLM considered ways to address these concerns and investigated possible methods of ensuring access to trails in the event that the lands were conveyed to the State. One suggestion from the public was to encumber the parcel with an easement for the trails. This was considered as an alternative; however, after preliminary investigation it was eliminated from detailed analysis as the trails are already afforded a method of protection by the State. The trails in Parcel G are State identified RS2477 trails, designated as RSTs 644, 650, and 1931 by Alaska Statute. Alaska Statutes 19.30.400 and 19.30.410 requires that the State manage these trails for public access and use and requires a specific process for the potential vacation or relocation of these trails. Therefore, any BLM action on the trails in Parcel G would be of lesser protection than those state processes which would go into effect if the lands are conveyed.

3.0 AFFECTED ENVIRONMENT and ENVIRONMENTAL CONSEQUENCES This section describes the existing environment and evaluates whether or not the affected environmental component affects the suitability of the lands for return to the public domain or if the component would be impacted by the connected action of conveying the lands to the State of Alaska. The criteria for suitability are described in 43 CFR 2372.1-3 and the conditions of acceptance of accountability and responsibility of the lands by BLM are found in 43 CFR 2374.1-2.

The criteria may be summarized as:

• are the subject lands free of improvements • are the subject lands free of contamination • has the character of the lands been changed other than by improvements

12 • have the lands or resources thereon been disturbed and if so, what measures have been taken to recondition the lands, and finally • are there encumbrances on the lands which the holding agency or its predecessors have granted.

Table 1 lists the valued environmental components that were identified as having either a potential impact on the suitability of the parcel for return to the public domain or as being potentially impacted by the lands being conveyed to the State.

3.1 Realty and Land Status

3.1.1 Affected Environment

Parcel G is just over 700 acres in size and is located northeast of Fairbanks, Alaska. The lands are currently within an approximately 8,855 acre federal land withdrawal that was reserved first in 1965 under PLO 3708. This withdrawal serves as a NOAA National Environmental Satellite, Data, and Information Service facility (NESDIS). There are two existing R/W in the parcel, the first being FF90548, for a 138 KV power transmission line, containing approximately 5 acres, crossing through sections 7 and 8 in the northern portion of the proposed relinquishment (Photo 3). The second R/W is FF097267, which is for a fiber optic line wholly within the same R/W corridor. Both of these R/W were renewed in 2017, are in compliance, and are up to date with annual rent payments.

In September of 2014, the BLM granted a mineral assessment permit to FGMI for exploratory drilling within an area of approximately 2000 acres. The permit was processed pursuant to 43 CFR 2920.5-1 and was granted initially for the disturbance of 25 acres which in 2016 was amended to allow up to 45 acres. Parcel G comprises the easternmost portion of this exploration area.

3.1.2 Environmental Consequences

Proposed Action According to 43 CFR 2372.1(10), it is necessary to document any easements or rights and privileges which the holding agency or its predecessors have granted covering the lands to be relinquished. The two existing R/W and the drilling permit are the only authorizations of this type that are realty based. The suitability criteria do not specify that the presence of R/W would make lands unsuitable for return to the public domain. The presence of a power line and fiber optic line on a strip totaling 5 acres (0.7% of the parcel) within the northern part of the parcel does not constitute a substantial change in the character of the lands. The exploratory drilling that has occurred on the parcel disturbed approximately 40 acres of land, the majority of the drill sites were located in the center section of the parcel (see Figure 2), adjacent to the existing RST 644 trail and the property boundary. The environmental consequences of the drilling exploration are addressed in Section 3.2.2, Vegetation.

Opening Parcel G to state selection and conveyance would have no effect on the R/W authorizations as they typically transfer with the parcel as long as the State concurs prior to

13 conveyance. The transfer of the 709 acres does contribute to the number of acres conveyed to the State as mandated under the Alaska Statehood Act. The transfer of the R/W would result in the loss of a small amount of fees to BLM. The exploratory drilling permit expires on September 21st, 2017, and it is likely that this will occur prior to the revocation decision by the Secretary of Interior. The conveyance documentation to the State would stipulate that this permit expires upon conveyance if necessary. If FGMI would like to continue drilling on the lands after conveyance, they would be able to apply to the State for authorization.

No Action Alternative There would be no changes in the R/W if the land remained in federal ownership. The drilling permit would still expire in September of 2017 and would be eligible for renewal under federal ownership.

3.2 Vegetation

3.2.1 Affected Environment

The 709 acres in this parcel are more than 85% undisturbed forested lands. An Environmental Assessment conducted in 2014 in response to the application for exploratory drilling, Gilmore Land Use Application Fairbanks Gold Mining, Inc., DOI- BLM-AK-F020-2014-0005-EA, characterized the vegetation in this area by using aerial photography and the National Wetland Inventory (NWI; NWI 2014) mapping. That EA stated: Vegetation in the proposed project area is typical of interior Alaska boreal forest, which is comprised of four vegetative cover types: forested, shrub, herbaceous, and unvegetated. Based on review of existing data, the majority of the project area is comprised of black and white spruce (Picea mariana and P. glauca) forest or woodland, paper birch (Betula papyrifera) forest, and mixed spruce-birch forest.

Based on site inspections by BLM staff, Parcel G, which is a subset of the area analyzed in the aforementioned EA, is predominately open black spruce forest with an understory of dwarf birch (Betula nana) and willow (Salix sp.) and ground cover of mosses, lichens, and bluejoint grass (Calamagrostis canadensis). Photos 1, 2a, and 2b provide an overview of Parcel G.

3.2.2 Environmental Consequences

Proposed Action The suitability criteria found in 43 CFR 2372.1(7) require an evaluation of the extent to which the subject lands have been changed in character other than by the construction of improvements. In 43 CFR 2372.1(8), the requirement is to quantify the extent of disturbance to the lands and what measures have been taken or are proposed to be taken to recondition the lands. As discussed above, the exploratory drilling has disturbed approximately 40 acres of land. This disturbance includes the clearing of surface vegetation for access roads and drill pad sites. Photo 4 shows an overview of drill pad sites and access roads after clearing and during use. The acreage that has been disturbed from the

14 exploration activities is 6% of the total land acreage in Parcel G. The permit stipulations include requirements for reclamation of all disturbed areas and site inspections in April and June of 2017 confirmed that these areas are being reclaimed and that native vegetation is re-stablishing on these sites. Photos 6-8 show a drill site pad and an access road that have had rehabilitation treatments performed. The overall area of vegetation disturbance and rehabilitation is not large enough to result in a substantial alteration to the character of the land.

There are no expected impacts to the vegetation if the land is conveyed to the state. The rehabilitation of the exploratory drilling areas will not change with a change in land ownership.

No Action Alternative There would be no expected changes in vegetation if the lands remained in federal management. The exploratory drilling permit would expire in September of 2017 unless renewed.

3.3 Recreation

3.3.1 Affected Environment

Parcel G is not covered by a BLM recreation activity management plan but it does have an existing trail system that includes three State of Alaska identified RS2477 trails (Figure 2). RST 650 crosses through the northern end of the parcel, RST 644 runs along the majority of the eastern boundary, and RST 1931 crosses the southern end of the parcel. Based on public comments, many user groups recreate in the area and on these trails, including running clubs, cycling clubs, hunters, hikers, off road vehicle users, skiers, and dog mushers. There are currently two special recreation permittees, Running Club North, and Skiland Summit Adventures. Running Club North organizes and holds an annual race, The Gold Discovery Run, and Skiland Summit Adventures operates a year round tour company.

3.3.2 Environmental Consequences

Proposed Action Recreational use of the parcel has no effect on whether or not the lands are suitable for return to the public domain. There are no criteria for suitability related to recreation.

There would be some impact to recreational use of the parcel if the lands are conveyed to the State. Both of the special recreation permittees would still use BLM lands if Parcel G became state property and they would be required to amend their existing authorizations to remove the use of Parcel G from the permits. If the permittees desired to continue their current use of these lands, they would need to seek authorization from the State. State authorization for their current activities would require completing Commercial Recreation Day Use Registration, which charges a $25.00 annual fee and daily per person user fee of $2.00. These fees are lower than what the permittees pay for the BLM permits. There

15 would be no expected impacts to general recreation users of the area if the lands are conveyed to the State as state lands are open to recreational use. A discussion of the potential impacts to the trails is discussed further in Section 4.3, Comments.

No Action Alternative There would be no changes to recreation if the lands were retained in federal management.

3.4 Wastes, Hazardous or Solid

3.4.1 Affected Environment

This area was originally withdrawn for the purposes of NASA satellite operations in 1965. A history of the area was researched and reported on in a Cultural Resources Survey published by Northern Land Use Research Alaska (NLUR), LLC, in March of 2014 as part of the environmental investigations for the FGMI exploratory drilling EA. The study describes the history of the subject area as being influenced by gold and mineral exploration in the early 1900s and by some military training activities in the 1940s. The Fort Knox gold mine began development in 1994 and has been operating adjacent to Parcel G. The FGMI exploratory drilling within Parcel G began in late September of 2014. Both past and present mineral exploration and past military activity are potential sources of solid and hazardous wastes. Today, much of the parcel is forested and there are little to no signs of past surface disturbance.

3.4.2 Environmental Consequences

Proposed Action According to 43 CFR 2372.1 (4) and (5), it is necessary to describe improvements existing on the lands and the extent to which the lands are contaminated and the nature of the contamination, as the presence of either can affect the suitability of the lands for return to the public domain. The NOAA’s NOI to relinquish reported construction of a communications tower and small communications building enclosed in a chain link fence, and plans to relocate the tower offsite. The NOI to relinquish also stated that the land had not been contaminated and that a Phase I Environmental Site Assessment (ESA) was performed (Appendix D). The ESA was completed in 2017 on behalf of NOAA by a local environmental consulting firm, Travis/Peterson Environmental Consulting, INC., and a copy of the report was provided to BLM on June 28th. During the ESA investigation, a site inspection was performed on June 23rd and included BLM staff, Travis/Peterson staff, and Fort Knox staff familiar with the area, the exploratory drilling, and access to the parcel. During this site inspection, the area where the NOAA communications tower was located was inspected and the tower and building were confirmed to have been removed. However, the chain link fence was still in place as were a couple of small concrete slabs and earth anchors. An old de-energized power line that ran from the existing permitted 138KV line to the communications site was also found (Figure 2). The final power pole next to the communications site had a transformer on it, which are sometimes found to contain PCBs.

16 These issues were reported to NOAA and were quickly addressed by the removal of the fence, the concrete pieces, and the earth anchors. The area was also contoured to match existing slopes. Further investigation of the transformer on the power pole confirmed it did not contain PCBs. Site photos of the reclaimed communications site was are included in the ESA in Appendix D. The de-energized power line could be considered solid waste and the removal of the poles and lines would be difficult and costly. NOAA instead elected to ask the state DNR, who would be the receiving agency if the conveyance takes place, if they would be concerned about the existence of the power poles and lines. The state DNR submitted a letter to BLM, through NOAA, stating that they would accept the parcel with the poles and lines on it (Appendix E).

The only other identified source of potential contamination is the exploratory drilling activity. The ESA states that the exploration being performed does not show any signs of hazardous recognized environmental conditions (HREC) currently or historically. All spills located within the project area have been minor (less than 8 gallons) and have been cleaned up to the standards required by the Alaska Department of Environmental Conservation (ADEC).

The final conclusion of the ESA is that the Phase I investigation revealed no evidence of hazardous substances, petroleum products, or environmental conditions on the property and that Parcel G is suitable for return to the public domain. There are no impacts expected from solid or hazardous wastes if the lands are conveyed to the State.

No Action Alternative An ESA would still have been performed if the withdrawal was relinquished but remained in federal management as an ESA is a requirement for BLM land acquisitions.

4.0 PUBLIC INVOLVEMENT 4.1 Public Notice Public notice began with the publication of maps and the purpose and need of this EA on the BLM National NEPA register on April 21st, 2017. The scoping comment period was open for 37 days and 15 comments were received by email. Notice of the comment period and public meeting (see section 4.2) was published on the Facebook page for BLM Alaska. There was also an article published in the local newspaper, the Fairbanks Daily News- Miner, and a radio interview aired on the local KUAC, National Public Radio station. Finally, an article was published in E&E news, a news organization focusing on news for energy and environmental professionals.

4.2 Public Meeting The BLM held a public scoping meeting on May 18th at a local fire station. Notice of the meeting was sent to approximately 625 resident addresses that were within a 10 mile radius of Parcel G or within a mile wide corridor of the Steese Highway from Fox, Alaska to the Fort Knox mine access road. Posters advertising the meeting were placed in 12 local public places such as the nearest post office, convenience stores, restaurant notice boards, and

17 sporting goods stores notice boards. There were 22 people in attendance and BLM gave a presentation about the relinquishment process and timelines. A question and answer session followed the presentation and information materials were made available to the public, including comment forms and contact information for agency personnel from NOAA, BLM, and the State of Alaska.

4.3 Comments The BLM received fifteen written comments were received from the public. Several of the commenters had concerns on multiple subjects but the main three topics were: the importance of continued access and preservation of the existing trail system, the possibility of increased radio frequency interference to NOAA’s activities, and the possible expansion of the Fort Knox Mine. Two of these concerns are discussed here and discussion of the possible expansion of the mine is covered in Section 5.0, Cumulative Impacts.

The trails in Parcel G that are of concern are the three state identified RSTs (Figure 2). One trail, RST 1931, accesses the parcel from the southern end and bisects the parcel on a roughly east/west line. The second trail, RST 644, is the one with the most amount of linear distance within the parcel. It runs roughly north/south along the eastern side of the parcel and in places is along the boundary between Parcel G and the Fort Knox mine. All three of these trails are state identified rights-of-way, claimed to have been acquired by the state under former 43 U.S.C. 932. If Parcel G is conveyed to the State, then the protections afforded these trails will be in effect. Alaska Statutes 19.30.400 and 19.30.410 discuss these kinds of trails and the state responsibilities and management of them. Under state management, these trails have more regulatory protection than they do under federal management.

In their NOI to relinquish, NOAA clearly states that this parcel was used by the FCDAS to support its satellite operations, that the parcel was used to provide a radio frequency and electromagnetic buffer zone. The notice also states that the parcel is no longer needed for the purposes for which it was withdrawn. There were four comments submitted that expressed concerns about potential radio frequency interference and one of these was also sent to NOAA’s point of contact and the following response was received from that contact, Al Wissman, Chief Data Management & Continuity Operations Branch, Office of the Assistant Chief Information Officer, NESDIS, NOAA:

“…For the last 15 years, NOAA Radio Frequency Engineers have evaluated the radio frequency interference characteristics of equipment (trucks, pumps, power supplies, etc.), being used at the Ft. Knox facility. This arrangement has largely eliminated the possibility of Ft. Knox generated radio frequency interference…Based on our studies, it is our opinion that returning the 709 acres back to the State of Alaska will not impact NOAA’s satellite operations at our Fairbanks facility.”

In light of this response, BLM does not foresee any adverse impacts involving radio frequency interference if Parcel G is conveyed to the State.

18 5.0 CUMULATIVE IMPACTS 5.1 Study Area and Timeframe In the 2014 EA for the FGMI Gilmore Land Use Application (the exploratory drilling), a Cumulative Effect Study Area (CESA) that includes Parcel G was described and analyzed. That CESA and parts of the analyses presented in Sections 4.2 and 4.3 of the Gilmore EA are appropriate to incorporate by reference in this EA. The study area established in the Gilmore EA encompassed a 5-mile radius around the exploratory drilling boundary and was 75,022 acres in size. The timeframe of the analysis was from the 1920s, when became more industrialized, through 2024, ten years from the EA’s baseline of 2014. The Gilmore EA conducted an analysis of surface disturbance using aerial photography and geographic information systems (GIS). The surface disturbance was classified into types: mineral development and exploration, transportation and infrastructure, and recreation.

5.2 Past and Present Actions The Gilmore EA reported in Section 4.3.1, Past and Present Actions, that an approximate total of 10,251 acres of surface disturbance within the CESA had been identified in their analysis and that mineral development and exploration activities comprised the majority of the disturbance (8,735 acres). The source of the activities were identified as either placer or hard rock mining and included the Fort Knox gold mine. An additional 1,255 acres of disturbance was attributed to primary roads and other settlement sources and 261 acres from recreational sources such as ski areas, facilities, and trails.

