93d Congress, 2d Session House Document No. 93-403
PROPOSED ADDITIONS TO THE NATIONAL WILDERNESS PRESERVATION SYSTEM
COMMUNICATION FROM THE PRESIDENT OF THE UNITED STATES TRANSMITTING
PROPOSALS FOR THIRTY-SEVEN ADDITIONS TO THE NATIONAL WILDERNESS PRESERVATION SYSTEM AND DEFERRAL OF ACTION ON FIVE AREAS SUITABLE FOR INCLUSION IN THE SYSTEM, AND RECOMMENDATIONS AGAINST THE INCLUSION OF FOUR OTHER AREAS STUDIED, PURSUANT TO SECTION 3 OF THE WILDER- NESS ACT OF 1964 [16 USC 1132]
PART 13
ALEUTIAN ISLANDS WILDERNESS ALASKA
DECEMBER 4, 1974. —Referred to the Committee on Interior and Insular Affairs and ordered to be printed with illustrations.
U.S. GOVERNMENT PRINTING OFFICE WASHINGTON : 1974 42 7117 O THE WHITE HOUSE
WAS HINGTO N
December 4, 1974
Dear Mr. Speaker: Pursuant to the Wilderness Act of September 3, 1964, I am pleased to transmit herewith proposals for thirty-seven additions to the National Wilderness Preservation System. As described in the Wilderness Message that I am con- currently sending to the Congress today, the proposed new wilderness areas cover a total of over nine million primeval acres. In addition, the Secretary of the Interior has recommended that Congressional action on five other areas which include surface lands suitable for wilderness be deferred for the reasons set forth below: A. Three areas which are open to mining might be needed in the future to provide vital minerals for the Nation, but these areas have not been adequately surveyed for mineral deposits. The areas are the Kofa Game Range, Arizona; Charles Sheldon Antelope Range, Nevada and Oregon; and, Charles M. Russell National Wildlife Range, Montana. B. One area is subject to withdrawals for power purposes and additional study is needed of the West's potential energy needs before a wilderness decision can be made. This is Lake Mead National Recreation Area, located in Arizona and Nevada. C. Certain parts of one area are subject to selection by the village of Mekoryuk under the terms of the Alaska Native Claims Settlement Act and a wilderness recommenda- tion should be made only after the completion of the Native selection process. The area in question is the Nunivak National Wildlife Refuge in Alaska. Four other possibilities considered by the Secretary of the Interior in his review of roadless areas of 5,000 acres or more were found to be unsuitable for inclusion in the Wilderness System: Deer Flat National Wildlife Refuge, Oregon and Idaho; Blackwater National Wildlife Refuge, Maryland; Mammoth Cave National Park, Kentucky; and, Upper Mississippi River Wildlife and Fish Refuge, Minnesota, Wisconsin, Iowa and Illinois. I concur in this finding and in the other recommendations of the Secretaries of the Interior and Agriculture, all of which are transmitted herewith.
Wilderness designation of both of these new wilderness areas and those already submitted that are pending be- fore the Congress would dramatically demonstrate our commitment to preserve America's irreplaceable heritage, and I urge the Congress to act promptly in this regard. Sincerely,
The Honorable Carl Albert Speaker of the House of Representatives Washington, D.C. 20515 I United States Department of the Interior
OFFICE OF THE SECRETARY WASHINGTON, D.C. 20240 AUG 7 1974
Dear Mr. President: It is with pleasure that I recommend the establishment of areas totaling approximately 1,395,357 acres in Aleutian Islands National Wildlife Refuge as part of the National Wilderness Preservation System. The recommendation stems from this Department's responsibility under the Wilderness Act (78 Stat. 890) to recommend to the President areas within its jurisdiction suitable for designation as wilderness. Having reviewed potential areas in Aleutian Islands National Wildlife Refuge, we conclude that 1,395,357 of the study area's 1,720,719 acres should be designated wilderness. The Aleutian Islands Refuge consists of all but seven of the islands that reach out from the Alaska mainland along a thousand-mile chain toward the Kamchatka Peninsula in the Soviet Union. The refuge was established in 1913 by Executive Order. Its nearly 70 main islands aggregate to 2,720,235 acres, making it one of the largest units in the National Wildlife Refuge System. (This Department has already studied separately and made wilderness recommendations with regard to two areas within the refuge, Unimak Island and a portion of the refuge that also lies within Izembek National Wildlife Refuge.) Most of the islands in the refuge are the emergent peaks of a submarine mountain range, and many of these are active volcanoes. The larger islands are less mountainous and, though treeless, are dotted with lakes. The sky above the refuge is almost always overcast, and precipitation occurs on an average of 200 days a year. No mineral survey of the area has been conducted; the area has no known mineral potential but does have potential for geothermal development. The Aleutian Islands are rich in wildlife. The sea otter, which bears the world's most valued fur, makes its principal home in waters off the central islands in the chain. The northern sea lion also inhabits refuge waters. Among the refuge's terrestrial mammals are the caribou, reindeer, and blue fox. The refuge is a habitat for large numbers of pelagic birds. Fulmars, petrels, cormorants, gulls, kittwakes, murres, anklets, and puffins numbering in the millions congregate in the islands' vast rookeries. The Aleutian Canada goose—one of the world's rarest birds—the bald eagle, the peregrine falcon, and gyr falcon are also found in the refuge. The great bulk of the study area is recommended for wilderness designation. The areas found to be unsuitable for such designation fall into the following general categories: (l) lands withdrawn or otherwise needed for military purposes; (2) lands eligible for selection under the Alaska Native Claims Settlement Act (85 Stat. 688); and (3) lands covered with substantial amounts of World War II refuse. Though the possibility of additional Alaska Native selection being made in the proposed wilderness area is remote, we have provided that wilderness designation shall be subject to such selection rights. It should also be pointed out that the State of Alaska is presently engaged in land use planning efforts. We recommend that the Congress give appropriate weight to the results of those efforts and to the views of the State government in considering this proposal.
In accordance with the requirements of the Wilderness Act, a public hearing on the recommendation was held at Adak, Alaska, on April 9, 197^« The hearing was continued at Atka and Unalaska, Alaska, on April 10 and concluded at Anchorage, Alaska, on April 17. Analyses of the hearing records and written expressions received, together with the letters received from other Federal agencies, are contained in the enclosed synopsis. Complete records have been compiled and are available for inspection by the public.
