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Home My WebLink AboutNational Petroleum Reserve in AK 105c Final Study Vol lll 1979NPR-A TASK FORCE ME 105(<) FINAL STUDY FOR THE SECRETARY OF THE INTERIOR 3 _ Volume 3 Record of Public Participation National Petroleum Reserve in Alaska Under authority of Naval Petroleum Reserve Production Act 1976 NATIONAL PETROLEUM RESERVE IN ALASKA 105 (c) FINAL STUDY VOLUME 3 FOR THE SECRETARY OF THE INTERIOR VOLUME 1 Summaries of Values and Resource Analysis and Land Use Options (Excluding Petroleum Values and Uses) VOLUME 2 Summaries of Studies SR1- Physical Profile SR3 - Socioeconomic Profile SR4 - Ecological Profile SRS5 - Regional Profile SR6 - Planning Area Analysis (The Summary of SR2- Values and Resource Analysis is contained in Final Study, Volume 1.) VOLUME 3 a Record of Public Participation BY NATIONAL PETROLEUM RESERVE IN ALASKA TASK FORCE NATIONAL PETROLEUM RESERVE IN ALASKA Under Authority of NAVAL PETROLEUM RESERVES PRODUCTION ACT 1976 PUBLIC LAW 94-258 U.S. DEPARTMENT OF THE INTERIOR ANCHORAGE, ALASKA APRIL 1979 ons 1OSK Force Members State Director (Chairman) Bureau of Land Managment, U.S. Dept. of the Interior Area Director Bureau of Indian Affairs, U.S. Dept. of the Interior Special Assistant to the Secretary of the Interior (Alaska) U.S. Dept. of the Interior Alaska Area Director National Park Service, U.S. Dept. of the Interior Chief, Field Operations Center Bureau of Mines, U.S. Dept. of the Interior Area Director Heritage Conservation and Recreation Service, U. S. Dept. of the Interior Area Director Fish and Wildlife Service, U. S. Dept. of the Interior District Chief, Water Resources Division U.S. Geological Survey, U. S. Dept. of the Interior Mayor North Slope Borough Comissioner State of Alaska, Department of Natural Resources Administrative Assistant, Lands Division Arctic Slope Regional Corporation TASK FORCE STAFF NPR-A 105(c) Planning Team U.S. Dept. of the Interior Mailing address: Bureau of Land Management, Anchorage Federal Office Bldg. 701 C Street, Anchorage, Alaska 99501 cinieeeeceeeniniemeemianeeir ens CO of COPICTIS cecenesenisenssiomesitatiecteemniens page Record of public participation and analysis of preliminary public CONCEMNS. 1... eee cece eee eee eee cece cece eeeseeuveeeees 1 PUPPOSE 2... ccc cee eee e ence eee eebeeeeneeeeese 1 The 1SSUC.... ccc ccc ccc eee ence eee ee tebeebeeeeeenees 1 Methods used to obtain public opinion............cec cece cee ceecceceeeee 1 Preliminary public concerns identified prior to development of the options........ 0... cece ccc cece cent eee eeeeeeeeneees 1 North Slope Borough, villages and Native interest groups......... 1 Fairbanks environmental groups............. 00 ccecceeceecceeceecee 12 State of Alaska...... 2... cece cece neces eteeeeeeeees 12 Institute of Northern Forestry............ ccc ccc ee cece cceeeeeeee 13 University of Alaska... 0.2... ccc ccc cece cece eee ccceeeeeeeees 13 Arctic Environmental Information and Data Center................. 13 Sierra Club... ... ccc ccc cece cece ete eeccebbeeeees 13 Trustees for Alaska...... 00... cece cc cece cece ccc cece cceceeeeenes 13 Alaska Chapter of The Wildlife Society..............0 ccc ecceeeeee 14 Alaska Conservation Society...........0 00. c cece eee ceccecceeceeee 14 National Audubon Society............ 0. ccc cece ccc c cc ceeeecceeee 14 Analysis of public response to the land use options....................0000.4 15 Public response to the land use options.............ececcececceceeceee 15 Inupiat people, North Slope Borough and Native interest groups...17 Environmental groups............ 00. ccc e cece eee ececceecceuceeeees 24 State and federal government..........0.0.0. 0c ccc cee ccececcceeucee 31 Development groupS........... 0c ccc cece cee cece cece ee eeeeeeceeeeees 42 Other interests....... 0. eee cece cece ene eeeeeeeeees 59 Appendix I - Areas of concern raised at the February 8 and 9, 1978, meeting with North Slope representatives .................... 68 Appendix II - NPR-A 105(c) Land Plan questionnaire.............ceceeceeeeee 72 ee ee aa Table EA ES TE 1. Selected major meetings on the 105(c) land use study... .............00. 3 RECORD OF PUBLIC PARTICIPATION AND ANALYSIS OF PRELIMINARY PUBLIC CONCERNS Purpose This document is a record of public involvement in the planning process of the 105(c) Land Use Study of the National Petroleum Reserve in Alaska (NPR-A). It includes an analysis of the concerns raised early in this Process, specifically response made before November 20, 1978. Also, part of the document is an analysis of the public's response to preliminary land use options. This compilation and analysis is not a decision-making document but should be used as added information to assist decision makers. It was developed from verbal and written opinions and the reasons for those opinions. In addition to this record, the State of Alaska position is given in Volume I(a) of the Final Study and a Native position in Volume I(b) of the Final Study. A summary of this document is presented in Volume | of the Final Study. A complete file of public commentary may be inspected at the Bureau of Land Management, Anchorage Federal Office Building, 70! C Street, Anchorage, Alaska 9950). The Issue The Naval Petroleum Reserves Production Act of 1976 (Public Law 94-258) Section 105(c) directed the Secretary of the Interior to establish a task force to determine the values of, and best uses for, the lands in the NPR-A. The Secretary was specifically directed to consider the Natives who live in or depend upon these NPR-A lands; the scenic, historical, recreational, fish and wildlife, and wilderness values; and the mineral potential and other values of these lands, excluding petroleum. Methods Used to Obtain Public Opinion The importance of public participation was recognized from the start of the Planning process. The Planning Team included representatives from the North Slope Borough and State of Alaska. A public Participation plan was developed to provide a framework of methods and schedules to initiate public involvement throughout the planning process. Accordingly, approximately 1,700 nmames were placed on a mailing list to receive information on the 105(c) study from its inception. Input of the Native people was obtained in the planning process, Particularly at seminars held on February 8 and 9, 1978, when village representatives were flown to Anchorage. Minutes of this meeting are given as Appendix |. Following the February seminars, meetings were held at each village to discuss the planning process and findings from the values analysis. Meetings were translated into Inupiat to help overcome the Problem of relating the legal and_ technical aspects and to express the sophisticated planning concepts in everyday language. Certain conclusions can be drawn from the comments submitted by the Native people, but this must be done with caution. As with any group there is a range of opinion; this document may be an in complete record of the total range of this thinking. A preparation plan, brochure and newsletter were prepared to make the public aware of the 105(c) study. Approximately 500 copies of the pre- paration plan, 2,000 copies of the brochure and |!,700 copies of the news- letter were distributed to state residents, special interest groups, universities and local, state and federal government. Other segments of the public were brought into the planning process intensively after the preliminary options had been developed in September 1978. Then, public meetings and workshops were held in Anchorage, Fairbanks, and all North Slope villages to give people the opportunity to review the study and express their values, concerns and opinions. The same staff members who were present at the Alaskan meetings also met with one special interest group in Spokane, Washington. Public meetings of the Task Force and Panel on Coordination were held at Anchorage, Fairbanks and Barrow. In addition the newsletter was distributed and Core Planning Team and Work Groups met small groups. Approximately 2,000 people attended 78 meetings. Twenty-four meetings were held on the North Slope, at all NPR-A villages and some villages affected by the 105(c) study but outside NPR-A. Twenty-seven of the 78 meetings were Task Force and Panel on Coordination meetings to coordinate the activities of 105(c) and to coordinate the 105(c) study with other NPR-A studies. Twenty-six meetings were held to present and obtain public comments on the options. Table | describes the meetings and subject matter discussed. Major problems in communication at the meetings were the complexity of the planning process, the parallel studies mandated under the Act, agency res- posibilities, and how the studies would come together. Much of the public comment at the village meetings involved concern about oil and gas exploration activities which are peripheral to 105(c). In addition to the meetings, 98 written and personal contacts were made to obtain information and to ask selected persons, groups and government agencies to review the field and technical data. Radio and television were used to provide maximum coverage in announcing public meetings. Ten video tapes with Inupiat translations were prepared to explain the 105(c) study and the resource values identified by each Work Group. The tapes were shown twice on TV in Barrow at prime time and once at Anaktuvuk Pass. An approximate combined total of 2,400 copies of six draft documents (Socioeconomic Profile, Physical Profile, Ecological Profile, Values and Resource Analysis, Planning Area Analysis, and Preliminary Recommen- dations and Options) prepared for the study were sent out for review to villages, industry, environmental groups, sportsmen's groups, universities and federal, state and local government. In an effort to get some response with regard to the preliminary study con- clusions, the North Slope Borough (NSB) prepared a questionnaire in co- Table 1. Selected major meetings on the 105(c) Land Use Study. the table. Number of People Acronyms used are identified at the end of Type of Meeting Date Place(s) Group in Attendance Major Topics Interagency 6/21/76 Anchorage Task Force 17 Seven meetings were held 6/28/76 Anchorage 15 to organize the task force, 8/13/76 Anchorage 29 and determine its role, 9/28/76 Anchorage 25 budget, membership and data 10/8/76 Anchorage 13 needs. BLM to chair the 10/15/76 Anchorage 25 task force and BLM planning 11/23/78 Anchorage 26 process to be used. Public participation needs were discussed. Public 12/7/76 ~~‘ Fairbanks Panel on 22 A meeting to update everyone Coordination on the activities of the NPR-A 103(b), 105(b) and 105(c) programs. Interagency 1/13/77 Anchorage Task Force 25 Nine meetings were held to 2/24/77 ~~ Anchorage 21 to coordinate the 105(c) 3/24/77 ~~ Anchorage 29 study with the 103(b), 104(d) 4/22/77 Anchorage 29 and 105(b) studies and de- 5/16/77.‘ Anchorage 12 termine budget and manpower 6/9/77 Anchorage 17 needs. Progress was reported 8/18/77 Barrow 33 at each meeting. The public 9/26/77 ‘Anchorage 20 participation plan was 11/4/77 Anchorage 22 reviewed and outlined Task Force involvement. Public 11/11/77 Anchorage American 12 Fisheries investigations on Fisheries Socie- NPR-A. ty, Alaska Chapter 11/16/77 Anchorage Alaska Center 9 Wilderness qualities of NPR-A. for the Environ- ment Table 1 - continued Number of People Type of Meeting Date Place(s) Group in Attendance Major Topics Public 11/30/77 Anchorage Panel on 8 Panel discussed their pro- Coordination posed charter. The panel agreed it should rotate its meetings around the state. The panel supported the 105(c) Study's public participation procedures. Public seminar 12/1-2/77 Anchorage General public 116 105(c) Work Groups presented the 1977 field season reports to North Slope representatives and the general public. Public 12/5-8/77 Fairbanks BLM Wildlife 75 Explanation of the 105(c) Conference Study and of the fisheries and wildlife inventories. Public 12/77 Washington, National Geo- 20 Explanation of the 105(c) D.C. graphical Study and an initial Association interpretation of the archaeological data gathered during the 1977 field season. Interagency 1/9/78 Fairbanks Task Force 23 1978 field season was re- 3/15/78 Anchorage 33 viewed to coordinate Work 5/18/78 Anchorage 22 Group activities. Results of Feb. 8, 9, 1978, meeting on wilderness, recreation, winter scenic quality, aerial surveys and public participation at villages were discussed. A need for interpretors at all meetings and meetings at Table 1 - continued Number of People Major ;lopicsi: ana Atkasook, Kaktovik, Anaktuvuk Pass and Nuigsut recognized. activitiy recommendation and rationale presented. Planning Team to review and report policy problems and major conflicts. Field crews to contact villages when in the area. 105(c) progress report given. Discussion of Work Group 2 (recreation, wilderness and visual resource) activities. Panel reviewed its objectives. Brief presentations on the 103(b), 104(d), 105(c) and 105(c) programs were given. The 105(c) study preparation plan and public participation plan were presented. The planning process and 1977 field inventories were pre- sented. The North Slope representatives voiced a lengthy list of concerns and issues for the 105(c) study P. L. 94-258, 105(c) study Type of Meeting Date Place(s) Group in Attendance Public 1/16- Barrow North Slope 20 19/78 Borough Histo- ric Commission Public 1/10/78 = Fairbanks Panel on 4] Coordination Departmental 1/17/78 Washington, Alaska Policy 15 1/18/78 D.C. Group and 47 Interior Agencies Public workshop 2/8-9/78 Anchorage North Slope 53 villages to address. State of Alaska 2/14/78 Juneau State Agencies, 9 Commissioners organization and public participation plan were presented. Table 1 - continued Number of People Type of Meeting Date Place(s) Group in Attendance Major Topics Public 3/6/78 Fairbanks Fairbanks 7 The 105(c) study organization environmental and progress were explained. groups Questions were asked about the relationship between the NPR-A studies, wilderness, FLPMA, and caribou. Interagency 3/14/78 Barrow NSB Planning 10 The procedure for determining Commission visual resource sensitivity was explained to ascertain how North Slope residents felt about scenic quality. 