There have been two previous relinquishments of lands within this withdrawal since 1965. The first one was the relinquishment of 63 acres in 2008 and the second was the relinquishment of 32 acres in 2011. The 63 acre parcel relinquished in 2008 was also state selected under the same General Purposes Grant selection application as Parcel G. Upon revocation of the withdrawal, the selection became effective and the land was conveyed to the State. The state DNR transferred ownership of that parcel to the state Mental Health Trust Authority and it was then sold to FGMI. Eventually, that 63 acres was developed by FGMI to continue their mining activities. The second relinquishment of 32 acres, also under the same state selection application, was conveyed to the state in 2011. This parcel was leased to FGMI to allow them to expand their waste dump area.

In 2014, FGMI applied for and was permitted to conduct mineral exploration drilling within a 2,000 acre area that Parcel G is a subset of. That drilling permit is scheduled to expire in September of 2017. There has been 40 acres of disturbance to the surface vegetation and required rehabilitation will be completed before the permit expires.

BLM received a NOI to relinquish 709.17 acres from NOAA in October of 2016 and this started the process of evaluating whether or not these lands are suitable for return to the public domain.

19 5.2 Reasonably Foreseeable Future Actions Based on the past two NOAA relinquishment requests, it is reasonably foreseeable that the Secretary of the Interior would accept the recommendation of BLM Alaska and decide to either revoke or retain the withdrawal depending on the findings of the field office. Provided the field office finds the lands suitable according to 43 CFR 2372, it is reasonably foreseeable that Parcel G would be conveyed to the State of Alaska as no other federal entities have expressed any interest in these lands.

If the lands are conveyed to the State, then the underlying state mining claims within Parcel G would become effective. These claims are held by FGMI and one of their subsidiaries. Considering the outcome of the previous relinquishments, the current mineral exploration activity, the conveyance of the lands to the State, and the resulting activation of the state mining claims, it is reasonably foreseeable that continuing mineral exploration and development will occur within Parcel G.

5.3 Cumulative Impacts for the Proposed Action The Proposed Action is twofold. First, upon receipt of a complete NOI to relinquish withdrawn lands, BLM must go through the process of determining whether or not the lands are suitable for return to the public domain. This involves evaluating the lands based on the suitability criteria found in regulation. This analysis of suitability and the subsequent recommendation to revoke or retain the withdrawal has no cumulative impacts. The primary result of this action is that BLM regains direct management of lands after revocation. In the absence of the state selection in this case, Parcel G would return to the public domain and be subject to the general land laws.

However, if the Secretary of the Interior decides to revoke the withdrawal in this case, the state selection will become effective upon the publication of a new PLO in the Federal Register and the process of conveyance will start. There is no alternative to this transfer in the absence of another federal agency acquiring or withdrawing the lands for another purpose. The transfer of Parcel G to the State is a connected action to the suitability determination and revocation and is the second part of the Proposed Action.

There are potential cumulative impacts related to the conveyance of the lands to the state. It is reasonably foreseeable that Fort Knox will expand their activities on to their state mining claims. Expansion of mining activities was one of the concerns mentioned by the public in the comments BLM received. Assuming that all of the acres of Parcel G (709.17) were to be disturbed by mining, and including the acres of disturbance from exploratory drilling (40 acres) and those reported in the Gilmore EA (10,251 total), the potential total acres disturbed would be just over 11,000 acres. The CESA as analyzed in the Gilmore EA was 75,022 acres. The total potential disturbance would constitute 15% of these acres, leaving 64,022 acres of undisturbed lands in the area. The development of Parcel G would constitute 6.4% of those 11,000 acres and would affect 1.1% of currently undisturbed lands. Therefore, the proposed action is not expected to have significant cumulative adverse effects on resources.

20 It is also important to note that the transfer of land ownership to the State is the first action that would be taken after the revocation of the withdrawal and once the land is owned by the state, it will be managed according to the State’s Eastern Tanana Area Plan and will be regulated by state statutes and regulations, including state mining laws. BLM will have no jurisdiction over what occurs on these lands after conveyance to the State of Alaska. Any impacts that occur after the lands are owned and managed by the State cannot be mitigated by BLM and the outcome cannot be modified by BLM-decision-making.

6.0 LIST OF PREPARERS Adam Carr, Eastern Interior Field Manager, BLM John Haddix, Assistant Field Manager, BLM Valerie Baxter, Realty Specialist, BLM Robin Mills, Archaeologist, BLM Jason Post, Fish Biologist, BLM Jim Herriges, Wildlife Biologist, BLM Eric Yeager, Outdoor Recreation Planner, BLM Tim Dupont, Outdoor Recreation Planner, BLM Jay Fennell, Geologist, BLM Ben Kennedy, Hydrologist, BLM

7.0 REFERENCES Alaska Department of Natural Resources (ADNR), 2015. Eastern Tanana Area Plan. Division of Mining, Land, and Water.

HDR, 2014. 2014 Environmental Assessment, Gilmore Land Use Application, Fairbanks Gold Mining Inc., DOI-BLM-AK-F020-2014-0005-EA. Prepared for U.S. Department of the Interior, Bureau of Land Management Eastern Interior Field Office and Fairbanks Gold Mining Inc., Fairbanks, Alaska. Prepared by HDR Alaska, Inc. Anchorage, Alaska

NLURA, 2016. 2016 Cultural Resources Survey of the Gilmore Exploration Area. Prepared for Fairbanks Gold Mining Inc., Fairbanks, Alaska. Prepared by Northern Land Use Research, Alaska, LLC.

NWI (National Wetlands Inventory), 2014. Wetlands Mapper. http://www.fws.gov/wetlands/Data/Mapper.html. Accessed 2014.

U.S. Department of the Interior, Bureau of Land Management (BLM), 2008. BLM Handbook H-1790-1 National Environmental Policy Act Handbook.

U.S. Department of the Interior, Bureau of Land Management (BLM), 2016. Eastern Interior Fortymile Record of Decision and Approved Resource Management Plan. December 2016. Eastern Interior Field Office, Fairbanks, AK.

21 U. S. Department of the Interior, Bureau of Land Management (BLM), 2007. Land Report and Decision Record, Plan Conformance, EA-AK-025-07-040. August 2007. BLM, Central Yukon field Office, Fairbanks, AK.

22

Appendix A – Figures and Photos

23

24

25

Photo 1. Looking south and west from the north end of Parcel G.

Photo 2a. Panoramic photo of Parcel G from northern end of parcel.

Photo 2b. Panoramic photo of Parcel G from middle of parcel.

26

Photo 3. Existing R/W for 138KV power line

Photo 4. Typical drill site access routes and pads.

27

Photo 5. Drill rig in operation, April 2016.

Photo 6. Drill site pad re-contoured and reclaimed.

28

Photo 7. Access route with overburden replaced as step 1 for reclamation, April 2016.

Photo 8. Access route, one year after use and reclaimed.

29

Appendix B – Notice of Intent to Relinquish from NOAA

30 UNITl!D STATe5 Dl!PARTMl!NT OP COMMERCE National Oceanic and Atmo•pharic AdministraUon CHIEF ADMINISTRATIVE OFFICER

OCT 18 2016

Bud C. Cribley Alaska State Director Bureau of Land Management 222 W. ih Avenue #13 Anchorage, Alaska 99513

Dear Mr. Cribley:

The Department of Commerce, National Oceanic and Atmospheric Administration (NOAA) wishes to relinquish a 709 .1 7 acre parcel of withdrawn public domain land which is no longer needed by NOAA, Fairbanks Command and Data Acquisition Station (FCDAS). This parcel is part of a larger parcel withdrawn on February 15, 2009, by virtue of the authority vested in the Secretary ofthe Interior by Section 204 of the Federal Land Policy and Management Act of 1976, 43 U.S.C. 1714 (2000); and was previously withdrawn by PLO No. 3708 [30 FR 8753 (1965)], as modified by PLO 6709 [54 FR 6319 (1989)], and partially revoked by PLO No. 7682 [72 FR 71940 (2007)]; and extended by PLO No. 7710 [73 FR 35708 (2008)], F-025943; and as partially revoked by PLO No. 7763 [76 FR 23334 (2011)].

This parcel was used by FCDAS to support its satellite operations, primarily to provide a RF /Electromagnetic buffer zone. The current and future land use provides a reasonably compact development pattern and separates sensitive satellite antennas from potential sources of radio frequency/electromagnetic interference inside the FCDAS. The land to be relinquished has not been significantly changed, disturbed or contaminated. Moreover, no easements or other rights and privileges have been granted to use this parcel. However, NOAA has constructed a communications tower and placed a communications building within the area being relinquished. NOAA will relocate this tower and building to land being retained by NOAA. Please reference the Notice of Intension to Relinquish (Attachment 1), together with the Legal Description and Survey for specific details.

The Environmental Assessment showed there was no evidence of recognized environmental conditions as defined by the American Society for Testing and Materials, except for the exploration of subject property by Fairbanks Gold Mining, Inc. Please reference Fort Knox Phase 1 Environmental Site Assessment, Parcel G, Executive Summary (Attachment 2). NOAA has complied with NEPA, see Categorical Exclusion (Attachment 3). If you have any questions, please contact Steve Hanson ofour Western Regional Center, Real Property Management Division at (206) 526-6160 or at [email protected].

Attachments: 1. Notice to Relinquish 2. Fort Knox Phase 1 Environmental Site Assessment, Parcel G Executive Summary 3. Categorical Exclusion

NOTICE OF INTENT TO RELINQUISH ACTION BY HOLDING AGENCY, 43 CFR §2372.1

Bureau of Land Management Public Land Order (PLO) No. 3708, as modified by PLO No. 6709; and Partially revoked by PLO No. 7682; and extended by PLO No. 7710; and Partially revoked by PLO No. 7763 by Department of Commerce, National Oceanic and Atmospheric Administration's Gilmore Satellite Tracking Station a.k.a. Fairbanks Command and Data Acquisition Station Fairbanks, Alaska

1. NAME AND ADDRESS OF HOLDING AGENCY:

Department of Commerce Department of Commerce National Oceanic and Atmospheric Administration National Oceanic and Atmospheric Administration Office of the Chief Administrative Officer National Environmental Satellite Data Real Property Management Division Information Service Western Regional Center Office of Satellite Operations 7600 Sand Point Way NE, Bldg.-1 Fairbanks Command and Data Acquisition Station Seattle, WA 98115-6349 1300 Eisele Road Fairbanks, AK 99712-1725

2. CITATION OF THE ORDER WHICH WITHDREW OR RESERVED THE LANDS FOR THE HOLDING AGENCY:

Withdrawn from public lands on February 15, 2009, by virtue of the authority vested in the Secretary of the Interior by Section 204 of the Federal Land Policy and Management Act of 1976, 43 U.S.C. 1714 (2000); Public Land Order (PLO) No. 3708 (30 FR 8753 (1965)), as modified by PLO 6709 (54 FR 6919 (1989)), and partially revoked by PLO No. 7682 (72 FR 71940 (2007)); and extended by PLO No. 7710 (73 FR 35708 (2008)), Serial No. F- 025943; and partially revoked by PLO No. 7763 (76 FR 23334 (2011) and consisting of approximately 8,405.27 acres expiring February 14, 2029.

3. LEGAL DESCRIPTION AND ACREAGE OF THE LANDS, EXCEPT WHERE REFERENCE TO THE ORDER OF WITHDRAWAL OR RESERVATION IS SUFFICIENT TO IDENTIFY THEM:

Lands to be relinquished (subject lands) are located within and being a portion of the E1/2 SE1/4 SE1/4, Section 7, Township 2 North, Range 2 East; and SW1/4 SW1/4, Section 8, Township 2 North, Range 2 East; a portion of the W1/2, Section 17, Township 2 North, Range 2 East; a portion of the E1/2 of Section 18, Township 2 North, Range 2 East; and a portion of the NE1/4 of Section 19, Township 2 North, Range 2 East; and a portion of Section 20, Township 2 North, Range 2 East; all within , Fairbanks Meridian, said Sections

NOTICE OF INTENSION TO RELINQUISH ACTION BY HOLDING AGENCY ATTACHMENT-1

are depicted on the plat of “Parcel G”, attached; containing approximately 709.17 acres more or less and said parcel is more particularly described in the Legal Description below.

4. DESCRIPTION OF IMPROVEMENTS EXISTING ON THE LANDS:

There are no major structures within the subject property. The Phase 1 contractor found a power pole with a transformer and a fenced area with a tower and small building. NOAA will be relocating the tower and building to a site being retained by NOAA.

5. THE EXTENT TO WHICH THE LANDS ARE CONTAMINATED AND THE NATURE OF THE CONTAMINATION:

Subject lands contained no recognized environmental conditions except for potential for hazardous substances or petroleum product use or generation resulting from property exploration by Fairbanks Gold Mining Inc.

6. THE EXTENT TO WHICH THE LANDS HAVE BEEN DECONTAMINATED OR THE MEASURE TAKEN TO PROTECT THE PUBLIC FROM THE CONTAMINATION AND THE PROPOSALS OF THE HOLDING AGENCY TO MAINTAIN PROTECTIVE MEASURES:

Subject lands have no known contamination; and no measures to protect the public are required.

7. THE EXTENT TO WHICH THE LANDS HAVE BEEN CHANGED IN CHARACTER OTHER THAN BY CONSTRUCTION OF IMPROVEMENTS:

Subject lands have not been changed; and no constructions of improvements have been made except as noted in paragraph 4, above. Subject lands have been used as a buffer zone for Gilmore Satellite Tracking Station to ensure that background levels of electromagnetic emissions from Fairbanks Gold Mining Inc. remain as low as possible to protect the operational integrity of the station.

8. THE EXTENT TO WHICH THE LANDS OR RESOURCES THEREON HAVE BEEN DISTURBED AND THE MEASURES TAKEN OR PROPOSED TO BE TAKEN TO RECONDITION THE PROPERTY:

Subject lands have seen limited disturbance; and no measures to recondition the property is required.

9. IF IMPROVEMENTS ON THE LANDS HAVE BEEN ABANDONED, A CERTIFICATION THAT THE HOLDING AGENCY HAS EXHAUSTED GENERAL SERVICES ADMINISTRATION PROCEDURES FOR THEIR DISPOSAL AND THAT THE IMPROVEMENTS ARE WITHOUT VALUE:

NOAA will relocate their tower and communications building located from its current location within the area to be relinquished to an area being retained by NOAA.

NOTICE OF INTENSION TO RELINQUISH ACTION BY HOLDING AGENCY ATTACHMENT-1

10. A DESCRIPTION OF THE EASEMENTS OR OTHER RIGHTS AND PRIVILEGES WHICH THE HOLDING AGENCY OR ITS PREDECESSORS HAVE GRANTED COVERING THE LANDS:

Holding agency has not granted any easements or other rights and privileges covering subject lands.

11. A LIST OF THE TERMS AND CONDITIONS, IF ANY, WHICH THE HOLDING AGENCY DEEMS NECESSARY TO BE INCORPORATED IN ANY FURTHER DISPOSITION OF LANDS IN ORDER TO PROTECT THE PUBLIC INTEREST:

The holding agency has a need to preserve a buffer zone to ensure that background levels of electromagnetic emissions remain as low as possible to protect the operational integrity of the Fairbanks CDAS; and provide security against trespassing and unauthorized uses that may potentially interfere with vital station operations. Point of contact: Larry L. Ledlow, at (907) 451-1274 or at the above address at the Office of Satellite Operations, Fairbanks Command and Data Acquisition Station, 1300 Eisele Road, Fairbanks, AK 99712-1725.

12. ANY INFORMATION RELATING TO THE INTEREST OF OTHER AGENCIES OR INDIVIDUALS IN ACQUIRING USE OF OR TITLE TO THE PROPERTY OR ANY PORTION OF IT:

NOAA was approached by Fort Knox Mine, P.O. Box 73726, Fairbanks, AK 99707-3726; expressing interest in subject land in connection with their mining operations. NOAA has made no public announcement of its intent to relinquish subject lands.

13. RECOMMENDATIONS AS TO THE FURTHER DISPOSITION OF THE LANDS, INCLUDING WHERE APPROPRIATE, DISPOSITION BY THE GENERAL SERVICES ADMINISTRATION:

NOAA recommends BLM conveys the subject area of lands to the State of Alaska for mineral development.

