2-1-17 Valdez (i.e. Governor Bill’s home town) still fights for Valdez LNG terminal…

…and, we wonder how the good folks on the Kenai Peninsula are reacting to that!  (Here’s the filing .pdf)

UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Alaska Gasline Development Corporation Docket No. PF14-21-000
BP Alaska LNG, LLC
Conoco Phillips Alaska LNG Company
ExxonMobil Alaska LNG, LLC
TransCanada Alaska Midstream, LP
COMMENTS REGARDING ALTERNATIVE ROUTE AND SITE ANALYSIS
FOR THE AKLNG PROJECT
THE CITY OF VALDEZ, ALASKA
THE MAYOR OF THE FAIRBANKS NORTH STAR BOROUGH, ALASKA
THE MAYOR OF THE CITY OF FAIRBANKS, ALASKA
THE MAYOR OF THE CITY OF NORTH POLE, ALASKA
THE ALASKA GASLINE PORT AUTHORITY
Dated: February 1, 2017
ii
TABLE OF CONTENTS
I. INTRODUCTION ………………………………………………………………………………………………….1
II. NEPA REQUIRES THOROUGH ANALYSIS OF THE VALDEZ
ALTERNATIVE ……………………………………………………………………………………………………3
A. The Valdez Alternative Is the Most Reasonable Alternative………………………………..4
B. The Project Applicants Have a Duty to Provide Sufficient Data to Objectively
Compare the Nikiski Alternative to the Valdez Alternative. ………………………………..5
C. The Project Applicant’s Preference for the Nikiski Alternative Has No Effect
on the Scope of the Analysis Required for the Valdez Alternative. ………………………6
D. NEPA Sets out Distinct Alternative Analysis Requirements for Route and Site
Alternatives. ………………………………………………………………………………………………….6
III. COMPARATIVE ADVANTAGES OF THE VALDEZ ALTERNATIVE ……………………9
A. The Valdez Alternative’s Collocation with Existing Rights-of-Way and Use of
Existing Infrastructure Minimizes Greenfield Construction. ………………………………..9
B. The Valdez Alternative Provides Several Socioeconomic Advantages. ………………12
C. The Valdez Alternative Avoids the Hazardous Construction, Operating, and
Shipping Conditions of Cook Inlet. ………………………………………………………………..17
D. The Valdez Alternative Avoids Several Environmentally Sensitive Areas…………..22
1. Cook Inlet Beluga Whale Critical Habitat. …………………………………………………23
2. Minto Flats State Game Refuge. ……………………………………………………………….31
3. Susitna Flats Game Refuge. ……………………………………………………………………..33
4. Denali State Park and Denali National Park. ………………………………………………35
5. Essential Fish Habitat. …………………………………………………………………………….37
E. The Valdez Alternative Better Advances Concepts of Environmental Justice ………38
IV. THE PROJECT APPLICANT’S ANALYSIS OF THE VALDEZ ALTERNATIVE
FAILS TO SATISFY NEPA …………………………………………………………………………………39
A. The Cost to Develop the Valdez Alternative’s Site. ………………………………………….41
B. Tanker Operations in Valdez Narrows. …………………………………………………………..43
C. Proximity of the Valdez Alternative to Wild and Scenic Rivers. ………………………..44
D. Challenges Associated with Thompson Pass and Keystone Canyon……………………48
E. Issues Associated With Traversing the Chugach National Forest. ………………………48
F. Air Permitting Issues…………………………………………………………………………………….49
G. Additional Impacts to Wetlands and Anadromous Fish. ……………………………………50
iii
LIST OF APPENDICES
A Yukon Pacific LNG Project, Final Environmental Impact Statement, FERC Docket
No. CP88-105-000, March 1995
B Guidance Manual for Environmental Report Preparation for Applications Filed
under the Natural Gas Act, FERC, December 2015
C Public Land Order 5010 (Map), Utility Corridor, Prudhoe Bay to Valdez, March
2004
D Trans-Alaska Gas System, Final Environmental Impact Statement, BLM No.
AK-PT-88-003-1792-910, June 1988
E American Lung Association, State of the Air, 2016
F FNSB Air Pollution Control Commission, Air Quality Comprehensive Plan,
May 2016
G Gas Distribution System Analysis, Northern Economics, Inc., June 29, 2012
H Cook Inlet Vessel Traffic Study, Report to Cook Inlet Regional Citizens Advisory
Council, Cape International, Inc., December 2006
I Coast Guard Report of Investigation: Grounding of the Tank Vessel Seabulk Pride
in Cook Inlet, February 2, 2006
J Cook Inlet Risk Assessment Final Report, Nuka Research and Planning Group,
LLC, January 27, 2015
K Recovery Plan for the Cook Inlet Beluga Whale, NMFS, December 27, 2016
L Minto Flats State Game Refuge Management Plan, ADFG, March 1992
M Alaska Department of Fish and Game, Minto Flats State Game Refuge, Fish and
Wildlife (last visited December 20, 2016)
N Susitna Flats State Game Refuge Management Plan, ADFG, March 1988
O Denali State Park Management Plan, Alaska Department of Natural Resources,
2006
P Fisheries Management Plan for the Salmon Fisheries in the EEZ off Alaska, NMFS,
June 2012
Q Alyeska Pipeline, Valdez Marine Terminal (last visited December 20, 2016)
R National Ocean and Atmospheric Administration, Ocean Facts, Where is the
highest tide? http://oceanservice.noaa.gov/facts/highesttide.html (last visited
December 20, 2016)
S River Management Plan for the Delta National Wild and Scenic River, U.S.
Department of the Interior, October 7, 1983
T River Management Plan for the Gulkana River, U.S. Department of the Interior,
August 2006
U Utility Corridor Resource Management Plan/Environmental Impact Statement
Record of Decision, BLM, January 11, 1991
iv
TABLE OF AUTHORITIES
Cases
All Indian Pueblo Council v. U.S.,
975 F.2d 1437 (10th Cir. 1992) …………………………………………………………………………… 3
BP Pipelines (Alaska) Inc. v. Alaska,
2011 WL 11549442 (Alaska Super.) ………………………………………………………………….. 42
Dubois v. U.S. Dep’t of Agric.,
102 F.3d 1273 (1st Cir. 1996) ……………………………………………………………………….. 3, 51
Nat’l Res. Def. Council v. Callaway,
524 F.2d 79 (2d Cir.1975) …………………………………………………………………………….. 3, 51
Nat’l Res. Def. Council, Inc. v. Morton,
458 F.2d 827 (D.C. Cir. 1972) …………………………………………………………………………. 3, 4
Sierra Club N. Star Chapter v. Pena,
1 F. Supp. 2d 971 (D. Minn. 1998) ……………………………………………………………………. 45
Sierra Club v. Marsh,
714 F. Supp. 539 (D. Me. 1989) ………………………………………………………………………. 4, 6
Van Abbema v. Fornell,
807 F.2d 633 (7th Cir. 1986) ………………………………………………………………………………. 6
Westlands Water Dist. v. U.S. Dep’t of Interior,
376 F.3d 853 (9th Cir. 2004) ………………………………………………………………………………. 4
Statutes
16 U.S.C. § 1278(a) …………………………………………………………………………………………….. 45
16 U.S.C. § 1281(a) …………………………………………………………………………………………….. 46
16 U.S.C. § 1502.25 ……………………………………………………………………………………………. 23
16 U.S.C. § 1536(a)(1). ……………………………………………………………………………………….. 23
16 U.S.C., Part B, § 4601 …………………………………………………………………………………….. 36
42 U.S.C. § 7503 ………………………………………………………………………………………………… 16
42 U.S.C. § 7509 ………………………………………………………………………………………………… 16
v
Other Authorities
FERC Guidance Manual (2015) ……………………………………………………………………………… 7
Forty Most Asked Questions Concerning CEQ’s NEPA Regulations, 1981 WL 149008
(F.R. 1981) ……………………………………………………………………………………………………….. 4
Regulations
18 C.F.R. § 380 …………………………………………………………………………………………………….. 6
18 C.F.R. § 380.12 ………………………………………………………………………………………………… 5
33 C.F.R. § 83.03(g) ……………………………………………………………………………………………. 13
33 C.F.R. § 83.09(c) ……………………………………………………………………………………………. 13
33 C.F.R. § 83.10(i) …………………………………………………………………………………………….. 13
40 C.F.R. § 1502.14 ………………………………………………………………………………… 2, 5, 40, 51
40 C.F.R. §§ 1500-08 ……………………………………………………………………………………………. 6
50 C.F.R. § 402.02 ………………………………………………………………………………………………. 23
Constitutional Provisions
Alaska Const. art. 8, § 2……………………………………………………………………………………….. 13
vi
GLOSSARY OF TERMS
ADF&G Alaska Department of Fish and Game
AGDC Alaska Gasline Development Corporation
AGPA Alaska Gasline Port Authority
AKLNG Alaska Liquefied Natural Gas
AKLNG Project The plan to construct one integrated liquefied natural gas (LNG) Project
(Project) with interdependent facilities for the purpose of liquefying
supplies of natural gas from Alaska, in particular from the Point Thomson
Unit (PTU) and Prudhoe Bay Unit (PBU) production fields on the Alaska
North Slope (North Slope), for export in foreign commerce and
opportunities for in-state deliveries of natural gas.
ANILCA The Alaska National Interest Lands Conservation Act
Beluga Critical
Habitat
Endangered Cook Inlet Beluga Whale Critical Habitat
BLM Bureau of Land Management
CEQ Commission on Environmental Quality
COE Army Corps of Engineers
EFH Essential Fish Habitat
EIS Environmental Impact Statement
EPA Environmental Protection Agency
ESA Endangered Species Act
FERC
FNSB
Federal Energy Regulatory Commission
Fairbanks North Star Borough
GTP Gas Treatment Plant
LNG Facility Natural gas liquefaction facility
LWCF Land and Water Conservation Fund
Mainline An approximately 800-mile pipeline to transport processed natural gas
south to tidewater
Marine Terminal Marine terminal with loading berths to load LNG tankers for export
MOF Material Offloading Facility
NEPA National Environmental Policy Act
vii
GLOSSARY OF TERMS (Cont.)
Nikiski Alternative Alternative pipeline route that runs within the Trans Alaska Pipeline
System (TAPS) utility corridor from the North Slope south to Livengood,
Alaska. At Livengood, the Nikiski Alternative deviates from the TAPS
utility corridor, travels to the west side of Cook Inlet, crosses Cook Inlet,
and makes landfall near Nikiski where the LNG Facility and Marine
Terminal would be located.
