Ambler SSR Appendix A

Ambler SSR Appendix A

Ambler Road Environmental Impact Statement Scoping Summary Report – Appendix A: Comments on Potentially Significant Issues Potentially significant issues are summarized in Section 2.2 of the Draft Scoping Summary Report, which provides a high-level overview of issues in broad groupings (e.g., issues related to the biological environment and issues related to the social environment). This appendix provides the detailed comments, organized by the same broad headings and then by sub- issues. These comments are presented verbatim from the communications received. The comments were included in this appendix because they were considered to be “substantive” and related to potentially significant issues. As defined by the BLM during the public scoping meetings, a substantive comment is one that is specific, presents new information, shares issues relevant to the environmental analysis, and/or suggests alternatives to the proposed project and the reason(s) why they should be considered. Non-substantive comments, such as expressing opinions for or against the project without including an explanation, are not included in this appendix; however, they are a part of the project record and will reside in the Administrative Record. Analysts assigned to write the EIS will delve further into the detailed comments related to each issue and use those comments to shape the analysis in the EIS. As presented at the scoping meetings, these comments will be considered to potentially refine the purpose and need, determine issues and impacts to be studied, determine alternatives to be studied, and potentially identify mitigation measures to apply to the project. i Ambler Road EIS Scoping Summary Report Appendix A Table of Contents Project and Process .................................................................................................................. 1 Issue 1: Access ...................................................................................................................... 1 Issue 2: Alternatives/Project Description ................................................................................14 Issue 3: EIS and EEA Process ..............................................................................................40 Issue 4: Maintenance and Operations ...................................................................................85 Issue 5: Mining Impact ...........................................................................................................93 Issue 6: Purpose and Need ................................................................................................. 110 Physical Environment ..............................................................................................................123 Issue 7: Geology/Topography/Soils .....................................................................................123 Issue 8: Land Use/Land Management .................................................................................127 Issue 9: Noise and Air Quality .............................................................................................131 Issue 10: Water (Waterways/Rivers/Tributaries/Watershed) ................................................144 Biological Environment ............................................................................................................154 Issue 11: Wetlands and Vegetation .....................................................................................154 Issue 12: Wildlife and Fish ...................................................................................................159 Social Environment .................................................................................................................182 Issue 13: Cultural/Historic Resources ..................................................................................182 Issue 14: Economics ...........................................................................................................187 Issue 15: Recreation and Tourism .......................................................................................205 Issue 16: Social Impact .......................................................................................................213 Issue 17: Socioeconomics ...................................................................................................223 Issue 18: Subsistence .........................................................................................................232 Issue 19: Wilderness ...........................................................................................................245 Other Topics ...........................................................................................................................253 Issue 20: Other Impact Topics .............................................................................................253 Issue 21: Mitigation (or Conditions of Permit) ......................................................................255 ii Ambler Road EIS Scoping Summary Report Appendix A Acronym List ADEC State of Alaska Department of Environmental Conservation ADNR State of Alaska Department of Natural Resources ADOT Alaska Department of Transportation and Public Facilities AIDEA Alaska Industrial Development and Export Authority AMD Ambler Mining District AMDIAP Ambler Mining District Industrial Access Project ANILCA Alaska National Interest Lands Conservation Act APE Area of Potential Effect BIA Bureau of Indian Affairs BLM US Bureau of Land Management CEQ Council on Environmental Quality CFR Code of Federal Regulations DEIS Draft Environmental Impact Statement DMTS Delong Mountain Transportation System DNR State of Alaska Department of Natural Resources DOT&PF Alaska Department of Transportation and Public Facilities EEA Environmental and Economic Impact Analysis EIS Environmental Impact Statement EPA US Environmental Protection Agency GAAR Gates of the Arctic National Park and Preserve GMP General Management Plan LEDPA Least Environmentally Damaging Practicable Alternative NCA National Climate Assessment NEPA National Environmental Policy Act NHPA National Historic Preservation Act iii Ambler Road EIS Scoping Summary Report Appendix A NPS National Park Service OHA Office of History and Archaeology OHV Off-highway Vehicle ROW Right-of-Way TAPS Trans-Alaska Pipeline System TCC Tanana Chiefs Conference USACE US Army Corps of Engineers USCG US Coast Guard USDOI US Department of the Interior USDOT US Department of Transportation WACH Western Arctic Caribou Herd iv Ambler Road EIS Scoping Summary Report Appendix A Project and Process Issue 1: Access 1. A lot more study is needed on a road through that area that area and I do not like the idea of a private road going near but bypassing many communities that do not have road access. 2. The EIS for the AIDEA AMDIAP project should assume community related commercial activity on the road will occur immediately upon the initiation of other traffic rather than treating such activity as a hypothetical future possibility, as indicated in the application. ...As noted in the SF-299, Question 16, the community of Kobuk currently has a road from the community to the Dahl Creek Airstrip and a road connects the Dahl Creek airstrip to the Trilogy Metals exploration camp at Bomite. These roads are currently suitable for seasonal use by vehicles ranging from pickup trucks to heavy equipment. Trilogy Metals regularly runs their 5000 gallon fuel truck between Dahl Creek and Bornite. It is less than two miles from the development at Bornite to the proposed project alignment and less than three miles from that point to a major proposed material site, landing strip and proposed construction camp. Former Cat trails already run from Bornite to the area of the proposed alignment and can be seen in the maps and photos provided with the application. The proximity of the AMDIAP to this existing road system, the fact that the Dahl Creek airstrip can accommodate deliveries of materials and equipment by Hercules aircraft and an application indicating that construction will occur in both directions from the material sites/construction camps along the alignment imply that the community of Kobuk will have road access to the project almost immediately after construction starts. 3. BLM needs to assess the potential cumulative impacts of the road being opened for public use. AIDEA has claimed that the road will stay closed to the public and will only be used as an industrial access road. However, it has provided no indication how it plans to keep the road private, particularly over the long term. The Dalton Highway was initially private and was eventually opened to the public. It is reasonably foreseeable that the Ambler Road could ultimately be open to the public. This will lead to even greater impacts to wildlife, and lead to potential conflicts between urban and traditional subsistence hunters. BLM should assess the full range of impacts, including socioeconomic and subsistence impacts that could stem from the road being open to the public. / Even if the road remains closed, it is also reasonably foreseeable that individuals will use the road illegally to reach this currently inaccessible area by private vehicles and recreational equipment. The cumulative effects of public use of the road must be fully evaluated in the EIS. Project and Process 1 Ambler Road EIS Scoping Summary Report Appendix A Issue 1: Access, continued 4. The EIS must assume that this road will

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