Enclosed is a draft bill which, if enacted, would incorporate the recommended area of Aleutian Islands National Wildlife Refuge into the National Wilderness Preservation System. Sincerely yours,
Nathaniel P. Reed Assistant Secretary of the Interior
The President The White House Washington, D.C. 20500 Enclosure A B_ !_ L. L,
To designate certain lands in the Aleutian Islands National Wildlife Refuge, Third Judicial Division, Alaska, as wilderness.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled, That in accordance with section 3(c) of the Wilderness Act of September 3, 196h (78 Stat.
890, 892; 16 U.S.C. H32(c)), certain lands in the Aleutian Islands
National Wildlife Refuge, Alaska, which comprise about 1,395»357 acres and which are depicted on a map entitled "Aleutian Islands Wilderness
Proposal" dated June 197^» except as provided in section 2 of this Act, are hereby designated as wilderness. The map shall be on file and available for public inspection in the Offices of the U.S. Fish and
Wildlife Service, Department of the Interior.
SEC. 2. As soon as practicable after this Act takes effect, a map of the wilderness area and a description of its boundaries shall be filed with the Interior and Insular Affairs Committees of the
United States Senate and the House of Representatives, and such map and description shall have the same force and effect as if included in this Act: Provided, however, That correction of clerical and typographical errors in such description and map may be made, and adjustments therein shall be made to reflect changes which may be occasioned by land selections made pursuant to the Alaska Native Claims
Settlement Act, 85 Stat. 688. SEC. 3. The area designated "by this Act as wilderness shall "be known as the "Aleutian Islands Wilderness" and shall be administered by the Secretary of the Interior in accordance with the applicable provisions of the Wilderness Act governing areas designated by that
Act as wilderness areas, and where appropriate any reference in that
Act to the Secretary of Agriculture shall be deemed to be a reference to the Secretary of the Interior.
SEC. it. Nothing in this Act shall be construed to diminish the authority of the Coast Guard, pursuant to Ik U.S.C. 2 and 8l and title 1 of the Ports and Waterways Safety Act of 1972 (33 U.S.C. 1221), the Department of Defense, pursuant to Executive Order 1733 which established the Aleutian Islands National Wildlife Refuge, and the Federal Aviation Administration to use the area designated wilderness by this Act for navigational, military, and maritime and aviation safety purposes. In the case of such use involving Coast Guard unmanned devices, the consent of the Secretary of the Interior to the use shall not be required. In recognition of the unique requirements for travel
in the area, the landing and taking off of aircraft, on lakes and waters to be designated by the Secretary of the Interior within the area, are hereby permitted. SEC. 5. Subject to all valid rights existing on the date of
enactment of this Act, lands designated as wilderness by this Act are hereby withdrawn from all forms of appropriation under the mining laws
and from disposition under all laws pertaining to mineral leasing and all amendments thereto. ALEUTIAN ISLANDS NATIONAL WILDLIFE REFUGE
ANALYSIS OF THE PUBLIC HEARING
A public hearing announcement was published in the Federal Register
on March 14, 1974. Written notification of the hearing and information
materials were sent to William A. Egan, Governor of the State of
Alaska; U.S. Senators Mike Gravel and Ted Stevens and Representative
Donald Young of Alaska; Secretaries of the Interior, Commerce, and
Defense; the respective chairmen of the Senate and House Committees
on Interior and Insular Affairs, Commerce and Merchant Marine and
Fisheries of the U.S. Congress; 60 members of the Alaska State
Legislature; 36 officials representing 17 agencies of the State of
Alaska; 50 officials representing 25 agencies and departments of
the federal government; the Joint Federal/State Land Use Planning
Commission; the Aleut Corporation, and the Alaska FederaTion of
Natives; 220 citizen organizations; and approximately 1800 individuals.
Each was sent a "package" consisting of the public hearing announcement,
a brochure summarizing the Bureau's wilderness study report. These
were mailed more than 30 days in advance of the public hearing.
The hearing record remained open for 30 days or until May 17, 1974.
1. Analysis of Testimony
In analyzing the written testimony, some contained lists
of people who were for or against the proposal, while others
had multiple signatures. Each signature was counted as one
testimony, but lists without signatures were not counted.
A total of 2-.9 individuals, orgaai.iat.ions and officials submitted
testimony.
42-797 O - 75 - pi.13 - 2 Communications were received from 6 federal agencies, 1 elected
'official, 1 state or local agency, 37 organizations and 304
individuals. Table 1 provides a breakdown of the number of
various categorized groups that testified orally or written,
their opinion on the proposal and residency.
Fifty-one of the testimonies were from Alaska and 298 v/ere non-
residents. One State official representing the Governor and a
State agency opposed the proposal as did the Federal-State
Land Use Planning Commission. Two federal agencies supported
the proposal and three opposed it. Thirty organizations supported
the proposal, four opposed it, one was partly for, five were
non-committal and the remaining 295 supported the proposal. Then
of the 349 testimonies, 327 were for, 11 against, 3 partly for,
and 8 were non-committal.
2. The Public Hearing
Public, hearings were held at Adak on April 9, 1974, at Atka and
Unalaska on April 10, 1974, and in the Loussac Library in Anchorage,
Alaska on April 17, 1974. Mr. Robert Price, Regio-ial Solicitor,
Anchorage Region, for the Department of the Interior served as
hearing officer. The Bureau of Sport Fisheries and Wildlife
was represented at Adaky Atka and Unalaska by David Spencer,
Alaska Refuge Supervisor, and at Anchorage by Gordon Watson
Alaska Area Director. Approximately 55 people attended the
hearing at Adak, 27 at Atka, 5 at Unalaska and 45 in Anchorage. Table 1. An Analysis of the Comments received from all Officials, individuals, and organizations, on the Aleutian Islands Wilderness Study Summary.
Type of Alaska Non- Type of Testimony Opinion on Proposal ' Tcstifier Resident Resident Oral Written For Against Partly For Non-committa
Llected Official 1 - - 1 - 1
Federal - Agencies 1 5 - 6 2 3 1
State & 1 1 - -• 1 Local - - - Agencies
Organ!;:.-- ulons 16 21 10 27 30 A 1 2
Individuals 32 272 15 289 295 2 2 5
Total all Groups 51 298 26 323 327 11 3 8
*- _
Includes '•'(.- leral-State Lnnd Use Planning Commission At Adak 9 people representing themselves testified and 6 supported
' the proposal and 3 were non-committal and concerned about various
aspects of the proposal. All were residents except one.