LEGAL DESCRIPTION Parcel G

A parcel of land located within Sections 7, 8, 17, 18, 19, and 20, Township 02 North, Range 02 East, Fairbanks Meridian, being more particularly described as follows (all bearings are based on the Alaska State Plane Coordinate System (NAD83) (2011), Zone 3);

COMMENCING at the South West 1/16 corner of said Section 8 and the POINT OF BEGINNING of the herein described parcel;

THENCE, S 01° 03’ 33” W, along the 1/16 line, a distance of 1320.74 feet to the West 1/16 corner of said Sections 8 and 17, said corner also being the North West corner of PLO

NOTICE OF INTENSION TO RELINQUISH ACTION BY HOLDING AGENCY ATTACHMENT-1

7763, thence continuing S 01° 03’ 33” W along the westerly line of PLO 7763 a distance of 330.00 feet to the south westerly corner of PLO 7763;

THENCE, S 41° 31’ 17” E, along the southerly line of said PLO 7763, a distance of 1950.25 feet to the southerly corner of said PLO 7763 on the center ¼ line of said Section 17;

THENCE, S 01° 04’ 45” W, along center ¼ line of Section 17, a distance of 3517.92 feet to the ¼ corner between Section 17 and said Section 20;

THENCE, S 88° 51’ 13” E, with the common south line of Section 17 and north line of Section 20, a distance of 478.71 feet to the northwest corner of PLO 7682;

THENCE, S 04° 37’ 28” W, along the westerly line of said PLO 7682, a distance of 2360.42 feet to the south westerly corner;

THENCE, S 38° 49’ 46” E, along the southerly line of PLO 7682, a distance of 1541.97 feet to its most south easterly corner;

THENCE, S 01° 06’ 28” W, a distance of 1455.29 feet to the northerly line of the Scheelite claim of M.S. 2008;

THENCE, S 73° 34’ 52” W, with the northerly line of said Scheelite claim, a distance of 685.63 feet to its northwest corner;

THENCE, N 54° 43’ 36” W; a distance of 231.00 feet; THENCE, N 01° 30’ 25” E, a distance of 1154.78 feet;

THENCE, N 89° 07’ 42” W, a distance of 1740.61 feet;

THENCE, N 00° 52’ 18” E, a distance of 555.25 feet;

THENCE, N 89° 07’ 42” W, a distance of 627.91 feet;

THENCE, N 00° 52’ 18” E, a distance of 578.37 feet;

THENCE, N 89° 07’ 42” W, a distance of 1119.46 feet;

THENCE, N 00° 52’ 18” E, a distance of 8103.74 feet;

THENCE, N 89° 07’ 42” W, a distance of 292.78 feet;

THENCE, N 00° 52’ 18” E, a distance of 1304.71 feet to the S 1/16 line of said Section 7;

THENCE, S 88° 38’ 03” E, along 1/16 line a distance of 694.20 feet to the S 1/16 corner between Sections 7 and 8;

NOTICE OF INTENSION TO RELINQUISH ACTION BY HOLDING AGENCY ATTACHMENT-1

THENCE, S 88° 43’ 31” E, along the S 1/16 line of Section 8, a distance of 1319.11 feet to the POINT OF BEGINNING and containing 709.17 acres, more or less.

ALASKA STATE LAW AND FAIRBANKS NORTH STAR BOROUGH ORDINANCE REQUIRES THAT INDIVIDUALS DIVIDING PROPERTY MUST COMPLY WITH PROPER SUBDIVISION PROCEDURES. THIS LEGAL DESCRIPTION SHALL NOT BE UTILIZED IN THE TRANSFER OR LEASE OF PROPERTY.

NOTICE OF INTENSION TO RELINQUISH ACTION BY HOLDING AGENCY ATTACHMENT-1

MAP

See attached Land Survey.

NOTICE OF INTENSION TO RELINQUISH ACTION BY HOLDING AGENCY ATTACHMENT-1

MAP

I I I I "l!lr.-­ - --''t---'~ .-----....,l"~'··,r I I I

NOTICE OF INTENSION TO REUNQU ISH ACllON BY HOLDING AGENCY OCTOBER 4, 2016

10/4/16

Appendix C – Cultural Assessment, Essential Fish Habitat, and ANILCA 810 Evaluation

31 Mills, Section l06 Cultural & Paleo Review, DOI-BLM-AK-F020-2017-0016, 6-23-17 Fairbanks District Office, Bureau of Land Management

ASSESSMENT OF CULTURAL AND PALEONTOLOGICAL RESOURCES1

Serial Number F-025943 NEPA Number DOI-BLM-AK-F020-2017-0016 National Oceanic and Atmospheric Applicant Administration (NOAA) Quadrangle Fairbanks Date 6-23-17

Location:

Parcel G consists of 709.17 acres and is located approximately 6.5 miles north and west of Fairbanks and is within the PLO 3709, as amended, boundaries. See Figure I. Fairbanks Meridian, Alaska:

T. 2N., R. 2E., sec, 7, SEl/4SEl/4 sec. 8, SW1/4SWI/4 sec. 17, W 1/2 (portion of), sec. 18, El/2 (portion of), sec. 19, NEl/4 (portion of), sec. 20, NW I /4 and portions of S 1/2

Description of Proposed Action:

The Fairbanks Command and Data Acquisition Station (FCDAS), also known as the Gilmore Satellite Tracking Station, is located east of Fox, Alaska in a valley within an 8,855 acre federal land withdrawal. In 1965, PLO 3708 established the withdrawal for the FCDAS, which was administered by NASA until 1989 when PLO 6709 transferred control of the withdrawal to the National Oceanic and Atmospheric Administration (NOAA). In 2008, BLM issued PLO 7710 to extend the withdrawal through 2029. The FCDAS facilities are concentrated along Eisele Road in the western portion of the withdrawal. The remainder of the withdrawal is predominantly unimproved forested land that serves as a buffer zone lo block external radio interference from hindering the FCDAS mission. NOAA filed a Notice oflntent to Relinquish on a 709.17 acre portion of the withdrawal with the BLM Alaska State Office on October 18, 2016, stating that they have determined that the subject lands, identified as Parcel G, are no longer needed to fulfill their mission.

The subject lands are included in the General Purposes Grant selection application F-029454 pursuant to Sec. 6(b) of

1 This review has been completed in accordance with Section 106 of the National Historic Preservation Act or 1966 (54 U.S.C, 300101) which requires that all Federal undenakings must consider the effects that the undenaking will have on historic propenies (defined as prehistoric or historic districts, sites, buildings, struclures, anifocts, records, or propenies or traditional religious or cultural imponance {36 CFR 800.16(1)(1))); and the Paleontological Resource Prolection Act or 2009 (16 U.S.C. 470aaa) which prohibits the excavation, removal, damage or defocemenl or paleontological resources located on Federal Lands. Mills, Section 106 Cultural & Palco Review, DOI-BLM-AK-F020-2017-0016, 6-23- 17 the Alaska Statehood Act as amended (PL 85-508).

The purpose of the action is to determine if the notice of in tent to relinquish a 709.17 acre portion of a public land withdrawal held by the National Oceanic and Atmospheric Administration (NOAA), under PLO 3709 as amendL-d, meets the requ irements listed in 43 CFR 2372.1-2 and whether or nol the lands are suitable for return to the public domain for disposition under lhe general public land laws.

OFFICE REVIEW

Existing data review and Description of past inventory work in the area

From 1990 through 1992 a small portion of Parcel G was licld invcs0gatoo by a cultural resources contract company (Northern Land Use Research, Inc.; see Dixon et al. 1993). At that time, NLUR located one site inside Parcel G, FAl-00374 (Figure 2).

In 2013 and 2014, the same cultural resources contract company (now Northern Land Use Research Alaska LLC) conducted systematic archaeological surveys across most of Parcel G (sec Figure 2; McGowan and Higgs 20]4). Some lands in the central western portion of Parcel G were not surveyed by pedestrian transects; they were eliminated from survey consideration because of the steepness of the terrain, and the unlikelihood of finding cultural resources on them. The BLM concurred with this survey strategy prior to the surveys occurring.

Figure 2 identifi es two portions of Parcel G that have not been surveyed for cultural resources: the northern-most portion of Parcel G, and a linear portion in the center ofSection 17, in the vicinity ofFAI·00374.

The Alaska Heritage Resources Survey (AHRS) database, maintained by the Alaska Slate Historic Preservation Office, indicates one known cultural or paleontological site inside the boundaries of Parcel G:

FAl-00374. The site consists of several military "fox holes" (shallow pits) that vary in size, but on the average, they arc approximately one meter in diameter with depths of less of than one meter. Military artifacts found in association with this series of holes include C-ration cans and rifle cartridges. Beginning in 1948, army personnel carriers were carried out in the area and troop maneuvers were conducted in the Gilmore and Pedro dome areas. Troop exercises were staged in winter and summer, and camps were established for durations of one day to multiple weeks. The site lies about 300 feet east of the area surveyed by NLURA in 2013, who discovered further evidence of military training (a group of four foxholes~no additional artifacts) in their survey area northwest of FAI-00374.

Accord¼ng to online information mai111aincd in the AHRS, FAI-00374 was determined to be not eligible 10 the National Register. This concurs with a rec(lmmcndation presented in Dixon ct al. 1993.

Anticipated impacts to cultural resources/ Effects on Cultural Resources

Io 2002, the BLM, the SHPO, the Advisory Council on Historic Preservation, and Alaska Department of Natural Resources signed a Programmatic Agreement regarding congressionally authorized land transfers between the BLM and the State of Alaska, pursuant to the Alaska Statehood Act (1958) and the Alaska Mental Health Enabling Act ( 1956). Thal PA states, in part, that to comply with Section l06 and Section I JO of the National Historic Preservation Act ( 1966, as amended), the BLM has to notify the Slate, for any piece of land that will be conveyed to the State, of the existence of any historic properties listed on the National Register, deemed eligible for listing on the register, any properties in the AHRS, and any other properties or sites known lo the BLM that have not been submiUed LO the AHRS. Importantly, no additional survey of the land in question is required prior to any conveyance,

2 Mills, Section 106 Cultural & Palco Review, DOI-BLM-AK-F020-2017-0016, 6-23-17

In short, the BLM is not aware of any other cultural resources on Parcel G at this time.

There arc no anticipated impacts to cultural or paleontological resources by the Proposed Action, i.e., relinquishment of the Parcel G back to the BLM, nor of the anticipated transfer of Parcel G to the State of Alaska.

Recommendation and/or Mitigative Actions Required None.

FIELD EXAMINATION

Description or the area surveyed See Dixon et al. 1993 and McGowan and Higgs 2014. Field survey techniques described are adequate for the level of survey undertaken and any results found.

Survey methodology See Dixon et al. 1993 and McGowan and Higgs 2014. Field survey techniques described are adequate for the level of survey undertaken and any results found.

Results of survey FAl-00374.

SUMMARY: CONCLUSIONS & RECOMMENDATIONS

After thorough cultural resources pedestrian surveys across most of Parcel G, only one known cultural site is known to exist, FAI-00374. This site was found to be not eligible to the National Register of Historic Places.

In 2002, the BLM, the SHPO, the Advisory Council on Historic Preservation, and Alaska Department of Natural Resources signed a Programmatic Agreement regarding congressionally authorized land transfers between the BLM and the State of Alaska, pursuant to the Alaska Statehood Act ( 1958) and the Alaska Mental Health Enabling Act ( 1956). That PA states, in part, that to comply with Section 106 and Section 110 of the National Historic Preservation Act ( 1966, as amended), the BLM has to notify the State, for any piece of land that will be conveyed to the State, of the existence of any historic properties listed on the National Register, deemed eligible for listing on the register, any properties in the AHRS, and any other properties or sites known to the BLM that have not been submitted to the AHRS. Importantly, no additional survey of the land in question is required prior to any conveyance.

The BLM is not aware of any other cultural resources on Parcel G at this time. There are no anticipated impacts to cultural or paleontological resources by the Proposed Action, i.e., relinquishment of the Parcel G back to the BLM, nor of the anticipated transfer of Parcel G to the State of Alaska.

Robin Mills, Archaeologist & Paleont y Coordinator BLM-FDO Eastern Interior FO

3 Mills, Section 106 Cultural & Palco Review, DOITBLM-AKTF020-2017T00l6, 6-23-17

References Cited

Dixon, E. James, Robert Sattler and Andrew Higgs 1993 Fort Knox Project Cultural Resources Survey. Report prepared for Fairbanks Gold Mining by Northern Land Use Research, Inc., Fairbanks. NLUR Technical Report 8.

McGowan, Sarah and Andrew Higgs 2014 Fort Knox Geotechnical Exploration Area Cultural Resources Survey, Fairbanks, Alaska. Report prepared for Fairbanks Gold Mining, Inc., Kinross Fort Knox, Fairbanks, AK. Project name and number as submitted to the State Historic Preservation Office, Anchorage, AK: Fort Knox Geotechnical Exploration Area Cultural Resources Survey, Fairbanks, Alaska, #2042.00.

4 Mills, Section 106 Cultural & Palco Review, DOI-BLM.AK-F020-2017-0016, 6-23-17 ..., I ;: : ·· ·. NOAARefin ishmeQt - Parcel G :::;;"". ~. • I ._ -- -~ :; ' : •; -­ .,,( - · ~: .,~ , ~= ~• :: ~H:: a: •••I fclrllitnaUfle,c.n'lftllFal. - Amm; "', '.. :. ": .. . "' ..:...... ,.. -.:...... :~ • j;/ , ~-; :;.s .:!··· ~- ·~··_,,,,, _ o· -lle- ~ ~­ \ ' -.;~· -: ; ;:;:·• • C'! !; ~. •-'.- nvt.ff acns l .~""+-. •1.n . :;• •·· - --- 'lta!S .. rt wd'i' !~~3•;.;1·•:~;- '·:: i:+~ f'-. ~· ~:• , -al~-­ c:.,. __: ~ -~... - - .. . · · ·· · · ~· ·· ...... •• ~ - A p NOM~••a,,.,..,.~ N \ ' ' ~~... · , .,;.;~::~~~=,:·::A:·!·.:·:- •·.. .,...,. 1~,,, ~.... · i ··--~...... , . ;_ . •••••...... ,.:···"•1 • ­ ·-- 1 -~ ...-L A ~•.!.& • ,._. ... .,...,, 1 • - '-••i ••• ,,.,,... -,_,_ ------1t ---wq. , ::_ ...... ~t:...... 'r-•·---- .. ._.J~· "'- i ~ ~;...:,::-~.!..-!':!·~;.::· ·:· · &laR·~~tltmas I , _* ""' --. •·' :-:-~ ... , -, • r.;: .. , · •· •••. • - - (ffl t :.mi _.._,.,_,,•r ~ ~, ..~r/!:ffiiiiiii? ;J; ;r · 11./ tf!-'1 41,i ::- •. :~ •• .••.~ ·:-,~ ".lo.tr' : ••~.:. ·- --...... ~ - .,,. . •· . ·~ -~. •. ~~·· a .. ,.,; ,;:~: ·t: :~~;;;;,.·~- ~ -':t=,-... ·1~ ,-~~ :: ;::;~·-~ ;:::, _,.. ] , ' r ... : ; !;: ...... ;#'... .."" '' ·••• • . I .i _,,. _..,_ ..,r· ...i • · / ' r . , ...... •• ' • .• l :· ., · ~ ... .- _,._., •• f ff ••• .,:•"''''••- :~· .,. ~.~ . ..•- • ,·•­,.. .. - J ••.- f - • • .. • ...... , ...... - , ' •• 'I. I -f. • • • • • ·-... I .,. •Paree• Gl .•·· ·· ·· ··J::iit,:,-- 1:f· ::,.: · ...... ,. ":•· .::. 1 · • . , .. :•:· .... ,11-:.1..,~}..,:-=,-"" l .. !I •• : : : ; : : • •• • : • •• r. .. ':. ::: ::. . : .. ; .:.• • ;:. . ~ -... :=. .; . ~ ~ --.:-!"'~-~.. (709:17 ncJ{ ~.· ·....r:::: ,i ,. , ·~r;·:•; .••... ;.. :·· ... ,,:H-1.:.:...:.:..;,,:.::::~~:.. -·-.t 'f,­ ~- , .· · r ttrt:=::(:}:: ) :·:::: i/:::==:trr:: ~../ f z:;i1 ::;:::; .. ' t ,I'~ ..,,/// t l j•••••••;~• ...... : . •• ., ~... ·• •• • •••·•• ' j ·" .. ;:•;•• I ,./ ,-- .,_r//, t'·~: ::: ~ =~ ) ~ :~~.: ~:: ·: •::: ::: :::;_~·)::;: :..=;:: :~.:: ~:• ·, ,. t: .. ::~r·:,•• ::.. · ,:: ...... ··· ·· t .,...... • ,');: ' • - ~ ., • e I. I I fll lj e I: tit + • o. I • ._. fl It ,., 1 1 1 ., '!'Ii, 1 O 16 .·/ '' ~<-1/"/, • .• 11 .. 'l '" .. ~...... •. ::i :; --c ...,'. ;:· ···- ~-· // '' ...... :-·'4: "•i.fj; =){:if{:;;·::: ::.TF"i~t }/::i.iliJifIii:·:;: . ' .?,?.""~l~t .::-: ., ·;: :::; .. :r'"~;· ::; .. ::·::::::j:;.·: ·•, .: // :1 l -­ ] •·-~ ,..., --~~A('.;ci'."~:i::Cl~:L~:'tJ~i1fj[f~~i.1i1 ~ .·- ­ r I _':> , :.J.. __. .. NOAA Withdrawal a~, I .. t ,. 1111 Ill {! Ill! Ill! t :,' ...... I, ... ~-~ j ,,#-....·•,. .;._r::. ~r- · /.,,. I J ~.· 4 ,.,,, · I ', ~ ~" .'-j-.. '·.. ' . if •._ ~ ~~~-- ---~.., ...... 1t . ~ ' J{ • -~ · .., ..~--·---, ~ ·-·-~ .. .. ,::::-...~ 1• I . , ;: I !'J ~~:,~ • ._ l I .J ) ¢~ I ---~.. - .. £.:...;_:'.;:-- I l f . .. ,..__ ·~~~ r-:--- .....-,_,..., - ...... ~ .•.,(l{,l ..::..~ .,==-==::.=___ :=­ ' -- - Figure 1. Location ofthe Parcel G proposed relinquishment within the NOAA withdrawal, northwest of Fairbanks, Alaska.