3/27- Kotzebue Corporation, 60 Task Force and Planning Team 31/78 Point Hope village people, (approx. ) members presented an overview Point Lay NSB Planning of the planning process and Wainwright Department organization. Issues dis- Barrow cussed were Wilderness, Wild and Scenic Rivers, wildlife refuges, oi] and gas explo- ration, Native allotments and subsistence. Public 4/-/78 Anchorage Alaska 250 Discussion of the 105(c) Anthropological study and some initial Association interpretations of the 1977 field season data. Public workshop 4/6/78 Barrow NSB, ASRC 21 Wilderness and its relation- and the public ships to NPR-A were discussed, and many issues were surfaced. Public 4/14/78 Barrow Panel on 28 Progress on the 104(d), Coordination 105(b) and 105(c) studies was presented. Table 1 - continued Number of People Type of Meeting Date Place(s) Group in Attendance Major Topics Public 4/19/78 Anchorage Chugach Gem and 50 Discussion of 1977 cultural Mineral Society resource inventories on NPR-A. Public 5/18/78 Anchorage Anchorage 60 Discussion of 1977 cultural Audubon Society resource inventories on NPR-A. Public 5/22- Atkasook Corporation 25 Task Force and Planning Team 26/78 Nuiqsut and village 12 members presented an overview Kaktovik people 40 of the planning process and organization. Public workshop 7/12- Barrow Community 19 Maps and information on the 14/78 representatives resources identified in the and the general 105(c) study were provided public for review and discussion. Interagency 7/20/78 Anchorage Task Force 23 Land use plan options were 9/21/78 Anchorage 23 reviewed. Work Groups were 10/12/78 Anchorage 22 asked for surplus funds to 11/2-3/78 Anchorage 25 finance preparation of the Native option. Task Force looked at legal and policy conflicts (boundary, 1872 Mining Law, EMMA's, waterfowl treaties, Wilderness Act, HR 39, Reindeer Act, corridors across Wild Rivers, land exchange to Natives). Issue papers on 105(c) Land Use options, completion of P.L. 94-258 requirements and NPR-A Native involvement and Optional Land Plan were presented. HCRS's option was adopted and Option I Table 1 - continued Number of People Type of Meeting Date Place(s) Group in Attendance Major Topics was modified at the 10/12/78 meeting. 105(c) progress report was given. Departmental 8/7-8/78 Washington, Alaska Policy 35 A progress report was given on D.C. Group and the 105(c) study. Linkage to Interior Agencies 105(b) was discussed. Final report content, policy, and procedures were discussed. Public 9/11/78 Barrow Borough Assembly 30 Very brief progress report. 9/11/78 Barrow Arctic Slope 28 The meetings beginning residents; on 9/11/78 were to present general public; the NPR-A land use plan special interest options for public parti- groups; local, cipation, to obtain comments state and and review. federal govern- ment 9/12/78 Point Lay Village residents 28 9/13/78 Anchorage Alaska Center 5 for the Environment 9/13/78 Atkasook Village residents 34 9/14/78 Wainwright Village residents 48 9/15/78 Nuigqsut Village resi- 31 105(c) Land Use options. dents 9/20/78 Anchorage Alaska Oil and 15 Gas Association Table 1 - continued Number of People Type of Meeting Date Place(s) Group in Attendance Major Topics 9/20/78 Anchorage BLM State Office 10 105(c) land use options resources staff 9/22/78 Anchorage Alaska mining 16 Association, Board of Direc- tors 9/25/78 Nuiqsut Village residents 44 9/26/78 Anaktuvuk Village residents 51 Pass 9/27/78 Fairbanks BLM Fairbanks 20 District Office 9/28/78 Fairbanks Fairbanks a] Environmental Center 10/2/78 = Fairbanks Chamber of 48 Commerce Congressional 10/3/78 Anchorage The Honorable 4 Congressman Young's, Senator Steven's, and Senator Gravel's staffs. Public 10/9/78 Noatak Village resi- 45 dents 10/10/78 Point Hope Village resi- 30 dents ol Table 1 - continued Number of People Type of Meeting Date Place(s) Group in Attendance Major Topics 10/16/78 Spokane, Northwest 20 Washington Miners Association 10/17/78 Anchorage Alaska State 5 Agencies Public 10/18/78 Fairbanks Real Alaska 8 Coalition 10/19/78 Fairbanks Rotary Club 10/20/78 Fairbanks Fairbanks 20 Press Club 10/23/78 Anchorage General public 50 10/24/78 Fairbanks Citizens for 12 Management of Alaska Lands 10/25/78 Fairbanks General public 22 Acronyms: BLM Bureau of Land Management EMMA Environmental Mineral Management Area HCRS Heritage Conservation and Recreation Service FLPMA Federal Land Policy and Management Act NSB North Slope Borough ASRC Arctic Slope Regional Corporation operation with the Task Force seeking comments on the options, subsis- tence, mineral development, Wild and Scenic Rivers, Native culture, Native allotments, and Wilderness. Over 500 copies of the questionnaire were distributed to meeting participants; however only 28 copies were returned. The questionnaire is reproduced as Appendix I|1. Preliminary Public Concerns Identified Prior to Development of the Options Numerous concerns became evident early in the planning process. The public participation plan helped to bring out these concerns so they could be dealt with by the Planning Team. North Slope Borough, Villages and Native Interest Groups Issues of concern to this group were recorded at the February 1978 meeting and are as follows: Protection of subsistence, traditional land use sites and the Native culture has repeatedly been expressed as a concern of the Inupiat. This includes continued use of snow machines, motorboats and airplanes for travel and access. They want a subsistence lifestyle protected by laws and regula- tions, not left to one manager's decision or without written guarantees. Subsistence hunters and fishermen spoke out on the schedule of the hunting seasons and need for winter trail markers and survival shelters. It was also felt that inadequate time was allowed in the 105(c) study to evaluate subsistence values. Land use designations that protect subsistence, traditional land use sites, the Native culture and stop resource development were wanted, but there was distrust of designations like Wilderness and Wild and Scenic Rivers. It was feared that Wilderness, Wild and Scenic Rivers, recreation and scenic designations might eventually curtail subsistence, especially by restricting use of snow machines, motorboats and airplanes, and might attract more people to compete for the wildlife. Part of the distrust for designations appears to stem from a lack of understanding how a given designation would affect subsistence. More local control of wildlife management and enforcement is desired. Natives want to be included in animal and fisheries studies; this is now partially prevented by governmental "red tape". Natives feel their system of fish and game management should be considered. They are concerned about the effects upon fish and animals of development, oil and gas exploration, and seismic explosions near lakes, aerial surveys, and noise of planes landing on lakes. Some of the game management problems stem from a long-standing mutual distrust between government researchers and the Natives. The Inupiat were concerned about the loss of local control and the erosion of their rights. It was asked if Washington, D.C., would hear villge concerns. Because villages have not always been able to voice their con- cerns prior to an adverse action, it was requested that a Native commission be established to provide a built-in review process at the village, Arctic Slope Regional Corporation (ASRC) and North Slope Borough (NSB) levels. 11 Since communication and cultural barriers frequently inhibit local input, Inupiat translation of all meetings was requested. The planning for NPR-A has regional effects, and the villagers of NPR-A wanted the people of Noatak, Kivalina and Kobuk to be contacted. The Natives want the plan to grant them their hunting and fishing camps as Native allotments. They want to know if allotments are being held up by the Department of the Interior because of the allocation of subsurface rights. They suggested that coal should be inventoried and developed near the villages, first for village use or potential commercial use later. Recreation is a term that needs to be defined from the Inupiat viewpoint. Additional sport hunters are not wanted, but guiding by local hunters is being considered. A winter evaluation of scenic quality is needed. Erosion is a problem where there are roads and "cat" trails. Sea walls are wanted at Point Lay and Wainwright to protect those villages from coastal erosion. Concern was expressed that the archaeological and historical values have not been completely inventoried because of the short time allowed for study, and it is unclear how those are impacted. Natives want the NPR-A boundary issues settled by Congress. They feel cooperative agreements between the federal, state and local government need to be examined for legal implications. Fairbanks Environmental Groups The primary concern expressed was for wilderness. The groups stress the flexibility and positive provisions of Wilderness designation; for example, it allows hunting and numerous recreation activities. Wildlife enhancement needs to be considered. The Colville River valley and Teshekpuk Lake areas should be considered for Wilderness, particularly to protect peregrine falcon habitat and large areas needed for caribou calving and habitat. Areas should not be suggested for Wilderness just for research attributes as long as the freedom to conduct research is not restrained elsewhere. The Task Force should recommend Wilderness Study Areas rather than ‘interim wilderness’. These groups note that although the plan focuses primarily on the North Slope, the regional aspects of caribou make it important that the people of Kotzebue, Kivalina, Kobuk, Shungnak, Noorvik, Noatak and Selawik be involved in the plan. State of Alaska The following comments reflect individual state agency responses to various technical reports. The organization of the study was questioned in March 1978 because it appeared cumbersome, the State thought the Core Team-Work Group 12 relationship was poorly defined, and surface-subsurface management was separated and was not conducive to attainment of a comprehensive result. In addition, in their opinion, the study should cover the implication of the haul road, be widely distributed for review and allow adequate time for comment. All options of the plan should reflect the North Slope views, they should not be expressed only in the Native position being developed. Reindeer herding should not be reintroduced in NPR-A because it would be detrimental to the Western Arctic caribou herd. The major and primary limitations to domestication of reindeer and muskoxen were considered to be sociological. The State would like a right of access to cross lands but does not want to identify or designate utility corridors at this time because a major transpor- tation study for the western Arctic is now underway. Wilderness evaluations should consider wildlife (particularly caribou, grizzly bear and peregrine falcon), and landscapes or unique ecological or geolo- gical features (oriented lakes, pingos, and sea ice ridges) not present in the Arctic Wildlife Range. Institute of Northern Forestry The Institute noted that researchers need large areas to study where the ecosystems are fragile. The group felt that large areas of Wilderness are a distinct advantage. University of Alaska The University noted that continuing the present freedom to conduct research in NPR-A is desired; they are uncertain that the Bureau of Land Management (BLM) will issue permits granting the same freedom from stipu- lations that the Navy has allowed. The University would prefer to do research under land uses less stringent than Wilderness and not under special permits. Arctic Environmental Information and Data Center The center proposed consideration of the Noluck Lake area, Utukok calving grounds, Colville River bluff area and Teshekpuk Lake area for Wilderness. Sierra Club The Sierra Club suggested that Wilderness designation in NPR-A should be used to protect ecosystems. Trustees for Alaska This group wants areas protected for their scientific and educational values, as well as for their intrinsic and intangible values. Areas of sig- nificant wildlife populations should be given’ special protection. The protective status of polar bear and other species should not be altered, and introduction of non-native species is vehemently opposed. 13 Wilderness, Wild and Scenic River and National Natural Landmark desig- nations were desired. Wilderness status was recommended for the protection of wildlife, for navigable rivers, and specifically for the De Long Mountains - Arctic Foothills, Utukok River uplands, Teshekpuk Lake area, Colville River valley, Kasegaluk Lagoon and the Ikpikpuk River. The Colville, Utukok and Nigu-Etivluk Rivers should be included in the Wild and Scenic Rivers System, in their opinion. While not in favor of opening the haul road, they did not oppose some additional recreational use of NPR-A. Present bag limits on game were felt to be adequate. The group noted that abandoned litter, buildings and equipment should be removed, and future regulations should stipulate removal of material upon abandonment of a site. Alaska Chapter of The Wildlife Society The concerns expressed related to establishing an equitable way of managing subsistence for the protection of wildlife without causing undue hardship on those dependent on natural resources. It was felt that com- prehensive inventories and studies were needed and the state should manage subsistence in cooperation with federal and private groups. Alaska Conservation Society This organization was concerned that there may not be enough time to ade- quately complete the study because original funding was delayed. A 2-year (minimum) extension was recommended. It was suggested that surface management of NPR-A be turned over to the U.S. Fish and Wildlife Service because the BLM lacked wildlife people with knowledge of Arctic ecosystems and subsistence use or oil and gas exploration experts. National Audubon Society According to this group, the interpretation of Wilderness should be liberal and evaluation criteria should be carefully selected and religiously followed. It was recommended that U.S. Fish and Wildlife Service criteria for identi- fying Wilderness, especially those relating wildlife to Wilderness, be used. The importance of the NPR-A coastline for marine mammals needs to be noted, in their opinion. 