At Atka 3 people spoke, 2 representing the villagers, none of
the speakers indicated their approval or disapproval of the
wilderness proposal but asked questions to clarify it .
At Unalaska three people spoke representing themselves, however,
one was a representative of the Aleut League, two were non-commitaal
but the other was opposed to wilderness in general but indicated
some islands could be placed in wilderness.
At Anchorage 11 people spoke, 1 represented the State of Alaska,
2 represented the Aleut Corporation, 7 represented conservation
organizations, and 2 represented themselves. All conservation
representatives and one individual supported the proposal. One
individual was non-committal, the State representative was
opposed and the Aleut representative offered an alternative
to the proposal.
Adak Hearing
Dr. Douglas Kramer stated that he supported the wilderness proposal
but was concerned about the AEC testing on Amchitka Island. He
suggested a written agreement be secured in the future operations
rather than verbal agreement at the Cabinet Level.
Mr. Carl Ash and Mr. George Eischens both testified they supported
the wilderness proposal but wished to have all of Adak excluded or provide for transportation corridors to caribou hunting
• areas so snowmachines could be used if the need arises.
Mr. Glenn Elison then stated he supported the entire proposal
and definately wanted to see Adak included and snowmobiling not
permitted. He also wanted those lands not selected by the
Natives included.
Ms. Sherry Spitler, a native Aleut, was non-committal about
the proposal but wanted a delay in the proposal until the Aleuts
completed their land selection. She was informed the Native Land
Claims Settlement Act takes precedence over the Wilderness Act.
She was also concerned about the effect that the proposal
would have on the Atka reindeer herd and egg gathering by Atka
villagers.
Robert Chlolosta was also non-committal about the proposal but
expressed his concern about the intention of the AEC regarding
Amchitka.
Dan Moore asked about search and rescue operations in wilderness
area and was informed that this was permitted in emergency operations,
He later stated all of the islands of Tanaga, Ogliuga and Kiska
should be included in the proposal.
Carl Strang, a non-resident from Indiana who had spent some time
in the Aleutians stated he supported the proposal but wanted
all of the lands included on islands where there were no residents and where 95 to 99 percent of the island was proposed for
'wilderness. He felt these exclusions would, "provide a toe -
hold for activities which would indirectly damage the rest of
the island...."
Don McGuire expressed concern about space for bases of commercial
fishery operations and was informed the exclusions would provide
space for such expansion if necessary.
Atka Hearing
Mr. Michael Snigaroff, President of the village of Atka, indicated
he did not fully understand the ramnifications of the wilderness
proposal as did Mr. Larry Dirks. They asked about hunting and
fishing on wilderness, existing and new hunting cabins, possible
land selections at Attu, jurisdiction of tidelands and gardens
on Amlia Island within the proposal.
They were informed that existing cabins could remain, that the
tidelands belonged to the State of Alaska, and they could hunt
and-fish in wilderness area, but not use mechanical equipment
and that the wilderness proposal would not interfere with
connnerical fishing operations. They were also requested to send
a map for the record to point out their garden area on Amlia which
they promised to do. <
I ; Daniel Prokopeuff requested information on our fox erradication
program and requested they not be exterminated from Atka and Arilia as they trapped them in the area. Vern Byrd, the Refuge Manager
"for the western Aleutians, explained the fox erradication
program and the Aleutian Canada geese transplant program.
None of the testifiers committed themselves on the proposals
but indicated their interest would be represented by the Aleut
Corporation in Anchorage.
Unalaska Hearing
-.
Mr. Richard Swarner and Mr. Walter Dyakanoff both requested that
the portions of Amaknak Island in the refuge be withdrawn from
the refuge. They were informed that this falls within the lands
selectible by the villagers of Unalaska.
Carl Moses, President of the Aleut Corporation, stated he could
see remote islands like Buldir, the Island of Four Mountains
and portions of the larger islands being placed into the
Wilderness System but he was unequivacally opposed to the
present wilderness proposal. He stated however, that the
Aleut Corporations formal statement would be given in Anchorage.
He felt the refuge should be opened up for grazing, mineral and
geothermal energy development.
Anchorage Hearing
Mr. Richard Downing representing the State Division of Aviation
stated the wilderness proposal would restrict aviation activity
and that the Aleutians were defacto wilderness and didn't need
designation. , Mr. Jack Hession representing the national Sierra Club said the
' Sierra Club supported the wilderness proposal but requested that
the Bureau establish more formal agreements with the AEG and
the military regarding the refuge and that lands not selected
by the villagers be reviewed for wilderness and that the
Bureau attempt to negotiate an agreement with the State of Alaska
to designate tidelands adjacent to the Aleutians as marine sanc-
tuaries.
Claudia Martin representing the Alaska Chapter of the Sierra
Club also supported the proposal and suggested a formal agreement
with the military be considered to guarantee further military
operations would not damage the island ecosystem. She also
suggested the Bureau should get control of the tidelands.
Larry Meculieff and George Pletnikoff representing the Aleut
Corporation stated man should be considered part of the animal
ecosystem and that establishing wilderness area does not allow
normal- interaction. They then read a letter from Dr. William
Laughlin who first criticized some errors in the Aleutian
Wilderness Field Report then suggested the Aleut Corporation
explore with the Bureau the feasibility of an agreement to have
the Bureau protect unlisted historical sites under the authority
of the Antiquities Act. He suggested the Aleut Corporation offer
an alternate to the wilderness proposal with a management system
where man is molded into the ecosystems. Larry Merculieff then pointed out it wasn't the Aleuts who caused
. the extinction or near extinction to the sea cow, Aleutian
Canada goose, sea otter and other forms of wildlife and caused
much destruction of the island environment in World War II.
He then stated he felt the Bureau did not spend enough time
trying to inform the village people in the islands about the
Wilderness Act.
Larry Merculieff then stated their alternative to the wilderness
proposal was the creation of an "Aleut Ecosystem Research
and Management Unit." The concept is to allow Aleut experiences
backed by appropriate scientific expertise to be molded into
the land management structures which directly affect the Aleut
lives and culture. He read a detailed letter from Dr. William
Laughlin explaining their theory.
Peg Tileston speaking for the Alaska Center for the environment
supported the proposal but also urged that military debris be
cleaned up and on completion be added to the wilderness system
and that tidal lands be placed under Bureau jurisdiction.
