The public comment period for the Ambler Road closes on October 29th!
Email your comments to BLM_AK_AKSO_AmblerRoad_Comments@blm.gov
In the body of the message, or as an attachment, reference the facts below to bolster your comment.
KEY CONCERNS ABOUT THE AMBLER ROAD
IMPACTS ON INDIGENOUS COMMUNITIES
· There is important local opposition to this project. Communities, tribes, and other entities have passed resolutions in opposition and have voiced serious concerns about the project, and the Western Arctic Caribou Herd Working Group had a formal vote opposing it 17:1.
· BLM is not providing adequate or meaningful participation for the people and communities most affected by the project because it has scheduled a short comment period during important food harvest seasons.
o People who live in these communities rely on these harvest seasons for food and their way of life. Last time, BLM recognized these concerns and provided nearly a year for the scoping process, but this time it is trying to rush the public’s review of the draft EIS in a mere 45 days. This cuts the public out of the process.
· The proposed road will run near, but not directly through, any communities — meaning, these communities will experience the negative impacts of being near an industrial road, without experiencing the benefits of being connected to the road. BLM needs to further study and consider the negative impacts to subsistence use and these communities.
· This region is already experiencing the serious effects of climate change, but the draft EIS does not adequately take those impacts and how they relate to the project into consideration.
WILDLIFE & ECOSYSTEMS
· 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. BLM needs more information about the design of the project and its impacts to fish and water.
· The road intersects with the migratory routes of three caribou herds, including the Western Arctic Caribou Herd. This 211-mile industrial road could have significant impacts on the migratory route and health of these caribou herds.
· AIDEA claims that this will be a private toll road, but has provided no indication how the road will be kept private over the long run. BLM has not fully considered the impacts this road will have (e.g., for hunting) if and when it becomes open to the public.
· The construction, maintenance and use of the road and its river crossings will negatively impact vegetation (e.g., with invasive species), permafrost conditions, and waterways in an area already under stress from climate change, making the cumulative effects of the project difficult to predict.
· The draft EIS lacks important information about the project area. For example, the draft EIS provides no in-depth analysis of the likely impacts to air quality in the region. The BLM does not even have existing background data for the project area, and instead relies on air quality data from Denali National Park and Preserve, hundreds of miles away.
· The wetlands studies for this region are also outdated and do not provide enough information for BLM to evaluate this project.
· The road would cross Gates of the Arctic National Preserve and the Kobuk Wild and Scenic River.
ECONOMICS- THE PROJECT JUST DOESN’T MAKE SENSE
· The total cost of building, operating, and maintaining this project is expected to be between $844.0 and $906 million. If the mines go bankrupt, the state will be on the hook. BLM’s draft EIS does not acknowledge or discuss AIDEA’s proposed financing of the road and the potential effects on the State of Alaska’s economy. This is a glaring deficiency in the draft EIS that must be corrected in order for the public to understand the potential impacts to Alaskan taxpayers and residents.
· The purpose of this road is to access a mining district. BLM failed to fully consider the impacts of these mines and any infrastructure related to the mines or roads (e.g., gravel mines for road construction, processing facilities, tailings disposal areas, ore/export terminals, gaslines, ports, etc.). BLM also failed to consider the serious risk of harmful acid rock drainage and other contamination from any mining activities.
THESE MINING COMPANIES HAVE A RECKLESS HISTORY
· Nova Gold, who’s CEO is involved in the Ambler project, is facing multiple lawsuits for “defrauding investors in connection with their material misrepresentations and omissions concerning the economic feasibility” mining projects. In the case of Ambler, the State of Alaska is the key investor— the public should note this company’s history of fraud and misrepresentation.
· The Rock Creek mine (under the same mining company) near Nome, was cited for multiple environmental violations in 2007-2012, including:
o Failure to control mine stormwater runoff- the company did not construct the required stormwater diversion ditches, so spring break up waters carried toxic minesite downstream. The EPA fined the mine for water quality violations in 2007.
o Two ironworkers died during routine construction in 2007 because, according to the Mine Safety and Health Administration report, “management policies and procedure were inadequate.”
o The mine received multiple notices of violating construction requirements for their tailings dam and tried to close the mine early to avoid fixing tailing seepage.
o Inadequate dust control- problematic dust from both open-pit blasting and general truck traffic was cited as a “significant problem”, but neither the state nor the mining company attempted to mitigate the issue.
FLAWS IN THE PUBLIC PROCESS
· The National Environmental Policy Act requires the BLM to consider alternatives to ConocoPhillips’ proposal. The draft EIS does not do a good enough job of considering alternatives to the proposal. All the alternatives in the draft EIS are hugely impactful and essentially the same, with only slightly different road routing.
· The Alaska Industrial Development and Export Authority (AIDEA) has not provided enough information about what this project will look like or about its potential impacts for the public to fully understand the proposal. AIDEA’s permit application and now BLM’s draft EIS provide only vague information about the fact that this project will start as a 1-lane “pioneer road” and will ultimately become a 2-lane gravel road. There is not enough information for BLM and the other agencies to approve this project.
· BLM is piling on projects and making it impossible for Alaskans to weigh in on all the proposals that will dramatically impact the Arctic. BLM should extend the comment periods and work to better involve the public in these decisions.
o A core purpose of this process is to involve the public and solicit feedback. That can’t be done when BLM is overwhelming the public with so many proposals at once.
o BLM is asking the public to weigh in on the Willow project, a massive oil and gas proposal on BLM-managed lands directly to the north of this project in the NPR-A, and the Alaska gas line project at the same time. This is in addition to the fact that both the Park Service and the Corps will have public comment periods on the Ambler Road that overlap with BLM’s. The public cannot possibly weigh in meaningfully on so many projects at once. This alone restricts public participation.
o BLM has also said it will release a decision on the Arctic Refuge and a plan for revising the management plan for the NPR-A any day now.
o All these projects will have major impacts to the Arctic—including to public health, sacred lands, food access, special areas, wildlife, the climate crisis, and more.