NMFS National Marine Fisheries Service
NOAA
PM2.5
Project Applicants
National Oceanic and Atmospheric Administration
Particulate matter pollution smaller than 2.5 microns
The Alaska Gasline Development Corporation
BP Alaska LNG LLC,
ConocoPhillips Alaska LNG Company
ExxonMobil Alaska LNG LLC
TAPS Trans Alaska Pipeline System
Valdez The City of Valdez, Alaska
Valdez Alternative The previously FERC-approved alternative from Livengood south along
the TAPS utility corridor to an LNG Facility and Marine Terminal at
Anderson Bay near Valdez
WSRA Wild and Scenic Rivers Act
1
COMMENTS REGARDING ALTERNATIVE ROUTE AND SITE ANALYSIS
FOR THE AKLNG PROJECT
THE CITY OF VALDEZ, ALASKA
THE MAYOR OF THE FAIRBANKS NORTH STAR BOROUGH, ALASKA
THE MAYOR OF THE CITY OF FAIRBANKS, ALASKA
THE MAYOR OF THE CITY OF NORTH POLE, ALASKA
THE ALASKA GASLINE PORT AUTHORITY
I. INTRODUCTION
The City of Valdez, the Mayor of the Fairbanks North Star Borough, the Mayor of the City
of Fairbanks, the Mayor of the City of North Pole, and the Alaska Gasline Port Authority hereby
submit these comments to the Federal Energy Regulatory Commission (“FERC”) in Docket No.
PF14-21, regarding the Draft Resource Reports filed by the project applicants as a precursor to the
Environmental Impact Statement (“EIS”) required by the National Environmental Policy Act
(“NEPA”) for the Alaska Liquefied Natural Gas Project (“AKLNG Project”). These comments
are intended to protect and advance the vital interests of the State of Alaska and the United States
of America implicated in the development of the AKLNG Project by promoting a thorough review
of project alternatives.
The project applicants are the Alaska Gasline Development Corporation (“AGDC”), which
manages the State of Alaska’s interest in the AKLNG Project, BP Alaska LNG LLC,
ConocoPhillips Alaska LNG Company, and ExxonMobil Alaska LNG LLC (together “Project
Applicants”). AGDC and the other Project Applicants recently entered into an agreement to
transfer sole control over the AKLNG Project to the State of Alaska. Accordingly, although the
Resource Reports to which these comments apply were filed by the Project Applicants, AGDC is
now the only entity listed as an applicant on the FERC docket for the AKLNG Project.
2
The purpose of the AKLNG Project is “to commercialize the vast natural gas resources on
Alaska’s North Slope.”1 The project includes three major components: (1) a gas treatment plant
(“GTP”) within the Prudhoe Bay Unit of the North Slope and attendant feeder lines to deliver gas
thereto; (2) an approximately 800-mile pipeline to transport processed natural gas south to
tidewater (“Mainline”); and (3) a natural gas liquefaction facility (“LNG Facility”) and a marine
terminal with loading berths to load LNG tankers for export (“Marine Terminal”).
The presently proposed alternative (“Nikiski Alternative”) runs within the Trans Alaska
Pipeline System (“TAPS”) utility corridor from the North Slope south to Livengood, Alaska. At
Livengood, the Nikiski Alternative deviates from the TAPS utility corridor, travels to the west side
of Cook Inlet, crosses Cook Inlet, and makes landfall near Nikiski where the LNG Facility and
Marine Terminal would be located. In addition to requiring analysis of the Nikiski Alternative,
NEPA requires that any EIS “[r]igorously explore and objectively evaluate all reasonable
alternatives” and “identify the agency’s preferred alternative.”2 These comments focus
specifically on the importance of analyzing the historically preferred alternative route from
Livengood south along the TAPS utility corridor to an LNG Facility and Marine Terminal at
Anderson Bay near Valdez, Alaska (“Valdez Alternative”). A robust analysis of the Valdez
Alternative is required in order to determine if the Project Applicants have justified deviating from
the decade’s worth of analysis that previously led FERC to choose the Valdez Alternative as the
preferred alternative.
1 Second Draft Resource Report 1 (June 14, 2016) at 1-4 (footnote omitted).
2 40 C.F.R. § 1502.14; Forty Most Asked Questions Concerning CEQ’s National Environmental
Policy Act Regulations, 46 Fed. Reg. 18026 (March 23, 1981) (“The “agency’s preferred
alternative” is the alternative which the agency believes would fulfill its statutory mission and
responsibilities, giving consideration to economic, environmental, technical and other factors.”)
3
II. NEPA REQUIRES THOROUGH ANALYSIS OF THE VALDEZ
ALTERNATIVE
NEPA mandates rational decision making based on considerations of impacts and
alternatives. The “heart” of the NEPA process is to “present the environmental impacts of the
proposal and the alternatives in comparative form, thus sharply defining the issues and providing
a clear basis for choice among options by the decision maker and the public.”3 In furtherance of
this purpose, FERC has a duty to “[r]igorously explore and objectively evaluate all reasonable
alternatives.”4 In addition to studying all “reasonable alternatives,” FERC must also analyze
“significant alternatives suggested by other agencies or the public during the comment period.”5
Regarding the level of detail required for analysis of reasonable alternatives:
It is absolutely essential to the NEPA process that the decisionmaker be provided
with a detailed and careful analysis of the relative environmental merits and
demerits of the proposed action and possible alternatives, a requirement that we
have characterized as the linchpin of the entire impact statement.6
In other words, “a thorough discussion of the alternatives is imperative”7 and “[w]hat is required
is information sufficient to permit a reasoned choice of alternatives as far as environmental aspects
are concerned.”8 “The degree of analysis devoted to each alternative considered in the EIS is to
be substantially similar to that devoted to the proposed action.”9 Thus, the EIS for the AKLNG
3 40 C.F.R. § 1502.14.
4 Id.
5 Dubois v. U.S. Dep’t of Agric., 102 F.3d 1273, 1286 (1st Cir. 1996) (quotations omitted).
6 Id. at 1286-87 (quoting Nat’l Res. Def. Council v. Callaway, 524 F.2d 79, 92 (2d Cir.1975)).
7 All Indian Pueblo Council v. United States, 975 F.2d 1437, 1444 (10th Cir. 1992).
8 Id. at 1444 (quoting Nat’l Res. Def. Council, Inc. v. Morton, 458 F.2d 827, 836 (D.C.
Cir.1972)).
9 Forty Most Asked Questions Concerning CEQ’s National Environmental Policy Act
Regulations, 46 Fed. Reg. 18026 (March 23, 1981).
4
Project must provide sufficient data and analysis of the alternatives to allow a reasoned choice
between the Nikiski Alternative and the Valdez Alternative.
A. The Valdez Alternative Is the Most Reasonable Alternative.
Reasonable alternatives are those “that are practical or feasible from the technical and
economic standpoint and using common sense, rather than simply desirable from the standpoint of
the applicant.”10 For an alternative to be reasonable, it need only meet the “underlying” or “general
goals” of the project.11 A reviewing agency’s failure to analyze viable, reasonable alternatives
renders an EIS inadequate,12 and disregarding an otherwise reasonable alternative because it does
not offer a complete solution is inappropriate.13
The Valdez Alternative is undoubtedly a reasonable alternative requiring robust and
thorough analysis. First, the Valdez Alternative satisfies the underlying project purpose and need
of the AKLNG Project, which is “to commercialize the vast natural gas resources on Alaska’s
North Slope.”14 Second, several stakeholders and state and federal agencies, including the
Environmental Protection Agency (“EPA”), have requested that the Project provide a detailed
study of the Valdez Alternative based upon a variety of concerns.15 Third, previous studies and
readily available data provide compelling evidence that the Valdez Alternative is less costly and
less environmentally impactful than the Nikiski Alternative as a result of its collocation with the
10 Id.
11 Sierra Club v. Marsh, 714 F. Supp. 539, 574-75 (D. Me. 1989).
12 Westlands Water Dist. v. U.S. Dep’t of Interior, 376 F.3d 853, 868 (9th Cir. 2004) (“The
existence of a viable but unexamined alternative renders an environmental impact statement
inadequate.”).
13 Nat’l Res. Def. Council, Inc. v. Morton, 458 F.2d 827, 836 (D.C. Cir. 1972).
14 Second Draft Resource Report 1 (June 14, 2016) at 1-4.
15 Second Draft Resource Report 10 (June 14, 2016) at iii-xxix.
5
TAPS utility corridor,16 avoidance of environmentally sensitive areas, and other characteristics.17
In fact, both FERC and the Bureau of Land Management(“BLM”)/Army Corps of Engineers
(“COE”) issued final EISs (in Yukon Pacific and TAGS, respectively) designating the Valdez
Alternative as the preferred alternative and determining that the Valdez Alternative was superior
to a project substantially similar to the Nikiski Alternative based upon objective criteria.18
Accordingly, any EIS for the AKLNG Project must “[r]igorously explore and objectively evaluate”
the Valdez Alternative.19
B. The Project Applicants Have a Duty to Provide Sufficient Data to
Objectively Compare the Nikiski Alternative to the Valdez Alternative.
Although FERC, as the lead NEPA agency for the AKLNG Project, has the ultimate
responsibility for complying with the mandates of NEPA and accompanying regulations, the
Project Applicants have a responsibility to provide information necessary to analyze the project
including project alternatives.20 Specifically, the Project Applicants are required to file resource
reports addressing specific subject matter in order to facilitate FERC’s review of the project.21 In
Resource Report 10, which addresses alternative analyses, the Project applicants “must describe
alternatives to the project and compare the environmental impacts of such alternatives to those of
the proposal” and “must demonstrate how environmental benefits and costs were weighed against
economic benefits and costs, and technological and procedural constraints.”22 FERC should
16 Id. at 10-127 (The Project Applicants define collocation as within 500 feet of existing ROWs).
17 Appendix A at 7-10 (Yukon Pacific LNG Project, Final Environmental Impact Statement,
FERC Docket No. CP88-105-000, dated March 1995).
18 Id.
19 40 C.F.R. § 1502.14(a).
20 18 C.F.R. § 380.12.
21 Id.
22 Id.
6
enforce NEPA’s mandate with regard to the Project Applicant’s duty to produce sufficient data
and analysis to objectively compare the Valdez Alternative and the Nikiski Alternative.
C. The Project Applicant’s Preference for the Nikiski Alternative Has No Effect
on the Scope of the Analysis Required for the Valdez Alternative.
The project’s principal goal of commercializing Alaska’s North Slope natural gas resources
overrides the Project Applicants preference for the Nikiski Alternative and requires a thorough
analysis of the most reasonable alternative for accomplishing the purpose of the AKKLNG project,
the Valdez Alternative.23 The Valdez Alternative must be thoroughly analyzed and compared to
the Nikiski Alternative regardless of the Project Applicant’s preference for the Nikiski Alternative.