14 ANALYSIS OF PUBLIC RESPONSE TO THE LAND USE OPTIONS Preparation of land use options began in June of 1978. Objectives and recommendations were developed for each resource and value. The objec- tives and recommendations and all concerns raised earlier in the planning process were fully considered in the development of land use options. Public meetings to consider the options were held from September through October 1978. The options have undergone several substantial changes since the three original options were developed by the planning team (shown in chronology chart). The six options in the Final Study are not the options that were reviewed by the public from September through October 1978. The preli- minary options were changed because of public comment, comments made by the State, North Slope Borough, the NPR-A Task Force and the Alaska Policy Group of the Department of the Interior. Public Response to the Land Use Options Responses received prior to October 24, 1978, were directed at the five options prepared on September 28, 1978 (as shown in chronology chart), and responses after that date were directed at the six options dated October 12, 1978, shown in chronology chart. The 73 responses to the land use options were in the form of minutes from 26 public meetings, 28 questionnaires (over 500 distributed), 18 letters, and a position paper by the North Slope Natives. The 73 responses came from Il villages, 23 individuals, 22 special interest groups, the North Slope Borough Natives as a single entity, | family, 4 federal agencies, 8 state agencies and from 3 local government groups. Of those responses to the preliminary options, 16 were from the North Slope, 48 responses came from Alaska (other than the North Slope) and 9 were received from outside Alaska. The analysis of public response should be read with three qualifiers in mind: 1) Very few people submitted comments; 2) the analysis of public opinion is believed to be representative of the groups, but some opinions were expressed only once, others more frequently; and 3) public opinion on the options may have changed because the options themselves have changed, as shown on the chronology chart. Therefore, analysis of the public's opinion about issues is perhaps more relevant than opinions on options. The opinions and reasons in the tabulation which follows are derived from a number of sources which range from special interest groups to individual private citizens. No attempt has been made to standardize the style or to interpret the remarks. The State of Alaska has Prepared a position paper, presented as Volume I(a) of the Final Study. The Native people have also Prepared a position paper and it is in Volume I(b) of the Final Study. Abbreviations or acronyms used in the tabulation are identified on the last page of the tabulation. 15 Chronology of Option Development (Letters and roman numerals indicate temporary designations) July 1, 1978 A A DEVELOPMENT OPTION PRESERVATION OPTION Cc July 7, 1978 B Sept. 28, 1978 I II III IV V NEW (Preservation) Oct. 12, 1978 I II III IV V VI (Total Wilderness) Wilderness Nov. 3, 1978 I II III IV V Option VI Dy | dropped New Option (wildlife, subsistence) Interim Wilderness | New Option (Wildlife) Nov. 30, 1978 I II III IV V VI Interim Wilderness 16 Zt RRRRRRRRRRRRRRRRRRRRRRRRRRRRRRRRE OPINIONS A Native option is needed. The Native option needs to be developed under different planning assumptions. Inupiat People, North Slope Borough and Native Interest Groups Ceeeeeeeeeeeeeooeeseeg~geqegeoo~wmeeseespseérsowowoéw«” REASON(S) Preparing three separate reports [104(d), 105(b), 105(c)] rather than one will not show how they collectively affect the Inupiat. The three studies [104(d), 105(b), 105(c)] need to be combined with ongoing social, political, economic and cultural activities in order to develop the Inupiat position. Planning assumptions for 105(c) report and resource values base do not reflect the Inupiat viewpoint. The subsistence analysis was generally limited to economics and not subsistence as a total system. NPR-A is pristine but extensively used by the Inupiat. Contrary to 105(c) Study Report 2, Section 10, there is a demand for land i.e., Native allotments, expansion of Barrow. Potential value of coal is recognized, but village sand and gravel needs were not adequately considered. Physiographic divisions in regional overview do not recognize Inupiat viewpoint of inland versus coastal physiographic regions. Need to emphasize how changes in wildlife populations affect people; emphasize a regional approach to caribou management by local boards and emphasize the Native requirements for sand and gravel. History shows the underlying assumption that Natives will be assimi- lated into a larger society is wrong and Natives can Participate in economic development and maintain traditional values. Focal point needs to be Inupiat, not a larger public. gi OPINIONS Native people do not trust and lack inter- est in improving the Task Force's options. REASON(S) The Inupiat economic system needs access to cash and subsistence. Subsistence requires unrestricted access to and through NPR-A. ASRC and village corporations were mandated by Congress to make a profit and will influence the Native option. NSB advocates a subsistence lifestyle and is particularly concerned about game management. Findings of 104(d), 105(b), 105(c) must be addressed in Native option. 105(c) public participation must continue throughout process. Public participation must be extend to the 104(d) and 105(b) studies and include Native people. A Native option will recognizes a international Arctic in terms of the migratory wildlife and will not isolate NPR-A from the rest of the Arctic. Inupiat position must consider the future of the people after resource development ceases. They do not like the premises the options were based upon. They do not like the manner in which 105(c) was organized and con- ducted. Oil and gas exploration, development and transportation should be incorporated into 105(c). The fragmented approach of the study (three separate reports) made public review utterly worthless. Allotments should be granted as they have been in other parts of Alaska. OPINIONS Compromise mineral development. Oil and gas stipulations under the 104(d) exploration program are not stringent enough and are inadequately monitored or there are no stipulations. 61 Native rights have been taken away because it is not understood how they function. REASON(S) Winter exploratory drilling under the 104(d) program has _ been allowed in critical caribou and waterfowl areas, and local resi- dents are not notified or included in the plans. We will be confined to our village and surrounded by government unless mineral development is controlled. Some of this winter's wells may destroy some values of the calving- ground and offshore areas. Recommendations of 105(c) become effective in 1980-81, but drilling starts in 2 months. Wells are scheduled this winter for critical environmental areas (barrier islands, caribou calving area, Howard Pass, falcon areas, special waterfowl areas and Peard Bay). Pads are left unvegetated and there are big puddles of semi-solidified mud and roads. Political decisions have been made in favor of state management. We do not want the State to compromise our federal rights. We do not want the State to say there will be no reindeer herding on the North Slope because it is a Native right granted by the federal government. Compromising and suggesting our rights be replaced by something else is totally unacceptable. If the federal government would do its job, the state would not compro- mise Native rights. We favor federal government over state government. oz OPINIONS There are geese, eider and brant molting and nesting areas at Teshekpuk Lake, from Icy Cape to Point Lay and the Point Franklin to Icy Cape area is of the highest value for molting and nesting. Turn the land over to the Native people on the North Slope. Update the inventory of traditional land use sites. Keep us informed on NPR-A activities. Wolverine are disappearing. Graves are being destroyed by vehicles running over them. Distinguish between commercial and subsistence fishing. Entire land belongs to Native people. REASON(S) Identify a goose molting area around Icy Cape because it is important to Wainwright. Show all molting areas because the ones shown are not the major or most important areas. That is how you acquired NPR-A. More data are available. The villages should be visited again to review the thousands of recommendations. Need to review drill sites beforehand. 104(d) never informs us of their activities. Natives have the right to know before gravel is removed because we know the land. A better translator is needed as we get closer to the final phases of the study. Talk with Natives and use their viewpoint as a starting point. Airplanes are used for hunting. No one takes the time to make sure it does not happen. Reports say we have been commercial fishing, but this is not Native fishing. They are the only group who said no to ANCSA. You folks are trying to take away our land. 12 OPINIONS Major archaeological and historical sites along rivers were not identified. A sixth option is needed that returns the land to the people. Follow the Native option. More time is needed to voice our opinion. Pipeline stopped caribou from coming to Anaktuvuk Pass. White man can not have our oil, land or way of life. REASON(S) The sites you located were considered major because you took field trips there. We feel a superior type of domination. We have no Native rights. Our land and oil has been taken from us. Otherwise, our efforts are useless. A lot of people want our land. People will come and dominate us. Federal government is not allowing enough time for us to review the Task Force report or to develop the Native option. Before, there was one herd, not a eastern and western herd. Herd has dwindled since pipeline was built and is getting smaller. Pipeline blocked the largest part of herd on eastern side. State says we slaughtered our main food; caribou have been used by the Natives as long as history. Oil companies want to make the profit off our land. We don't get a equal share. Someday oil and minerals will be gone and so will be the caribou and wildlife as the land develops. If roads and pipelines are developed and people come to NPR-A, it will leave no place for animals, and without animals our way of life cannot survive. 22 OPINIONS REASON(S) Federal government should protect There are Natives that depend on subsistence. subsistence lifestyle from development. Development should be stopped during caribou migration. Subsistence is our most valuable asset and should be continued. Maintain the status quo for 20 years. The minerals are not needed right now. Hardrock minerals, coal, oil and gas Develop coal for home use in Atkasook. should be developed. Develop outside the critical areas and |5-mile radius around Atkasook. At least 100 miles from calving and nesting areas. Develop minerals after a 20-year moratorium. Develop the minerals in the Colville area immediately. Agree with option II1!. Maintain a status quo for 20 years. It meets guidelines recommended by Natives. Agree with recommendations 1-6 of Option III. Protect the area around Atkasook and Nuiqsut from development. Subsistence provisions of HR 39 are The Inupiat Community of the Arctic Slope and NSB should act as local suitable. and regional fish and wildlife counciis. Subsistence and Native culture should be The Natives will be the first ones to feel change. tected. Designate Colville, Nigu-Etiviuk and Utukok Protect the rivers from physical and chemical change. Rivers as Wild or Scenic. Designate no other rivers but leave all rivers alone. Designate the Noatak and Kobuk Rivers as Wild or Scenic. £2 OPINIONS Native allotments should be granted immediately. Alaskan Wilderness is acceptable. The 105(c) Task Force has taken every step to protect Native rights. Do not allow mineral development. Agree with all of Option IV. Might oppose Option III. Sooner than you think, Eskimos will have to live on fish. Make all rivers critical areas. There are no falcon nesting areas near Nuiqsut. Do not identify ongoing exploration areas as important wildlife habitat. Delay oil and gas exploration while the 105(c) study is ongoing. You have not given the Natives sufficient time to work on the 105(c) land use plan. REASON(S) Let Natives provide the economic scale to protect rivers. All methods seem pretty good (Long-term leases and permits, trust title, P.L. 94-258). Designate all of NPR-A Wilderness. Designate the area around villages Wilderness. No reason given. No reason given. No reason given. No reason given. Whaling is going to be stopped. No reason given. No reason given. No reason given. No reason given. You are asking for our opinion in | month and 5 days. A lot of people cannot understand your study. Have someone we can understand come up and explain the plan. ve OPINIONS Things about NPR-A bother me. REASON(S) Explain Native allotments to us before the major decision. Inupiat have been here since prehistoric days, yet Russia sold Alaska to the USA and then our land was selected for a National Petroleum Reserve and nobody said anything to us. We occupied the land and hunted caribou from the Alaskan Brooks Range to Canada and now the caribou herd is blocked off by the haul road. KRRRRTRRRRRARRRRRARRRRRRRRARRRRRRRARRRRRRARRARARRARARS Environmental Groups DOEELELLEELELEOELEEOLPEOCGLOEEELEEELOCOLOOOOOLOOLOOLOOLEOGE_ OPINIONS Add an option that provides maximum protection to NPR-A, wilderness, scenic quality, wildlife and cultural resources. Manage non-Wilderness areas as Inupiat Conservation Area under multiple-use concepts, consistent with FLPMA and place the highest priority on subsistence. REASON(S) None of the five options provide optimal protection. Utukok, De Long Mountains, Kasegaluk Lagoon, Teshekpuk Lake, Col- ville River valley and possibly the Ikpikpuk River areas should be classified Wilderness. Adopt the team's explanation of wilderness values. Archaeological values would be protected. It is an equitable solution to Native claims in NPR-A. It is an alternative to wilderness for protection of subsistence. The problem of motorized vehicle use and coal development in Wilderness would be avoided. There is little sport hunting so giving subsistence a preference over sport hunting would not be a major problem. Subsistence harvest should be within optimal substained yield for wildlife. S2 OPINIONS Concepts of critical habitat, critical environmental areas and special areas too vague. Nearly all general recommendations are supported. Oppose Option |. Changes in Option | are needed. REASON(S) No hardrock mining should be allowed because of related transporta- tion systems and it is too disruptive to wildlife. Develop oil and gas for village needs only. Develop coal for villages, but no large-scale developments because tundra cannot be reclaimed, particularly over permafrost. None of the alternatives adequately protect Native cultural values. Leaves too much interpretation to future manager. More details are needed. If the area is critical habitat, then withdraw the area from surface disturbing uses. Preliminary document is impressive because it is concise and lucid. The recommendations are environmentally sound and thought provoking. Six options provide a fair range of alternatives. Option | places heavy emphasis on resource development and incentives for development. Lands are opened to 1872 Mining Law. Critical environmental areas were removed. Designate Colville, Nigu-Etiviuk and Utukok as Wild Rivers. Withdraw key archaeological sites. Outline management for key subsistence sites. Delay mineral development. 