5 Mills, Section I 06 Cultural & Palco Review. DOl•BLM•AK· F020· 20I7.0016, 6·23• I 7

FAI-00374

Figure 2. Yellow polygon is hand drawn approximation of the area of NL URA archaeological survey in 2013. Blue outline polygon is hand drawn approximation of NLUR archaeological survey in early l 990s. Red polygon outline is hand drawn approximation of boundary Parcel G.

6 Essential Fish Habitat (EFH) Clearance

CASE FILE: F-025943

DATE: July 18, 2017

EA NUMBER: DOI-BLM-AK-F020-2017-0016

Proposed Action: The National Oceanic and Atmospheric Administration (NOAA) intends to relinquish 709 acres back to the BLM who will then transfer the land to the Department of Natural Resources, State of Alaska.

EFH Finding: Based on the finding that there are no salmon species catalogued by the State of Alaska in the area encompassed by the proposed action and under BLM management, the proposed action is assigned the EFH determination: No affect, and no further EFH consultation is required.

Prepared by: Jason Post, Eastern Interior Fish Biologist COMPLIANCE WITH

ANILCA SECTION 810 EVALUATION AND FINDINGS

DOI-BLM-AK-F020-2017-0016CASEFILE/PROJECT NUMBER: F-025943

Location: Parcel G consists of 709.17 acres and is located approximately 6.5 miles north and east of Fairbanks and is within the PLO 3708, as amended, boundaries. Legal Description: Fairbanks Meridian, Alaska T. 2N., R. 2E., sec, 7, SE1/4SE1/4 sec. 8, SW1/4SW1/4 sec. 17, W1/2 (portion of), sec. 18, E1/2 (portion of), sec. 19, NE1/4 (portion of), sec. 20, NW1/4 and portions of S1/2.

Proposed Action: NOAA filed a Notice of Intent to Relinquish (NOI) of Parcel G. The lands and minerals within Parcel G will be recommended suitable for return to the public domain and disposition under the general land laws. NOAA will be notified that BLM will assume accountability and responsibility for the lands and the recommendation for revocation of the withdrawal for Parcel G will be forwarded to the Secretary of Interior for final decision and publication in the Federal Register.

Evaluation of Effects on Subsistence Uses and Needs

Fisheries, wildlife and other resources 1) Expected reduction, if any, in harvestable resources: The proposed action will have no direct effect on harvestable resources. Indirect and cumulative effects will be negligible.

The NOAA withdrawal is entirely within the Fairbanks North Star Bourough, where all residents are considered non-rural. All lands in Parcel G are state-selected and so are not considered public lands for Federal subsistence purposes. The nearest sizable area open to Federal subsistence use is the White Mountains National Recreation area, approximately 14 miles distant. Only wide-ranging species could potentially be affected by future possible changes in land use under state management.

2) Expected reduction, if any, in availability of resources due to alterations in resource distribution, migration, or location: No direct impact on the availability of resources will result from the proposed action. Any indirect or cumulative impacts would be negligible. See #1.

Access

1) Expected limitations, if any, in the access of subsistence users resulting from the proposed action: No direct impact on the access of subsistence resources will result from the proposed action. See #1.

2) Availability of other lands, if any, for the purposes sought to be achieved: NOAA requested relinquishment of this specific portion of the withdrawal, returning it to BLM management. As described in the EA, BLM has no discretion beyond assessing suitability.

3) Other alternatives, if any, which would reduce or eliminate the use, occupancy, or disposition

32 of Public Lands needed for subsistence purposes: The No Action Alternative.

Finding This proposed action will not significantly restrict subsistence uses. No reasonably foreseeable and significant decrease in the abundance of harvestable resources, alteration in the distribution of harvestable resources, or limitations on harvester access will result from the proposed action.

PREPARED BY: /s/ Jim Herriges DATE: July 24, 2017 Jim Herriges, Wildlife Biologist

33

Appendix D – Environmental Site Assessment

Note: Appendices D-H contain hundreds of pages and paper copies are available for review at the BLM - Fairbanks District Office in Fairbanks, Alaska

34 PHASE I ENVIRONMENTAL SITE ASSESSMENT

PARCELG FAmBANKS, ALASKA

Prepared for NOAA FAIRBANKS COMMAND AND DATA ACQUISITION STATION (FCDAS) Eisele Road, Fairbanks, Alaska 99712

Prepared by

TRAVIS/PETERSON ENVIRONMENTAL CONSULTING, INC. 329 2nd Street Fairbanks, Alaska 99701

Travis/Peterson Environmental Consultlng, Inc.

Project Number 1342-17

June, 2017 NOAA, 1342-17 June 28, 2017 Parcel G Phase I ESA Pagei

EXECUTIVE SUMMARY

Introduction Travis/Peterson Environmental Consulting, Inc. conducted a Phase I Environmental Site Assessment in conformance with American Society for Testing and Materials (ASTM) Practice E2247-16, Standard Practice for Environmental Site Assessments for Forested or Rural Properties, in conjunction with The Department of the Interior Bureau of Land Management (BLM), Pre-Acquisition Environmental Site Assessments Handbook H-2000-01 for the subject NOAA Fairbanks Command and Data Acquisition Station (FCDAS) property known as Parcel G. NOAA has notified BLM of intent to relinquish the subject property; return Parcel G to public domain. BLM will subsequently offer conveyance of ownership of the subject property to the State ofAlaska.

The legal description ofthe subject property according to the State of Alaska Record of Survey:

A parcel ofland located within Sections 7~ 8, 17, 18, 19, and 20, Township 02 North, Range 02 East, Fairbanks Meridian, being more particularly described as follows (all bearings are based on the Alaska State Plane Coordinate System (NAD83)(201 l), Zone 3:

"Commencing at the South West 1/1 6 comer ofsaid Section 8 and the Point ofBeginning ofthe herein described parcel:

Thence, S 0J0 03' 33" W, along the 1/16 line, a distance of 1320.74 feetto the West 1/16 comer ofsaid Section 8 and 17, said comer also being the North-West comerof PLO 7763, thence continuing S 01' 03' 33" W along lhc westerly line ofPLO 7763 a distance of330.00 feet to the south westerly comer ofPLO 7763;

Thence, S 41 ° 31' 17" E, along the s011therly line ofsaid PLO 7763, a distance of 1950.25 feet to the southerly comer of PLO 7763 on the center ¼ line ofsaid Section J7;

Thence, S 01° 04' 45" W, along center¼ line of Section 17. a distance of3517.92 feet to the¼ comer between Section 17 and said Section 20;

Thence, S 88° 51' 13" E, with the common south line ofSection 17 and north line of Section 20, a distance of478.71 feet to the northwest comer ofPLO 7682;

Thence, S 04° 37' 28" W, along the westerly line ofsaid PLO 7682, a distance of2360.42 feet to the south westerly comer;

Thence, S 38° 49' 46" E, along the southerly line ofPLO 7682, a distance of1541.97 feet to its most south easterly corner;

Thence, S OIO 06' 28" W, a distance of 1455.29 feet to the northerly line of the Schee lite claim of M.S. 2008;

Thence. S 73° 34' 52" W, with the northerly Une ofsaid Scheelite claim, a distance of685.63 feet to its northwest comer;

Thence, N 54° 43' 36" W, a distance of231.00 feet;

Thence. N OIO 30' 25" E, a distance of [ I 54.78 feet;

Thence, N 89° 07' 42" W, a distance of ]740.61 feet;

Travis/Peterson Environmental Consulting, Inc. NOAA, 1342-17 June 28, 2017 Parcel G Phase I ESA Page ii

Thence, N 00° 52' 18" E, a distance of555.25 feet;

Thence, N 89° 07' 42" W, a distance of627.91 feet;

Thence, N 00° 52' 18" E, a distance of578.37 feet;

Thence, N 89° 07' 42" W, a distance of1119.46 feet;

Thence, N 00° 52' 18" E, a distance of8103.74 feet;

Thence, N 89° 07' 42" W, a distance of292.78 feet;

Thence, N 00° 52' 18" E, a distance of 1304.71 feet to the S 1/16 line of said Section 7;

Thence, S 88° 38' 03" E, along 1/16 line a distance of694.20 feet to the S 1/16 comer between Sections 7 and 8;

Thence, S 88° 43' 31" E, along the S 1/16 line of Section 8, a distance of 1319.11 feet to the Point of Beginning and containing 709.17 acres, more or less."

Purpose The purpose of this assessment is to determine the presence or absence of recognized environmental conditions (RECs), as defined in ASTM E2247-16 in conjunction with the BLM Pre-Acquisition Environmental Site Assessment Handbook H-2000-01, in connection to the subject property. H-2000-01 also required assessment of whether non-scope issues which may attach liability to BLM are present. A public records review, site inspection, user provided information, and interviews were used to characterize the subject property.

Findings The following potential RECs and non-scope issues were found: • Exploration of the subject property by FGMI presents the potential for hazardous substance or petroleum product use or generation. Currently no signs support that the exploration should be considered a HREC or REC. Minor spills 8-gallons or less have occurred in the subject area but have all been handled and cleanup to ADEC's standards and considered cleanup complete; • The final power pole on the de-energized power line facility was identified to be holding a transformer. The transformer shows no signs of leakage or corrosion and contains a label stating, "no PCBs."; and • The de-energized power line facility beginning at the Golden Valley Right-of Way on the north boundary of the subject property leading to the antenna tower site, may be considered a solid waste and physical safety hazard if the gaining land owner declines to accept conveyance ofthe subject property as is, with the existing de-energized power line and transformer (see Section 5.3.12).

Opinions The opinion on each of the potential RECs and non-scope issues identified in Section 7 are detailed below. 1. The exploration being performed does not show any signs ofHREC or RECs currently or historically. All spills located within the project area have been minor and handled/cleaned up to ADECs standards. Travis/Peterson Environmental Consulting, Inc. NOAA, 1342-1 7 June 28, 2017 Parcel G Phase I ESA Page iii

2. The non-scope solid waste (de-energized power line facility and power pole with the transformer) identified in the historic antenna tower area, in TPECI personnel's opinion does not pose a potentia1 for REC. The transfo rmer located on the power pole is labeled with "no PCBs" and does not show signs ofcorrosion or fluid leakage. 3. The de-energized power line facility is a potential solid waste and physical safety liability for NOAA which may attach to BLM if the State of Alaska declines to accept conveyance of the subject property with the de-energized power line facility present.

Additional Investigations TPECI does not fee l that there are any additional investigations that need to be performed on the property to detect the presence of hazardous substances or petroleum products.

Data Gaps It is TPECI's professional opinion that there are no data gaps that affect the ability to identify RECs.

Conclusions TPECI has performed a Phase I ESA in conformance with the scope and limitations of ASTM Practice £2247-16, in conjunction with the BLM Pre-Acquisition Environmentat Sjte Assessments Handbook H-2000-0 I of the subject property with the legal description outlined in Section 2J . Any exceptions to, or deletions from, this practice are described in Section 10 ofthis report. This Phase I has revealed no evidence of hazardous substances, petroleum products, or environmental conditions on this real property. No further inquiry is needed for purposes of all appropriate inquires; therefore, this property is suitable for acquisition.

Travis/Peterson Environmental Consulting, Inc. NOAA, 1342-17 June 28, 2017 Parcel G Phase I ESA Page iv

TABLE OF CONTENTS

1.0 INTRODUCTION...... 1 1.1 Purpose...... I 1.2 Scope ofservices...... I 1.3 Significant Assumptions ...... 2 1.4 Limitations and Exceptions ...... 2 1.5 Special Terms and Conditions ...... 3 1.6 User Reliance ...... 3

2.0 SITE DESCRI'PTION ...... 3 2.1 Location and Legal Description ...... 3 2.2 Site and Vicinity General Characteristics ...... 4 2.3 Current Use of the Property ...... 5 2.4 Descriptions of Structures, Roads, Other Improvements on the Site ...... 5 2.5 Current Uses ofAdjoining Properties ...... 6

3.0 USER PROVIDED INFORMATION ...... 6 3.1 Title Records ...... 6 3.2 Environmental Liens or Activity and Use Limitations ...... 6 3.3 Specialized knowledge ...... 6 3.4 Commonly Known or Reasonably Ascertainable Information ...... 6 3.5 Valuation REduction for Environmental issues ...... 6 3.6 Owner, Property Manager, and Occupant Information ...... 7 3.7 Reason for Performing Phase I ...... 7 3.8 Other ...... 7

4.0 RECORDS REVI.EW ••••••••••••••...... •••..•.••••••••••••••.•••••••••••••••.•.•..•.••..7 4.1 Standard Federal, STATE, and TRIBAL Environmental Record Sources ...... 7 4.2 Additional Environmental Record Sources ...... 8 4.3 Physical Setting Sources ...... 9 4.4 Historic Use Information on the Property ...... 9 4.4. l Aerial Photography ...... 9 4.4.2 Property Tax Files ...... 10 4.4.3 United States Geological Survey Topographic Maps ...... 10 4.4.4 User Provided Cultural Resource Survey ...... 11 4.5 Historical use information on adjoining properties ...... 12

5.0 SITE RECONNAISSANCE ...... 12 5.1 Methodology and limiting conditions ...... 13 5.2 General Site Setting ...... 13 5.2.1 Current Uses of the Property ...... 13 5.2.2 Past Uses Ofthe Property ...... 13 5.2.3 Current Uses ofAdjoining Properties ...... 14 5.2.4 Past Uses Of Adjoining Properties ...... 14 5.2.5 Current or Past Uses in the Surrounding Area ...... 14 5.2.6 Geologic, Hydrogeologic, Hydrologic, and Topographic Conditions ...... 14 5.2.7 General Description of Structures ...... 14

Travis/Peterson Environmental Consulting, Inc. NOAA, 1342-17 June 28, 2017 Parcel G Phase I ESA Pagev

5.2.8 Roads ...... 14 5.2.9 Potable Water Supply...... ,... 14 5.2. lO Sewage Disposal System ...... 14 5.3 Exterior Observations ...... ••.••.•..•.•.••...... •...... •...... ••...... 15 5.3. ] Hazardous Substances and Petroleum Products - Identified Uses...... 15 5.3.2 Storage Tanks ...... 15 5.3.3 Odors ...... , ...... ,,.,...... 15

5.3 ...4 Pools of Liquids ...... 4 •• 4 ...... l 5 5.3.5 Drums ...... 15 5.3.6 Hazardous Substances and Petroleum Products Containers... •. ..•••...••.••••...... 15 5.3.7 Unidentified Substance Containers ...... 15 5.3.8 PCBs ...... ,...... ~ ...... +•+•+ ...... 15 5.3.9 Pits, Ponds, or Lagoons ...... 15 5.3.10 Stained Soil or Pavement ...... 15 5.3.11 Stressed Vegetation ...... •..••.•••...•...... •.••...•. 15 5.3.12 Solid Waste...... ~·~······················ ...... 16 5.3.13 Wastewater ...... 16 5.3. )4 Wells ...... 16 5.3.15 Septic Systems...... 16 5.3.16 Non-Scope Issues ...... 16 5.3.17 Physical Hazards ...... 16 5.4 Interior Observations ...... 17

6.0 INTERVIEWS...... 17 6.1 Owner...... ~·· · ·11••·······•+ ...... 17 6.2 Site manager...... ~~ ··········...... 17 6.3 occupants...... 18 6.4 Local Governmental officials ...... 18 6.. 5 Others ...... ~ ...... -.... 19

7.. 0 FINDINGS '!' ...... 19

8.0 0 PINIONS...... - 19

9.0 ADDITIONAL INVESTIGATIONS ...... - ...... 19

10..0 DATA GAPS...... -...... - ...... - .... - .. 20

11 .. 0 CONCLUSIONS ...... - ...... 20

12.0 DEVIATIONS ...... 20

13.0 ADDITIONAL SERVICES...... - ...... 20

14.0 REFERENCES...... 2O

15.0 SIGNATURE OF TUE ENVIRONMENTAL PROFESSIONAL ...... - ...... 22

16.0 QUALIFICATIONS OF THE ENVIRONI\-IENTAL PROFESSJONAL...... 22 Travis/Peterson Environmental Consulting, Inc. NOAA, 1342-17 June 28, 2017 Parcel G Phase I ESA Page vi

LIST OF APPENDICES

Appendix A Site (Vicinity) Map Appendix B Site Plan Appendix C Site Photographs Appendix D Historical Research Documentation Appendix E Regulatory Records Documentation Appendix F Interview Documentation Appendix G Special Contractual Conditions between User and Environmental Professional Appendix H Qualifications ofthe Environmental Professional

Travis/Peterson Environmental Consulting, Inc. NOAA, 1342-17 June 28, 2017 Parcel G Phase I ESA Page I

1.0 INTRODUCTION Travis/Peterson Environmental Consulting, Inc. (TPECI) conducted a Phase I Environmental Site Assessment (ESA) in conformance with American Society for Testing and Materials (ASTM) Practice E2247-16, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process for Forestland or Rural Property for Parcel G. This Phase I ESA has also been prepared in conformance with the Bureau of Land Management's (BLM) Handbook Pre-Acquisition Environmental Site Assessments H-2000-01. Parcel G is subsequently referred to in this report as the 'subject property'.

