Support the AAP and the Draft SEIS

The BLM recently published the Draft Supplemental Environmental Impact Statement (D-SEIS) for the AAP. This document provides many speculative impacts and worst-case scenarios are unlikely to occur and provide a general negative view of the project. AIDEA submitted detailed comments about the issues with the document. We now await BLM’s consideration of these and all the other comments on the document. The Final EIS is anticipated in Spring 2024.

AAP Draft SEIS Comments and Concerns

The AAP team has reviewed the BLM's draft SEIS, identifying numerous areas of concern and incomplete analyses. Our key takeaways are in the attached document. These deficiencies imply potential impacts that are unlikely to occur from the project. Below are some highlights of these comments and concerns for the document:

• The BLM's Draft SEIS should only be evaluating the areas of federal land where BLM has jurisdiction. The first 25 miles of the road. BLM's decision-making authority is limited regarding the project. A road is guaranteed in ANILCA Section 201(4)(b) and other laws for access.
• There is speculative and editorial content in the Draft SEIS that should be removed. For example, the SEIS states there is a possibility the road could become public. The road will be a private, controlled industrial-access road. The permits are all based on a private, controlled industrial access road. No federal public funds will be used on the road with strings that mandate public access, like what occurred with the Dalton Highway. The ANCSA corporations, whose land the road must cross, do not
• support a public road. The federal government, whose land the road must cross, does not support a public road. The State of Alaska has the authority to grant a road with limited access.
• There are unfounded opinions, speculations, and worst-case scenarios that will likely never occur but are stated as fact. One example is the assumption that the road would experience numerous unauthorized users or trespassers that would result in significant catastrophic scenarios. In Alaska, there are industrial-private access roads that have existed for decades with little to no impacts of this nature like the Red Dog and Pogo Mine Roads.
• The Draft SEIS must acknowledge the road can coexist with the environment. The Red Dog Mine shows industry can enhance the environment and provide economic opportunities, leading to improved quality of life for residents near the road.
• The positive impacts of the project, such as job creation, are not given due consideration. Jobs are crucial for sustaining a subsistence lifestyle and have been linked to increased lifespan and better living standards in rural communities. For example, the Red Dog Mine and Infrastructure have positively improved the communities of Noatak and Kivalina. These communities have almost doubled the average income compared to other rural communities in the borough. And these communities are growing!
• Alternatives being reconsidered again (“resurrected”) are inappropriate because the alternative selected in the JROD is not subject to judicial review and was determined by USACE to be the alternative with the least environmental impact.
• Mineral resources were guaranteed at statehood and clearly stated in ANILCA Section 201(4)(b). The Draft SEIS needs to take that into consideration.
• The Draft SEIS needs to accurately reflect that AIDEA has committed to working with the local communities and others for the use of the road after its useful life.
• The expansion of impacted communities to 66 is unfounded since that number encompasses all potential alternatives. The focus of the SEIS should remain on the 10 villages closest to the road.
• The Draft SEIS provides a worst-case scenario of potential spills of fuel. Catastrophic scenario analysis is not standard practice for NEPA documents and should be removed or qualified with its low likelihood.
• The dust impacts on vegetation have been over-emphasized and should be qualified by the low probability of being an impact. Speculative impacts, like dust on vegetation, need to be qualified to reflect the ability to mitigate just like at Red Dog Mine.
• The Draft SEIS has an underrepresentation of unemployment in the area by using 9% as its basis since that number inaccurately represents unemployment. The Workforce Development Working Group is highly concerned about the high rate of unemployment in the region.
• Potential impacts resulting from the road are not placed in an appropriate context with current climate change trends. The road hasn't been built yet and the caribous population varies. The Western Arctic Caribous Herd actually increased after the Red Dog Mine and Infrastructure was built.
• The Draft SEIS sites caribous behavior as definitive. Caribous research is ongoing and inconclusive at its current stage. For example, select data states caribous won't cross a road whereas other data demonstrates caribous will cross linear features.
• Suggesting this project will damage fish habitat is unfounded based on permitting requirements and mitigation measures. This is exemplified by the Red Dog Mine and Infrastructure. AIDEA has been working closely with the Subsistence Advisory Committee made up of Alaska Native leaders from the area to address potential concerns.
• The Draft SEIS infers the road will cut off hydrology and ignores the fact that AIDEA has committed a significant number of bridges and culverts to maintain hydrologic connectivity.
• The document assumes that all of the foreseeable mines will be built at the same time and will become a reality. This is ludicrous and therefore the impacts need to be reconsidered.
• The ethnographic reporting should be concluded as part of the Final EIS and not ongoing.
• Form letters and non-substantive comments should not be considered in the decision-making process.
• The Ambler Road or Ambler Access Project (AAP) is a crucial project for the future of Alaska. AAP will provide much-needed jobs and enable the production of critical minerals to reduce our country's dependence on China and other foreign countries. These critical minerals are needed for renewable energy and a green economy.
• The future success of Northwest Alaska is relying on this project for jobs and economic opportunities.