92 OPINIONS Do not endorse Option I|, but it is a commendable compromise solution. Implement Option IV until data gaps are filled. REASON(S) Accelerate government inventory of hardrock minerals and_ coal if environmental damage is not excessive. Might be the type of plan needed after (d)(2). It does designate the most deserving wilderness and Wild Rivers pro- tects peregrine falcon, and designates land as interim wilderness. Applaud suggestion for mineral leasing over 1872 Mining Law. A mechanism is needed to minimize environmental impacts in mining areas. Develop where the least environmental impact will occur, in or out of EMMA*. Use the Native allotment alternative that best protects subsistence. HR 39 subsistence provisions are suitable. Retain the federal land in public ownership. Mitigating measures of EMMA* are good. Option Il needs to address protection of caribou migration routes. More information is needed on movement of Western Arctic caribou herd, effects of development on caribou, and on minerals, oil, gas and coal. The status of (d)(2) lands is unresolved. It is premature to make a decision. *EMMA was the acronym for Environmental Mineral Management Area, a concept that was developed with Option Il in an earlier draft. Public and technical opinions have caused the Planning Team to drop this terminology. Mineral Leasing Areas have been substituted for EMMA's in the current options. No attention is drawn to the EMMA acronym from this point on. Le OPINIONS Option V is the most acceptable. Option V would be the most suitable wilderness alternative with the addition of Valley of Willows, upper Ikpikpuk River and study status for entire 3f area identi- in NPR-A Study Report 2, Section 5. Would not support Options V or VI. Some recommendations are needed in all options. Hardrock mining should be environmentally sound and not subsidized. REASON(S) Option IV provides a slightly stronger will to protect surface values. It protects the Native culture. Option V is the most suitable wilderness alternative. Non-wilderness will put the land in a holding pattern for 20 years. The nationally and internationally significant wildlife and the wilder- ness values would be protected. Wilderness in De Long Mountains would Protect the caribou migration routes. Subsistence use and motorized access would be continued. Wilderness designation should be postponed, pending (d)(2) legislation. Total Wilderness is not practical. Some areas are not suitable for wilderness. Prefer development in some areas over others. The De Long Mountains should be given complete protection. Off-road vehicle planning should identify prohibitions. DEWLine program should be adopted. Colville, Nigu-Etiviluk and Utukok should be designated Wild Rivers. Withdraw key archaeological sites. Land should be returned to natural uses. Industry should pay full production cost. 82 OPINIONS Favor mineral exploration in the future under government contro! and in non- wilderness. Review oil and gas development needs. Coal should be developed. Oppose the designation of EMMA's. REASON(S) Keep environmental considerations in mind when selecting mining sites. Use construction techniques not dependent on gravel. Federal land managers must protect wildlife and fish habitat. Hardrock mining should be allowed on a permit and lease basis if it does not conflict with prime surface values. Non-petroleum mineral values are not well Known and known values are uneconomical . Exploration process should be separated from the decision to develop. Prior to exploration, examine existing transportation systems, land- ownership, and related infrastructure. Identification of mineral development areas and transport corridors can be delayed. Need to see results of current exploration program. Development is contingent upon OCS leases. Develop coal on a small scale for and near villages. Large-scale coal development is not desirable. Surface disturbance should be confined to areas of low surface values. Coal development should be delayed 20 years until mining and wildlife conflicts are understood and mineral needs are known. EMMA's are unnecessary because existing laws are adequate except for the 1872 Mining Law. They give preference to minerals in marginal economic and environmental situations. 62 OPINIONS Subsistence provisions of HR 39 are suitable. U.S. Fish and Wildlife Service should have surface management of NPR-A. Some areas could be National Ecological Reserves. Guidelines are needed for vehicle use. Designate Colville, Nigu-Etivuluk and Utukok as Wild rivers. REASON(S) Transportation systems would be needed through EMMA's. NPR-A should be consistent with (d)(2) areas. NPR-A Planning Team is commended for using them. Wildlife is the primary surface resource. The wildlife values are still there but chances of finding commercial quantities of oil have diminished. Mission of USF&WS is protection of wildlife. They have experience in wilderness management, oil and gas development and management of subsistence areas. Wilderness values are low but small- to medium-sized areas are good examples of Arctic flora and fauna. Vehicle travel to and within Alaskan Wilderness is essential but needs restrictions. Limit snow machines to when there is snow. Need to address future forms of vehicles. Allow motorized travel to wilderness for non-motorized uses. Do not use snow machines and motorboats for recreation after you are in the Wilderness area. They should be protected from physical and chemical changes. Nothing else would be effective protection. Do not downgrade to Scenic River designation because it dilutes the Wild and Scenic Rivers Act. OPINIONS Do not use the term Alaska Wilderness. Object to Interim Wilderness. oe Protect and preserve crucial wildlife habitat. The most important values in NPR-A are wildlife, wilderness and cultural/sub- sistence values, with wildlife No. |. A cooperative management plan is needed for caribou. REASON(S) Protect the rivers because they provide the most practical means of access. It implies less than National Wilderness. Subsistence, motorboats and aircraft are compatible with the Wilder- ness Act. Call it Wilderness with special language to allow subsistence and motorized access. Stick to standard terminology of Wilderness Study Area with interim protection. The 20 years of status quo would allow sufficient time for decisions and options to be considered. Do not allow new designation for Congress to judge previous Wilderness designations. Existing Wilderness terms are quite adequate. Give an explanation of special areas. Are Areas of Critical Environmental Concern and Special Areas the same? Where are FLPMA guidelines? What rules and regulations would govern special areas? Wildlife is linked to wilderness and culture/subsistence. A federal/state management plan is needed. w _ OPINIONS Peregrine falcons should be protected. The state's traditional role in fish and game management should be maintained. A transportation plan is needed. Support facilities should be temporary. Issue Native allotments by long-term lease or permit and P.L. 94-258. REASON(S) If special areas are not adequate, critical habitat designations are needed for protection. Comfortable with State's role but the federal government has power and responsibility on federal land if state fails. Plan a balanced system. Do not encourage transient visitors or year-round residents. No transportation systems should be developed to subsidize resource develpment. Do not build permanent towns and villages. There is no preferred way to grant allotments. FFIFIFIRARRARARARARARRARARARAARARAARARARAAARA State and Federal Government eweeeeeeeeeeeoeooesosewwww©OOOOEOOOOLOEOPOG OPINIONS Omit statement that corridor withdrawals should avoid natural corridors. If government did not interfere with free enterprise, conservation and recycling of metal would be more viable. Clarify that it is desirable to maintain sport hunting and fishing opportunities as long as wildlife resources are sufficient and conflicts with subsistence activities are not too great. Have problems with Option |. REASON(S) Earlier it was stated that no corridors should be designated and in fact, this does designate corridors. A state/federal process of review is recommended. No reason given. No reason given. Irreversible environmental and social impacts would result. ce OPINIONS Option I is acceptable. Option V does not make a strong case for permanent Wilderness. Options II, III and IV are the most reasonable but more information is needed. Work closely with the North Slope Borough to get a Native position. Take Options II,IV and V out. Add road powers to NSB's mandatory powers. Need to explain how transportation system functions. REASON(S) Allows scattered mineral development, and patenting of land would occur. It decreases the likelihood of a rational management scheme for northern Alaska. Private industry can explore and develop under general land laws and have positive management and enforcement of environmental laws. Does NPR-A deserve Wilderness status? There was no comparison of NPR-A wilderness values to other poten- tial Wilderness areas. Impacts of Option II were not identified. Desirability of Option II depends on the adequacy of present regulations and the potential that change will occur. What are the impacts of Wilderness in Option IV? What will have changed under Option IV by 2000? A unified NSB position would be beneficial. No development is allowed in areas of state and national importance for potential mineral development. It is implied but needs to be stressed. Important that reader understands transportation systems. Perhaps there is a more detailed analysis elsewhere in the report but it is also needed here. The existing transportation system depends upon the air mode. €€ OPINIONS Before Option II! is adopted, take a close look at the present management and regulations, their long-term conse- quences,and the likelihood of their being changed. Option IV does not justify designating all of NPR-A Wilderness. Option V states development has occurred. It is difficult and short sighted to con- sider Wilderness inside political bound- aries without regard for surrounding lands. Need to explain why the plan says no reindeer herding. Normal use could occur after excavation of a archaeological site. Management under one agency may not be lawful. REASON(S) Depending on the air mode of transportation detracts from the marine mode and increases marine costs. Problems with marine transportation are rising costs and complication of unloading because expensive equipment and large warehouses are needed; there are no deep-water ports and the sea ice may not move out some years so barges can come in. Status quo options tend to be looked upon as do-nothing options. Option II! is less likely to be carried out for 20 years than a Con- gressionally mandated option, since a change in surface management regulations could change the rules. If Wilderness now, why not in the year 2000? Where has development occurred? How does NPR-A compare with (d)(2) lands proposed for Wilderness? Exploitable resources are forgone for Wilderness. Compare NPR-A resources to resources on Native and state land. How does NPR-A compare to the rest of the North Slope? No reason given. No reason given. No reason given. ve OPINIONS Text should explain special areas in Option III. Oppose Option V. Favor Option III. Has there been an attempt to validate the visual resource assessment in the context of the indigenous culture? REASON(S) No reason given. It essentially locks up the resources. If this is indicative of BLM reports, they cannot do the job. Development of NPR-A needs to be consistent with projects surrounding the Reserve. No one is interfering with exploration on Native lands adjacent to NPR-A or monitoring the exploration. The status quo should be maintained for 20 years. Land use designations proposed by other options are premature and not responsive to long-term environmental and cultural realities. Caribou need a complete management approach, not just isolated wilderness. Option II! is compatible with mineral and petroleum programs. Planning must be based upon factual knowledge. Virtually nothing is known about the petroleum resources. A 20-year moratorium and sound environmental management of explora- tion and development would best fit the land and people. Gives NPR-A breathing space from the pressures of coastal management, ANSCA, OCS, the haul road, mining and the Prudhoe Bay pipeline. Option II! is a surprise because planners are generally compelled to do something. The NPR-A landscapes are different from temperate landscapes where the evaluation methods were developed and the Native people have dif- ferent cultural bias towards visual resources. S€é OPINIONS Federal plans should be consistent with local and state plans and regulations unless they are incompatible with federal law. Capital budget program is a local prero- gative. More information is needed about subsist- ence and caribou management boards. There will be no suitable Wilderness areas after 2000 in Option |. Mineral entry could directly conflict with key subsistence sites. Mining techniques and the scale of operation used in the past are different and were not in the Arctic. Concepts of Option I! are sound but raise questions as to how they actually work. 105(c) Study has major problems. REASON(S) Plan does not reflect that it is compatible with state and local plans and regulations. Who will prepare it? Who will participate and what will it review and coordinate? Who will it advise? How does it fit into current’ fish and_ wildlife structure? management Widespread exploration, development and selection of land will leave no suitable areas. No reason given. Statement that mining in the past has naturally rehabilitated in 75 years is not accurate for the Arctic. Would leasing apply to oil, gas and coal in addition to hardrock minerals Would private industry proceed with exploration but development be delayed until 2000, or is production unlikely until 2000? Are EMMA's in the best place? Is it likely that more EMMA's would be designated and if so how many and where? Its timing does not allow 105(b) information to be incorporated or allow the 105(c) Study to consider the outcome of (d)(2) legislation. 