1.1 PURPOSE The purpose of the Phase I ESA is to provide an objective, independent, professional opinion of the potential Recognized Environmental Conditions (RECs), if any, associated with the subject property.

RECs mean the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property:

1. Due to any release to the environment; 2. Under conditions indicative of a release to the environment; or 3. Under conditions that pose a material threat ofa future release to the environment.

The term is not intended to include de minimis conditions that generally do not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies. Conditions determined to be de minimis are not RECs.

1.2 SCOPE OF SERVICES This Phase I ESA conforms to the scope of services out1 ined in the ASTM E2247-]6 as well as the BLM Pre-Acquisition Environmental Site Assessment Handbook H-2000-01. No deviations from this practice were encountered as described in Section 10 ofthis report.

The scope of this Phase I ESA includes the following: • Records Review - Review of reasonably ascertainable records (standard federal, state, and tribal environmental records, additional environmental records, available historic records, and other available environmental reports, etc.); • Site Reconnaissance - A visit and inspection ofthe subject property including general site setting, interior and exterior observations, and uses and conditions of the property and adjoining properties; • Interviews - Interviews conducted with present and past owners, operators, and/or occupants ofthe subject property, if feasible and/or applicable; and with local and/or state government officials (if feasible and/or applicable); and • Report Preparation - The evaluation of information and the preparation of the report including the findings, opinions, conclusions, and recommendations, ifany, for additional investigation(s).

Travis/Peterson Environmental Consulting, Inc. NOAA, 1342-17 June 28, 2017 Parcel G Phase I ESA Page 2

1.3 SIGNIFICANT ASSUMPTIONS This Phase I ESA provides an objective, independent, professional opinion of the potential RECs, if any, associated with the subject property. However, even with the proper application of the methodologies presented in the ASTM E2247-16, there is the possibility that there may be conditions that exist on the subject property that could not be identified within the scope of the assessment or which were not reasonably ascertainable from the available infonnation. TPECI is not obligated to identify mistakes or insufficiencies in information provided. TPECI believes the infonnation obtained from the user, record reviews, and the interviews concerning the subject property is reliable.

The identification of RECs in connection with the subject property may impose an environmental liability on owners or operators of the subject property, reduce the value of the subject property, or restrict the use or marketability of the subject property. Therefore, further investigation may be warranted to evaluate the scope and extent of potential environmental liabilities.

1.4 LIMITATIONS AND EXCEPTIONS This report has been prepared for the use by NOAA and should not be reproduced or disseminated without the written approval of NOAA. TPECI has retained a copy of this report. No additions or deletions are pennitted without the express written consent ofTPECI. Use ofthis report in whole or in part by parties other than NOAA and BLM without authorization 1s prohibited.

Infonnation obtained from a reasonably ascertainable records review, the site inspection, user provided infonnation, and interviews were used to characterize the subject property. The findings and conclusions are limited to and by the available and provided infonnation and the quality and completeness of answers provided to the proposed questions during the interview(s). The user or environmental professional is not obligated to identify mistakes or insufficiencies or to review every possible record that might exist with respect to a property. Events occurring on the subject property after the date ofthe inspection are beyond the scope of this report. TPECI makes no expressed or implied representations or warranties regarding any changes in condition ofthe premises after this date.

No Phase I ESA can wholly eliminate uncertainty regarding the potential for RECs in connection with the subject property. Performance of this practice is intended to reduce, but not eliminate, uncertainty regarding the potential for RECs in connection with the subject property. A Phase I ESA does not include any testing or sampling of materials (for example, soil, water, air, building materials).

If information becomes available concerning the subject property that was not included in this report, it should be made available to TPECI so that the conclusions and/or recommendations can be re-examined and modified, if applicable.

This Phase I ESA is valid for 180 days following the completion of the assessment.

Travis/Peterson Environmental Consulting, Inc. NOAA, 1342-(7 June28,2017 Parcel G Phase I ESA Page3

1.5 SPECIAL TERMS AND CONDITIONS Authorization to perfonn this assessment was given by NOAA and BLM on June 2, 2017. NOAA and BLM agreed to the scope ofservices and schedule proposed for Phase I ESA.

1.6 USER RELIANCE This report is for the use and benefit of, and may be relied upon by, NOAA and BLM and any of its affiliates, and third parties authorized by NOAA and BLM.

2.0 SITE DESCRIPTION The following sections provide an overview of the site location, current use, and development.

2.1 LOCATION AND LEGAL DESCRIPTION The subject property is located approximately 25 miles northeast of Fairbanks, Alaska at the western boundary ofthe existing Fort Knox Gold Mine.

The legal description ofthe subject property is:

A parcel of land located within Sections 7, 8, 17, 18, 19, and 20, Township 02 North, Range 02 East, Fairbanks Meridian, being more particularly described as fo Uows (all bearings are based on the Alaska State Plane Coordinate System (NAD83) (2011), Zone 3:

"Commencing at the South West 1/16 comer ofsaid Section 8 and the Point ofBeginning ofthe herein described parcel:

Thence, SO 1° 03' 33" W, along the 1/16 line, a distance of 1320.74 feet to the West 1/16 comer ofsaid Section 8 and 17, said comer also being the North-West comer ofPLO 7763, thence continuing S O1' 03' 33" W along the westerly line ofPLO 7763 a distance of330.00 feet to the south westerly comer ofPLO 7763;

Thence, S 41 °31' 17" E, along the southerly tine ofsaid PLO 7763, a distance of 1950.25 feet to the southerly comer ofPLO 7763 on the center¼ line ofsaid Section f7;

Thence, S 01° 04' 45" W, along center¼ line of Section 17, a distance o f3517.92 feet to the ¼ comer between Section 17 and said Section 20;

Thence, S 88° 51' 13" E, with the common south line of Section 17 and n.orth line ofSection 20, a distance of478.71 feet to the northwest corner ofPLO 7682;

Thence, S 04° 37' 28" W, along the westerly line ofsaid PLO 7682, a distance of2360.42 feet to the south westerly comer;

Thence, S 38° 49' 46" E, along the southerly line ofPLO 7682, a distance of 1541.97 feet to its most south easterly comer;

Thence, S 01° 06' 28" W, a distance of 1455.29 feet to the northerly line of the Scheelite claim ofM.S. 2008;

Thence, S 73° 34' 52" W, with the northerly line of said Scheelite claim. a distance of685 .63 feet to its northwest comer;

Thence, N 54° 43' 36" W, a distance of23 l.00 feet;

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Thence, N 01° 30' 25" E, a distance of 1154.78 feet;

Thence, N 89° 07' 42" W, a distance of 1740.61 feet;

Thence, N 00° 52' 18" E, a distance of555.25 feet;

Thence, N 89° 07' 42" W, a distance of627.91 feet;

Thence, N 00° 52' 18" E, a distance of 578.37 feet;

Thence, N 89° 07' 42" W, a distance of 1119.46 feet;

Thence, N 00° 52' 18" E, a distance of 8103.7 4 feet;

Thence, N 89° 07' 42" W, a distance of292.78 feet;

Thence, N 00° 52' 18" E, a distance of 1304.71 feet to the S 1/16 line ofsaid Section 7;

Thence, S 88° 38' 03" E, along 1/16 line a distance of694.20 feet to the S 1/16 comer between Sections 7 and 8;

Thence, S 88° 43' 31" E, along the S 1/16 line ofSection 8, a distance of 1319.11 feet to the Point of Beginning and containing 709.17 acres, more or less."

The subject property is: I. Owned by the United States ofAmerica; 2. Surface estate is managed by NOAA subject to PLO 3708, as modified by PLOs 6709, 7682, 7710, 7763 (collectively the withdrawal); 3. Subsurface estate is managed by the BLM; 4. Has been selected by the State ofAlaska pursuant to the Alaska Statehood Act; and 5. Entirely covered by State Mining Claims located by FGMI or an FGMI affiliate pursuant to Alaska Statute (A.S.) 38.05.275 and Alaska Administrative Code (AAC) IIAAC 86.115.

The subject property encompasses approximately 709 .17 acres of land and lies within the U.S. Geological Survey Livengood A-1 and Fairbanks D-1 topographic quadrangle maps.

2.2 SITE AND VICINITY GENERAL CHARACTERISTICS The following text is adapted from the 2016 Cultural Resources Survey of the Gilmore Exploration Area, which covered Parcel G (NLURA, 2016):

The study area is located within the broader Yukon-Tanana Upland physiographic region of central Alaska (Wahrhaftig 1965). The uplands in this area consist of broad rolling hills and domes rising to between 2,000 and 4,500 feet in altitude. The hills contain schist, crystalline limestone, quartzite, amphibolite, and gneiss bedrock of Precambrian and early Paleozoic age that are intruded by Mesozoic plutons and dikes (Cobb 1973:126). Overlying the bedrock are fine aeolian sediments. In general, brown forest soils occur in areas with slopes of more than 12% and above, while poorly~drained loamy soils with a peaty surface layer and shallow permafrost table occur in areas of less than 12% slope (Selkregg 1974:171).

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Dominant trees of the area include black and white spruce (Picea marinia and Picea glauca), paper birch (Betula papyrifera), and quaking aspen (Populas tremuloides). A few isolated stands of cottonwood (Populus balsomifera) and tamarack (Larix laricina) are also present. Black spruce is the predominant tree on north facing slopes and areas of permafrost. Tall willow (Salix spp.) and alder (A/nus sp.) shrubs are also present in low, wet and recently disturbed areas. The understory is comprises rose (Rosa spp.), high bush cranberry (Viburnum edule), Labrador tea (Ledum palustre), raspberry (Rubus idaeus), and blueberry (Vaccinium spp.). The dominant forest ground cover consists of moss (Sphagnum spp.) and lichens, with fireweed (Epilobium angustifolium), bluejoint grasses (Calamagrostis spp.) and horsetails (Equisetum spp.) more frequent in wet or disturbed areas.

2.3 CURRENT USE OF THE PROPERTY Currently, a majority of the property remains undeveloped forested land. FGMI is conducting mineral assessment activity consisting of soil sampling and dri Hing within the subject property in order to complete geological mapping of the area in accordance with BLM Land Use Permit FF096399. The total permitted disturbance is approximately 45 acres and is concentrated on the eastern side of the subject property. Reclamation is being completed concurrently and in accordance with the applicable state and federal law.

2.4 DESCRIPTIONS OF STRUCTURES, ROADS, OTHER IMPROVEMENTS ON THE SITE Access to the site is through f ort Knox Mine and onto a series of existing user-established trai1s. When travel is planned where an existing trail does not exist, new trails may be constructed by bu lldozer, by pushing organics to the side and stockpiling for reclamation. New trails were established during exploration activities and extend from the existjng trail network to the drill pad. These new trails and pads are closed to unauthorized users during construction, operation, and rec]amation activities (HDR, 2014).

During exploration, driU pads were constructed using a bulldozer. Drill pads consist of native overburden that has been pushed over to clear an area. Overburden disturbed during construction was placed along the edges of the drill pad until it was reclaimed. There are 45 acres permitted for disturbance. Currently 40 ofthe 45 acres have been disturbed with 31 acres reclaimed.

There are no major structures within the subject property. The previously mentioned antenna tower has been removed, however at the time ofthe site reconnaissance performed by TPECl the fence surrounding the historic antenna remained in place along with exjsting grounding cables and minor concrete foundations. On Monday June 26, 2017 FGMI completed removal of the fencing and all existing grounding cables and debris. Pictures of the removal were provided by FGMI and included in the attached photographic log. Mr. AI Wissman was consuhed on details regarding this particular area he had the fo llowing to say, "There was power from the electric coop. However, the transmission line was broken for many years. There was never any backup power. In effect, there hasn't been power to the site for many years (I'm guessing in the 70's or late 80's). The previous equipment from the state used batteries which was removed a long time ago...AII antennas for sate!Hte operations were removed fo ng before 1990's. The tower was taken down and removed by our staff last fall. There is no report regarding the tower removal."

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During the site reconnaissance TPECI also observed a de-energized power line facility with electric transmission wires present leading from the Golden Valley Right-of-Way on the north boundary of the subject property to the antenna site. The de-energized power line facility is approximately two miles in length with a pole approximately every 250 feet. The de-energized facility is apparently out-of-service. A transformer (with a label "no PCBs'') is mounted on the final pole leading to the antenna site. No signs of leaking or evidence of corrosion was observed on the transformer.

Multiple historic sites were identified in the vicinity of the property by Northern Land Use Research, LLC. who conducted a Phase I Cultural Resource Survey under the authority of the Bureau of Land Management in 2013 and a Phase II Cultural Resource Survey in June of2015 (NLURA, 2016).

2.5 CURRENT USES OF ADJOINING PROPERTIES To the east of the subject property is Fort Knox Mine which has been in operation since 1994 (NLURA, 2016). To the north, west, and south, the subject property is bordered by the National Oceanic and Atmospheric Administration (NOAA) Fairbanks Command and Data Acquisition Station (FCDAS) which was built by the National Aeronautics and Space Administration (NASA) in the 1960s and operated by NOAA since 1973 (NLURA, 2016).

3.0 USER PROVIDED INFORMATION The following sections detail information provided by the User (FGMI) for use in developing this Phase I Assessment.

3.1 TITLE RECORDS No title records were provided by the User.

3.2 ENVIRONMENTAL LIENS OR ACTIVITY AND USE LIMITATIONS No environmental lien or activity and use limitation information was provided by the User.

3.3 SPECIALIZED KNOWLEDGE The User does not have any specialized knowledge or experience that is material to RECs in connection with the property.

3.4 COMMONLY KNOWN OR REASONABLY ASCERTAINABLE INFORMATION The User did not provide any commonly known or reasonably ascertainable information within the local community about the property in regard to RECs.

3.5 VALUATION REDUCTION FOR ENVIRONMENTAL ISSUES The User did not provide any information that would necessitate a valuation reduction due to environmental issues.

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3.6 OWNER, PROPERTY MANAGER, AND OCCUPANT INFORMATION The subj ect property is located on land managed by NOAA (surface estate). The Bureau of Land Management (BLM) manages subsurface estate. Currently FGMI is conducting pennitted expJoration activities on the property as discussed in Section 2.3.

3.7 REASON FOR PERFORMING PHASE I This Phase I is being performed to evaluate the property for RECs prior to the potential relinquishment ofthe Withdrawal

3.8 OTHER Mr. Mark Huffington of FGMI provided TPECI a copy of the March 2016 Cultural Resources Survey of the Gilmore Exploration Area, which covers Parcel G conducted by Northern Land Use Research Alaska, LLC and the September 2014 Environmental Assessment (DOI-BLM-AK­ F020-201 4-0005-EA) prepared by HOR Alaska, Inc. Pertinent information from these reports is reproduced in this Phase I.

4.0 RECORDS REVIEW Reasonably ascertainable standard sources were obtained and reviewed by TPECI as part ofthis Phase I ESA. The following sections outline the findings of the reviewed records.