FERC is not constrained in its analysis to the alternatives presented by the project applicant. In
fact, overreliance on data provided by an applicant or too much deference to the applicant’s own
determination of reasonable alternatives may render an EIS inadequate.24 Accordingly, even if the
formal application for the AKLNG Project fails to provide a thorough analysis of the Valdez
Alternative, FERC is nevertheless required to conduct such analysis.
D. NEPA Sets out Distinct Alternative Analysis Requirements for Route and
Site Alternatives.
NEPA, the Commission on Environmental Quality’s (“CEQ”) regulations implementing
NEPA,25 FERC regulations,26 case law, and internally developed FERC guidelines provide
specific guidance to agencies and applicants in fulfilling their obligations under NEPA. These
sources set out distinct requirements for analysis of major route and site alternatives such as the
23 Sierra Club, 714 F. Supp. at 557.
24 See, e.g., Van Abbema v. Fornell, 807 F.2d 633, 639-43 (7th Cir. 1986); Sierra Club, 714 F.
Supp. at 586-87, 589-90.
25 40 C.F.R. §§ 1500-08.
26 18 C.F.R. § 380.
7
alternative mainline pipeline route from Livengood south to Anderson Bay and the alternative
LNG Facility and Marine Terminal site at Anderson Bay associated with the Valdez Alternative.
As a major route alternative, the pipeline route for the Valdez Alternative “should be
addressed in sufficient detail to justify the decision to eliminate [it] from detailed consideration”
and include analysis of “the environmental characteristics of the major route alternative and the
corresponding segment of the proposed route.”27 For each route alternative, the Project Applicants
must “provide clear statements regarding the relative advantages and disadvantages” upon direct,
indirect, and cumulative impacts, including the reasoning behind the route selection.28 In
furtherance of this requirement, the Project Applicants are required to file “environmental
comparison tables that include all of the resource data that is pertinent and useful for comparing
the alternatives.”29 To allow an objective comparison, the data used for comparing the route
alternatives must be consistent.30 In addition to providing objective information required to
compare the environmental characteristics of the routes associated with the Valdez Alternative and
27 Appendix B at 7-8 (Guidance Manual for Environmental Report Preparation for Applications
Filed under the Natural Gas Act, FERC, dated Dec. 2015).
28 Id. at 7.
29 Appendix B at 3 and 8 (The information ordinarily required for major route alternative
comparison charts includes the following: (1) total length; (2) length of new right-of-way vs.
existing right-of-way; (3) amount of affected wetlands; (4) total waterbody crossings; (5) major
river crossings; (6) affected significant fisheries; (7) affected endangered and threatened species
and their habitat; (8) affected cultural resources; (9) affected forest, agricultural, open recreation
and historic, residential, and commercial and industrial lands; (10) number of residences and other
structures within 50 feet of construction area; (11) amount of affected federal lands, national
forests, national parks, and BLM land; (12) amount of affected state lands, state parks, and wildlife
management areas; (13) affected trails; (14) affected recreation or other land use areas; and
(15) the number of affected paleontological sites.).
30 Id. at 5.
8
the Nikiski Alternative, the Project Applicants must also discuss the technical and economic
characteristics of the routes.31
NEPA also sets out distinct guidelines for analyzing site alternatives such as the presently
proposed LNG Facility and Marine Terminal site at Boulder Point for the Nikiski Alternative and
at Anderson Bay for the Valdez Alternative. Alternative sites should be analyzed “for all new
major aboveground facilities, particularly LNG facilities,”32 especially where critical habitat or
threatened or endangered species are present.33 Because the Nikiski Alternative’s site is located
within the critical habitat of the endangered Cook Inlet Beluga Whale, analysis of the AKLNG
Project must include thorough consideration of alternative sites that avoid the critical habitat such
as the Valdez Alternative’s site. Alternative site analysis must include a comparison of
environmental characteristics of the alternative sites, should provide a table comparing relevant
factors,34 must “[i]dentify and discuss the decision criteria and weighting used at each decision
point and clearly state the basis for each decision”35 and “provide a clear statement of why each
alternative site was are [sic] considered less preferable or rejected.”36
31 Id. at 7.
32 Id. at 10.
33 Id.
34 Id. at 11 (The information ordinarily required for alternative site (e.g. LNG facilities nad
compressor stations) comparison charts includes the following: (1) area (acres) required; (2) land
availability; (3) presence of wetlands; (4) presence of critical habitat or federally endangered or
threatened species; (5) zoning (e.g., industrial, residential, agriculture); (6) miles of pipeline
required to reach the site; (7) number of noise sensitive areas within one mile of the site; (8) air
quality considerations; (9) noise considerations; (10) access to electric power and/or additional
facilities required; (11) technical considerations; and (12) economic considerations.).
35 Id.
36 Id.
9
III. COMPARATIVE ADVANTAGES OF THE VALDEZ ALTERNATIVE
The Valdez Alternative offers several advantages over the Nikiski Alternative, none of
which have been acknowledged or analyzed by AKLNG. These advantages are primarily
attributable to the Valdez Alternative’s comparatively high percentage of collocation to existing
rights-of-way, utilization of existing infrastructure, and avoidance of environmentally sensitive
areas. Despite the existence of the previously completed TAGS and Yukom Pacific EISs
identifying some of these advantages, the Project Applicants have not included these advantages
in its analysis of the Valdez Alternative. As a result, the Project Applicants have not satisfied the
duty under NEPA to objectively analyze reasonable alternatives.
A. The Valdez Alternative’s Collocation with Existing Rights-of-Way and Use of
Existing Infrastructure Minimizes Greenfield Construction.
The Nikiski Alternative deviates from the TAPS utility corridor and the Valdez Alternative
at Livengood before travelling 402.7 miles south to Nikiski, including a 28.4-mile section of
offshore pipeline crossing Cook Inlet.37 As a result, the Nikiski Alternative has a substantially
lower amount of collocation with existing rights-of-way than the Valdez Alternative. In fact, only
36 percent38 or approximately 290 miles39 of the Nikiski Alternative is collocated with existing
rights-of-way. Curiously, the Project Applicants employ a different definition of Greenfield
(one mile from the centerline of existing ROWs)40 than that adopted by FERC (500 feet from the
centerline of existing ROWs). Using the Project Applicant’s definition of Greenfield, 27 percent
37 Second Draft Resource Report 1 at 1-134; Second Draft Resource Report 1 at 1-28 ‒ 1-29.
38 Second Draft Resource Report 10 at 10-127.
39 Second Draft Resource Report 1 at 1-30.
40 Second Draft Resource Report 10 at 10-134 (Greenfield is defined as when the “Mainline is
located at least 1 mile (from the centerline) from existing ROWs. Existing infrastructure may
consist of pipelines, major roads, railroads, and underground/aboveground utilities that are
2.5 miles or greater in length.”).
10
or 218 miles of the Nikiski Alternative will require Greenfield construction41 with 196 miles or
approximately 90 percent of that Greenfield construction occurring south of Livengood.42
Applying FERC’s definition, 64 percent or approximately 510 miles of the Nikiski Alternative
requires Greenfield construction. Thus, by failing to use FERC’s definition of Greenfield, the
amount of Greenfield construction required for the Nikiski Alternative is understated by nearly
300 miles. The fact that 90% of the Greenfield construction required for the Nikiski Alternative
occurs south of Livengood, where the Nikiski Alternative deviates from the TAPS utility corridor,
suggests that the Valdez Alternative’s collocation with TAPS will result in substantially less
Greenfield construction. Because the amount of Greenfield construction is a key factor in
determining the least impactful alternative for the AKLNG Project, it is critical that the amount of
Greenfield construction required for each alternative is objectively analyzed using standardized
definitions and criteria.
BLM’s comments to the Project Applicant’s Resource Reports reflect concern regarding
the amount of Greenfield construction required for the Nikiski Alternative. BLM has stated “[w]e
strongly encourage that the proposed action is conducted such that, to the full extent feasible,
activities and development are co-located with previously extant development and minimize
creation of new footprints on the landscape.”43 Even the Project Applicants have acknowledged
that “[i]nstallation of new pipelines along existing rights-of-way (such as other pipelines and
roads) is often environmentally preferable to constructing in a new Greenfield right-of-way, as
41 Id. at 10-134, 10-127 (“‘collocation’ is defined as where the Mainline parallels an existing
road, pipeline, powerline, or railroad within 500 feet, with no overlap of the ROWs or placing of
the Mainline in existing ROWs.”).
42 Id. at 10-133 ‒ 10-134.
43 BLM Alaska Comments on Resource Reports for AKLNG Project (Sept. 26, 2016).
11
impacts can normally be reduced by siting within and/or adjacent to previously disturbed utility
rights-of-way and roads.”44
The amount of Greenfield construction required for the Valdez Alternative has yet to be
provided by the Project Applicants. However, the Project Applicants have stated that the Valdez
Alternative “has a considerable amount of collocation with [TAPS] and a highway system for
almost its entire length.”45 In fact, the Valdez Alternative would allow for nearly the entire pipeline
to be constructed within an existing utility corridor.46 The Valdez Alternative’s collocation with
existing rights-of-way provides advantages over the Nikiski Alternative by minimizing impacts to
resources and reducing costs associated with Greenfield construction. In addition, the availability
of previously gathered data regarding the Valdez Alternative and TAPS will facilitate efficient
navigation of the permitting process.
By occupying the same utility corridor as TAPS, the Valdez Alternative also allows for the
utilization of existing work pads, camp pads, access roads, airstrips, and the vessel traffic safety
system. Unlike the Valdez Alternative, which would “use existing camp pads except at Anderson
Bay,” the Nikiski Alternative would require construction of gravel camp pads at all construction
camp sites.47 By using existing gravel work pads, the Valdez Alternative “would mitigate a
44 First Draft Resource Report 10 (Feb. 11, 2015) at 10.
45 Second Draft Resource Report 10 at 10-72.
46 Appendix C (Public Land Order 5150, Utility Corridor Prudhoe Bay to Valdez with General
Land Status, Alaska Department of Natural Resources, dated March 2004); Appendix D at 9
(Trans-Alaska Gas System, Final Environmental Impact Statement, BLM No. AK-PT-88-003-
1792-910, dated June 1988) (“The proposed TAGS project would be built primarily on federal and
state land within an existing utility corridor that contains a public/private road, a major oil pipeline,
and Federal lands that have been authorized to contain chilled gas ANGTS pipeline.”).