Bob Childers representing the Fairbanks Environmental Center
supported the proposal and emphasized the values of wilderness
designated lands in Alaska.
Sharon Cisson read a letter from James Kowalsky representing
Alaska Friends of the Earth supporting the wilderness proposal.
42-797 O - 75 -pi. 13 - 3 He then cited many instances and actions the State of Alaska
'had taken in the past harmful to wilderness. He emphasized
greater need for designated lands under the Wilderness System.
Sharon Cisson then stated she personally supported the proposal.
Mark Ganople representing the Wilderness Society and the Alaska
Wilderness Council supported the wilderness proposal but criticized
the Bureau for not completing its wilderness studies as directed
by the Wilderness Act of 1964.
Mrs. Petrivelli, an Aleut, then stated she didn't know about
the Wilderness Act and wanted to know how they would be able
to select their lands. 3. Written Testimony * a. Communications from Elected Officials.
Mr. Robert W. Pavitt, representing the Governor of Alaska, wrote
the Aleutians are defacto wilderness and "that there is no need
to institute wilderness status at this point and time." He felt
it should be delayed until an overall land use plan is developed
for Alaska. .
b. Communications from State Agencies and Non-Elected Officials.
None were received.
c. Communications from the Joint Federal/State Land-Use Planning
Commission for Alaska.
The Land Use Planning Commission wrote that they felt that the present
study did not adequately consider the impact on the entire Aleutian
Region and the Pacific Rim and that a wilderness recommendation should
await a long term land use plan for Alaska and should not be conducted
piecemeal refuge by refuge.
d. Communications from Federal Officials and Agencies.
Thomas V. Falkie, Director, U.S. Bureau of Mines, did not comment on
the proposal except to say he ,felt no sufficient mineral survey had been
conducted in the Aleutians.
Lyle K. Brown, Director of the Federal Aviation Administration, Alaska,
only commented that the FAA controlled airspace over the refuge. Joseph Marlane, General Council of the Department of Commerce recommended * against the proposal until full consideration is given to the way such a proposal fits in with the overall coastal zone management program under consideration by the State of Alaska.
Maurice Lundy, Regional Director, Bureau of Outdoor Recreation, Seattle, concurred with the Bureau proposal.
John Rutter, Regional Director, National Park Service, Setttle, concurred and suggested a special provision be added in the establishing legis- lation so that the Secretary could add lands not selected by the
Aleuts.
Martin G. Slapikos, Deputy Secretary, Headquarters, Alaska Command, remarked that they must object to the proposal unless the legislature establising wilderness recognizes the military's present rights in the Aleutians and the "reservation should not interfere with the use of lands for military or naval purposes."
J. R. Iverson of the 17th Coast Guard District, U.S. Coast stated they operate 3 long range aids to navigation transmitting stations, one major seacoast light station and 12 minor aids to navigation in the Aleutians. Continued access and operations of these facilities is a necessity. e. Communications from Organizations
«» In addition to the ten organizations that testified at the hearings,
26 submitted written testimony. Five of these were from Alaska and
21 were from other states. Only one organization opposed the proposal,
The American Mining Congress, on the grounds no thorough mineral survey • had been conducted.
Six organizations which supported the proposal had these additional comments:
Kodiak-Aleutian Chapter, Alaska Conservation Society
Kenai-Aleutian Chapter, Alaska Conservation Society
1) Lands not selected by the natives should be reviewed for
possible inclusion for wilderness at a later date.
Federation of Western Outdoor Clubs—Seattle
1) A written agreement should be reached between the Bureau and
military on the remaining lands to guarantee protection.
2) Lands not selected by the natives should be considered for
inclusion.
3) Make the tidelands a marine sanctuary.
Hennepin County Park Reserve District—Minnesota
1) Make military remove their debris.
I
Wilderness Committee of North Virginia
1) Add any military lands that become available.
2) Add lands not selected by natives. Western Wilderness Association—Nevada
*1) Void all military withdrawals and agreements and add to
wilderness as well as the lands requested for exclusion by
the military.
2) Remove all refuse and add areas to wilderness
3) Add lands not selected by natives.
In addition to these six organizations the following 19 supported the proposal:
Mt. Shasta Area Adubon Society—California
Federation of Outdoor Western Clubs
Environmental Defense Fund
Southern Oregon-Northern California Wilderness Coalition
Chemithon Corporation
Sussex Woodlands
Woman's Day
Church of the New Covenant
Maintain Eastern Oregon Wilderness
Enpro-Chapter of the Audubon Society
Sagaro Ecology Club
The Wilderness Society
Ecology Center of Southern California
Valley Center for Ecology
Live Wilderness Expeditions
Southwest River Study Committee
Sagaro Ecology Club—Catherine Call ; Upper Cook Inlet Chapter of the Alaska Conservation Society Sierra Club—Tampa Florida Chapter
* f. Communications from Individual Citizens
A total of 289 individuals submitted written testimony. Seventeen were Alaska residents and the remainder non-residents. All supported the proposal, llany citizens requested the military be restricted and additional military lands be added. Others requested the remaining military debris be removed and these lands included in wilderness.
Several asked to have those lands included which the natives did not select and only a few requested the tidelands be included. ALEUTIAN ISLANDS
Wilderness Study Summary ALEUTIAN ISLANDS NATIONAL WILDLIFE REFUGE, ALASKA
42-797 O - 75 - pt.13 - 4 Islands of Four Mountains
This report was prepared pursuant to the Wilderness Act, Public Law 88-577. Publication of the findings and recommendations herein should not be construed as representing either the approval or disapproval of the Secretary of the Interior. The purpose of this report is to provide information and alternatives for further consideration by the Bureau of Sport Fisheries and Wildlife, Secretary of the Interior, and other Federal agencies.