9€ OPINIONS Option |! has most appeal. Assessment of recreation values appears accurate. Coal resources were projected too high. Explain terms used in the plan. Spell out purpose of cooperative management agreement for Colville River delta and Colville River corridor. Statement, "no way to stop development", in Option | is not true. Land use planning is one key to successful management of fish and wildlife resources. Wilderness could be reviewed under BLM control. Environmental and social costs should be included in projects costs. Define surface resource values. Provide access for recreationists, sub- sistence users and commercial users. Subsistence will be determined largely by availability of resources. REASON(S) It lacks information and management guidelines for each option. No reason given. No reason given. No reason given. Explain the terms key subsistence sites, federal land, one agency, and Alaskan Wilderness. BLM, all No reason given. Development is subject to existing law. Use of land impacted. largely determines if wildlife are adversely or beneficially BLM has demonstrated planning ability. Too often others have had to bear the cost of development directly or indirectly. They mean fish, wildlife and other surface values in one place and land surface values in another. Wildlife not adequately protected under land surface values definition. Traditional use should be one of the determining criteria for motorized access. The determination should be made by Board of Game and Board of Fisheries. LE OPINIONS Adoption of local advisory boards is not necessary. Do not support Option |1. Do not support Option |. EMMA concept is a good approach. Would support Option II! if some changes were made. Support recommendations 2 and 3 of Option IV. REASON(S) Department of Fish and Game has increased emphasis on sub- sistence utilization. Local representatives are on the boards. State House Bill 960 was recently passed making subsistence the highest beneficial use of wildlife and created a subsistence section in the De- partment of Fish and Game. It creates instant Alaskan Wilderness. Because of recommendation | and 3. Lands would be placed in private ownership and it does not protect environment or wildlife. It gives more preference to development that environmental consid- erations. Wilderness should be determined by importance of wildlife, not lack of development potential. It recognizes that significant environmental values are often associated with mineralized areas. Provides for intensive planning and mitigating measures. Environmental concerns are recognized and considered in the Process. Protect areas from development by designation where sufficient infor- mation is available (Colville delta, barrier islands, Icy Cape, Utukok area, and Teshekpuk Lake). The lower Colville River should not be designated Wilderness because it is extensively used for subsistence and transportation. se OPINIONS Recreation should not be considered in NPR-A. There is plenty of gravel on North Slope. Eolian sand could be used. Exploration can be done better by private industry under government regulations. Do not blanket designate barrier islands and Colville delta as critical habitat. Private exploration is desirable under Option |. Can EMMA's be designated in Option II? Option I!| could be the most reasonable. Against Option IV and V. State of Alaska will have a stake in the ultimate disposition of NPR-A. Option | is the only acceptable choice. REASON(S) Recreation would not be significant for 20 years. Scarcity comes from the amount of gravel the State would like to see removed. It has low value for construction, but could be used for mortar. There is more incentive, efficiency and better environmental protec- tion if private industry does the exploration and government regulates it. More economic and environmentally desirable to produce from these areas simultaneously if oil is present, than at a later date. Appropriate regulations should be followed. The report correctly states that very little is known about minerals. Allow private mineral exploration and necessary transportation routes and facilities. They lock up potentially significant mineral and hydrocarbon areas in Alaska. Once boundary disputes are resolved, State may gain valuable oil, gas and minerals. State may have the option to select land in NPR-A. State should have access to geologic information on oil and minerals. The State Department of Environmental Conservation would have responsi- bilities, regardless of which option goes into effect. Option | provides environmental protection during exploration. 6E OPINIONS Term "key archaeological site" should be stated clearly. Consider U.S. Fish and Wildlife Service for manager of NPR-A. De-emphasize government exploration and turn it over to private enterprise. There are too many federal controls and regulations. Continued government evaluation of locat- able minerals in the De Long Mountains concerns us. Do not support present memorandum of understanding between BLM and USGS. Support Option V without recommendation |. Do not support creation of instant Wilderness for all of NPR-A in Option V. REASON(S) To date, few if any, significant archaeological sites have been found in the Reserve. USGS and BLM have not adequately considered the living resources. Private enterprise could do the job at a lower cost. It would be easier to get compliance on environmental standards. Private industry is more innovative and Progressive. Union Oil drilled the first well from a ice pad in 1976, while USGS is still considering the technology. State Department of Environmental Conservation can do its environ- mental reviews better by commenting on exploration and development plans. One government evaluation is preferred over multi-assessments by in- dustry, but government efforts have not been good and efforts to upgrade quality have not been effective. It usurps authority granted BLM by Congress. Agency responsibilities should be defined and a memorandum of under- standing written that is acceptable. Drop recommendations for Alaskan Wilderness. Many portions do not require such protection. Development in some areas may be preferred to development of offshore areas or other important biological areas. No decisions on designating land should be made to Protect the environ- ment or to encourage development until more information is available. rr ov OPINIONS Zoning powers of the NSB should be mentioned. Highest and best use of NPR-A is maint- enance of indigenous fish and wildlife. Strongly support an ecosystem approach of evaluating NPR-A. State Department of Fish and Game would participate in a cooperative management agreement for the Colville River delta. Sport hunting would not be significant on NPR-A. The |5-mile radius around falcons is excessive. Hardrock minerals should be leased, and not patented in Option |. Scenic Rivers, Critical Environmental Areas, and Wilderness, critical habitat may unduly restrict development in Option |. You are to be complimented on your efforts for doing a enormous job in such a short time. Little consideration was given the vegetation resource, except as a compo- nent of other listed values. Discussion of cultural resources within the Reserve is inadequate. No No No No No No No No No No reason reason reason reason reason reason reason reason reason consideration was given rare, given. given. given. given. given. given. given. given. given. REASON(S) threatened or endangered plants. No special management areas or areas of environmental concern were proposed for plants. The 2-page summary presents nothing that could not be gleaned from a single source on the history and prehistory of the North Slope area. \v OPINIONS Bureau of Land Management should be involved in cooperative management of caribou. Large-scale development would impact fish habitat and should be included as a potential resource conflict. Too much is presumed by promoting the HR 39 definition of subsistence, supporting subsistence over other uses, and assuming that the State of Alaska has the right to regulate hunting and fishing. REASON(S) Surely the intensive inventory conducted the past two summers has more to say. Where are the 1,200 cultural sites identified within the Reserve, which sites are more significant, what protective measures are being recommended and for which sites or areas? Option | is the sole alternative which addresses cultural resources, and there is a lack of sufficient detail. What kind of withdrawal is being proposed and for which key archaeolo- gical sites? There should be some consideration of cultural resources in Option II, Ill, IV, and V. It appears the areas of archaeological concern identified in Option | fall within EMMA's proposed in Option II. It is difficult to accept that the three areas of archaeological concern identified in Option | are the only ones. Many know archaeological sites in NPR-A are significant. Caribou management is discussed on page 2 of the preliminary final report and the Native regional corporations, Alaska Fish and Game and U.S. Fish and Wildlife Service are mentioned as cooperating in a management scheme, but BLM was not mentioned. No reason given. No reason given. ev OPINIONS The first four statements under general policies for hardrock minerals probably preclude development in the foreseeable future and tend to negate your develop- ment options. The status of public land in NPR-A has been determined by an Acting Associate Solicitor's opinion. Only those Native allotments filed prior to ANCSA should be considered. Class | air quality would probably pro- hibit a coal-fired electric generating plant in NPR-A. REASON(S) No reason given. The last paragraph on page 50 [of the September 1978 Option draft] should be modified to reflect the solicitor's opinion. No reason given. No reason given. TRFRRRRRRRRAARAAARRRAARARRAARARRAARRRAARARRAAARRARFRARE Development Groups SPROLGGOPOONOOEGOOOLOOEOEOOOEOEOOOOOOOOOOOOOOOOOOOOOOE OPINIONS Option I is workable and acceptable, but no incentive to miners. Object to leasing of hardrock minerals. REASON(S) All laws protecting wildlife and the environment should be obeyed. Land claimed by miners (1 percent) would not affect other uses. Development would be done in an acceptable manner under law. With Wild and Scenic Rivers, critical habitat, and ACEC's, Option I creates a "dis-incentives" to miners. NPR-A is one of least favorable areas for mining by virtue of its location. Option I merely restricts mining less than the present withdrawal but more than other public land. Government could not administer a leasing program efficiently. ev OPINIONS Plan is biased against minerals. The land is for the people to use. It is wrong to delay mineral development for 20 years. A new mining district could be established in the De Long Mountains. Object to the Council on Environmental Quality (CEQ) report on hardrock mining. REASON(S) Adequate laws already exist, FLPMA especially, and miners are complying. Leasing in Missouri has not worked because the government is too slow. In Wyoming the industry was blackmailed into doing things to get the lease. All options are anti-development. Mineral values information is being withheld by the Department of the Interior. All options are preservation oriented. Unique or critical zones would constrain development. The plan seems to let resource values get in the way of land use by people. Minerals in NPR-A are not sub-economic. If the area had been open to mineral development, it would have been developed by now. New discoveries of lead-zinc-silver along with Drenchwater are encouraging prospects. Given reasonable access and an opportunity to meet environmental requirements, the De Long Mountains could be mined. Mineral development is not likely for 20 years due to the location, access needs and the need for additional evaluations. Mining is not like it was 20 years ago or even 2 years ago. CEQ should not use the mining practices from years ago to judge today's mining laws. vy OPINIONS Biases toward mining showed. Spirit of options are acceptable but people should not be protected from changes they want. An analysis of mineral potential has not been made based upon information provided. Designate the Colville, Nigu-Etivluk and Utukok Rivers as Wild or Scenic Rivers. REASON(S) Need to show shortcomings of laws identified last summer, not years ago. What the mineral industry needs to do now, under law, is the base level. Miners in Alaska are not behaving the way described in CEQ report. Permit, reclamation and environmental safeguards are being accepted and followed. Verbally, it was stated that Option | throws the area open, implying un controlled, but in report it is explained that it is subject to existing laws. Get the truth about mining and treat it fairly. It was contradictory to saying mining is frought with dangers. Government could be accused of colonialism if it freezes out the options of people. No reason given. Transportation corridors need to be provided. The rivers are pretty well protected now. Access is needed across them, especially in the winter months. Protect the rivers as much as practical. The rivers do not need to be protected from physical and chemical change. Exclude the lower parts of Utukok and Etiviuk Rivers from designation. SV OPINIONS None of the Wilderness option is suitable. REASON(S) A