47 Appendix D at 7.
12
substantial portion of the adverse impacts expected from material extraction and placement.”48
Similarly, for the Valdez Alternative:[A]ll of the proposed pipeline construction camps except Prudhoe Bay and
Sourdough Creek would utilize former TAPS construction camp sites . . . [and] Approximately 100 miles of existing access roads, permanent or abandoned, would
be repaired for reuse and approximately 34 miles of new access roads would be
constructed.49
While the Valdez Alternative is estimated to require approximately 34 miles of new access roads
for the entire project, the Nikiski Alternative will require approximately 120 miles of new access
roads south of Livengood alone.50
In order to satisfy the requirements of NEPA and ensure that the least impactful alternative
is selected, the cost-saving and environmental benefits associated with utilizing existing
infrastructure must be taken into consideration. The Project Applicants can facilitate the objective
comparison of the Valdez Alternative and the Nikiski Alternative by providing the necessary data
associated with the Valdez alternative necessary to complete an objective comparison.
B. The Valdez Alternative Provides Several Socioeconomic Advantages.
The Valdez Alternative provides substantial socioeconomic benefits including reduced
costs resulting in increased monetary returns to the State and natural gas access for Fairbanks and
communities along the Richardson Highway, which struggle with extremely poor air quality as a
result of little access to natural gas. Conversely, the Nikiski Alternative poses some substantial
negative socioeconomic impacts on commercial fisheries in Cook Inlet and subsistence hunting
areas in Minto Flats and other areas. In order to satisfy the requirements of NEPA, the Project
48 Id. at 10.
49 Id. at 4.
50 Appendix F to Second Draft Resource Report 1 at Table 1 (120 miles calculated by totaling all
new access roads south of mile 401 where Livengood is located.).
13
Applicants must objectively compare the socioeconomic impacts of the Nikiski Alternative to
those of the Valdez Alternative.
First, the State has a constitutional duty to “provide for the utilization, development, and
conservation of all natural resources belonging to the State, including land and waters, for the
maximum benefit of its people.”51 Lower project costs maximize socioeconomic benefits to all
Alaskans by allowing a greater return on investment for the State and lower tariffs for
transportation of State-owned royalty gas. Accordingly, the cost savings associated with the
Valdez Alternative’s collocation with TAPS, use of existing infrastructure, and avoidance of
environmentally sensitive areas weighs heavily in favor of selecting the Valdez Alternative in
order to comply with the Alaska Constitution.
Second, the Nikiski Alternative poses far greater negative socioeconomic impacts to
commercial fisheries and subsistence hunting areas. The Project Applicants acknowledge that
“[d]uring construction of the Marine Terminal, it is anticipated there would be temporary but
significant adverse effects on some set gillnet permit holders participating in the Cook Inlet
commercial salmon fishery”52 and “commercial set gillnet permit holders displaced by Marine
Terminal construction could also face uncertainty about their ownership of shore fishery leases at
the end of the construction period.”53 Moreover, the Project Applicants do not account for losses
that will be experienced by drift and purse seine fisheries. A vessel engaged in fishing must avoid
vessels restricted in their ability to maneuver, which includes vessels engaged in dredging,
surveying, or pipe laying,54 and is prohibited from impeding the passage of any other vessel
51 Alaska Const. art. 8, § 2.
52 Second Draft Resource Report 5 at 5-178.
53 Id. at 5-179.
54 33 C.F.R. § 83.03(g).
14
navigating within a narrow channel, fairway, or traffic lane.55 Accordingly, vessel traffic
associated with construction of the Nikiski Alternative and LNG shipping will negatively impact
Cook Inlet commercial fisheries.56
Similarly, the Nikiski Alternative will result in far greater impacts to subsistence hunting
areas as a result of Greenfield construction therein. The Project Applicants have yet to complete
subsistence studies necessary to precisely identify impacts on subsistence resources or otherwise
address concerns regarding the Nikiski Alternative’s impacts on subsistence hunting.57 However,
anecdotal evidence clearly supports the conclusion that the Valdez Alternative poses far fewer
impacts to subsistence areas. For example, the Nikiski Alternative passes through the Minto Flats
and Susitna Flats State Game Refuges while the Valdez Alternative does not affect any state game
refuge. In addition, comments at scoping meetings for the AKLNG Project reveal that Alaska
citizens recognize that the Nikiski Alternative is likely to have a far greater impact on subsistence
hunting.58
Second, the Valdez Alternative’s proximity to Fairbanks and communities along the
Richardson Highway provides superior socioeconomic benefit to the Nikiski Alternative by
providing access to inexpensive natural gas for communities facing exceptionally high energy
prices and poor air quality. Unlike communities along the Nikiski Alternative, communities along
the Valdez Alternative do not have access to reasonably priced natural gas. Fairbanks, Alaska’s
second largest city, and several other communities including Glennallen, Copper Center, and
55 33 C.F.R. § 83.09(c); 33 C.F.R. § 83.10(i).
56 Second Draft Resource Report 5 at 5-136 (“increased vessel traffic related to Project
construction and operations could affect commercial fishing vessels by interfering with fishing
and navigation, and reducing the total allowable fishing area.”).
57 Id. at 5-191.
58 See id. at 5-xxii.
15
Valdez suffer from high energy costs, which negatively impact local economies and result in poor
ambient air quality due to overreliance on wood and heating oil to heat homes. Fairbanks
frequently experiences particulate air pollution at rates that exceed National Ambient Air Quality
Standards as measured by concentration of particulate matter smaller than 2.5 microns (“PM2.5”).59
For 2015, Fairbanks was ranked the fifth most polluted city in the United States as measured by
short-term PM2.5 pollution and the twenty-third most polluted city in the United States as measured
by year-round PM2.5 pollution.60
Exposure to particle pollution has substantial health impacts including death. According to
the American Lung Association “particle pollution does not just make people die a few days earlier
than they might otherwise—these are deaths that would not have occurred if the air were cleaner.61
Moreover, even short-term exposure to particle pollution has been linked to:
1. death from respiratory and cardiovascular causes, including strokes;
2. increased mortality in infants and young children;
3. increased numbers of heart attacks, especially among the elderly and in people with
heart conditions;
4. inflammation of lung tissue in young, healthy adults;
5. increased hospitalization for cardiovascular disease, including strokes and congestive
heart failure;
6. increased emergency room visits for patients suffering from acute respiratory ailments;
7. increased hospitalization for asthma among children; and increased severity of asthma
attacks in children.62
From 2011 to 2014 elevated PM2.5 concentrations increased hospital admittance in the
Fairbanks area by 22.8% for pediatric asthma, 9.3% for adult asthma, and 7.2% for COPD.63
59 Appendix E at 5 (American Lung Association, State of the Air, dated 2016).
60 Id. at 3-4
61 Id. at 7.
62 Id.
63 Appendix F at 12.
16
Poor air quality in the Fairbanks area, is directly linked to the unavailability of affordable
natural gas for heat and power generation. For example, although the Fairbanks North Star
Borough (“FNSB”) has approximately 100,000 residents, only about 1,100 commercial and
residential properties currently have access to natural gas.64 Providing the Fairbanks area with
natural gas, which would allow conversion of residential and commercial heating systems, is
estimated to reduce PM2.5 emissions from approximately 2,200 tons per year to less than 200 tons
per year.65 Accordingly, providing affordable natural gas to the Fairbanks area is vital to eliminate
the deleterious particle pollution presently occurring there.
In addition to public health impacts resulting from Fairbanks areas high levels of air
pollution, the EPA’s designation of large portions of Fairbanks and North Pole as nonattainment
areas for particle pollution standards negatively effects economic growth in the Fairbanks area.
Air quality permits for any commercial or industrial activity cannot be obtained if the activity will
increase the amount of PM2.5 emissions over current amounts.66 The Fairbanks area may also be
subject, under federal law, to the imposition of economic sanctions such as withholding federal
funds for highway construction, reducing or eliminating federal expenditures on military bases in
the area, and creating additional challenges for the local power plants and refinery to install
emission controls or obtain permits.67
The Nikiski Alternative deprives the Fairbanks area from access to natural gas by
circumventing the area. If the Nikiski Alternative were built, a costly spur pipeline at least 30 miles
64 Id. at 13.
65 Appendix G at 3 (Northern Economics, Fairbanks North Star Borough Gas Distribution System
Analysis, dated June 29, 2012).
66 Id. at 6.
67 42 U.S.C. § 7503, 7509.
17
long (minimum cost of $50-$60 million) is needed to serve the Fairbanks area. An additional 20
miles of spur line is needed to service North Pole, Alaska, with ten more miles required to extend
service from North Pole to Eielson Air Force Base. The Valdez Alternative brings the pipeline in
much closer proximity to Fairbanks, North Pole, and Eielson, which would provide the
inexpensive natural gas necessary to eliminate the substantial health risks associated with particle
pollution, facilitate growth in the Fairbanks economy, and provide relief from high energy prices.
Providing affordable natural gas to the United States military bases near Fairbanks is also a
consideration that weighs in favor of the Valdez Alternative, which would bring the AKLNG
Project mainline in much greater proximity to Fort Wainwright and Eielson Air Force Base.
The Valdez Alternative provides substantial socioeconomic benefits to Alaskans not
provided by the Nikiski Alternative including: (1) reduced costs that allow for Alaska’s resources
to be developed for the maximum benefit of the people as mandated by the Alaska Constitution
and (2) improved air quality and energy prices for the Fairbanks area and Richardson-Highway
communities. Conversely, the Nikiski Alternative will cause negative socioeconomic impacts
including substantial losses in commercial fishing revenues and permanent impacts to subsistence
hunting that are avoided by the Valdez Alternative as well as impacts caused by additional
construction necessary to provide service to Fairbanks. These examples of socioeconomic impacts
reveal why the Project Applicants must objectively compare the alternatives in order to determine
which alternative best advances the vital interests implicated in the construction of the AKLNG
Project.
C. The Valdez Alternative Avoids the Hazardous Construction, Operating, and
Shipping Conditions of Cook Inlet.
The Valdez Alternative presents several advantages over the Nikiski Alternative associated
with the suitability of the respective Marine Terminal sites. The Nikiski Alternative’s site at
18
Boulder Point requires construction and operations in Cook Inlet, which is relatively shallow and
routinely experiences heavy winter ice flows and extreme tidal floods. Conversely, the Valdez
Alternative’s site at Anderson Bay is deep, ice free, and experiences much less dramatic tidal
action.