4.1 STANDARD FEDERAL, STATE, AND TRIBAL ENVIRONMENTAL RECORD SOURCES TPECI engaged Environmental Data Resources, Inc. (EDR) on June 6, 2017 to scan standard federal records and provide a summary of facilities that are identified on any ofthe lists searches (EDR, 2017a). A copy ofthe EDR report, dated June 6, 2017, is included in Appendix C.

The standard federal records searched, the specific radii of the search, and the numbers of sites identified by EDR are outlined below.

Search Radii Total Search Standard Federal Environmental Records (miles) Result National Priority List (NPL) 2.5 0 Proposed National Priority List Sites (Proposed NPL) 2.5 0 Federal Suoerfund Liens (NPL LIENS) 1.5 0 National Priority List Deletions (Delisted NPL) 2.5 0 Comprehensive Environmental Response, Compensation, and Liability 2.0 0 lnfonnation Svstem (CERCLIS) Federal Facility Site Information Listing (FEDERAL F AClLITY) 2.0 0 CERCLIS No Further Remedial Action Planned (CERC-NFRAP) 2.0 0 Corrective Action Report (CORRACTS) 2.5 0 Resource Conservation and Recovery Act (RCRA) - Treatment, 2.0 0 Storage and Disposal (RCRA-TSDF) RCRA- Large Quantity Generators

Search Radii Total Search Standard Federal Environmental Records (miles) Result Land Use Control lnfonnation Svstem (LUCIS) 2.0 0 Emereencv Rcsoonse Notification System CERNS) 1.5 0 EDRs search radius for adJmnmg properties 1s 0.25 miles. TP - Target Property; TAP - Target and AdJommg Properties.

No sites were identified by the EDR Report.

The standard state and tribal records searched by EDR, the specific radii of the search, and the numb ers o f s1't es 1'd en ffi 1 1e dbI Y EDR are outi' me db eow. I Search Radii Total Search Standard State and Tribal Environmental Records (miles) Result Contaminated Sites Database (SHWS)* 2.5 0 Solid Waste Facilities (SWF/LF) 2.0 0 Leakinl! Under1?:round Storal!e Tank Database (LUST) 2.0 0 Leaking Underground Storage Tanks on Indian Land (INDIAN LUSTI 2.0 0 Regulated Above Ground Storage Tanks (AST) 1.75 0 Underl!round Storage Tank Database (UST) 1.75 0 Undenrround Storal!e Tanks on Indian Land (INDIAN UST 1.75 0 Undcrl!round Storal!e Tank Listing (FEMA UST) 1.75 0 Engineering Controls Site Listing (ENG CONTROLS) 2.0 0 Contaminated Sited with Institutional Controls (INST CONTROLS) 2.0 0 Voluntarv Control Program Sites N CP) 2.0 0 Voluntarv Control Prioritv Listing (INDIAN VCP) 2.0 0 Identified and/or Prooosed Brownfields Sites

No sites were identified by the EDR Report.

4.2 ADDITIONAL ENVIRONMENTAL RECORD SOURCES Additional environmental records (outside of those required by ASTM E2247-16) were also searched and compiled by EDR. As the list of additional records is extensive and no additional sites were identified, the records are not listed below. A copy of the EDR report, dated June 6, 2017, is included in Appendix E.

A review of the Alaska Department of Environmental Conservation (DEC) Contaminated Sites Database on June 6, 2017 revealed no contaminated sites on or near the subject property. A contaminated sites map is included in Appendix D (DEC, 2017a).

A review of the DEC Spill Prevention and Response (SPAR) Database on June 15, 2017 revealed four spill reports associated with the subject property. Copies of the FGMI spill reports to SPAR and copies of the SPAR Database report pages are included in Appendix D (DEC, 2017b).

• ADEC Spill Database #14309928402, Fort Knox October 2014 Monthly Spill Report 8­ gallons ofhydraulic oil, 10/11/14; o Contaminated soil excavated; o Soil thennally remediated at OIT in Moose Creek, Alaska; and o Case closed 11/3/14, no further action required.

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• ADEC Spill Database# (Not included on ADEC database although it was reported on end of month report for July 2015), Fort Knox July 2015 Monthly Spill Report, 3-gallons ofhydraulic oil, 7/29/15; o Absorbs put down to collect free product; and soil shoveled into buckets; and o Absorbs burned in smart ash burner and soil thermally remediated at OIT in Moose Creek, Alaska. • ADEC Spill Database # (Not incruded in ADEC database, although it was reported on an individual spill report), 1.5 quarts of gear oil. Discovered when FGMI did not have equipment on site. Likefy spill was from a mechanized trail user, 5/11/16; o Soil shoveled into buckets; and o Soil thermally remediated at OIT in Moose Creek, Alaska. • ADEC Spill Database #15309908901, Fort Knox Gilmore Exploration Project 3-gallon ethylene glycol, 3/30/15; o Absorbs put down to pick up free product and soil excavated; o Absorbs burned in smart ash burner and soil thermally remediated at OIT in Moose Creek, Alaska; and o Case closed 4/3/1 5, no further action required. • ADEC Spill Database #16309924701, Fort Knox Gilmore Drill Site GL-43, I-gallon hydraulic oil, 9/3/1 6; o Absorbs used to pick up free product, soil shoveled into 5-gallon buckets; o Absorbs burned in smart ash burner and soil thermally remediatcd at OIT in Moose Creek, Alaska; and o Case closed 10/3/ J6, no further action required.

4.3 PHYSICAL SETTING SOURCES The subject property encompasses approximately 709.17 acres of land and lies within the U.S. Geological Survey Livengood A-I and Fairbanks D-1 topographic quadrangle maps. Elevation within the subject property varies from 1,300 feet at creek bottoms to 2,600 feet on the hilltops.

TPECI engaged EDR on June 6, 2017 to obtain historical topographic maps of the subject property (EDR, 2017c). A copy ofthe EDR Topo Report is included in Appendix D.

4.4 HISTORIC USE INFORMATION ON THE PROPERTY The following sections outline the standard historical sources used to develop a history of the previous uses ofthe subject property and surrounding area in order to help identify the likelihood ofpast uses having led to RECs in connection with the subject property.

The subject property has been part ofa larger track of land subject to the Withdrawal (as outlined in Section 2.1) designed to protect FCDAS which was issued in 1965 (79 FR 40142).

4.4.1 Aerial Photography TPECI engaged EDR on June 12, 2017 to obtain historical aerial photographs of the subject property (EDR, 2017b). EDR provided aerial photographs of the subject property for the following years 1949, I 951, 1967, and 1985. TPECI also consulted the Fairbanks North Star Borough (FNSB) GIS on June 12, 2017 to obtain additional available aerial photos of the subject property. The FNSB GIS provided the aerial photographs ofthe subject property for 2003, 2007,

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and 2012 (FNSB, 2017). All aerial photographs are included in Appendix D and discussed below.

1949 and 1951 Aerial Photographs The 1949 and 1951 aerial photographs are very similar. Trails along the north, south and east of the subject property can been seen.

1967 Aerial Photograph The southeastern portion of the trail ending at a larger clearing where there are utilities as discussed in Section 2.4 and 5.2.7 can be seen. Other trail marks can be seen along the eastern boundary of the subject property. Dark areas on the map are likely densely populated with trees.

1985 Aerial Photograph In the 1985 aerial photograph, trails appear to be similar to how they are currently. The density ofvegetation can also be seen.

2003 Aerial Photograph The trails shown in this aerial photograph are very similar to the 1985 photo. The imagery is slightly corrupted so specific details are hard to see.

2007 Aerial Photograph The trails and roads are similar to the 2003 photography but more accurately represent what is present today. The mining development has increased a great deal from the 2003 imagery.

2012 Aerial Photograph Trails within the subject property are similar to the 2003 and 2007 aerial photograph. An additional trail can be seen extending from the northeast comer of the property. The location where FGMI gains access to the property can be seen in the center of the eastern boundary. Mining development ofFort Knox has also reached closer to the subject property.

4.4.2 Property Tax Files TPECI visited the FNSB on June 12, 2017 to obtain property tax files for the subject property. All obtained files are included in Appendix E.

Based on the information contained in the FNSB tax files Tax Lots 700 and 800 are owned by Alaska DNR and the remaining Tax Lots I 700, 1800, 1900, and 2002 are owned by the Alaska Mental Health Trust. All of the tax lots have a property class of vacant land and land class of remote property except Tax Lot 1800 which has a land class of general residential. The tax files for the subject property do not indicate the presence of any RECs from historic ownership.

4.4.3 United States Geological Survey Topographic Maps TPECI engaged EDR on June 6, 2017 to obtain historical United States Geological Survey (USGS) Topographic Maps of the subject property (EDR, 2017c). EDR provided USGS Topographic Maps for the subject property for the following years 1949, 1952, 1954, 1972, 1975, 1981, 1992, and 1994. All USGS Topographic Maps are included in Appendix E.

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4.4.4 User Provided Cultural Resource Survey Detailed information on the mining history of Gilmore Creek is included in the 2016 Cultural Resources Survey of the Gilmore Exploration Area in Section 3.2 (NLURA, 2016). TPECI has reviewed this and reproduced information in this Phase I as necessary.

The following text summarizing the mining history is from the 2016 Cultural Resources Survey of the Gilmore Exploration Area (NLURA, 2016):

• Placer Operations o Gilmore Creek's boom phase occurred in sync with the Fairbanks production and town development period (1901-1909), followed by the low-grade mining and industrialization period (1910-1945), and Post-WWII period (1946­ present). o By 1909 Gilmore Creek was being mined extensively for nearly its entire length. o By 1912, only five small claims on the creek were being worked. o Starting in 1914, several individuals were conducting annual assessment work and sinking shafts on Gilmore and Tom creeks. o The 1920s saw an upsurge in gold mining on Gilmore Creek. Charles Gius & Co. ran an open cut work operation and James McPike was operating a ground scraping plant at the mouth ofthe creek. o In 1924, the FE Co. started buying up extensive placer holdings on most major creeks in the Fairbanks Mining District for future dredging, including Gilmore Creek. o In August 1928, the FE Co. began operation of Dredge No. 8 on their holdings on Gilmore Creek. The following year Dredge No. 8 was in operation from May l to December 23 (Wimmler 1929). Over the next decade, the FE Co. mined using scrapers and hydraulicking plants in areas too difficult to reach with a dredge. That activity was particularly concentrated at the mouth of Gi lmore Creek (Smith 1939a). o By 1937, another mining company, Gilmore Mining Co., Inc. (GMCI) had seven men hydraulicking with a scraper on Gilmore Creek (Stewart 1937). o By 1940 Dredge No. 8 had moved on to Goldstream Creek (Stewart 1941). o The GMCI maintained claims on Gilmore and Tom creeks well into the 1960s, but is uncertain how much mining was actually done during the later years of operation. o Reports ofactive placer mining by the State and the US regulatory agencies taper offduring the 1950s and 60s.

• Lode Operations o Research into the Index of Quartz Locations (Fairbanks) identified several people who began to prospect for lode ore in the Gilmore Dome area and on the hillslopes above Gilmore Creek as early as 1909 but in earnest from 1912 to I 915. o In 1913, Fred Bond and J. Neal were posting lode claims on the Right Limit and Head of Gilmore Creek. Later in 1915 and 1916, F. Bond began concentrating his claim effort on the "ridge between Tom and Gilmore creeks" and "Twelve Pup, a tributary of Gilmore Creek" as the location of several of his quartz claims (Fairbanks District, Book I, Index to Quartz Locations 1904-1961 p.144).

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o In 1915 Johnson and Ewers located a ledge near the head of Gilmore Creek that \ was rich in tungsten (Fairbanks Daily Times 1915; McDonald 1916). o Back on Gilmore Dome, from 1942 to 1944, Cleary Hill Mines Company (CHMC) leased the Stepovich's claims. o Lode claims continue to be posted sporadically throughout the 1950s and 60s by a new group of claimants o In 1982, Resource Associates of Alaska began work on the Tungsten Hill property reopening a small pit for evaluation purposes.

4.5 HISTORICAL USE INFORMATION ON ADJOINING PROPERTIES The following text is from the 2016 Cultural Resources Survey ofthe Gilmore Exploration Area (NLURA, 2016):

In 1994, Fort Knox Gold Mine was opened under the operation of FGMI (Sattler et al. 1994). Kinross Gold Corporation (Kinross), a global mining enterprise, formed in 1993 and acquired the mine in 1998 with FGMI being a wholly owned subsidiary of Kinross. The Gilmore Dome deposit is mined using conventional open pit methods (Alaska DNR 2015a).

Other non-mineral resource developments and activities topographically tied to Gilmore Creek include recreation, military and research activities. For example, the U.S. Army (based out of Ft. Wainwright in Fairbanks) conducted military preparedness and training exercises on the hills north of Fairbanks during the I 940s and 1950s, including in the Gilmore Dome area, just outside of the Parcel G boundaries (Williams 1951). After review of all the available documents, the (_ likelihood of anything hazardous associated with nearby sites seems minimal. The survey showed limited photos depicting anything ofconcern still existing in this area.

The 1960s "space race" encouraged development of satellite tracking facilities on Gilmore Creek, also taking advantage of the undeveloped hilltops above Gilmore Creek. For example, in 1961, the newly formed NASA established the Gilmore Tracking Station at the current site ofthe FCDAS, which is located on Gilmore Creek and the ridge above Rose Creek. The FCDAS started as a small satellite tracking station operated by the University of Alaska Geophysical Institute under contract to NASA to communicate with and track the movements of earth observation satellites. During the 1960s and early 1970s, NASA constructed several station structures on the ground mined by the FE Co. during the 1930s. From 1973 through 1984, NASA and National Oceanic and Atmospheric Administration (NOAA) jointly operated the station. In 1984, NOAA assumed sole control of the station, which was renamed at that time as FCDAS (Manitakos et al. 2008). The facility currently remains in operation.

Additional information regarding mining in the area surrounding the subject property was reviewed by TPECI in the NLURA Cultural Resource survey.

5.0 SITE RECONNAISSANCE Eddie Packee and Michaela Hale ofTPECI conducted a site inspection ofthe subject property on June 23, 2017. The following FGMI and BLM employees accompanied TPECI personnel during the site inspection:

\,. • Mark Huffington, Environmental Superintendent with FGMI;

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• Bartly Kleven, Environmental Manager with FGMI; • Mindy Krzykowski, Environmental Engineer with FGMI; • David Quandt, Operatfons Manager with FGMI; • Craig Natrop, Technical Services Manager with FGMI; • Shawn Colburn, Senior Exploration Geologist with FGMI; • Valerie Baxter, Realty Specialist with BLM; • Larry Beck, Environmental Protection Specialist with BLM; and • Adam Carr, Eastern Interior Field Manager with BLM.

Site inspection photos documenting the inspection and a map showing the photo locations are included in Appendix C.

The objective of the site reconnaissance is to obtain information indicating the like1ihood of identifying RECs in connection with the property.

5.1 METHODOLOGY AND LIMITING CONDITIONS The subject property encompasses approximately 709 acres. While TPECI personnel were unable to visit the entirety of the property, they were able to observe the disturbed areas related to drilling, reclamation areas of previous drilling pads, and historic antenna sites discussed in the previous Phase I ESA. As discussed in Section 4.4. I TPECI also engaged EDR to obtain historical aerial photographs of the subject property. TPECI has reviewed these aerial photographs and did not identify any additional areas which required ground truthing.

Northern Land Use Research, LLC. conducted a Phase I Cultural Resource Survey under the authority ofthe Bureau of Land Management in 2013. Based on the results ofthe Phase I survey, a Phase II Cultural Resource Survey of the subject property was done in June of 2015, which included a thorough inspection of approximately 600 acres located in the surrounding area which included the 709 acres of the subject property (NLURA, 2016). Multiple historic features were identified as a part of these surveys however they do not seem to affect the 709 acres of Parcel G. TPECI has reviewed the results of the surveys and reproduced pertinent information in the following sections.

5.2 GENERAL SITE SETTING The following sections outline the general setting of the site based on visual and/or physical observations TPECI personnel made during the site reconnaissance.

5.2.1 Current Uses of the Property Current uses of the property are detailed in Sections 2.3 and 2.4 of this Phase I. Currently a majority of the property remains undeveloped forested land. FGMI is conducting mineral assessment activity consisting of soil sampling and drilling within the subject property in order to complete geological mapping ofthe area in accordance with BLM Land Use Permit #FF096399. All reported spills within the subject property have been 8-gallons or less and reported to ADEC who determined each reported site as cleanup complete and closed out.

5.2.2 Past Uses of the Property Section 4.4 details the information TPECI has found regarding past uses ofthe property.

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5.2.3 Current Uses of Adjoining Properties See Section 2.5 for infonnation on current uses ofadjoining properties.

