RE: Scoping of Proposed Alaska Industrial and Development Export (AIDEA) Ambler Road Project
To Whom It May Concern:
Kachemak Bay Conservation Society (KBCS) is a thirty-five year old nonprofit based in Homer, Alaska. Our mission is to protect the environment of the Kachemak Bay region and greater Alaska by encouraging sustainable use and stewardship of natural resources through advocacy, education, information, and collaboration.
Though Homer is more than 500 miles from the proposed project, we and our constituents on the Kenai Peninsula are deeply concerned by the prospect of the construction of a 211 mile road to access the Ambler Mining District. As Alaskans and stewards of our natural resources we urge the Bureau of Land Management to address following issues with regard to the scope of the environmental impact statement: 1) The impact of road itself on the water quality and the numerous species who live and travel though the region; 2) the issues that arise because the road’s permitting is separate from the permitting of the mining operations––the road is of a piece with the mine and their impact must be considered together 3) the absence of any substantive cost-benefit analysis on this fantastically expensive and invasive project.
1) As you know, this road will cross 2,900 streams, 11 major rivers, and 1,700 acres of wetlands. These waters are home to whitefish, sheefish, salmon, pike, burbot, grayling, and more. A project of this scale will have serious, negative impacts to water and fish. A large 2006 study found that more than 60% of large U.S. mines failed to meet downstream water requirements. The Bureau of Land Management (BLM) needs detailed information about baselines for all the species who live in the region, baselines for water quality in streams and other groundwater. After a strong establishment of baselines, precautions to maintain the health of the ecosystem must be taken seriously. Furthermore, BLM must ask what will happen after the expected 50 years of private use? Under Section 810 of ANILCA, BLM must determine whether the project “may significantly restrict subsistence uses:” After the 50 years of expected private mining use, hunters, fisherman, foresters, etc. will use this road just like they do the Dalton Highway. Permitters cannot ignore this inevitability when creating an EIS for the road and must address it.
2) The road proposed is explicitly to access Ambler Mining District. When creating an EIS of the road, BLM must address that the most significant environmental impact of the road will be increased mining in Ambler District. If permitted, the primary impact of the road will be the impact of the mines in Ambler District. An EIS of the road must trigger an EIS of the mining operations. There is no no other way to do an EIS of the road. This is serious and very important.
3) We must ask are there reasonable alternatives to the road and mine: AIDEA is interested in developing the Ambler Road as part of its mission to “...increase job opportunities and otherwise encourage the economic growth of the state, including the development of its natural resources...,” that is to mine. Alternatives BIA must consider are not different road routes, but different projects other than mining in Ambler and a state-funded 211 mile road through precious wilderness. BLM must seek alternative investments that have a lower impact on the environment and subsistence, and will provide more good jobs into the future.
According to the BLM Fact Sheet, the road is projected to cost $350 million; and then $10 million expected annual maintenance costs. Past remote projects show a strong trend of costing significantly more than estimates. We must probe how realistic this estimate is. Does AIDEA think that sufficient jobs and revenue will be created to justify this expenditure? What evidence do they have to support this belief? Further, we must ask if we could make a better investment. As far as an EIS goes, “better” means lower impact. How good is a mine that will operate for 50 years and leave toxic waste for perpetuity? What are the alternatives? Would alternatives do less harm to groundwater and wild populations in this unique place? AIDEA has provided no such analysis. Such an analysis is sorely needed. KBCS believes that there are stronger alternatives to developing the Ambler Mining District: development of solar energy industry, wind energy industry, hydro power. A cost-benefit analysis of similar levels of investment in alternative energy industry is needed.
Alaskans need long-term job creation and long-term economic growth; we need to protect our wild places so our great grandchildren will be able to enjoy the same bounty and beauty we do. When looking for reasonable alternatives to the Ambler Access Road, we must consider development of the alternative energy industry.
We thank you for your careful consideration. The issues raised here are of the greatest importance to the future of Alaskan economic development and the stewardship of the wild places we all love.
President Kachemak Bay Conservation Society