Both ice flows and extreme tides in Cook Inlet pose substantial challenges to safe
construction and operation of the Marine Terminal and to tanker traffic. In fact, there are several
instances of vessel casualties resulting from ice and tides in recent years.68 As recently as 2006,
“a sudden force generated by ice and current” caused a 601-foot tanker, the Seabulk Pride, to part
from its mooring lines at the Kenai Pipe Line Dock in Nikiski and run aground.69 A Coast Guard
investigation into the grounding concluded that:
The only sure course of action that would have prevented this casualty was to
require the ship to depart the terminal during the icing conditions experienced. The
forces generated at max flood combined with ice present a substantial risk to a
vessel moored at the KPL dock.70
Although the vessel “was refloated without significant oil spillage,” the 2006 Cook Inlet Vessel
Traffic Study concluded that “catastrophe was narrowly averted, given the numerous rocks and
reefs in the vicinity.”71 In 2000 a freight ship, the M/V Torm Pacific, was moored at a terminal in
Nikiski “when it was struck by a large pan of ice moving at approximately 5.3 knots. The vessel
was sheared from the pier, parting 24 mooring lines, and struck the terminal’s northern catwalk.”72
68 Appendix H at 3-5 (Cook Inlet Vessel Traffic Study, Report to Cook Inlet Regional Citizens
Advisory Council, Cape International, Inc., dated Dec. 2006).
69 Appendix I at 2 (Coast Guard Report of Investigation: Grounding of the Tank Vessel
SEABULK PRIDE in Cook Inlet, dated Feb. 2, 2006).
70 Id.
71 Appendix H at 5.
72 Id.
19
Yet another breakaway occurred in 2000 when the T/B Energizer, moored at Nikiski, “was struck
by a large pan of ice, parting mooring lines and the cargo transfer hose” and causing a 60-gallon
petroleum product spill and property damage.73 Finally, in 1999 a freight ship, the M/V Ocean
Laurel, “was struck by a large pan of ice, estimated to be ¾ mile in length” which “sheared off the
pier, parting 19 mooring lines, and struck the pier face.”74 These instances of large vessels coming
unmoored from facilities in proximity to the proposed location of the Nikiski Alternative’s Marine
Terminal illustrate the reality that ice and currents in Cook Inlet pose a serious threat to safe tanker
operations in Cook Inlet and will inevitably result in costly tanker delays.
In response the unmooring incidents described above, the Coast Guard has adopted special
procedures for operating in Cook Inlet during winter ice conditions. The Coast Guard’s guidelines
prohibit vessels from “forcing ice” and set out procedures for operating when ice is present in the
inlet. Some procedures include discontinuing all transfer operations, disconnecting transfer hoses,
positioning a designated vessel up current as an ice scout, and unmooring moored vessels, all of
which could impede the ability of tankers to moor and receive LNG for export.75
The State of Alaska has commissioned several studies examining the risks of operating
vessels in Cook Inlet that also provide useful insight into the nature of the risks implicated by the
Nikiski Alternative’s Marine Terminal site. For example, the 2015 Cook Inlet Risk Assessment
goes as far as recommending the construction of a small-diameter, 8-inch pipeline across Cook
Inlet from the Drift River Terminal to an existing refinery in Nikiski in order to avoid the risks
73 Id.
74 Id.
75 United States Coast Guard, Operating Guidelines for Ice Conditions in Cook Inlet
(Dec. 6, 2015).
20
associated with tanker traffic presently occurring in Cook Inlet.76 The assessment makes this
recommendation despite the fact that only approximately 38 one-way crude tanker transits per year
would be eliminated by the pipeline.77 The concern expressed in the Risk Assessment over
38 one-way tanker transits annually suggests that the additional 30 round-trip LNG tanker transits
per month that are required for the Nikiski Alternative would raise much greater concern.78
Another study, the 2006 Cook Inlet Vessel Traffic Study, describes Cook Inlet as “a water vexed
by: sudden, severe weather; strong tides, and large ice pans aggressively moved by strong tides in
the winter.”79 That study concluded “[s]evere environmental conditions (high winds, ice, strong
tide currents) coupled with human error in negotiating these conditions during vessel operations
pose the most likely root cause of the next major vessel casualty and oil spill.”80
Even FERC itself has previously determined that the Valdez Alternative’s site is more
favorable than the Nikiski Alternative’s site for four out of six objective Marine Terminal Criteria
(with the same favorability for the remaining two criteria).81 Specifically, the Valdez Alternative’s
site was found to better (1) minimize exposure to extreme oceanographic conditions, (2) minimize
distance from shore to a 60-feet [Mean Low Water Level] depth, (3) maximize suitability of tanker
maneuvering and anchorage area, and (4) minimize potential hazards to navigation.82
76 Appendix J at 3 (Cook Inlet Risk Assessment Final Report, Nuka Research and Planning
Group, LLC, dated Jan. 27, 2015).
77 Id.
78 Second Draft Resource Report 1 at 1-11.
79 Appendix H at 2.
80 Id. at 7.
81 Appendix A at 6.
82 Id.
21
BLM/COE’s analysis also concluded that the Valdez Alternative’s site is “favorable” for
purposes of minimizing “exposure to extreme oceanographic conditions” and “potential hazards
to navigation,” while the Nikiski Alternative’s site was “unfavorable” for both of those criteria.83
Regarding ice flows in Cook Inlet, the BLM/COE determined that “floating ice and icing
conditions can be severe problems”84 and concluded that “ice in Cook Inlet would be an inherent
winter hazard.”85 In addition, BLM/COE found that:
The presence of tidal extremes in excess of 30 feet vertical height and
accompanying currents reaching as high as 6 to 7 knots present major problems to
marine construction, facility design, and routine operations and would also
increase the potential for accidents. Extreme winter icing conditions would
increase the probability that operations would have to be curtailed at times and
would increase the potential for accidents.”86
The advantages of the Valdez Alternative’s site identified by FERC and BLM/COE directly
correlate to increased safety and decreased impacts on the environment.
The excessive maritime navigational hazards present in Cook Inlet also explain why
Valdez is the preferred location for the Marine Terminal based upon the expertise of marine pilots
with experience in navigating these waters.87 Marine pilots are specially licensed individuals,
independent of vessel crew, who are enlisted to navigate vessels in hazardous areas in and out of
port. Accordingly, marine pilots are uniquely situated to assess the comparative risks associated
with navigating Cook Inlet, and their preference for the Valdez Alternative warrants thorough
consideration. A survey of experienced Alaska marine pilots revealed a strong preference for
83 Appendix D at 8.
84 Id. at 6.
85 Id.
86 Id. at 12-13.
87 Appendix E to City of Valdez Scoping Comments, dated Dec. 4, 2015, Maritime Navigational
Risk Analysis of Shipping North Slope Liquefied Natural Gas (2012).
22
Valdez with over 60 percent of respondents stating that Cook Inlet should not even be considered,
over 80 percent stating that Nikiski poses risk, and only about 10 percent stating that Valdez poses
risk.88
In addition to posing substantial safety and environmental risks, the hazardous conditions
of Cook Inlet increase capital and operating costs and will inevitably result in shipping delays.
Thus, in order to comply with NEPA, the Project Applicants should conduct an objective analysis
of the risks associated with Cook Inlet, including analysis of the Valdez Alternative which entirely
avoids these risks.
D. The Valdez Alternative Avoids Several Environmentally Sensitive Areas.
The Project Applicant’s acknowledge that the Nikiski Alternative “requires crossing Cook
Inlet, including through Beluga Whale ESA [Critical Habitat Area 2], active faults, extensive
wetlands, and is in proximity to [Denali National Park and Preserve].”89 However, the comparative
analysis provided to date has failed to acknowledge that the Valdez Alternative avoids these and
other environmentally sensitive areas including Minto Flats Game Refuge, Susitna Flats Game
Refuge, Denali State Park, and several rivers and streams designated as Essential Fish Habitat
(“EFH”). Failing to consider these glaring environmental impacts when comparing project
alternatives is an abrogation of the duties imposed by NEPA and impedes the objective analysis
necessary to determine an impactful alternative. The environmentally sensitive areas impacted by
the Nikiski Alternative and the nature of those impacts are discussed below.
88 Id.
89 Second Draft Resource Report 10 at 10-73.
23
1. Cook Inlet Beluga Whale Critical Habitat.
The Nikiski Alternative’s preferred route requires construction of a 28.4-mile subsea
pipeline and Marine Terminal within Endangered Cook Inlet Beluga Whale Critical Habitat
(“Beluga Critical Habitat”) designated under the Endangered Species Act (“ESA”). The Marine
Terminal requires a trestle extending over 3000 feet from shore and a Material Offloading Facility
(“MOF”), both of which are located within Beluga Critical Habitat and require substantial
dredging and pile driving. Moreover, all of the alternative routes analyzed by the Project
Applicants for reaching the Nikiski Alternative’s site at Boulder Point travel through Beluga
Critical Habitat. The Nikiski Alternative poses obvious risks of impacts to Cook Inlet Beluga
Whales, and FERC guidelines state that analysis of alternatives that avoid impacts on endangered
species and critical habitat is particularly important.90 Accordingly, the Project Applicants must
thoroughly consider the scope of impacts posed by the Nikiski Alternative and alternatives such
as the Valdez Alternative that avoid such impacts.
In addition to analyzing alternatives that avoid impacts to endangered species and critical
habitat, NEPA also requires FERC to prepare its draft EIS concurrently with any studies required
by the ESA.91 Under the ESA, federal agencies are required to ensure that agency actions do not
“jeopardize the continued existence of any endangered species or threatened species or result in
the destruction or adverse modification of [critical] habitat.”92 “Destruction or adverse
modification” is defined as:
A direct or indirect alteration that appreciably diminishes the value of critical
habitat for the conservation of a listed species. Such alterations may include, but
are not limited to, those that alter the physical or biological features essential to the
90 Appendix B at 10.
91 16 U.S.C. § 1502.25.
92 16 U.S.C. § 1536(a)(1).
24
conservation of a species or that preclude or significantly delay development of
such features.93
Thus, the Nikiski Alternative may be precluded from permitting under the ESA for causing
“destruction or adverse modification” to Beluga Critical Habitat. Even if the Nikiski Alternative
is able to comply with the requirements of the ESA, it will likely face permitting delays, legal
challenges, and mitigation requirements that will increase project costs and could prevent timely
completion of the project.
(a) The Scope of Construction and Nature of Operations in Cook
Inlet Beluga Whale Critical Habitat Suggests Adverse Impacts
Are Likely.
The scope of work required for the Nikiski Alternative’s sub-sea pipeline and Marine
Terminal is alarming considering it will occur entirely within Beluga Critical Habitat. If the
Nikiski Alternative were constructed, the near-shore portion of the pipeline would extend 645 feet
into Cook Inlet from Boulder Point and 475 feet into Cook Inlet from Shorty Creek,94 and will be
buried from the shoreline using an open-cut method.95 In addition to the near-shore trench, the
Project Applicants also anticipate additional offshore, 6-foot-deep trenches of 3,200 feet for
Boulder Point and 10,000 feet for Shorty Creek to be constructed utilizing a dredge vessel.96 The
total amount of subsea dredging for this portion of the subsea pipeline is estimated to be between
250,000 and 470,000 cubic feet.97 After trenching, offshore installation of concrete-coated, 42-
93 50 C.F.R. § 402.02.