slight amount of physical and chemical change is acceptable. Protect the rivers with existing environmental laws. Wilderness is unnecessary for the next 25 years. Wilderness designation should wait until the mineral data are gathered, and analyzed and no values are found to be needed immediately. There are major mineral resources in the De Long Mountains and Utukok area. Designation of the Teshekpuk area is okay, but study it first. All options withdraw potentially highly valuable mineral areas prior to adequate evaluation. Government surveys are not competent due to a lack of knowledge about economic conditions. Majority of NPR-A would remain wilderness because exploration and development is expensive. De Long Mountains are wilderness without designation because of their remoteness. Do not return NPR-A to open public land status either because it allows too much freedom of classification. Do not lock up coal lands. Wilderness is not an alternative but a lack of solid planning for the future. Wilderness should not be used to protect wildlife; refuges are for that. BLM biased toward environmental side of study. or OPINIONS Support Wilderness alternative 2. How can the government evaluate wilderness without an economic appraisal of minerals by private industry? Term "potential world class base metal district" is not just rhetoric. Option | would protect the Native cultural values. Foolish to single out a minority culture and not others. REASON(S) Area has few wilderness qualities. No more Wilderness is needed in Alaska, especially the north part. No one will enjoy the wilderness values of NPR-A. Development would only affect small parts of NPR-A. Even if homesteads are set aside before any Wilderness designation, few people will take advantage of it. Government does not have the personnel, equipment or money to do more than a cursory mineral evaluation. De Long Mountains black shale belt could be one of the largest lead-zinc districts in the world. At least four lead-zinc deposits have been found on the southern end of the De Long Mountains. Two important prospects are already known on NPR-A (Drenchwater and Story Creek). It allows for healthy cultural change and lessens the chances of increas- ing alienation from world societies. Gives incentive to companies to use Natives for exploration and development. Each minority responsible for retaining the values they desire, not government. There is too much interference by government. Leave the Native culture alone because you are being bureaucratic and Promoting dissent between minorities. Ly OPINIONS Options should not be concerned with protecting a Native cultural values. Issue Native allotments under 1906 Native Allotment Act. Issue Native allotments by long-term lease or permit. No Native allotments should be granted by long-term lease or permit. Native allotments should not be granted. Weighting of visual impacts was largely from an aerial viewpoint, an unnatural viewpoint. Start mineral development immediately. Subsistence provisions of HR 39 are suitable. REASON(S) What are they being protected from, a better standard of living? Development allows the Natives to choose between old cultural values and obtaining a better standard of living. Issue to properly filed Native allotment applications. Issue limited allotments to Native users. Allow subsistence, but do not prevent all other uses of the land. Treat Natives and non-Natives alike when issuing allotments. Even Prudhoe Bay makes a small alteration of the total caribou environment. Any mineral deposit requires years of lead time to develop. Mineral shortages are catching up with us rapidly. Start now and do not stop. Develop minerals by 2000. Exploration, discovery, assessment, and feasibility studies take 10-15 years and production |0 years after that. Free market system needs trary time slots. flexibility and does not fit into arbi- Subsistence provisions should be the same as for areas outside NPR-A. Eskimos should return to traditional ploiting the area as mining would. ways; otherwise they are ex- Ee > oo OPINIONS HR 39 is not acceptable. Consider Options | and II. Minerals should be developed on NPR-A. REASON(S) HR 39 is a short-term solution, but artificial preservation of a changing culture could make it worse in the long run. Subsistence should not be an overwhelming management criterion. Development would occur slowly enough for Natives to change. Subsistence should not be allowed at the expense of all other uses. Natives cannot live off the land forever and would be given alternative methods if development takes place. It is discriminatory and infringes on state rights. No one should have subsistence privileges when on welfare. They are the only middle-of-the-road options. Options | and II are multiple-use, while protecting critical habitat and ACEC's. All other options biased towards environment and ignore the great mineral potential. In Option I1, allow private industry mineral exploration immediately and no Wilderness designation until resources are fully evaluated. Develop hardrock minerals in the De Long Mountains and North Slope of Brooks Range, oil and gas where available, and coal for local use and possibly future gasification. Leave exploration and development to industry with minor aid from USGS and USBOM. Economics will dictate pace of development. Total costs should be mitigated or compensated during development. Develop coal region and mountain belt. 6V OPINIONS Do not designate Colville, Nigu-Etiviuk or Utukok Rivers as Wild or Scenic Rivers. REASON(S) Develop minerals wherever they occur and can be mined economically. Develop high-grade deposits. Develop De Long Mountains and southern region. Develop oil and gas in central portion of NPR-A. The coal in NPR-A is not particularly attractive because there is better coal closer to transportation systems. All minerals should be developed unless they conflict with Wilderness, or are along Colville, Nigu-Etiviuk and Utukok Rivers. Mining should be compatible with environmental laws. Socioeconomics — will dictate time tables and type of mineral development. Develop economically viable areas to keep up with demand. Develop any mineral needed by our technological society. Changing economics could make NPR-A a leading mineral-producing area. Designation of rivers would prevent some uses which are compatible if people would just use a realistic set of values. No designation is better because designations attract potentially harmful exploitation. The rivers are better protected if special interest agencies do not manage them. Protect the rivers from misuse. Await further economic study before designating rivers. os OPINIONS No additional rivers need to be designated Wild or Scenic. Support option that closes least land to the Natives. All of the options protect Native cultural values. Object to statement that oil and gas potential of NPR-A is probably somewhat low. REASON(S) No further protection is needed. The rivers will never be enjoyed because of their remote location. How can you protect rivers from pollution, when Mother Nature is the only polluter? Existing BLM, EPA, etc., laws and regulations are sufficient to protect the rivers. They will remain wild and scenic no matter what. "Get the hell out and leave them to manage their own land". No reason given. Offshore areas have greater potential for large deposits of oil and gas than any other offshore area in the United States. It is too early to tell what the oil and gas potential is. All of the geological ingredients of oil fields are present. There are undrilled areas of NPR-A large enough for a field the size of Prudhoe Bay. Only one well per 200 square miles to one per 10,000 square miles has been drilled in potential oil trends. Gubik gas field and Umiat oil field are sub-economic but encouraging. A third major trend found in NPR-A is similar to producing oil and gas areas in Canada, Idaho and Wyoming. 1S OPINIONS Oppose any additional studies for Option Il. Option | allows exploration but prevents development. A National Energy and Mineral Reserve makes the most sense. REASON(S) All necessary geological factors for a commercial-size oil fields are Known to occur. It is a short-sighted, pessimistic viewpoint of energy potential in the area. It is not a center option nor in the best interest of our nation's greatest need, energy. The environment, Wilderness, recreation areas, fish and wildlife all can accommodate oil and gas. A more suitable center option would be a multiple-use option under proper and reasonable regulations. Option II! is another stalling or delaying option, and enough public land is in this category. Oil industry is trying to remedy the nation's dependence on foreign oil, but runs into opposition like Option ||| everywhere. Two-thirds of all public land is closed to mineral development or restricted by degrees. Withdrawal of public land is serious because 50 percent of all energy resources are on public land. Scenic Rivers would block transportation and pipeline corridors. Critical habitat could prohibit development of large areas. The restrictions imposed by Scenic Rivers and critical habitat on oil and gas development need to be clearly stated. That is why NPR-A was established. NPR-A was not intended to be a great park or Wilderness Area. 2s OPINIONS Do not agree with any of the options. Option | needs major revisions. Agree with Option V. Wilderness in Option II is excessive. Historically, Wilderness Study Areas are never reduced to a less restrictive classification. EMMA's are not needed. REASON(S) There is already too much government interference, restrictions and red tape to harass the public. Leave NPR-A alone or develop an option acceptable to all people. Options give preference to minorities that should be treated as equal. There should be no Wild and Scenic Rivers, critical environmental areas, reduce critical habitat areas and exclude Wilderness. Except for limited archaeological sites and critical habitat, open it to multiple use with safeguards against changes in the future. Leave all land open to all Alaskans to establish temporary home-sites with optional ownership in a specific time period. Option || should be evaluated for impacts on future decisions. Is this much wilderness necessary to achieve the objectives? Neither objectives or justifications for size and shape of areas are given. Is wilderness designation really a good way, or best way, to manage and protect wildlife; is it better than ACEC or critical habitat? Nearly 100 percent have moved to full Wilderness. From a management standpoint, there is no difference between Study Area and Wilderness. Requires no more than existing law. A need for leasing has not been supported by facts or justification and is only the opinion of the current administration. €S OPINIONS Option I! could have more ACEC's. Options Ill, IV, V and VI are not acceptable. REASON(S) Administration's proposed Mining Law revisions go beyond EMMA and may contradict. Mining under existing law would be done under the same concept as a EMMA whether it is called a EMMA or not. Description of EMMA would read the same without the term EMMA. Private industry does not need help locating minerals and private industry must obtain a production permit, provide maximum environ- mental and surface protection, and comply with reclamation laws with the EMMA concept. Access can be handled so it meets environmental requirements for roads and rail systems. EMMA would only change the mining laws, yield royalties, give govern- ment the right to stop development which would stop exploration. There are adequate surface management laws and, in fact, EMMA already exists. Surface values could be protected by ACEC's without changing the mining laws. Exploration, mining and access need to be consistent with ACEC's. They preclude mineral evaluation and development. These options allow some government inventory, but the government is not capable of evaluating mineral potential. Under Option IV, it is assumed that mining would not be allowed, but even if it were for a while, there still would not be any Private indus- try investments in exploration in wilderness areas. In Option Ill, if exploration and development is delayed 20 years, there would not be any development for 40 years. OPTIONS It is ironic that we talk of locking up more lands in Alaska. g Agree with Option |. The |5-mile radius around falcons nests is too large. Industry and government can work together to develop resources without affecting wildlife and Native populations. The term "wilderness alternative" is misleading because it assumes some form of wilderness. Remember fish and caribou management is a form of exploitation. If we must have Wilderness, then let it be Alaska Wilderness. REASON(S) Option II1 could be criticized for opening NPR-A to uncontrolled government exploration which is worse than private enterprise. lf the government follows its surface management regulations, then Husky Oil has not done a very good job in the past. Our nation is struggling to alleviate its domestic energy shortage. We are still debating whether to develop potential petroleum of the Reserve. Another Arab embargo would be more crippling since imports have climbed from 35 percent to 46 percent. Domestic oil production has fallen off from 9.2 to 8.7 billion barrels per day. Parts of Option |. All of Option |. Existing protective laws need to be enforced vigorously. No reason given. No reason given. No reason given. No reason given. No reason given. sg OPINIONS REASON(S) To have an accurate mineral assessment No reason given. requires that private enterprise conduct it. Do not develop minerals. No reason given. Option V protects the Native culture. No reason given. Issue Native allotments by trust No reason given. title. No trust title should be awarded to No reason given. individuals. Issue Native allotments if NPR-A No reason given. status is changed. Most options are viable for No reason given. different interests. Recognize that man must exploit No reason given. minerals somewhere. Agree with part of Option |! No reason given. The primary difference between Options No reason given. | and II is the Wilderness in Option Il. Publicity of the NPR-A 105(c) Study was in- Did not hear about the study until public review period was over. adequate in the lower 48 states. Disagree that southern NPR-A will receive Areas of NPR-A are 100 miles from the coast and villages and are major recreation use as stated in the plan. difficult and costly to get to for recreationists. Statement lacks an appreciation of cost and difficulty of access, or is a elitist approach. 