5.2.4 Past Uses of Adjoining Properties See Section 4.5 for infonnation regarding historic uses ofadjoining properties.

5.2.5 Current or Past Uses in the Surrounding Arca There are no other uses identified in the surrounding area other than those outlined in Sections 5.2.3 and 5.2.4.

5.2.6 Geologic, Hydrogeologic, Hydrologic, and Topographic Conditions The subject property has rolling hills with elevation varying from 1,300 above mean sea level (amsl) feet at creek bottoms to 2,600 amsl feet on the hilltops. Tom Creek begins within the subject property and is a tributary to Gilmore Creek which begins near the southeast comer of the subject property and flows west.

5.2.7 General Description of Structures There are no major structures within the subject property. During the site reconnaissance TPECI observed a de-energized power line facility with electric transmission wires present leading from the Golden Valley Right-of-Way on the north boundary of the subject property to the antenna site. The de-energized power line facility is approximately two miles in length with a pole approximately every 250 feet. A transformer (with a label "no PCBs") is mounted on the final pole leading to the antenna site. No signs of leaking or evidence of corrosion was observed on the transfonner. There was also a fenced area containing concrete foundation left over from the antenna tower and building previously located on the property. On Monday June 26, 2017 FGMI completed removal of the fencing and metal grounding cables and debris found within this area. Pictures of the removal are included in the photographic log of this report. TPECI does not believe the transfonner contains PCBs in concurrence with the label. There were no RECs identified in this area.

5.2.8 Roads There are no public roads that access the property. Trails have been established by FGMI within the subject property for use during exploration activities. See also Section 2.4 for infonnation on site improvements. Gilmore trail does run through the subject property, and is used by the public for foot and sled dog races and A TV/UTVs.

5.2.9 Potable Water Supply The source ofpotable water for the subject property may be groundwater accessed via a well or surface waters, and none were identified during assessment activities. There are currently no needs for potable water within the subject property.

5.2.10 Sewage Disposal System There are no sewage disposal systems within the subject property. Personnel involved m exploration activities within the property have access to a port-a-toilet on FGMI property.

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5.3 EXTERIOR OBSERVATIONS

5.3.1 Hazardous Substances and Petroleum Products - Identified Uses Currently a portion of the subject property is being explored by FGMI. Exploration presents the only potential use or generation of hazardous substance. FGMI is responsible for any hazardous substances used, generated, or accidentally released. All reportable releases have been 8-gallons or less and reported to ADEC who determined them cleanup complete and closed.

5.3.2 Storage Tanks There are no known or observed aboveground or underground storage tanks on the property.

5.3.3 Odors There were no strong, pungent, or noxious odors identified during the site visit.

5.3.4 Pools of Liquids There were no pools or sumps containing liquids likely to be hazardous substances or petroleum products identified during the site visit.

5.3.5 Drums There were no drums identified during the site visit.

5.3.6 Hazardous Substances and Petroleum Products Containers No hazardous substances and petroleum product containers were identified within the subject property during the site reconnaissance.

5.3.7 Unidentified Substance Containers No unidentified substance containers were found during the site reconnaissance.

5.3.8 PCBs As shown in site photograph 7 (Appendix C) TPECI personnel observed a power pole with a transformer on the property. TPECI does not believe the transformer contains PCBs, based on the label on the side stating, "no PCBs".

5.3.9 Pits, Ponds, or Lagoons TPECI personnel did not observe any pits, ponds, or lagoons on or near the subject property. Pat, Tom, and Gilmore creeks are within or near the subject property.

5.3.10 Stained Soil or Pavement There is no pavement within the subject property. TPECI personnel did not find any stained soil on the subject property. During the site investigation Mr. Beck, Ms. Hale, and Ms. Kleven located a drilling rig on one ofthe drilling pads, secondary spill containments were placed under each drilling rig to catch any drips in accordance with FGMI best practices.

5.3.11 Stressed Vegetation TPECI personnel did not observe any stressed vegetation during site reconnaissance.

Travis/Peterson Environmental Consulting, Inc. NOAA, 1342~17 June 28, 2017 Parcel G Phase I ESA Page 16 ( 5.3.12 Solid Waste Identified in the site visit the area containing the historic antenna tower would have been considered an area of solid waste and physical safety hazard. However, on Monday June 26, 2017 FGMI staff completed the removal ofthe fencing and metal debris. They also contoured the existing pad to help eliminate any other topographic hazards. The de-energized power line facility traveling approximately two miles from the Golden Valley Right-of-Way on the north boundary ofthe subject property to the historic antenna site where a final pole with a transformer (labeled no PCBs), will be considered a solid waste and safety hazard if the gaining land owner does not want to keep it onsite. Pursuant with BLM policy all solid waste sites within the project area are identified on the site maps attached in Appendix B. Each solid waste site is also shown in the photographic log, with detailed description found in Appendix C.

5.3.13 Wastewater TPECI personnel did not observe or identify any wastewater or other liquid present during the site visit.

5.3.14 Wells Three wells are located within the subject property however, TPECI personnel were unable to physically view these wells during the site inspection. The wells are groundwater observation wells.

5.3.15 Septic Systems TPECI personnel did not observe any septic systems within the subject property. Personnel involved in exploration activities within the property have access to a port-a-toilet on FGMI property.

5.3.16 Non-Scope Issues As discussed in the NLURA Cultural Resource Report Site areas within the subject property were used as a former military training area from the Period. No sites were able to be physically located during the site visit, and are not considered a potential concern as RECs. The de-energized power line facility has already been discussed in Section 5.3 .12 of this report. No other non-scope observations i.e. asbestos containing materials, radon, lead based paint, drinking water systems, health and safety issues were observed at the time of inspection.

5.3.17 Physical Hazards The only physical hazard observed within the project area was the left over solid waste of grounding cables, fencing and debris at the historic antenna tower area. On Monday June 26, 2017 the removal of these physical hazards was completed and no further investigations are required. Photographs of the historic antenna area and photographs of the removal can be found in the photographic log in Appendix C.

The de-energized power line facility running to the antenna site is standing with all wires appearing secure. Should the power line be allowed to fall into disrepair, physical safety hazards may manifest by fallen poles and by entanglement with wires laying at ground level. \.

Travis/Peterson Environmental Consulting, Inc. NOAA. 1342-17 June 28, 2017 Parcel G Phase l ESA Page 17

5.4 INTERIOR OBSERVATIONS TPECI personnel did not observe any major structures on the subject property. No heating or cooling systems, associates stains, corrosion, or drains and sumps were identified.

6.0 INTERVIEWS During the course ofthis Phase I ESA, TPECI interviewed the following people:

• Mr. Mark Huffington, FGMI Environmental Superintendent, responses in Section 6.3; • Mr. Larry Beck, BLM Environmental Protection Specialist, responses in Section 6.2; • Ms. Lenore Heppler, BLM Field Manager, responses in Section 6.2; • Mr. Robin Mills, BLM Archaeologist, responses in Section 6.2; • Ms. Rene Fencl, BLM, responses in Section 6.2; • Ms. Valerie Baxter, BLM, Realty Specialist, no response; • Mr. Al Wissman, NOAA, responses in Section 6. 1; and • Mr. Mike Garrett, ADEC Environmental Program Specialist, responses in Section 6.4.

All interviewers used the ASTM E2247-16 User Questionnaire to assist in gathering any information that may be crucial in identifying RECs connected with the subject property. All interview documentation can be found in Appendix F.

6.1 OWNER Mr. A] Wissman from NOAA was interviewed by TPECI and documented with the ASTM ( E2247-I 6 User Questionnaire. A copy of the User Questionnaire has been included for reference in Appendix F. Currently NOAA is the owner ofthe subject property.

Mr. Al Wissman discussed the current and past use of the subject property as a radio frequency interference buffer for the satellite communications and data acquisition. In Mr. Wissman's interview he explains that the 709 acres being released, NESDIS/FCDAS does not use. Mr. Wissman also includes that currently there is a power line, power pole and transformer within the project area. The remainder of questions were answered with the statement "none to my knowledge."

6.2 SITE MANAGER Mr. Larry Beck, Mr. Robin Mills, Ms. Lenore Heppler, and Ms. Rene Fencl from BLM were interviewed by TPECI and documented with the ASTM E2247-I 6 User Questionnaire. Copies of all the User Questionnaires have been included for reference in Appendix F. Currently BLM is managing subsurface estate of the subject property. Upon relinquishment by NOAA, BLM will also manage the surface estate.

Mr. Beck included some information regarding the history of the site, as well as, possible problematic areas to acknowledge including the o1d Antenna tower and power poles, as well as the west boundary area that could have supplied the subject property with RECs during its placer mining era.

Mr. Mills included valuable historic and prehistoric cultural resource and paleontological information regarding the subject property. Consistent with the cultural resource survey, Mr.

Travis/Peterson E nvironmental Consulting, Inc. NOAA, 1342-1 7 June 28, 2017 Parcel G Phase I ESA Page 18 ( Mills described past uses of the property to include US military training, mineral prospecting including placer gold. However, Mr. Mills does mention that due to the lack of direct evidence prospecting must not have been that extensive. With these historic activities, the possibility of generating hazardous substances, pits, and domestic habitation of adjoining properties was also discussed.

Ms. Heppler conducted her interview over the phone with TPECI employee Michaela Hale. Ms. Heppler was helpful in identifying that there are multiple walking trails that could possibly go through the property. She also identified the possibility of the exploration drilling as a potential for petroleum products.

Ms. Fencl identified the current and past use ofthe subject property as the Fairbanks Command and Data Acquisition Station/tracking station.

6.3 OCCUPANTS Mr. Huffington from FGMI was interviewed by TPECI and documented with the ASTM E2247­ 16 User Questionnaire. A copy of the User Questionnaire has been included for reference in Appendix F. Currently; FGMI is the only entity using any part ofthe subject property.

Mr. Huffington disclosed that minor spills associated with drilling activities have occurred on the subject property. Copies of all the spills reported by FGMI are also included with Mr. Huffington's User Questionnaire. All the spills reported were 8-gallons or less and were all handled by FGMI appropriately and closed by ADEC. Mr. Huffington also supplied TPECI with the BLM Land Use Permit #FF096399 included in Appendix E. Mr. Huffington is very knowledgeable about the current operations of the exploration taking place on the subject property, particular as it relates to the use, treatment, storage, disposal and generation of hazardous substances or petroleum products. He explained that "Petroleum storage does not occur at the site. Fuel for refueling equipment is transported from offsite by a contractor pickup truck mounted fuel tanks (up to 500-gallons). Lubricants (up to 30-gallons) are transported from offsite contractor pickup truck. No vehicles or equipment with the exception of stationary equipment (i.e., drill rigs, light plants) are fueled or serviced within 100-feet of surface water. Fueling and service vehicles are equipped with adequate materials (i.e., absorbent pads, booms, etc.) to immediately contain and commence cleanup of spilled fuels and other petroleum products."

Mr. Huffington also was able to give a little more insight into the structures and pools/sumps located on the subject property. He explained that the only structure is a FCDAS area approximately 100-feet by 100-feet that is enclosed by a chain link fence along the Gilmore Dome-Cleary Summit Trail. There are indeed sumps located onsite. The temporary lined sumps used for drilling purposes and reclaimed after drilling were all installed and operate in accordance with the BLM permit #FF096399. Mr. Huffington is a valuable source of information pertaining to the daily operations and current status ofthe subject property.

6.4 LOCAL GOVERNMENTAL OFFICIALS Mr. Mike Garrett from ADEC was interviewed by TPECI with Ms. Ashley Adamczak (ADEC) also present and documented with the ASTM E2247-16 User Questionnaire. A copy ofthe User \. Questionnaire has been included for reference in Appendix F.

Travis/Peterson Environmental Consulting, Inc. NOAA, 1342-17 June 28, 2017 Parcel G Phase I ESA Page 19

Mr. Garrett was able to review ADEC database to uncover spill report summaries of the four listed spill sites found on the SPAR website. Copies ofthe SPAR website spill information along with the ADEC database spill report summaries are included with Mr. Garrett's User Questionnaire in Appendix F. Outside of this helpful information, Mr. Garrett was not too familiar with the site and could not offer more information regarding the site conditions.

6.5 OTHERS No additional interviews were conducted other than those listed in the above sections.

7.0 FINDINGS The following potential RECs and non-scope issues were found: • Exploration of the subject property by FGMI presents the potential for hazardous substance or petroleum product use or generation. Currently no signs support that the exploration should be considered a HREC or REC. Minor spills 8-gallons or less have occurred in the subject area but have all been handled and cleanup to ADEC's standards and considered cleanup complete; • The final power pole on the de-energized power line fac ility was identified to be holding a transformer. The transformer shows no signs of leakage or corrosion and contains a label stating, "no PCBs."; and • The de-energized power line facility beginning at the Golden Valley Right-of Way on the north boundary of the subject property leading to the antenna tower site, may be considered a solid waste and physical safety hazard ifthe gaining land owner declines to l accept conveyance ofthe subject property as is, with the existing de-energized power line and transformer (see Section 5 .3. l 2).

8.0 OPINIONS The opinion on each of the potential RECs and non-scope issues identified in Sectron 7 are detailed below. I. The exploration being performed does not show any signs of1-IREC or RECs currently or historically. All spills located within the project area have been minor and handled/cleaned up to ADECs standards. 2. The non-scope solid waste (de-energized power line facility and power pole with the transformer) identified in the historic antenna tower area, in TPECI personnel' s opinion does not pose a potential for REC. The transformer located on the power pole is labeled with "no PCBs" and does not show signs ofcorrosion or fluid leakage. 3. The de-energized power line facility is a potential solid waste and physical safety liability for NOAA which may attach to BLM if the State of Alaska declines to accept conveyance ofthe subject property with the de-energized power line fac ility present.

9.0 ADDITIONAL INVESTIGATIONS TPECI does not feel that there are any additional investigations that need to be performed on the property to detect the presence of hazardous substances or petroleum products.

Travis/Peterson Environmental Consulting, Inc. NOAA, 1342-17 June 28, 2017 Parcel G Phase I ESA Page 20 ( 10.0 DATA GAPS It is TPECI's professional opinion that there are no data gaps that affect the ability to identify RECs.

11.0 CONCLUSIONS TPECI has performed a Phase I ESA in conformance with the scope and limitations of ASTM Practice E2247 and BLM Pre-Acquisition Environmental Site Assessments H-2000-01 of the subject property with the legal description outlined in Section 2.1. Any exceptions to, or deletions from, this practice are described in Section 10 ofthis report.

This Phase I has revealed no evidence of hazardous substances, petroleum products, or environmental conditions on this real property. No further inquiry is needed for purposes of all appropriate inquires; therefore, this property is suitable for acquisition.

12.0 DEVIATIONS The deviations include the BLM Pre-Acquisition Environmental Site Assessments H-2000-0 I Non-Scope items found in Section 5.3. I 6

13.0 ADDITIONAL SERVICES No additional services other than those outlined for a Phase I in ASTM E2247-16 and BLM Pre­ Acquisition Environmental Site Assessment H-2000-1 were conducted.

14.0 REFERENCES BLM H-2000-01, Bureau of Land Management. Chapter IV- Phase I Environmental Site Assessment. Rel. 2-298. 08-21-2012.

79 FR 40142, Notice of Realty Action. Notice by the Bureau of Land Management. 7-77-2014. Accessed via: federalregister.gov/a/2014-16227

Chevron, 2013, DELO: A History of Firsts. Published in 2013. Accessed 7/27/2016 via: http://www.hnfunkhouser.com/Portals/0/lmages/Delo-History-Timeline.pdf

DEC, 2017a, Alaska Department of Environmental Conservation Contaminated Sites Database. Accessed 6-6-2017 by M. Hale of TPECI. http://www.arcgis.com/home/item.html?id=31524 0bfbaf84aa0b8272ad 1cef3cad3

DEC, 2017b, Alaska Department of Environmental Conservation Spill Prevention and Response Accessed 6-15-2017 by M. Hale of TPECI. http://www.dec.alaska.gov/Applications/SP AR/PublicMVC/Perp/SpillDetails

EDR, 2017a. The EDR Radius Map with GeoCheck Parcel G. Inquiry Number: 4678431.3s. Environmental Data Resources. 6-6-2017.

EDR 2017b. EDR Aerial Photo Decade Package. Inquiry Number: 4678431.6 Environmental Data Resources. 6-12-2017 . .... Travis/Peterson Environmental Consulting, Inc. NOAA, f342-17 June 28, 2017 Parcet G Phase I ESA Page 21

EDR, 2017c. EDR Historical Topo Map Report wjfh Ouadma:tch. Inquiry Number:4678431.7. Environmental Data Resources. 6-6-2017.