As the Nation's principal conservation agency, the Department of the Interior has basic responsibilities for water, fish, wildlife, mineral, land, park, and rec- reational resources. Indian and Territorial affairs are other major concerns of America's "Department of Natural Resources." The Department works to assure the wisest choice in managing all our resources so each will make its ful! contribution to a better United States—now and in the future. ALEUTIAN ISLANDS LOCATION MAP This sea otter and pup are among the thousands which presently thrive in the Aleutians. ALEUTIAN ISLANDS WILDERNESS STUDY SUMMARY
This brochure summarizes the wilderness study conducted on the Aleutian Islands National Wildlife Refuge by the Bureau of Sport Fisheries and Wildlife at the direction of the Secretary of the Interior. Its aim is to assist the reader in forming an opinion of the desirability of including all or portions of the refuge into the National Wilderness Preservation System. The Wilderness Act of September 3, 1964, (Public Law 88-577) requires that the Secretary of the Interior review every roadless area of 5,000 contiguous acres or more and every roadless island, regardless of size, within the National Wildlife Refuge System within ten years after the effective date of the Act, and report to the President of the United States his recommendations as to the suitability or non- suitability of each such area or island for preservation as wilderness. A recommendation of the President for designation as wilderness does not become effective unless provided by an Act of Congress. In defining wilderness, the Act also included areas of less than 5,000 acres that are of sufficient size to make preservation and use in an unimpaired condition practicable. Sections 4(a) and (b) of the Wilderness Act provide that (1) the Act is to be within and supplemental to the purposes for which National Wildlife Refuges are established; and (2) Wilderness areas shall be administered so as to preserve their wilderness character and shall be devoted to the public purposes of recreational, scenic, scientific, educational, conservation and historical use insofar as primary refuge objectives permit. Wilderness designation does not remove or alter an area's status as a National Wildlife Refuge. The Aleutians contain some of the world's largest seabird rookeries. introduction Like a giant series of stepping stones, the Aleutian Islands arc 1,100 miles westward into the North Pacific Ocean to within 600 miles of the Asian mainland. The chain of over 200 fog- enshrouded volcanic islands - rich in fish and wildlife resources was set aside as the Aleutian Islands National Wildlife Refuge by Executive Order 1733 on March 3, 1913. The order was later modified so that the refuge now contains all of these remote, treeless islands except Akun, Akutan, Sanak, Tigalda, Umnak, Unalaska, Sedanka and portions of Amaknak. The primary purpose in establishing the 2,720,430-acre refuge was as a preserve and breeding ground for native birds, for the propagation of reindeer and furbearing animals, and for the encouragement and development of the fisheries. Though some of the Aleutians were badly scarred during World War II as Americans fought to oust the Japanese who occupied Attu and Kiska Islands, most of the islands still retain their natural, primeval values. Refuge goals have been refined and now emphasize preserving in a natural state this unique island ecosystem with its abundance of fish and wildlife resources. Unimak, the largest island in the Aleutians, is not considered in this study. Due to its size, and unusual floral and faunal characteristics, it previously underwent study and public evaluation for its wilderness qualities at a public hearing in December 1971. The 1,451-acre Cape Krenitzin Peninsula at the tip of the Alaska Peninsula was also considered earlier with the Izembek Wilderness Proposal. Thus, the present study considers only 1,720,719 acres of the Aleutians. The Aleutian Islands National Wildlife Refuge is administered from two headquarters: the islands west of Samalga Pass from Adak, Alaska, near the center of the chain and 1,200 air miles southwest of Anchorage, Alaska; and the eastern Aleutians from Cold Bay, on the Alaska Peninsula. r>iii«\
An abandoned barabara is a reminder of the past, when seafaring Aleuts thrived throughout the islands. history
The Aleuts, the Native people of the Aleutians, thrived in villages along the coasts of the Aleutian Islands and the Alaska Peninsula for thousands of years. These seafaring people lived in underground lodges called bardbaras and traveled along the coast in their sleek, kayak-like bidarkas. An abundance of plants, sea mammals, birds and fish provided them with food, clothing and shelter. When the Russian explorers first arrived in the 18th century, approximately 16,000 Aleuts occupied this region. Discovery of the valuable sea otter pelt led to exploitation of both this animal and the Aleuts by the Russian fur traders for a number of decades. Whole villages were enslaved to help harvest the sea otter, and diseases rapidly decimated the people. By the mid 1800's, the sea otter had been greatly reduced and fewer than 1,000 Aleuts survived. With the sale of Alaska to the United States in 1867, the fur pillage was renewed in earnest, and not until 1911 were stringent regu- lations adopted to protect the nearly-extinct sea otter. During the 1920's, most of the islands were leased for commercial fox farming. The boom ended abruptly during the 1940's when the popularity of fox fur waned and prices plunged, but in the meantime many of the islands' birds had been jeopardized by the introduced foxes. During World War II, when the Japanese seized Kiska and Attu Islands, the United States responded by constructing large staging and bombing bases in the Aleutians. Thousands of structures were erected on Amchitka, Shemya, Adak and other refuge islands. An assault on Attu resulted in a hard-won victory for the United States, followed by evacuation of the remaining Japanese forces from Kiska. American forces deserted most of the islands at the end of the war, abandoning equipment and structures. Miles of roads, old landing strips, wrecked ships, warehouses, telephone .lines, trash dumps and scattered oil drums are still present.
42-797 O - 75 - pi. 13 - 5 The present-day Aleut village of Atka on Atka Island Ls the only Native village in the study area. Because of the Japanese attack nearly all of the civilian Native population was moved by the United States government to southeast Alaska. Attu Vil lage was captured by the Japanese and its population of 45 taken to Japan. Survivors were released in 1945 following the Japanese surrender. Today, numerous old village sites of great historical and archeological value remain within the refuge but only the village of Atka, with a population of about 88, is located within the wilderness study area.
A one-man Japanese submarine lies on Kiska Island, a remnant of the Japanese occupation of Kiska and Attu Islands during World War II. Amukta Island The islands are treeless but bloom with a profusion of flowers during summer.
physical description
The wilderness study area is part of the Aleutian archipelago - a chain of 200-plus islands, associated offshore rocks and reefs that constitute a barrier between the Bering Sea and North Pacific Ocean. The islands, of recent volcanic origin, are the emergent peaks of a submarine ridge that extends more than 12,000 feet below sea level. Were all of the Aleutians below and above the sea visible, they would comprise one of the most spectacular mountain ranges in the world. Many of the volcanoes in the study area are still active, and sharp-coned peaks that rise from 3,000 to over 6,000 feet above sea level send plumes of steam and smoke high into the foggy skies. Over 2,450 miles of irregular coastline vary from gently sloping sand beaches to towering rocky cliffs. Numerous waterfalls tumble down the steep slopes, while shallow lakes and streams are common on the less mountainous islands. Rocky coastlines and volcanic mountains add scenic beauty to the storm-tossed islands. The Aleutian Islands have been described as a melting pot for faunal and floral elements from two continents not yet in equilibrium. The western Aleutians show floral characteristics similar to the Kamchatka Peninsula of Siberia, while the eastern islands are floristically closer to the Alaska Peninsula. The shoreline waters support extensive beds of kelp and other seaweeds, while tall ryegrass grows along the beaches. Rains turn the drab brown winter vegetation into a lush green land- scape during the summer. The many grasses, sedges, lichens and heath plants are interspersed with a colorful variety of flowers that include lupine, monkshood, buttercup, iris, fireweed and several species of orchid. The climate is maritime, characterized by cool summers, mild winters, overcast skies and gale-force winds. The mean annual temperature is near 40°F and temperatures below zero are rare. Precipitation falls almost 200 days a year, in the form of rain, mist or snow.