9¢ OPINIONS Human activities can be successfully pursued and still maintain a healthy Dall sheep population. Designation of the one-mile protected area and |5-mile critical habitat area falcons is not needed. Headwaters of rivers in NPR-A have no attraction for sport or subsistence fisherman. Southern NPR-A would be staked by miners if there were no withdrawals. No additional state and federal explo- ration is needed to identify minerals. REASON(S) Few hard data are available to indicate the area has recreation potential. My experience in respect to cost and logistics would support this opinion. Healy - Mt. Hayes area proves this. There is no merit in setting interim protection more stringent than followed elsewhere. These designations lack an appreciation of the tenacity, resilience and general capacity of the peregrine falcon to exist within close proximity to man. Peregrine falcons were observed first-hand in 1965 in NPR-A. It has not been demonstrated that protection is necessary. No special protection from a fisheries viewpoint is needed. No char or lake trout are present. Fish populations are occasional trash fish. limited to moderate numbers of grayling and Belts of claims, miles wide, from the Etiviuk River to the Kokolik river would have been staked for potential lead and zinc resources if NPR-A was not withdrawn. There are metalliferous values like oil shale and coal of demonstra- bly major significance. Resource potential has been sufficiently demonstrated. Opening NPR-A to leasing and lode mineral entry will quickly identify significant mineral resources. LS OPINIONS It is not feasible to assess and incor- Porate mineral values into a plan in such a short and finite time span. Access is not discussed. The degree and necessity for excluding certain or most human activities from specific and widespread geographic areas is questionable. Mineral resources are inadequately addressed. REASON(S) Sufficient environmental regulations and controls exist to control development. State and federal exploration is not what our economic system is all about. Industry must seek out minerals if they are to be exploited in the most economical fashion. Mineral deposits may be found 10 to 100 years after an initial discovery in an area. The time table does not recognize the historical perspective of mineral location. Continued government exploration is not a suitable alternative. Whether NPR-A is used for mineral exploration, recreation or sub- sistence, access routes are required. Where could mineral resources be moved over corridors to markets? Sufficient surface routes are needed that will not conflict with other values, or identify surface routes as a priority use. Report is deficient unless access is discussed. Special study areas and critical environmental concern areas for certain terrestrial mammals, fish and birds are poorly substantiated. Determination that minerals are subeconomic is inaccurate because there was no attempt to identify economically viable transportation routes. Significance of recently discovered minerals was not adequately covered. 8s OPINIONS Question the objectivity of the entire study. Recommend adoption of Option | with some changes. REASON(S) Compare the two pages devoted to mineral resources to the five pages of wildlife. Remove all biases towards mineral development and then there would be an acceptable degree of multiple use. Do not designate the Colville River as a Scenic River or preclude transportation routes. Do not designate the Colville River or Utukok area critical environ- mental areas within view of the Utukok and Etivluk Rivers. Rivers can be protected by existing legislation. Critical environmental areas rule out economically viable resource extraction. Do not extend protection of peregrine falcons beyond a |,500-foot radius. A \5-mile radius protective area around falcons eliminates most prospective oil shale and metalliferous mineral areas. Delete the reference to recommendation 2, in recommendation 5, of Option |. Administer NPR-A the same as other federal lands and let the U.S. Geological Survey and U.S. Bureau of Mines retain and/or control mineral resources. Government mineral inventory should remain subordinate to private exploration efforts. Identify viable access routes to known mineral resources immediately and set aside corridors for all reasonable and possible future access needs. 6S OPINIONS REASON(S) Options I1, II1l and IV are totally They are fraught with constraints or outright anti-resource biases. unacceptable. Bureau of Land Management has an No reason given. inherent natural bias which would be termed the preservationist's point of view. FRGGIRRRRRRRRSRRRRRRRRRRRRRRETRRRRRRRRRRAARRPIIGIRR Other Interests LOC COOOOOCOOOOEOEOOOOGOOOOOGEOOOOOOOOOOOOONOOOOGE (Individuals who did not fit into any of the identified groups) OPINIONS REASON(S) The options need to be changed. Need four or five transportation routes within and out of the area. Allow pipelines, coal slurry lines, all-season roads, railroads and power lines to be built. Let the State manage the fish and game without any federal direction and oversight. Favor mineral extraction and development. Develop oil, gas and coal close to villages and only for domestic use. Develop hardrock minerals, coal, oil and gas wherever transportation corridors can help the economic factors. Develop hardrock minerals, coal, oil and gas wherever it occurs. Develop after a minimum of 20 years. Develop minerals wherever they are located, if it is economical. Strict environmental safeguards should be followed. Development should not substantially alter the caribou range or cause permanent pollution. Q °o OPINIONS Do not extract or develop minerals. Subsistence provisions of HR 39 are suitable. Strike out HR 39. REASON(S) Develop hardrock minerals, coal, oil and gas immediately. Develop as rapidly as the economy allows. Develop minerals at a pace dictated by economic and environmental considerations and mining techniques. Develop slowly and take longer than 20 years. Develop coal when outside sources are depleted. Develop gas at Barrow under strict controls. Identify small areas for the development of coal, gas, or oil for local use. Only feasible area to develop is Barrow for gas. Delay development for longer than 20 years. Do not develop minerals in ecological concern areas or river areas. Other groups besides Natives need to be recognized as potential sub- sistence users. Support HR 39 if development of other resources is not excluded. There is no HR 39. The State can manage the wildlife better than the federal government. Place hunting and fishing under state authority. U.S. Department of the Interior has no obilgation or authority over racial grounds. ANCSA extinguished aboriginal rights and everyone should be treated equally, or it is discriminatory. 19 OPINIONS Do not designate Colville, Nigu-Etivluk and Utukok Wild or Scenic Rivers. Protect the Colville, Nigu-Etivluk and Utukok Rivers from physical and chemical change but do not close them completely. The options could be improved from the Native's standpoint. Native cultural rights should not be Protected. REASON(S) Subsistence rights should be leased. Use traditional and cultural methods, not motorized vehicles for subsistence; otherwise base subsistence upon need. They are not wild or scenic. The rivers are frozen most of the year and traverse barren land. They are already protectd by their remoteness. If the rivers are designated, current methods of transportation would not be allowed. The rivers should not be polluted but if rechanneling or damming serves a purpose, allow it. Allow use of fixed-wing aircraft for recreation, backpacking, hunting and fishing. Do not designate the rivers because waste and fallout can be cleaned up with dollars and the will. Let the State protect the rivers because it has strict water Purity laws. Protect the rivers by the regulations of management agencies like Bureau of Land Management, State Department of Environmental Conservation, State Division of Lands, Alaska Department of Fish and Game, etc. Let Natives select land of their choice under ANCSA. Let Native culture evolve at its own speed. White cultural rights should be considered. Natives will protect their rights if they are important. 29 OPINIONS Issue Native allotments under 1906 Native Allotment Act. Issue allotments under P.L. 94-258 and long-term leases and permits. Issue allotments under P.L. 94-258. Favor Alaskan wilderness. No Alaskan Wilderness should be designated in NPR-A. REASON(S) It is sad if Natives loose their culture but it is their own choice or weakness. Oppose segregation of Alaskan residents by origin or race. The Government should not protect cultural values. The options already look like a Native-only hunting grounds. Oppose an option that makes Fairbanks citizens second class in the NSB. Consider Natives a special interest group and treat all users alike. Drop any recommendation that preserves a cultural benefit that could be an albatross in 10 years. Give them land for homes and recreation cabins but nothing more. No allotments should be granted under long-term leases and permits, P.L. 94-258 or trust title. This appears to be a fair and equitable way to grant allotments. Give the Natives the majority of NPR-A. Alaskan Wilderness is the best concept yet of wilderness. For the areas outlined in Option V. For the areas outlined in Option III. It is not correct or suitable on these lands. No wilderness alternatives are suitable on this large a land area. All options are slanted at not allowing Caucasian use. €9 OPINIONS Alaskan Wilderness is a good concept but not for the North Slope at this time. Caribou situation was not dealt with squarely. Report is biased toward Natives. Would like to see bears increase. The level of subsistence use on the Colville River is not high. Statement that Eskimos do not consider hunting and subsistence recreation is not true. REASON(S) Rewrite the options and allow other folks to use the area. Do not designate any area Wilderness, but protect rivers and environ- mental concern areas in Option |. Inventory the minerals and then designate areas without mineral values Alaskan Wilderness. Additional Wilderness is not needed because there are already the Arctic Game Range, Gates of the Arctic National Park, Noatak River, etc. Believe in old concept of multiple use. Western caribou herd is in trouble because of subsistence. The options suggest one herd rather than two. Commissioner of Fish and Game and real caribou biologist were not consulted. Printing of questionnaire on NSB stationary shows bias of report. Easy for a few wilderness hunters to literally wipe them out. No Eskimos were seen from breakup to mid-October 1977, or the summer of 1978 from breakup to September in the Umiat area. Evidence of one group was seen at NARL cabin and two fish camps below Ocean Point. Even if Fairbanks, Anchorage and Barrow people were included, subsis- tence use would not be high. They enjoy the thrill of the hunt. v9 OPINIONS Examine facts before excluding people from using resources of NPR-A. Consider motor boating opportunities on Colville River above Umiat. Do not change 1872 Mining Law to a leasing system. Agree with general policies except transportation. Agree with Option | if some changes are made. Agree with Option II. Agree with parts of Option III. REASON(S) Look at present subsistence uses and areas. You are over-stepping state jurisdiction. River evaluated during extremely low water period. Heritage Conservation and Recreation Service team said motor boating is not possible, but it is. They didn't seem to understand the river or the capabilities of jet boats. Two jet boats used the river in 1978. Mining regulations are enforced; leasing is not needed. It is not clear if the plan is to respond to a need or stimulate development. Critical environmental areas and critical habitat should not preclude mineral exploration, development or transportation to the south and east across the Colville River. Change the subsistence portion. Federal and state environmental agencies should work with industry. Critical areas should be put back in. Alter the Colville Scenic River to allow sport hunting by boat and aircraft. Leave subsistence to the State to define and regulate. No reason given. g9 OPINIONS REASON(S) Maintain the status quo on development for one more generation so Natives can formulate their plan. Support recommendation 2 of Option III. Agree with parts of Option IV. Support recommendations |, 4, 5, and 6 of Option IV. Agree with parts of Option V. Status quo on development for one more generation so culture can for- mulate their plan. Support recommendation 2 of Option V. Planning process was based upon predeter- No reason given. _ mined conclusions. Air quality and caribou do not follow No reason given. NPR-A boundary. NPR-A team is to be complimented for a No reason given. thorough study and effort to seek public input. Designate Colville, Nigu-Etiviuk and Utukok No reason given. as Wild or Scenic Rivers. Do not designate any other rivers Wild or No reason given. Scenic. Designate the Awuna as a Wild or Scenic No reason given. River. Options | and V protect Native cultural No reason given. values. No Native allotments should be granted. No reason given. Issue Native allotments under long-term No reason given. leases permits or trust title. 