FNSB, 2017, Fairbanks North Star Borough Geographic Information System. Accessed 6-12­ 2017 by M. Hale ofTPECI. http://gis.co.fairbanks.ak.us/website/fnsbgis/viewer.htm

HDR, 2014, 2014 Environmental Assessment, GHmore Land Use Application, Fairbanks Gold Mining, Inc., DOI-BLM-AK-F020-2014-0005-EA. Prepared for U.S. Department of the Interior, Bureau of Land Management Eastern Interior Field Office and Fairbanks Gold Mining, Inc.~Fairbanks, Alaska. Prepared by HDR Alaska, Inc. Anchorage, Alaska.

NLURA , 2016, 20 I 6 Cultural Resources Survey of the Gilmore Exploration Area. Prepared for Fairbanks Gold Mining, Inc., Fairbanks, Alaska. Prepared by Northern Land Use Research Alaska, LLC.

(

Travis/Peterson Environmental Consulting, Inc. NOAA, 1342-17 June 28, 2017 Parcel G Phase I ESA Page 22

15.0 SIGNATURE OF THE ENVIRONMENTAL PROFESSIONAL

"I declare that, to the best of my professional knowledge and belief, I, meet the definition of Environmental professional as defined in §312. JO of 40 CFR§ 312. I have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property. I have developed and performed the all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312."

VV,ie_--- 2 ~, 2 CJ t 7­ Edmond C. P kee, Jr., PhD., CPSSc. CPESC, CPSWQ Date Senior Scientist

16.0 QUALIFICATIONS OF THE ENVIRONMENTAL PROFESSIONAL The qualifications of the environmental professional that completed this Phase I ESA are presented in Appendix H.

(

Travis/Peterson Environmental Consulting, Inc. APPENDIX A SITE MAP

Travis/Peterson Environmental Consulting, Inc. TRAVIS/PETERSON ENVIRONMENTAL CONSULTING, INC. FAIRBANKS GOLD MINING, INC. FIGURE! 329 2ND STREET FAIRBANI

Travis/Peterson Environmental Consulting, Inc. LEGEND

FGMI EXPLORATION AREA

SUBJECT PROPERTY

USER ESTABLISHED TRAILS LOCATION OF UNDISCLOSED SOLID WA.STE IF THE GAINING LAND OV\.NER DOES NOT WA.NTTO KEEP THE PO\/IIER POLE/ POV\IER LINE ONSITE.

NOTE: THIS IS NOT EXACT LOCATION OF EXPLORATION/DRILLING.

TRAVIS/PETERSON ENVIRONMENTAL CONSULTING, INC. FAIRBANKS GOLD MINING, INC. FIGURE2 329 2NDSl'REET FAIRBANKS, Al.ASKA 9'J701 PARCELG PHASE I SITEMAP PROJECTNO: 1342-17 FILE: PROJECTS/1342117/APPENDICTS'B- SITE MAPS AND DRAWINGS/FIGURE 2.SKF DATE: 06/12/2017 SCALE:NONE APPENDIXC SITE PHOTOGRAPHS

Travis/Peterson Environmental Consulting, Inc. Fairbanks Gold Mining, Inc., 1342-16 Parcel G Phase I ESA - Photographic Log and Notes Page 1

PHOTOGRAPillC LOG AND NOTES Photograph No. 1

Overall view of Fort Knox Pit

View: West

GPS: 64.996205 -147.347644

Photograph No. 2

Typical drilling pad without reclamation.

View: Southeast

Travis/Peterson Environmental Consulting, Inc. Fairbanks Gold Mining, Inc., 1342-16 Parcel G Phase I ESA - Photographic Log and Notes Page2

Photograph No. 3

Cable left behind on the existing concrete foundation ofthe historic antenna tower

View:N/A

GPS: 64.987765 -147.399939

Photograph No. 4

Concrete foundation located in the historic antenna tower area.

View: East

Travis/Peterson Environmental Consulting, Inc. Fairbanks Gold Mining, Inc., 1342-16 Parcel G Phase I ESA - Photographic Log and Notes Page3

Photograph No. 5 Left behind cable ' from the historic antenna tower.

Note: To be picked up by FGMI Monday June 26, 2017.

, View: Northeast

Photograph No. 6

Left behind cable , and inactive powerline in the historic antenna tower area.

Note the existing fence in the background.

, All ofthis is to be removed/picked up by FGMI on Monday June 26, 2017.

View: North

Travis/Peterson Environmental Consulting, Inc. Fairbanks Gold Mining, Inc., 1342-16 Parcel G Phase l ESA - Photographic Log and Notes Page4

Photograph No. 7

Existing power pole/power line located in the historic antenna tower area. Note the transfonner on the power pole, however there was a label statingt "no PCB".

View: North

Photograph No. 8

Overview ofthe entire historic antenna tower area.

View: Northeast

Travis/Peterson Envi.ronmcntal Consulting, Inc. Fairbanks Gold Mining, Inc., 1342-16 Parcel G Phase I ESA - Photographic Log and Notes Page 5

Photograph No. 9

Overview looking at drill pads. Some have been reclaimed and some have just began drilling.

View:North

OPS: 64.992923 -147.390385

Photograph No. 10

Drill pad area that has been reclaimed.

View: South

OPS: 64.994978 -147.391246

Travis/Peterson Environmental Consulting, Inc. Fairbanks Gold Mining, Inc., 1342-16 Parcel G Phase I ESA - Photographic Log and Notes Pnge6

Photograph No. 11

View following up the inactive powerline to the "Y" of GVEA active powerlines

View: North

Photograph No. 12

Connection point of the inactive powerline from the historic antenna tower to the active GVEA powerlines.

View: Northeast

GPS: 65.009644 -147.404289

Travis/Peterson Environmental Consulting, Inc. Fairbanks Gold Mining, Inc., 1342-16 Parcel G Phase I ESA - Photographic Log and Notes Page 7

Photograph No.13

Typical area of reclamation.

View: Southwest

Photograph No. 14

Completed historic antenna tower solid waste removal

View: North

Travis/Peterson Environmental Consulting, Inc. Fairbanks Gold Mining, Inc., 1342-16 Parcel G Phase I ESA - Photographic Log and Notes Page 8

Photograph No. 15

Completed historic antenna tower solid waste removal

View: Northeast

Photograph No. 16

Filling depressions in the historic antenna tower location

View: East

Travis/Peterson Environmental Consulting, Inc. Fairbanks Gold Mining, Inc., 1342wJ6 Parcel G Phase I ESA - Photographic Log and Notes Page 9

Photograph No. 17

Contouring the pad at the historic antenna tower site.

View: Northeast

Photograph No. 18

Removal ofthe left ground anchors/cables at the historic antenna site

View: Southeast

Travis/Peterson Environmental Consulting, Inc.

Appendix E – State of Alaska letter agreeing to presence of de-energized power line and transformer

35 Department of Natural Resources DIVISION OF MINING, LAND AND WATER/ DIRECTOR'S OFFICE 550 W ..,, Ave, Ste 1070 Anchorage. AK 99501-3576 GOVERNOR BILL WALKER Mam: 907.269-8600 Fax: 907.269-8904

June 29, 2016

Erika L Reed Deputy State Director, for Alaska Lands and Cadastral Survey Bureau of Land Management Alaska State Office 222 W. Seventh Ave, #13 Anchorage, AK 99513-7504

Dear Ms. Reed,

Regarding your inquiry on June 27 concerning the powerline, poles and pole mounted transformer. Based upon the potential future use of the existing infrastructure to provide power to Parcel G the State has no reservations accepting Parcel G with the infrastructure intact. The State requests that no action be taken to dismantle and remove with the powerline, standing supporting poles or the transformer. The Transformer appears to be in sound condition and contains no PCBs.

:~aryou for your consideration,

~ t\ Par s, Deputy Director Division of Mining, Land and Water

cc: B Goodrum J Proulx G Etter

BLM Af:'. DllJ LAHD:3 :JUH 29., 2017 AM10:oo:41

Appendix F – Land Surveyor Report and Recorded Survey

36 Land Surveyor Report United States Department of the Interior - Bureau of Land Management Alaska State Office th 222 W. 7 • Ave #13, Anchorage Alaska 99513

Worksheet Request Number: 9410-17-LSR-006-2 PLO Nos. 3708; 6709; 7682; 7710 and 7763 all located within T. 2 N., R. 2 E., F.M.

Final Determination by the Certified DOI Land Surveyor: The draft plat of the Record of Survey for Parcel G, surveyed by Jake Gerondale, Registered Professional Land Surveyor No. LS-11758 has been reviewed. All the bearings shown on the plat have been changed from grid bearings to true mean bearings. The bearings and distances shown on this plat are now consistent with the descriptions ofthe Public Land Orders and, once filed in the local recording district, the plat No. and date filed will need to be included in the legal description for publishing in the .Federal Register.

A review of the above request has been completed and the following determination(s) has been made by the DOI Land Surveyor or Certified Federal Surveyor:

(Check one) The [land description/ land surveys] is/are acceptable for the stated purpose, see X comments below. The [land description / land surveys] has/have potential problems as noted below; however, the risk appears minor and the action within the stated purpose should not be affected. The [land description / land surveys] has/have potential problems and should not be used for the stated purpose. The following errors and/or concerns as noted below need to be corrected/addressed before this/these [land description/ land surveys] should be used. A boundary survey is required. (See cost/time estimate below)

Recommendations/Comments/Concerns/Corrections: Lounsbury and Associates prepared the draft plat for the "Record of Survey of Parcel G", that encompassed lands the National Oceanic and Atmospheric Administration (NOAA) wished to relinquish to the BLM, which is part ofa larger parcel ofland previously withdrawn by PLO Nos. 3708 and 6709, partially revoked by PLO Nos. 7682 and 7763 and extended by PLO No. 7710. The draft plat of the Record of Survey for Parcel G, surveyed by Jake Gerondale, Registered Professional Land Surveyor No. LS-11758 has been reviewed. All the bearings shown on the plat have been changed from grid bearings to true mean bearings. The bearings and distances shown on this plat are now consistent with the descriptions ofthe Public Land Orders and, once the plat is filed in the local recording district, the plat No. and date filed will need to be included in the legal description for publishing in the Federal Register. See Attachment "A" for the updated legal description for publishing in the Federal Register. The two edits necessary for Attachment "A", prior to publishing in the Federal Register, are to add the plat No. and date it was filed. These edits will need to be made in the first paragraph ofthe attachment.

I certify that the parcel described on the attached document(s) contains 709.17 acres.

This report correctly represents the records and documents evaluated by me or under my direct supervision in conformance with the requirements ofthe Department of the Interior Standards for Federal Lands Boundary Evidence, ofthe parcel(s) ofland identified.

Name: DOI Land Surveyor, or Office, Title and Contact Date: Certified Federal Surveyor Information: Cadastral Surveyor BLM Alaska State Office tr~ 222 W. 7th Ave., #13 """=\-{t~lt""":\-­ Bryan S. Seibold Anchorage, AK 99513 AK-942 Deputy Branch Chief (907) 271-4225

This report correctly represents the records and documents evaluated under my direction and control and in conformance with the requirements ofthe Department ofthe Interior Standards for Federal Lands Boundary Evidence, ofthe parcel(s) ofland identified.

Name: Certified DOI Land Surveyor Contact Information: Date: Chief Cadastral Surveyor BLM Alaska State Office 222 W. 7th Ave., #13 • 1/1 to/ rt­ ~L; Ofowf]~ Anchorage, AK 99513 AK-942 Branch Chief (907) 271-4214 Authorized Officer: ~ I concur with the above recommendation(s) and:

o Additional funding is not required.

o Funding for the recommended action(s) is authorized in the amount of$_____ Cost code: ------o Funding for the recommended action(s) will be provided at a later date. o I do not accept the above recommendation(s) for the following reason(s):

Comment:

Authorized Officer Name: Office, Title and Contact Date: Information: Chief, Branch ofLands and Reality BLM Alaska State Office 222 W. 7th Ave., #13 Dave Mushovic Anchorage, AK 99513 AK-941000 Branch Chief (907) 271-4682

This report is to be retained in the official case file.

ATTACHMENT “A”

LEGAL DESCRIPTION Parcel G

A parcel of land situated within sections 7, 8, 17, 18, 19 and 20, Township 2 North, Range 2 East, Fairbanks Meridian, Alaska, being a portion of that parcel of land described in Public Land Order Nos. 3708, 6709 and the plat for the Record of Survey, Parcel G, surveyed by Jake Gerondale, Registered Professional Land Surveyor No. LS-11758, for Lounsbury and Associates, filed in the Fairbanks recording district as plat No. 2017-54 on July 21, 2017, and being more particularly described as follows (all bearings are true mean bearings):

(Record bearings and distances from the Bureau of Land Management plat of survey for Township 2 North, Range 2 East, Fairbanks Meridian, Alaska, officially filed on July 28, 1988, are shown in parenthesis.)

BEGINNING at the southwest 1/16 section corner of section 8, marked with a 2 1/2 inch diameter iron post, with brass cap marked SW 1/16 S8 1987;

THENCE, South 0° 12' 28" East, on the north and south center line of the southwest 1/4 of section 8, a distance of 1320.74 feet (South 0°10’ East, 20.01 chains) to the west 1/16 section corner of sections 8 and 17, marked with a 2 1/2 inch iron post, with brass cap marked S8 W1/16 S17 1987, said corner being identical with the northwest corner of Public Land Order No. 7763;

THENCE, South 0° 12' 28" East on the north and south center line of the northwest 1/4 of section 17, identical with the westerly line of Public Land Order No. 7763, a distance of 330.00 feet, identical with the southwesterly corner of Public Land Order No. 7763;

THENCE, South 42° 47' 04" East, on the southwesterly line of Public Land Order No. 7763, a distance of 1950.25 feet to the north and south center line of section 17, identical with the most southerly corner of Public Land Order No. 7763;

THENCE, South 0° 10' 47" East (South 0°10’ East), on the north and south center line of section 17, a distance of 3517.92 feet to the 1/4 section corner of sections 17 and 20, marked with a 2 1/2 inch iron post, with brass cap marked T2N R2E S17 1/4 S20 1987;

THENCE, North 89° 53' 20" East (North 89°55’ East), on the line between sections 17 and 20, a distance of 478.71 feet, identical with the northwest corner of Public Land Order No. 7682;

THENCE, South 3° 22' 04" West, on the westerly line of Public Land Order No. 7682, a distance of 2360.42 feet, identical with the southwesterly corner of Public Land Order No. 7682;

37

THENCE, South 40° 05' 00" East, on the southerly line of Public Land Order No. 7682, a distance of 1541.97 feet to the north and south center line of the southeast 1/4 of section 20, identical with the most southerly corner of Public Land Order No. 7682;

THENCE, South 0° 08' 36" East (South 0°09’ East), on the north and south center line of the southeast 1/4 of section 20, a distance of 1455.29 feet to line 1-2 of the Scheelite Load claim of Mineral Survey No. 2008, marked with a 2 1/2 inch iron post, with brass cap marked E CC S20 E S MS2008 1987;

THENCE, South 72° 19' 41" West on line 2-1 of said Scheelite Load claim of Mineral Survey No. 2008, a distance of 685.63 feet (South 72°22’ West, 10.39 chains) to corner No. 1, Scheelite Load claim of Mineral Survey No. 2008, marked with a 3/4 inch aluminum rod, with aluminum cap marked T2N R2E C1 S MS2008 1987;

THENCE, North 55° 58' 55" West; a distance of 231.00 feet;

THENCE, North 0° 15' 04" East, a distance of 1154.78 feet;

THENCE, South 89° 36' 39" West, a distance of 1740.61 feet;

THENCE, North 0° 23' 40" West, a distance of 555.25 feet;

THENCE, South 89° 36' 14" West, a distance of 627.91 feet;

THENCE, North 0° 23' 53" West, a distance of 578.37 feet;

THENCE, South 89° 35' 55" West, a distance of 1119.46 feet;

THENCE, North 0° 24' 18" West, a distance of 8103.74 feet to the section line between sections 7 and 18;

THENCE, South 89° 35' 38" West, on the line between sections 7 and 18, a distance of 292.78 feet;

THENCE, North 0° 24' 25" West, a distance of 1304.71 feet to the east and west center line of the southeast 1/4 of section 7;

THENCE, South 89° 54' 39" East (South 89°52’ East), on the east and west center line of the southeast 1/4 of section 7, a distance of 694.20 feet to the S 1/16 section corner of sections 7 and 8;

THENCE, North 89° 59' 47" East, on the east and west center line of the southwest 1/4 of section 8, a distance of 1319.11 feet (South 89°59’ East, 19.99 chains) to the southwest 1/16 section corner of section 8 and the POINT OF BEGINNING, containing 709.17 acres, more or less.

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