The Aleutians contain many offshore rocks, reefs ;-md 2.700 miles of shoreline. •••,
,-
Caribou were introduced to Adak Island in 1958 . e SEA 0 \A V
u
MAP (b Aleutian Islands Wilderness Proposal Aleutian Islands National Wildlife Refuge Buldir I. MAP<*
I LANDS SUITABLE FOR WILDERNESS MA? 10 uttu i.J H LANDS NOT SUITABLE FOR WILDERNESS k SemUopochnoi t. LANDS NOT IN WILDERNESS STUDY AREA ] LANDS SUBJECT TO NATIVE VILLAGE SELECTION 4f / J Amchitko '• ~*~ HEADQUATER SITE 'V/
o c C 50 50 A C \ SCALE IN MILES Preliminary subject to change Preliminary-Subject to change
IU*00' 162*30'
Ownii Illon* LEGEND ;& LAND NOT WITHIN REFUGE
V WJO' M«JO' HM.KM KKKI-
/ )AMAK ISLAND
\S>
JS»8'
I6Z°30' MAP 1 MAP 2 AMAK ISLAND AND SANAK ISLAND GROUP ALEUTIAN ISLANDS WILDERNESS PROPOSAL ALEUTIAN ISLANDS NATIONAL WILDLIFE REFUGE ALASKA LAND NOT WITHIN REFUGE
---- BOUNDARY OF LANDS PROPOSED FOR NATIVE VILLAGE WITHDRAWAL
EASTERN FOX GROUP ALEUTIAN ISLANDS WILDERNESS PROPOS> ALEUTIAN ISLANDS NATIONAL WILDLIFE REFUGE ALASKA MAP 3 •COO
N
••"Otf—U
LEGEND PROPOSED EXCLUSION
LAND NOT WITHIN REFUGE
BOUNDARY OF LANDS PROPOSED FOR NATIVE VILLAGE WITHDRAWAL
ISLANDS OF THE FOUR MOUNTAINS AND WESTERN FOX GROUP ALEUTIAN ISLANDS WILDERNESS PROPOSAL ALEUTIAN ISLANDS NATIONAL WILDLIFE REFUGE ALASKA MAP 4 LEGEND L J PROPOSED EXCLUSION
— .— BOUNDARY OF LANDS PROPOSED fOR NATIVE VILLAGE WITHDRAWAL
EASTERN ANOREANOF ISLAND GROUP ALEUTIAN ISLANDS WILDERNESS PROPOSAL ALEUTIAN ISLANDS NATIONAL WILDLIFE REFUGE LEGEND PROTOSCD CXCLUSION
WESTERN ANDREANOF ISLAND GROUP ALEUTIAN ISLANDS WILDERNESS PROPOSAL ALEUTIAN ISLANDS NATIONAL WILDLIFE REFUGE ALASKA MAP 7 Preliminary-Subject to change
CA« 3AJAKA
OOLIUGA IS. tsuwn. \. JrSLAHO
i" ' /•'"-
1 ri *
.-I ...51° 19'
DELAROF ISLAND GROUP LEGEND ALEUTIAN ISLANDS WILDERNESS PROPOSAL PROPOSED EXCLUSION ALEUTIAN ISLANDS NATIONAL WILDLIFE REFUGE ALASKA MAP 8 4- 4-
4-
—f 4-
7 Beams set
LEGEND [ \ PROPOSED EXCLUSION -4- ± "t"'"' RAT ISLAND GROUP ALEUTIAN ISLANDS WILDERNESS PROPOSAL MAP 10 ALEUTIAN ISLANDS NATIONAL WILDLIFE REFUGE ALASKA MAP 9 PrtlHni""»'giibliel 10 Olong«
ALAIDXJ '4- ISLAND HIZKIN _. _ -, ISLAND ISLAND^' 5
SI-JO'——
LEGEND PROPOSED EXCLUSION
oi t a < t
NEAR ISLAND GROUP ALEUTIAN ISLANDS WILDERNESS PROPOSAL ALEUTIAN ISLANDS NATIONAL WILDLIFE REFUGE ALASKA MAP 11 One of the many sea mammal rookeries in the Aleutians.
Resources
The wildlife resources of the Aleutians are rich and varied. The sea otter has made a comeback and approximately 60,000 now thrive in the shallow offshore waters of the Aleutians. Most of these are located in the central Andreanofs, the Delarofs, Rat and Sanak Island groups within the study area. Over 75,000 sea lions and thousands of hair seals haul out on the rocks at numerous sites within the area. Fur seals migrate through the islands as do several species of whales and porpoises. A few walruses occasionally haul out on Amak Island. Almost all terrestrial mammals in the study area have been introduced by man. Foxes were established on all major islands and many of the smaller ones by the late 1940's. More than 2,500 wild reindeer thrive on Atka and caribou have been introduced on Adak. Birds are much in evidence at all times and one hundred and eighty three species have been recorded in the islands. The most obvious feature of the Aleutian wildlife is the large number of pelagic birds. Fulmars, petrels, cormorants, gulls, kitt- wakes, murres, auklets and puffins numbering into the millions congregate in the vast, closely-packed rookeries along vertical cliffs, in caves and on beaches. The largest known fulmar colony, estimated at 450,000 birds,is located on Chagulak Island. Spectacular concentrations of waterfowl occur during migrations and the majority of the world's emperor geese winter in the area. The Aleutian Canada goose - considered one of the world's rarest birds - formerly nested on many islands west of Yunaska, but is found at present only on tiny Buldir Island, which escaped fox introductions. Large numbers of migrating shorebirds frequent island beaches, lowlands, lakes and lagoons, although only a few species nest in the chain. Bald eagles and peregrine falcons occupy aeries on many of the islands. Multitudes of lapland longspurs migrate through the islands annually and nest
The least auklet is the most abundant nester in the Islands. Hundreds of bald eagles nest on prominent rocky points.
