On Tuesday, the Bureau of Land Management (BLM) opened a 45-day scoping period to guide the process of drafting a Supplemental Environmental Impact Analysis (SEIS) for the proposed Ambler Road. BLM’s stated intent is to identify issues with its previous analysis of impacts to subsistence, and to conduct consultation with Tribes before initiating a secondary review. They are seeking public input on the scope of the analysis and what should be considered during this process. The following are factors that could be included in their review: all potential alternatives to the proposed road development, additional assessments of resource impacts, including ecological, cultural, historical, and subsistence resources, as well as mitigation and protection measures for those resources. It is essential that this SEIS be as thorough and robust as possible, and to achieve this, Alaskans need to speak loudly and clearly.

It is due in large part to Alaskans raising their voices and sharing concerns with the initial EIS that we have the opportunity to further guide BLM’s analysis before more decisions are made about the future of the road. In August, Clean Water and Mining program coordinator, Katie McClellan, traveled to Kotzebue and the Upper Kobuk villages of Ambler, Shungnak, and Kobuk with local community members and coalition partners to show the film Paving Tundra and facilitate community discussions about the proposed Ambler Industrial Access Road. Participating conservation organizations attended in order to provide information and listen to community members’ opinions. By and large, the feedback received from community members highlighted concerns regarding the impacts the road’s development would have on their communities, culture, and traditional ways of life. 

We invite you to weigh in on the proposed Ambler Road by submitting your comments to BLM by November 4th. The Northern Center will be engaging in this process by sharing the following concerns. We encourage you to consider these points in your personal comments:

  • The previous EIS and permitting process was inadequate, with a rushed approval process that did not fully consider the impacts of the Ambler Road. The SEIS must be broad and thoroughly analyze all design components and potential impacts to ensure that the agencies have sufficient information to address them. Baseline information about project design, and fish, caribou, wildlife, wetlands, water quality, and permafrost resources was missing from the previous EIS and needs to be included in the SEIS. The SEIS also needs to address alternatives, including a no-road alternative, and adoption of mitigation measures to minimize impacts of the development, as the alternatives considered in the EIS were effectively the same with major impacts resulting from each, and no measures to address those impacts.
  • Construction and use of the road would create significant air, water, and land pollution via dust, runoff, and exposure of naturally occurring asbestos, affecting the quality of local waterways and the surrounding lands. BLM needs to thoroughly analyze the impacts that development would have on the habitat surrounding the roadway, particularly on waterways and lands that are crucial for subsistence.
  • Furthermore, AIDEA has not provided adequate design information about the road beyond developing a 1-lane pioneer road that will eventually become a 2-lane gravel road. With so little information about its design, BLM cannot approve the road without further broad review of the design, the construction and maintenance process, and their cumulative impacts. As this road is being developed to access a mineral district, BLM needs to consider the impacts of those mines and related infrastructure including gravel pits, spur roads, processing facilities, tailings disposal areas, gaslines, etc. part of the road development project and therefore assess them in the SEIS.
  • The Ambler Industrial Access Road would cross 11 major rivers, nearly 3,000 streams, and fill in thousands of acres of wetlands, creating significant and irreversible impacts to fish passage and healthy aquatic habitat used by culturally and ecologically important species such as sheefish and salmon.
  • The proposed roadway would cut through the heart of the Western Arctic Caribou herd’s migration path. The herd’s population is currently at its lowest point in the last decade and is considered as being in “preservative decline” by the Alaska Department of Fish and Game. Development would disrupt the herd’s migration, place further stress on the caribou, potentially contributing to further population loss, and would affect the ability of local communities to subsistence hunt. The EIS did not sufficiently assess the road’s impacts to subsistence under ANILCA Section 810, and the SEIS must thoroughly analyze the effects the road would have on the caribou and other subsistence resources.
  • In its previous Environmental Impact Study, BLM did not adequately assess cultural and tribal resources, including historic and sacred areas, traditional hunting grounds, and subsistence resources of critical importance to the physical and cultural health of local tribes. BLM must provide meaningful consultation with Tribes, as required by section 106 of the National Historic Preservation Act, including meeting with all Tribal councils and villages. As most rural communities have limited access to broadband, it is imperative that BLM offer multiple methods of online and offline engagement, creating adequate opportunities for communities to submit comments in-person, over the phone, online, and in written form. BLM must also offer longer comment periods to ensure that communities have adequate opportunity to submit comments without sacrificing valuable hunting and harvesting time.

To be considered, all comments must be received prior to Nov. 4, 2022. Comments must be submitted through either email to BLM_AK_AKSO_AmblerRoad_Comments@blm.gov; the BLM ePlanning website linked here; via fax by dialing (907) 271-5479; or mailed to BLM Alaska State Office, ATTN: Ambler Road Scoping Comments, 222 W. 7th Ave. Stop #13, Anchorage, AK 99513. For more information on this project, please contact BLM Project Manager Wendy Huber at (907) 271-3137 or whuber@blm.gov

For a sample comment that you can personalize, click here.

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