99 OPINIONS There are too many government regulations. HR 39 provisions for subsistence are not suitable. Sportsmen are not being listened to and decisions are political. Agree with most of Option |. Favor hardrock mineral, oil, gas and coal development. Do not designate Colville, Nigu-Etivluk and Utukok as Wild and Scenic Rivers. None of the Native cultural values alter- natives are wanted. REASON(S) There are 2,600 regulations to comply with. State should manage subsistence, fish and wildlife consistent with Statehood Act. HR 39 is strongly opposed because it provides local control of wildlife. If one Native objects, the Secretary of the Interior can intervene. Subsistence should be defined. Game management should not be decided on racial grounds. Plan overstresses Native concerns and does not treat all citizens equally. Need a statewide approach to game management. Spent 6 weeks preparing a 98-page report on subsistence to testify in Washington and did not receive any acknowledgement. Delete subsistence because it should be managed by the State. Proceed at normal rate consistent with BLM policy and NEPA. Support slow approach to resource development for one more generation. Weigh 6 salmon against $100,000 of clean up or family incomes from mining. Designation would greatly inhibit travel during winter and summer. Current regulation are sufficient to control development and provide protection from physical and chemical change. Native culture is rapidly changing because of forces outside NPR-A. State should manage subsistence with much Native input. OPINIONS REASON(S) Mandatory State and Native cooperative management would be better from a Native standpoint. Allow Native allotments under 1906 No reason given. Native Allotment Act. Development would affect the caribou. No reason given. State game department has not been No reason given. contacted. No other rivers should be designated No reason given. wild or scenic. No wilderness designation is needed. Area will remain wilderness and there is no way to change it. L9 Limit wildlife and subsistence management by prohibiting control and research. Existing environmental laws provide sufficient protection. Abbreviations and abbreviations used in tabulation ASRC - Arctic Slope Regional Coporation NSB - North Slope Borough ANCSA - Alaska Native Claims Settlement Act P.L. 94-258 - National Petroleum Reserves Production Act FLPMA - Federal Land Policy and Management Act (d)(2) - Section 17(d)(2) of ANCSA OCS - Outer Continental Shelf USFWS - U.S. Fish and Wildlife Service BLM - Bureau of Land Management USGS - U.S. Geological Survey ACEC's - Areas of Critical Environmental Concern USBOM, BOM - U.S. Bureau of Mines EPA - Environmental Protection Agency NARL - Naval Arctic Research Laboratory AREAS OF CONCERN RAISED AT THE FEBRUARY 8 AND 9, 1978 MEETING WITH NORTH SLOPE REPRESENTATIVES Native allotments: Can a recommendation be built into the plan which supports a policy change allowing for granting of these? Reporting to the villages: This has been taken lightly in the past. The example used was of Husky Oil failing to report back to Wainwright on drilling plans, exploration results, etc., after promising to do so. The residents of the North Slope feel that much exploratory work, seismic and drilling, with associated activities, has adversely affected fish populations in lakes. What is planned to be done to reestablish these fish populations? Exploration people are not adequately cleaning up wires after seismic operations. Caribou have become tangled in these and die. Also, wolverine dens and nearby habitat have been bulldozed. Is there a recognized Native allotment within National Petroleum Reserve? This is important because these allotment applications are traditional use areas. Is there any method for transportation of coal from NPR-A_ without degradation of the area? Coal studies should be done in the vicinity of the villages first, rather than after studying coal in the other areas of the Reserve. How can erosion be prevented? This is a problem where there have been roads and cat trails during exploration activities. Is there a possibility of building sea walls at Point Lay and Wainwright to stop erosion action? This erosion threatens to force moving all or parts of these communities. Moving is not desired by the residents. Help has been promised in this regard, but nothing has been done. What are the conflicts between Wilderness status and subsistence use of lands? Many of the fish camps are inhabited six months of the year. (May through September.) Lands designated as Wilderness or Wild and Scenic Rivers may have bad effects since the laws could be changed to restrict use of airplanes, motor boats and snowmobiles for access and for subsistence hunting and fishing. Many of the land use recommendations may be good or bad depending upon the legal implications. Since this is the area of responsibility of the Solicitor's Office of the Department of the Interior, can an answer and analysis be provided in a timely manner? If not, this could upset good recommendations. 68 What is the definition of Wilderness? Questions arose about the use of untrammeled and its implications. Designation of recreation areas may cause problems similar to Wilderness status. It may serve to attract people from outside the area to the NPR-A. Designations of scenic areas may also have this same effect: Attracting people. There is need for a winter scenic evaluation. Define recreation from the Inupiat point of view; there was diversity about this definition. Forrest Solomon could not view dancing as recreation, saying that "It comes from my subsistence, from my whaling. It is my heritage." This view seemed pervasive among the Inupiat represen- tatives. Recreation was seen as alien in concept. Hunting seasons are inconsistent with subsistence uses. This needs careful attention. More local control in wildlife management and enforcement. If numbers of animals are made public, this will attract hunters in greater numbers from outside the North Slope. Are the counted numbers of caribou correct? Why aren't Native people participating in the animal and fisheries studies? More local involvement at this level is needed. To facilitate the above, the "red tape" associated with such cooperative work must be cleared up. It was felt that this should be cleared up legislatively and mandated in such acts as P.L. 94-258. Aerial surveys may be disrupting caribou, birds, and other wildlife; researchers should consider this in future studies. Consideration of Native systems of fish and game management has not been given. It seems that the non-Native view is that the Inupiat just take whatever is available without any concepts of conservation and management. Considerations of predator control programs, especially for brown bears in the Utukok River calving grounds for caribou, should be made. (This objective can be tied to the inappropriate seasons for hunting recom- mendations made earlier. ) There is concern for the effects of drilling on the fish in lakes and streams due primarily to water pumping (dewatering). There is credibility problem between government researchers and _ local residents of NPR-A. This mutual distrust affects negatively the ability of the two groups to work together, or to view the other's commentary and input as valid. 69 Guiding of hunters and fishermen by local residents may be an area to deserve recommendation. (Problems here involve the State licensure requirements and guiding territories, as well as the Philosophical differences arising from such a shift. Where such species as brown, grizzly bear, etc., are concerned, this is not a problem in philosophy). Written records of historical and archaeological sites are not kept by local people. What are the effects of drilling for oil, or seismic activity, on historical or archaeological sites? Under what jurisdiction are they protected? What assurance is there that minimum disturbances will occur in areas of concern? What methods of coordinating are there to insure that local concerns are taken into consideration in this regard? There is problem in the areas of historical and cultural resources in getting a complete inventory of activities, uses, sites, etc., and getting local input and review for this plan due to the detailed work that there is to do and the short time allowed for meeting the planning deadline. Local people want local review whenever work that describes their activity and areas is done. There is no such thing as "recreation" in an Eskimo culture. These activities often described as recreational are for subsistence--survival. How are we going to assess subsistence issues which are not covered in inventories due to the short time frame for the planning? Are allotment application conveyances being held up due to concern over control of subsurface rights on the part of the Department of the Interior? Local input into impact analysis is not sufficient as it concerns the Presidential or 105(b) study. North Slope should have a represen- tative on the Task Force for this study. No meetings of the 105(c) Task Force should be held without North Slope participation. There is concern over the lack of Bureau of Indian Affairs (BIA) partici- pation in the Task Force. From a realty standpoint, BIA focus appears absent. Are the scenarios developed for the 105(c) study valid? And is it proper to do this study from the standpoint of these scenarios? Are fishing camps or other subsistence sites considered before drilling activity begins? There should be a built-in process of review at the village, Arctic Slope Regional Corporation and North Slope Borough levels to determine village and regional concerns over subsistence site disturbance and other concerns prior to any drilling. 70 Local input is needed for each site where drilling might occur. Particular concern should be paid to evaluation of land use information and better interaction with local people. A study may be needed to determine the effects of ice thickness of runways over lakes. Is the ice thickness sufficient to keep noise and pressure damage to fish down? The runway (a permanent landing strip) for the deep well at the Tunalik site near Wainwright is in conflict with a heavily used subsistence area. Husky Oil Company has been contacted but has not reponded at this time. A federally funded Native Commission is needed to insure adequate local Participation in the NPR-A studies. The boundary issue needs to be settled by Congress. This recommendation needs to be put forth as part of the Land Use Plan. A look at existing leases is needed, with examination of the cooperative agreements between federal, state and local governments. 71 Name Occupation Appendix Il NORTH SLOPE BOROUGH P.O. BOX 69 BARROW, ALASKA 99723 (907) 852-2611 NPR-A 105(C) LAND PLAN QUESTIONNAIRE* Address The NPR-A planning team has outlined five land -plan options for NPR-A. (See Briefing Book Option | Page _38, Option I! Page _43, Option Ill Page _50, Option IV Page _53, Option V page ~55). ~ Fhese were also discussed at the public meeting. The options range from permanent closure of the area to development to immediate opening of the area to mineral development subject to economics of the area. a. Do you agree with any of the options discussed or part of options? b. If so which one or parts? c. Are there specific alternatives to these options that you would propose? d. Are you in favor of mineral extraction and development on NPR-A? If so what kind and in which areas: (1) Hardrock - metallic, base minerals, i.e. zinc, lead, etc. (2) Oil and gas (3) Coal e. Are there any specific areas where minerals should be explored and possibly developed? If you favor mineral development how fast should it occur? *[These page references relate to the September 1978 draft of options titled “Preliminary Recommendations and Land Use Options."" This questionnaire was developed in September 1978.) 72 2. (1) Immediately (2) After 20 years (3) Longer All of the options include the recommendation that the subsistence provision of HR 39 (D-2 legislation) should apply to the area. A copy of this section of the bill is included in your informational material. a. Are the subsistence provision of Sec VII of HR 39 suitable for NPR-A? b. Do you have recommendations for changes in Section VII? All of the options include designation of the Colville, Nigu- Etiviuk and Utukok as wild or scenic river. This would prevent dams or other development that would change the rivers. Are these designations acceptable? a. Should these rivers be protected from physical and chemical changes? b. Are there other means to protect the rivers than through legal designation? Please recommend. c. Should other rivers be included in wild or scenic designation? Please name: Native Values The plan options provides protection of subsistence in varying degrees. No specific Native option has yet been developed but one is being developed. Do you feel that any of the alternatives provide protection for Native cultural values? Which one? Do you see changes that could be made in any option that would be better from the Native standpoint? 73 Native allotments One of the key issues raised during NPR-A discussion with Native people over the last year was the issue of Native allotments. Since NPR-A (Pet 4) was withdrawn in 1923 Native allotments under the 1906 Act have been legally excluded unless use was begun by 1918. The NPR-A land plan has developed the following alternatives con- cerning Native allotments. Are there any which solve the issue satisfactorily? a. Reinstate all Native allotments applications properly filed under the 1906 Native Allotment Act and reconsider each based upon its merits under that act. b. Take the steps necessary to issue long term leases or permits for use of subsistence sites by families and/or individuals within NPR-A. These leases should allow for the building of cabins and ice cellars. c. Identify key subsistence sites or homogenious clusters of sites and designate the area or areas as valuable for subsistence gathering purpose under 104(b) of Public Law 94-258. d. The Secretary of Interior under (his powers set forth in 25- USC 465 will) transfer trust title for (individual users of) subsistence sites to the Inupiat Community of the Arctic Slope, the Regional Tribal government under the Indian Re- organization Act. Wilderness The Wilderness Act requires that all roadless Federal lands that are 5,000 acres and more be inventoried and analyzed for possible designation as_ wilderness. Most of NPR-A is technically qualified as Wilderness. The NPR-A planning options provide a wide variation in possible designation - these range from complete designation of all of NPR-A to wilderness to no designation. Key areas considered for wilderness designation include the De Long Mountains, Utukok area, and Teshekpuk. Wilderness designation would stop all major development including roads, mining, oil and gas development. All of the wilderness recommendations include the concept of Alaskan type wilderness which would allow continuation of vehicle access as long as the resources were not being damaged. Is this concept suitable? Do you agree? The briefing book ex- plains these. Which wilderness alternative is most suitable? 74