on the refuge in company with a variety of other interesting songbirds and the only upland game bird, the rock ptarmigan. Four native species of salmon and the Dolly Varden spawn in freshwater streams where they constitute an important food source for bald eagles and also make significant contributions to commercial fishing operations in the surrounding seas. The Aleutian Islands are of vglcanic origin and lie within a geothermal resource province. Sixteen islands within the study area are classed as having significant geothermal potential. The area lies outside the petroleum province of Alaska and has no known metalliferous mineral deposits worthy of commercial development, although one known sulfur deposit occurs on Little Sitkin and a few specimens of coal have been collected from Amchitka. A hiker walks a lonely Aleutian beach in search of driftwood and glass floats from fishing nets. puBlic use
The Aleutians' remote setting, inclement weather conditions, sparse human population, high transportation costs, and lack of commercial facilities discourage any extensive public recreational use of the refuge. Most use is confined to the immediate areas surrounding the military and civilian population centers. Sport fishing, beachcombing, berry picking and wildlife observation are some of the popular pastimes, with hunting confined to the islands of Atka, Great Sitkin, Adak and Attu. The islands, with their extensive diversity of scenic, fishery and wildlife resources, hold a great potential for an expansion of wildlife-oriented recreational use, and some increase can be expected as the nation's population grows and becomes more mobile.
-A 5
A family enjoying clam digging. . , '.. .:,
The endangered Aleutian Canada goose, decimated by the introduction of foxes, now nests only on Buldir Island. rmmqement
The Bureau's primary refuge management objectives in the Aleutian Islands National Wildlife Refuge are to preserve and protect the many ecological values and to restore those that have been destroyed through past misuse. To fulfill these objectives, periodic resource inventories, research studies, and routine patrols are necessary. These functions are accomplished by boat, aircraft or afoot, and will not conflict with wilderness designation. Use of overland vehicles for the Bureau's management functions is confined to road systems on existing military installations, which are excluded from the wilderness proposal. The State of Alaska has primary juris- diction over resident fish and wildlife species. Their management functions are also conducted from aircraft or vessels. Public access to the study area is also by boat and aircraft. The Bureau does not contemplate any habitat improvement other than revegetation of denuded areas, which are largely confined to refuge lands excluded from the proposal. Restoration of the endangered Aleutian Canada goose population is a primary Bureau goal requiring removal of introduced rats and foxes, which are detrimental to the survival of these birds. One grazing lease in existence on Caton Island is managed so as to be compatible with wilderness designation. Other islands have some grazing potential but such activities have been considered unacceptable to refuge goals because of detrimental effects on vegetation and wildlife. Thus, future expansion of the grazing program is not anticipated in the refuge. The Executive Order establishing the refuge states, "The establishment of this reservation shall not interfere with the use of the islands for lighthouse, military, or naval purposes..." Essentially, this authorizes the military access to the refuge for these purposes. Most of their activities are confined to specifically withdrawn areas, including 61,000 acres on Adak; 1,900 acres on Ugamak; and 1,800 acres on Attu. Military use on Shemya Island is by an existing agreement. Atomic Energy Commission activities on Amchitka were arranged by verbal agreement at the Cabinet level. Though there is a need for a formal agreement between the Bureau and the military on any planned future operations, such an agreement has never been promulgated. M " I , ,. „ I , I 1
Military debris from World War II litters the foreground with an active military site on Attu in the background. development
Japanese and American military forces abandoned vast amounts of equipment, material and buildings which were placed on the islands during World War II. Other military sites have been constructed since the war and more recently the Atomic Energy Commission has developed large portions of Amchitka Island for experimental military tests. These activities have resulted in considerable surface disturbance. Some of the abandoned sites contain major military debris, such as runways, more than 20 Quonset huts, large buildings, construction equipment, and extensive road systems, while others have only minor debris, such as short road systems, few Quonset huts, and oil drums. The major debris sites will require extensive effort and costs to restore to former conditions, while most of the material at the minor debris sites could be removed and the area allowed to revert to natural conditions. Other developments on the study area are a few old cabins used for hunting, trapping, and fishing. Six cabins were placed on Adak to provide shelter for hunters and to administer and manage the introduced caribou. No highways are planned in the area proposed for wilderness designation and other developments, such as fish-processing sites, can be confined to areas excluded from the proposal. warn
The Adak Naval Station demonstrates the high strategic military value of the Aleutians. SOCIAL And economic considerations The bulk of the 6,300 people inhabiting the study area is concentrated at military bases. Approximately 5,000 personnel are based at the Adak Naval Station on Adak Island; 1,100 at Shemya Air Force Station on Shemya Island; and 42 on Attu Island. Fewer than 100 people, mostly Native Aleuts, reside in Atka, the only Native village within the study area. The economy and human population distribution of the Aleutian area is based primarily upon government and seafood industry activities. The seafood industry, which represents the primary source of Native employment, operates in the eastern Aleutians. Governmental activities, mainly associated with the military, are concentrated in the central and western portions of the chain. Government employment is mostly with the Departments of Defense, Transportation, and the AEC, which represent large capital investments and sizable payrolls, but have little economic impact on the Native populations of the chain. The Aleutians are considered of high strategic military importance and the bases of Adak and Shemya critical to the balance of power in the North Pacific. On Amchitka, the transient population varies with Atomic Energy Commission activities. Present projects are scheduled to be terminated during 1973, and future use of the island will depend on the necessity of nuclear testing to insure an adequate national defense. The single refuge grazing lease on Caton Island has little effect on the economic stability of the area, while the potential economic value that could be realized from developing the sulfur deposits on Little Sitkin is unknown. Development would be severely hindered by great shipping distances, absence of a suitable harbor, rugged terrain and extreme climatic conditions. Recreational use and tourism is not expected to increase rapidly, but with improved access and cheaper transportation costs, the number of visitors could increase and have an economic impact. The refuge's value as an outdoor scientific laboratory is expected to grow as the world's major insular ecosystems are altered by man. The varied natural terrestrial and marine communities offer many opportunities for research. .