94 Second Draft Resource Report 1 at 1-165.
95 Second Draft Resource Report 2 at 2-122.
96 Second Draft Resource Report 1 at 1-165.
97 Id. at 1-166.
25
inch-diameter pipeline sections, weighing 33 tons each will begin.98 The Project Applicants have
described this process as follows:
During the second summer season, the pipeline would be laid across Cook Inlet
using conventional laybarge methods. All pipe joints would be welded on the
laybarge, which would be pulled along the ROW using anchors. The barge would
normally employ 12 anchors to keep it positioned as it is pulled ahead along the
ROW. It is anticipated that three anchor handling attendant tugs would be used to
constantly reposition the anchors and thereby maintain a proper anchoring spread.
Mid-line buoys may be used on the anchor chains when crossing other subsea
infrastructure (i.e., pipelines and cables).99
The ROW required for the subsea portion of the pipeline is 13,200 feet wide to accommodate the
pipelay barge and will affect over 44,343 acres during construction.100 Next, after completing the
pipeline shore approaches and pipe lay to the offshore tie-in point, the connection of these two free
pipe ends would be performed using an above-water tie-in, the now connected pipe will be returned
to the sea floor, surveys will be performed, and additional subsea free-span supports installed.
The massive construction effort required for the subsea pipeline alone is enough to warrant
serious consideration of project alternatives that avoid crossing Beluga Critical Habitat. However,
impacts associated with construction and operation of the Marine Terminal may result in impacts
that exceed even those associated with pipeline construction. The length of the trestle and loading
berths for the Marine Terminal are particularly concerning because they are permanent structures
on pilings located within the Beluga Critical Habitat. The trestle required by the Nikiski
Alternative would extend approximately 3,300 feet into Cook Inlet with trestle-support pilings
spaced at 120 feet.101 The trestle and loading berths alone will require approximately 320 pilings
98 Id. at 1-1xxiii.
99 Id. at 1-166.
100 Id. at 1-96, 1-99.
101 Id. at 1-12.
26
while additional pilings will also be required for the marine operations facility.102 During
construction of the Marine Terminal, approximately 800,000 cubic yards would be dredged
affecting 52 acres.103 Additional impacts to Beluga Critical Habitat are attributable to the MOF
adjacent to the trestle “that would be a dock used during Project construction to enable direct
deliveries of materials, equipment, modules, and other cargo”104 and to vessel traffic associated
with both construction and operation of the Marine Terminal. The material offloading facility will
require additional pile driving and approximately 940,000 cubic yards of dredging within Beluga
Critical Habitat.105 The Project Applicants have indicated that dredge material disposal will impact
approximately 1,200 acres and that an “unconfined aquatic disposal site is being evaluated for
disposition of the dredged material.”106 Together, the subsea pipeline, marine offloading facility,
and Marine Terminal are estimated to require as much as 1,410,000 cubic yards of dredging all
within Beluga Critical Habitat.107 Disposal of this dredge material within Cook Inlet would have
additional impacts to Cook Inlet Beluga Whales as a result of additional vessel traffic and
disturbances to the marine environment from disposal.
During construction, approximately 195 barge shipments are anticipated to deliver
materials for the Marine Terminal in addition to the vessel traffic required for the actual
construction of the pipeline, trestle, loading berths, and other facilities.108 In addition, barges
102 Appendix E to Second Draft Resource Report 1at E-15 – E-21.
103 Second Draft Resource Report 1 at 1-99.
104 Id. at 1-11.
105 Id. at 1-131, 1-99.
106 Id. at 1-99.
107 Id. at 1-131, 1-165.
108 Id. at 1-133.
27
tended by tugs will be required to transport dredge material from the MOF to the dredge disposal
in approximately 4,000 cubic yard increments which would equate to approximately 235 barge
trips from the MOF to the dredge disposal site.109 After construction, up to 30 LNG tankers would
berth and load at the Marine Terminal per month.110 To facilitate LNG tanker berthing, “[a] total
of five assist tugs are currently planned to support LNG operations, with four of the tugs used to
assist the LNG [carriers] during berthing operations.”111 The support tugs “would be ice class and
would assume the additional responsibilities of patrol/scouting, ice clearing, and ice breaking
during winter months.”112 Pipeline inspection and maintenance activities will also result in
additional vessel traffic and subsea disturbances during normal operations.113 Thus, substantial
vessel traffic associated with the Nikiski Alternative will persist as long as the AKLNG Project is
operational.
Even before the designation of Beluga Critical Habitat, BLM/COE found that constructing
an LNG pipeline across Cook Inlet “introduces a major construction activity into the marine
environment and subjects the project to an additional potential impact from accidents and pipeline
maintenance or repair.”114 In addition, BLM/COE noted that “[b]urial of the pipe crossing Cook
Inlet deeply enough to ensure it would not be exposed by scour or endangered by ships anchors
would be difficult” and that “[w]inter construction or repair would be practically impossible
109 Id. at 1-131, 1-132.
110 Id. at 1-11.
111 Id. at 1-177.
112 Id.
113 Second Draft Resource Report 3 at 3-368 (“Pipeline surveillance overflights for routine
pipeline inspections (estimated at 26 flights per year), monitoring, and maintenance, could result
in disturbance of marine mammals such as belugas, harbor seals, and harbor porpoises.”).
114 Appendix D at 12.
28
because of floating ice and the extreme tidal current.”115 BLM/COE even suggested that as a result
of these difficulties, two crossings might be necessary in order to ensure dependable operation
noting that “[t]he crossings would need to be widely separated so that in the event one fails flow
could be maintained by diverting gas to the other crossing.”116 BLM/COE concluded that “[a]ll
these factors make construction of the pipeline crossing and construction and maintenance of the
marine terminal more difficult and possibly make the entire systems more susceptible to accidents
during operations.”117 With BLM/COE’s previous analysis of the Cook Inlet crossing in mind, the
Project Applicants should analyze whether a single pipeline crossing adequately protects the
AKLNG Project from the risk of lengthy operational disruptions. Addressing BLM/COE’s
previously stated concerns regarding whether two subsea pipelines are required is necessary to
determine the full scope of the Nikiski Alternative’s impact on Beluga Critical Habitat.
The substantial impacts caused by construction and vessel traffic required for the Nikiski
Alternative are further exacerbated by the concentration of construction activity in the summer
months, conflicts with other user groups in Cook Inlet, and the probability that additional impacts
will occur as the result of the complexity of the construction and hazardous construction
environment. For example, offshore construction at the pipeline and the Marine Terminal may
only be conducted during “ice-free” working windows, which limits the ability of the contractors
to avoid impacts on Beluga Critical Habitat.118 Similarly, the Project Applicants have stated that
they intend to avoid conflicts with other waterway and near-shore users including commercial and
115 Id. at 13.
116 Id.
117 Id.
118 Second Draft Resource Report 1 at 1-112, 1-130.
29
recreational fishing operations,119 which will result in additional conflicts between minimizing
impacts to belugas and Beluga Critical Habitat and to other users. It also appears that the analysis
does not account for delays in the project caused by other vessel traffic, commercial fishing, beluga
whale movements, accidents, regulatory delays, spills, or other potential sources of delay, which
exacerbate impacts on Cook Inlet Beluga Whales by either increasing the concentration of work
or requiring additional time for completion.
The combination of impacts from mainline pipe construction across 28.4 miles of Cook
Inlet, Marine Terminal construction, and vessel traffic associated with construction and operation
poses the greatest threat to Cook Inlet Beluga Whale critical habitat since the habitat has been
designated. Even the Project Applicants acknowledge that “Beluga Critical Habitat could be
impacted by Project activities”120 and that “[o]peration of the construction and pipelay equipment
would generate sound with frequencies within the beluga hearing range and at levels above
threshold values . . . and may result in temporary displacement of belugas.”121
(b) The Nikiski Alternative Implicates Nearly Every Source of
Adverse Impacts Identified in the National Marine Fisheries
Service (“NMFS”) Recovery Plan for Cook Inlet Beluga Whales.
The NMFS Recovery Plan for the Cook Inlet Beluga Whale identifies several sources of
adverse impacts to Cook Inlet Beluga Whales and their habitat and notes that “a lack of
understanding of distribution, migration, and behavior patterns of prey inhibits potential mitigation
measures and argues for a more precautionary approach to maximize opportunity for CI beluga
recovery.”122 The Project Applicant’s failure to thoroughly analyze alternatives that avoid impacts
119 Id. at 1-112.
120 Appendix H to Second Draft Resource Report 3 at 64.
121 Id. at 65.
122 Id. at 9.
30
to Cook Inlet Beluga Whales is particularly disconcerting considering construction and operation
of the Nikiski Alternative implicates nearly every source of adverse impacts identified in the
NMFS Recovery Plan.123 Construction activities are known to disturb and modify the habitat of
belugas and beluga prey impacting a beluga’s ability to feed.124 Moreover, a “construction and
operation of new physical structures (e.g., bridges, docks, dams, etc.) and increased numbers of
vessels in CI beluga habitat can potentially affect the distribution, migration, or behavior of CI
belugas and their prey.”125 Accordingly, the large-scale construction required for the offshore
portion of the pipeline, the LNG Facility, and the Marine Terminal at the Nikiski Alternative’s site
is likely to negatively impact Cook Inlet Beluga Whales.
The construction and operation activities required for the Nikiski Alternative will cause
anthropogenic noise known to impact belugas, including noise from the following sources
identified by NMFS:
1. Tug boat noise: propeller cavitation (the formation of bubbles in a liquid) and engine
noise including azimuth/bow thruster noise;
2. Cargo/tanker noise: propeller cavitation and engine noise including bow thruster
noise;
3. Small vessel noise: outboard and inboard engine noise and propeller cavitation;
4. Dredging: suction and/or grabbing operations;
5. Pile driving noise: hammering or vibratory noise (rotatory or oscillatory to a lesser
extent);
6. Shore construction noise: other than pile driving;
7. Depth sounders: from vessels;
8. Research related noise: sonars such as acoustic Doppler current profilers and dual
frequency imaging sonars, scientific echo sounders and other active transducers, boat
transit for photo-identification surveys, and instrument deployment/retrievals, etc.;
and
123 Appendix K (Recovery Plan for the Cook Inlet Beluga Whale, NMFS, dated Dec. 27, 2016).
124 Id. at 8.
125 Id. at 9.
31
9. Pipe and cable laying operations.126
Impacts associated with these sources of anthropogenic noise are not limited to the construction
period. Rather, many of these sources known to disturb Cook Inlet Beluga Whales will persist for
the duration of the AKLNG Project’s operation.