The Aleutians are strikingly beautiful on a clear winter day. conclusions
The Aleutian Islands National Wildlife Refuge possesses some outstanding wilderness values. Approximately 1,395,357 acres appear suitable for inclusion in the National Wilderness Preservation System. This area includes many acres of great scenic, scientific, archeological, historical and ecological value. Approximately 325,362 acres of the study area appear unsuitable for wilderness designation. These excluded areas would provide for military operations and future expansion of the fish industry, as well as for Aleut land selections under the Alaska Native Claims Settlement Act. The unsuitable areas include: (1) 64,700 acres withdrawn for military and lighthouse purposes on Ugamak, Adak and Attu; (2) 3,520 acres on Shemya covered by an agreement with the military; (3) 26,596 acres on Amchitka requested for exclusion by the military; (4) 197,028 acres eligible for selection by the Aleuts under the Alaska Native Claims Settlement Act; (5) 32,869 acres with major military refuse sites located on Great Sitkin, Tanaga, Ogliuga, Amchitka, Kiska, and Attu; and (6) 649 acres of Samalga and Unalga excluded because the greater portion of these two small islands falls within Native withdrawals. In addition, under the authority of the Alaska Native Claims Settlement Act, numerous cemeteries and historical sites may be selected by the Natives. It is not known which sites will be selected, but these selections will take precedence over any wilderness designation. It is recommended, however, that any lands within the Native withdrawal area not selected by the Natives be evaluated as to their suitability for wilderness at a later date. Since waters below the line of mean high tide are not under refuge jurisdiction, motorboats may be used for commercial fishing and for access to the island beaches and lagoons. Aircraft may also land in these waters and within excluded areas. Alternatives to the proposed action have been explored and an Environmental Statement prepared for review by the Council on Environmental Quality as required by the National Environmental Policy Act of 1969 (Public Law 90-190). Buldir Island contains the only colony of red-legged kittiwakes in the study area. Evidence of the volcanic origin of the Aleutians is everywhere in the chain.
Persons interested in the proposal are encouraged to inspect the Aleutian Islands. Additional information may be obtained from the Refuge Managers, Box 5251, Adak, Alaska 98791, and Pouch 2, Cold Bay, Alaska 99571, or from the Area Director, U. S. Fish and Wildlife Service, 813 D Street, Anchorage, Alaska 99501. List of Document Parts — House Document 93-403
PART
1. Mount Rainier Wilderness, Mount Rainier National Park, Washington 2. Kenai Wilderness, Kenai National Moose Range, Alaska 3. Cloud Peak Wilderness, Bighorn National Forest, Wyoming 4. Agassiz Wilderness, Agassiz National Wildlife Refuge, Minnesota 5. Sheldon Wilderness, Sheldon National Antelope Refuge, Nevada (and proposed deferral of action on portions of the Charles Sheldon Antelope Range, Nevada and Oregon) 6. Monarch Wilderness, Sequoia and Sierra National Forests, California 7. Santee Wilderness, Santee National Wildlife Refuge, South Carolina 8. Everglades Wilderness, Everglades National Park, Florida 9. Salmon River and Idaho Wildernesses, Boise, Challis, Payette, Salmon, Bitterroot, and Nezperce National Forests, Idaho 10. Parker River Wilderness, Parker River National Wildlife Refuge, Massa- chusetts 11. Hawaii Volcanoes Wilderness, Hawaii Volcanoes National Park, Hawaii 12. Big Lake Wilderness, Big Lake National Wildlife Refuge, Arkansas 13. Aleutian Islands Wilderness, Aleutian Islands National Wildlife Refuge, Alaska 14. Beartooth Wilderness, Custer and Gallatin National Forests, Montana 15. Dinosaur Wilderness, Dinosaur National Monument, Utah and Colorado 16. Lacassine Wilderness, Lacassine National Wildlife Refuge, Louisiana 17. Popo Agie Wilderness, Shoshone National Forest, Wyoming 18. Mattamuskeet Wilderness, Mattamuskeet National Wildlife Refuge, N. Car.; Swanquarter Wilderness, Swanquarter National Wildlife Refuge, N.Carolina; Cedar IslandWilderness, Cedar Island National Wildlife Refuge, N. Carolina; Pea Island Wilderness, Pea Island National Wildlife Refuge, North Carolina 19. Organ Pipe Cactus Wilderness, Organ Pipe Cactus National Monument, Arizona 20. J. N. "Ding" Darling Wilderness, J. N. "Ding" Darling National Wildlife Refuge, Florida 21. Trinity Alps Wilderness, Klamath, Shasta-Trinity, and Six Rivers National Forests, California 22. Assateague Island Wilderness, Chincoteague National Wildlife Refuge and Assateague Island National Seashore, Maryland and Virginia 23. Death Valley Wilderness, Death Valley National Monument, California and Nevada 24. Fort Niobrara Wilderness, Fort Niobrara National Wildlife Refuge, Nebraska 25. Medicine Lake Wilderness, Medicine Lake National Wildlife Refuge, Montana 26. Great Smoky Mountains Wilderness, Great Smoky Mountains National Park, North Carolina and Tennessee 27. Big Blue, Courthouse Mountain, Dolores Peak, and Sneffels and Mount Wilson Wildernesses, San Juan and Uncompaghre National Forests, Colorado 28. Lake Woodruff Wilderness, Lake Woodruff National Wildlife Refuge, Florida 29. Anaho Island Wilderness, Anaho Island National Wildlife Refuge, Nevada 30. Noxubee Wilderness, Noxubee National Wildlife Refuge, Mississippi 31. UL Bend Wilderness, UL Bend National Wildlife Refuge, Montana 32. Bombay Hook Wilderness, Bombay Hook National Wildlife Refuge, Delaware 33. Back Bay Wilderness, Back Bay National Wildlife Refuge, Virginia 34. Gila Wilderness, New Mexico (addition) 35. Proposed areas for which deferral of action is recommended: Kofa Game Range, Arizona Charles M. Russell National Wildlife Range, Montana Lake Mead National Recreation Area, Nevada and Arizona Nunivak National Wildlife Refuge, Alaska 36. Areas found unsuitable for inclusion in the System: Deer Flat National Wildlife Refuge, Oregon and Idaho Blackwater National Wildlife Refuge, Maryland Mammoth Cave National Park, Kentucky Upper Mississippi River Wildlife and Fish Refuge, Minnesota, Wisconsin, Iowa, and Illinois
O