(c) The Valdez Alternative’s Avoidance of Harmful Impacts to
Cook Inlet Beluga Whales Support its Thorough Consideration.
The Nikiski Alternative poses substantial risks of impacts to Cook Inlet Beluga Whales as
a result of the construction, maintenance, and operation of the 28.4-mile section of subsea pipeline
and Marine Terminal within Beluga Critical Habitat. Many of the anticipated impacts associated
with construction and operation of the Nikiski Alternative have been expressly identified by NMFS
as posing a threat to Cook Inlet Beluga Whales. Thus, it is likely that the Nikiski Alternative will
experience substantial mitigation costs, legal challenges, or the inability to obtain federal permits
necessary for construction of the route. The Nikiski Alternative’s high risk of substantial impacts
on Cook Inlet Beluga Whales weighs heavily against deviating from the previously approved
Valdez Alternative, which entirely avoids all such impacts.
2. Minto Flats State Game Refuge.
The Minto Flats State Game Refuge is located approximately 35 miles west of Fairbanks,
Alaska, and encompasses 500,000 acres of wetland in Interior Alaska.127 The refuge was
established by the Alaska Legislature in 1988 “to ensure the protection and enhancement of habitat,
the conservation of fish and wildlife, and to guarantee the continuation of hunting, fishing,
126 Id. at 6.
127 Appendix L at 2 (Minto Flats State Game Refuge Management Plan, ADFG, dated
March 1992).
32
trapping, and other compatible public uses.”128 The refuge is a vital area for harvesting fish,
wildlife, and other resources for Athabascan Indians and others living in the vicinity.129
The refuge contains some of the highest quality waterfowl habitats in Alaska and sustains
the largest trumpeter swan breeding population in North America.130 It is also an important spring
and fall waterfowl staging area, particularly for geese and swans.131 More than 150,000 ducks nest
in Minto Flats annually.132 In addition to waterfowl, the refuge also provides excellent habitat for
big game and furbearers133 including Wood Bison which are present in Minto Flats year-round and
are listed as threatened under the ESA.134 The Minto Flats Game Refuge Management Plan sets
out goals that guide all management decisions for the refuge. These goals include:
1) Minimizing harmful disturbance to fish and wildlife;
2) Maintaining, protecting, and enhancing the quality and quantity of habitat for
historically occurring resident and migratory wildlife and fish habitat; and
3) Maintaining, protecting and enhancing water quality, water quantity, and
circulation patterns necessary for the growth and propagation of fish and
wildlife.135
128 Id.
129 Id.
130 Id. at 6; Appendix M (Alaska Department of Fish and Game, Minto Flats State Game Refuge,
Fish and Wildlife, http://www.adfg.alaska.gov/index.cfm?adfg=mintoflats.species (last visited
Dec. 20, 2016)).
131 Id.
132 Id.
133 First Draft Resource Report 3 at 3-154.
134 Second Draft Resource Report 3 at 3-387.
135 Appendix L at 4.
33
The Nikiski Alternative will traverse 37.7 miles136 of the refuge and requires four new access roads
totaling over 30,000 feet in length.137 Accordingly, the Nikiski Alternative does not advance the
management goals for the refuge and will negatively impact this sensitive environment during
construction and also cause long-term disturbances as a result of increased access to the area by
recreational users and pipeline maintenance activities.
Although pipeline construction is not entirely precluded in the refuge, the project applicant
“must demonstrate that there is a significant public need for the corridor that cannot be reasonably
met off-refuge.”138 Because the Valdez Alternative entirely avoids the refuge and satisfies the
underlying purpose and need of the AKLNG Project, the public need for crossing the refuge can
be reasonably met off refuge. Thus, construction of the Nikiski Alternative across the Minto Flats
Game Refuge may be precluded entirely. Even if the AKLNG Project obtains the necessary
permits for the Nikiski Alternative to cross Minto Flats, construction therein will require
substantial mitigation and will likely result in permitting delays or litigation.
3. Susitna Flats Game Refuge.
The Susitna Flats Game Refuge encompasses approximately 300,800 acres located
between Beluga River and Point MacKenzie, and “was created to ensure the protection of fish and
wildlife populations, particularly waterfowl nesting, feeding, and migration; moose calving areas;
spring and fall bear feeding areas; and salmon spawning and rearing habitats.”139 As the Project
Applicants have acknowledged, “as many as 100,000 waterfowl use the refuge as a staging area in
136 Second Draft Resource Report 3 at 3-280.
137 Id. at 3-345; Appendix F to Second Draft Resource Report 1 at Table 1.
138 Appendix L at 5.
139 Appendix N at 2 (Susitna Flats State Game Refuge Management Plan, ADFG, dated
March 1988).
34
the spring. Several thousand lesser sandhill cranes and up to 8,000 swans use the Refuge for
migrating and nesting.”140 The refuge also provides prime habitat for beaver, mink, otter, muskrat,
coyote, and wolf populations among others.141 Activities that occur in the refuge must:[B]e consistent with the following goals in accordance with the purposes for which
the refuge is established. . .
1. Manage the refuge for the protection, preservation, and enhancement of
fish and wildlife habitat and populations.
2. Manage the refuge to protect, maintain, and enhance public use of fish
and wildlife and their habitat and general recreation in a high quality
environment.142
The Nikiski Alternative crosses 14.8 miles of Alaska Department of Fish and Game
(“ADF&G”) managed Susitna Flats Game Refuge143 and will require construction of five new or
improved access roads totaling over 84,000 feet.144 Any construction work in the Susitna Flats
Game Refuge requires a special-use permit and new utilities are allowed to cross the refuge only
“where no feasible off-refuge alternative exists, using existing corridors wherever possible,
consistent with refuge goals and objectives.”145 In the present case, adoption of the Valdez
Alternative would entirely avoid any impacts caused by the Nikiski Alternative to the sensitive
wetland area encompassed by the refuge. Even if the AKLNG Project is granted permits to
traverse the refuge, mitigation measures and potential litigation will likely increase costs and delay
construction.
140 Second Draft Resource Report 3 at 3-246.
141 Appendix N at 4.
142 Id. at 3.
143 Second Draft Resource Report 3 at 3-280.
144 Id. at 3-344, 346-347; Appendix F to Second Draft Resource Report 1 at Table 1.
145 Second Draft Resource Report 8 at 8-72.
35
4. Denali State Park and Denali National Park.
Denali State Park is a 325,240-acre area located near the base of Denali, the tallest
mountain in North America.146 Denali State Park recreation area affords tremendous views of
Denali; contains three major rivers, the Susitna, Chulitna, and Tokositna; and has three glaciers
adjacent to or within its boundaries, the Ruth, Eldridge and Tokositna.147 Denali State Park must
be managed in a manner to “protect the natural and cultural resources of the park and ensure that
the park’s resources are maintained to allow for the public’s experience and understanding of the
unique natural features that are found in this part of Alaska.”148 In order to protect the natural
resources found in Denali State Park, the management plan developed for the park states that nonrecreation
activities should be located outside the park,149 development should be kept out of sight,
facilities should be designed to blend rather than contrast with the natural landscape, and the scale
of facilities should be kept small.150
The Nikiski Alternative crosses approximately 38 miles of Denali State Park affecting
approximately 750 acres.151 In addition, the Nikiski Alternative also includes plans to construct
32 new access roads totaling over 35,000 feet152 and 13 material sites within the boundaries of the
park.153 Large scale construction, such as that required for the Nikiski Alternative, is not
146 Id. at 8-98.
147 Appendix O at 5 (Denali State Park Management Plan, Alaska Department of Natural
Resources, dated 2006).
148 Id. at 6.
149 Id. at 7.
150 Id.
151 Second Draft Resource Report 8 at 8-143.
152 Appendix F to Second Draft Resource Report 1 at Table 1.
153 Second Draft Resource Report 3 at 3-345.
36
compatible with the management goals and objectives for the park. Moreover, the Denali State
Park Management Plan provides that pipelines may only cross park lands by permit and when no
other viable alternatives are available.154 In the present case, a viable alternative exists in the
Valdez Alternative, which entirely avoids Denali State Park. Thus, the Nikiski Alternative may
be precluded from traversing Denali State Park altogether.
The portion of Denali State Park affected by the Nikiski Alternative is also qualified as
section 6(f) property under the Land and Water Conservation Fund (“LWCF”) Act.155 The LWCF
Act requires that “[n]o property acquired or developed with assistance under this section shall,
without the approval of the Secretary, be converted to other than public outdoor recreation use.”156
The Project Applicants’ analysis of Denali State Park erroneously suggests that Senate Bill 70’s
removal of the “special use site” status of specific lands to allow a natural gas pipeline through
Denali State Park, somehow affects the LWCF Act restrictions on the use of the land.157 Nothing
in Senate Bill 70 affects the status of Denali State Park’s 6(f) land status under the LCWF Act.
Accordingly, approval of the lands for a pipeline right-of-way requires approval from the Secretary
of the Interior.
154 Appendix O at 8.
155 First Draft Resource Report 8 at 8-44; 54 U.S.C.A. § 200305.
156 54 U.S.C.A. § 200305.
157 Second Draft Resource Report 8 at 8-99 (“Denali State Park is considered a 6(f) property under
the LWCF Act (16 USC § 4601). Section 6(f) of the LWCF Act requires that no property acquired
or developed with LWCF assistance should be converted to a use other than public outdoor
recreational uses without the prior approval of the Secretary of the Interior. However, Alaska
Senate Bill 70 (AK SB70) (Alaska State Legislature, 2015) passed on May 15, 2015, provides
exceptions from designation as a special purpose site for portions of Denali State Park to allow for
ROW leasing associated with natural gas pipelines.”).
37
Not only would the Nikiski Alternative result in negative impacts to Denali State Park
during construction, but the visual impacts and impacts caused by increased ease of access to
otherwise pristine lands will remain indefinitely. Visual impacts will also affect Denali National
Park despite the fact that the Nikiski Alternative, as presently proposed, does not traverse Denali
National Park. A pipeline right-of-way and attendant access roads and other facilities within view
of Denali National Park is detrimental to the wilderness character of the park and will negatively
impact the tourism industry associated with the park.158 Impacts to tourism in the Denali Borough
would be highly detrimental considering “the tourism industry makes up the largest portion of total
employment in the Denali Borough, at about 40 percent of all jobs.”159
The impacts on Denali State Park and Denali National Park attendant to the Nikiski
Alternative militate against deviating from the previously appoved Valdez Alternative, which
entirely avoids such impacts. Moreover, numerous agency and citizen comments expressing
concern over impacts associated with the segment of the Nikiski Alternative traveling through
Denali State Park support a thorough review of the Valdez Alternative.
5. Essential Fish Habitat.
The Nikiski Alternative, south of Livengood, will cross approximately 32 rivers and
streams designated by the National Oceanic and Atmospheric Administration (“NOAA”) as EFH,
all of which contain salmon populations.160 EFH is defined in the Magnuson-Stevens Act as “those
waters and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity.”161
One stated purpose of the Magnuson-Stevens Act is “to promote the protection of essential fish
158 See Second Draft Resource Report 5 at 5-xxv.
159 Id. at 5-52.
160 First Draft Resource Report 3 at 3-34.
161 16 U.S.C. § 1802.
38
habitat in the review of projects conducted under Federal permits, licenses, or other authorities that
affect or have the potential to affect such habitat.”162 Accordingly, the Magnuson-Stevens Act
supports selection of project alternatives that minimize impacts to EFH.
Although, the Project Applicants have not yet provided sufficient data to compare the
impacts to EFH caused by the Valdez Alternative to those caused by the Nikiski Alternative, a
review of EFH maps for Alaska reveals a far greater amount of EFH rivers and streams located
along the Nikiski Alternative than along the Valdez Alternative.163 Anecdotally, it is apparent that
the Nikiski Alternative crosses far more well-known salmon rivers and streams including the
following major crossings: Beluga, Theodor, Lewis, Ivan, Yentna, Deshka, Chulitna, Tanana, and
Nenana (four crossings). Of these, one crossing of the Nenana, the Yentna crossing, and the
Beluga crossing are planned to be open-cut crossings whereby the river bed is actually
excavated.164 In addition to these major crossings, other well-known fisheries and spawning
grounds are also impacted, such as Byers Creek, Honolulu Creek, Troublesome Creek, East Fork
Chulitna River, and Alexander Creek. An objective comparison of the impacts of the Valdez
Alternative and the Nikiski Alterative with regard to EFH will reveal the far greater impacts
associated with the Nikiski Alternative.
E. The Valdez Alternative Better Advances Concepts of Environmental Justice
Environmental justice refers to the “fair treatment and meaningful involvement of all
people regardless of race, color, national origin, or income with respect to the development,
162 16 U.S.C. § 1801.
163 See Appendix P (Fisheries Management Plan for the Salmon Fisheries in the EEZ off Alaska,
NMFS, dated June 2012).
164 Second Draft Resource Report 2 at 2-106.
39
implementation, and enforcement of environmental laws, regulations, and policies”165 FERC is
required to address any “disproportionately high and adverse health or environmental effects of
their programs, policies, and activities on minority populations and low-income populations.”166
The substantially reduced adverse impacts of the Valdez Alternative as compared with the Nikiski
Alternative suggest that the Valdez Alternative will have lesser impacts on minority and lowincome
populations. For example, by avoiding impacts on traditional subsistence hunting and
fishing areas such as Minto Flats, the Valdez Alternative will avoid any disproportionate impacts
on native populations who rely on such resources for their livelihood. Moreover, the Nikiski
Alternative deprives minority and low-income residents of the Fairbanks area access to low-cost
natural gas, which would provide relief from health impacts caused by the extremely poor air
quality there. The Project Applicants have failed to provide sufficient data related to the relative
environmental justice impacts associated with the Valdez Alternative and Nikiski Alternative,
thereby depriving stakeholders and FERC itself the ability to meaningfully compare the impacts
of each alternative.
IV. THE PROJECT APPLICANT’S ANALYSIS OF THE VALDEZ
ALTERNATIVE FAILS TO SATISFY NEPA
Despite the clear guidelines mandating objective comparison of reasonable alternatives,
the Project Applicants have provided a de minimis analysis of the Valdez Alternative consisting of
approximately five pages.167 In light of FERC’s previous decisions concluding that the Valdez
Alternative is superior to alternatives substantially similar to the Nikiski Alternative, the Project
Applicant’s justification for deviating from the thoroughly studied and traditionally preferred
165 Second Draft Resource Report 8 at 8-219.
166 Id.
167 Second Draft Resource Report 10 at 10-92 – 10-95; 10-136 – 10-137.
40
alternative is inadequate and inexplicable.168 Rather than focus on purported disadvantages of the
Valdez Alternative, the Project Applicants should be obligated to show, by objective comparison,
why deviating from the Valdez Alternative is appropriate.
The primary purpose of NEPA is to “present the environmental impacts of the proposal
and the alternatives in comparative form, thus sharply defining the issues and providing a clear
basis for choice among options.”169 Presently, the dearth of data and analysis provided regarding
the Valdez Alternative serves to cloud the issues rather than sharply define them. Moreover,
focusing on the Valdez Alternative’s purported disadvantages to the exclusion of its advantages
does not provide sufficient justification for deviating from the previously approved and historically
preferred Valdez Alternative.170 In light of the Valdez Alternative’s history of approval by FERC
and BLM/COE and its clear environmental advantages, a detailed analysis of the Valdez
Alternative is required to satisfy the requirements of NEPA. Having addressed the Valdez
Alternative’s numerous comparative advantages, these comments will now address the Project
Applicant’s stated reasons for eliminating the Valdez Alternative from detailed consideration.
The Project Applicants cite the following purported disadvantages of the Valdez
Alternative as support for failing to provide a detailed comparative analysis:
1. the prohibitive costs to develop the site,
2. the risks of constraints during operations in the Valdez Narrows,
3. the schedule risk of permitting a pipeline through two Wild and Scenic Rivers,
4. the technical/logistical impracticalities of laying a 42-inch pipeline through the steep
grade of Thompson Pass and the narrow work areas of Keystone Canyon,
5. permitting issues associated with traversing the Chugach National Forest,
6. significant challenges associated with air permitting, and
168 Appendix A at 7-10.
169 40 C.F.R. § 1502.14.
170 Second Draft Resource Report 10 at 10-93.
41
7. additional impacts to wetlands and anadromous fish streams.171
Each of the above-listed reasons for choosing to deviate from the Valdez Alternative and eliminate
it from consideration are unconvincing when viewed in light of the greater overall negative impacts
of the Nikiski Alternative. Moreover, the analysis of these purported disadvantages, contained in
the draft resource reports, lacks sufficient factual support for the assertions made therein. The
specific shortcomings associated with the reasons cited for eliminating the Valdez Alternative
from thorough review are addressed in turn below.
A. The Cost to Develop the Valdez Alternative’s Site.
According to the Project Applicants, excavation costs for 39 million cubic yards of
excavation is the primary reason development of the Valdez Alternative’s site at Anderson Bay is
prohibitively costly.172 However, previous FERC-adopted estimates regarding the amount of
excavated material at the site placed the amount at approximately 9.7 million cubic yards173 for an
LNG plant and marine terminal with the same capabilities as that proposed by AKLNG.174 The
Project Applicants have not provided any evidence supporting the excavation estimate used in the
analysis even though it is four times larger than previous, well-supported estimates adopted by
171 Id. at 10-92.
172 Second Draft Resource Report 10 at 10-92 (“during the feasibility study for this Project, it was
estimated approximately 39 million cubic yards of overburden and rock would be removed.”).
173 Appendix A at 5.
174 Id. at 4 (“The Yukon Pacific LNG facility would receive and liquefy 2.1 billion cubic feet per
day of conditioned natural gas delivered by pipeline from Prudhoe Bay. . . . Major facilities in the
plant would include four LNG process trains consisting of gas pretreatment and liquefaction, four
800,000-barrel aboveground LNG storage tanks, and a marine facility to load two tankers of
125,000 cubic meters capacity within a 12-hour period.”); Second Draft Resource Report 1 at 1-9 ‒
1-11 (The Project Applicant’s proposed LNG Plant includes 2 LNG storage tanks each capable of
storing 240,000 cubic meters or approximately 3 million barrels total; “loading and circulating
piping, from the LNG storage tanks to the loading arm would transfer approximately 12,500 cubic
meters of LNG per hour;” “the Liquefaction Facility would be designed to process an average
stream day rate of 2.7 billion standard cubic feet per day.”).
42
FERC itself. The excavation estimate presently included in the analysis far exceeds the 15 million
cubic yards of actual excavation required for the TAPS terminal,175 which occupies approximately
1,000 acres,176 the same amount estimated to be required for the AKLNG Project,177 and was
constructed on terrain substantially similar to that at Anderson Bay, where the Valdez Alternative’s
site would be located. Moreover, as noted in previous FERC-generated EIS “the selection of
Anderson Bay as the preferred terminal location was the culmination of a series of studies spanning
more than 15 years.”178
The Project Applicants’ comparative analysis does not contain any cost studies and does
not acknowledge that any excess excavation costs associated with the Valdez Alternative’s site
would likely be offset by cost savings attributable to (1) utilizing existing infrastructure,
(2) avoiding unnecessary Greenfield construction,179 including the 28.4-mile subsea section of the
pipeline, and (3) requiring substantially less dredging and construction for the Valdez Alternative’s
smaller Marine Terminal trestle. By focusing on one purported disadvantage of the Valdez
Alternative, while failing to acknowledge its project-wide advantages over the Nikiski Alternative,
175 BP Pipelines (Alaska) Inc. v. Alaska, 2011 WL 11549442 at *51 (Alaska Super.) (“Mr. Lloyd
testified about the excavation work when the VMT was originally constructed. He explained that
‘the amount of material excavated in the Terminal had escalated from a planned 4 million cubic
yards to approximately 15 million cubic yards.’ . . . Overall, this Court was persuaded that Pro
Plus’s estimated 10 million cubic yards of excavation is reasonable.”).
176 Appendix Q (Alyeska Pipeline, Valdez Marine Terminal http://www.alyeskapipe.
com/TAPS/ValdezTerminalAndTankers (last visited Dec. 20, 2016)).
177 Second Draft Resource Report 1 at 1-6 (“The proposed Liquefaction Facility would be
approximately 921 acres (901 acres onshore and 20 acres offshore).”).
178 Appendix A at 2-43.
179 Second Draft Resource Report 10 at 10-134 (Greenfield is defined by the Project Applicants
as when the “[m]ainline is located at least 1 mile (from the centerline) from existing ROWs.
Existing infrastructure may consist of pipelines, major roads, railroads, and
underground/aboveground utilities that are 2.5 miles or greater in length.”).
43
the analysis presented by the Project Applicants does not reflect the type of objectivity required
by NEPA. As evidenced by construction of the Valdez Marine Terminal and previous studies
determining that the Valdez Alternative’s site is viable and preferred, perceived challenges
associated with construction at Anderson Bay are not an adequate justification for selecting the
previously disavowed Nikiski Alternative.
B. Tanker Operations in Valdez Narrows.
In Second Draft Resource Report 10, risks and constraints associated with operating in the
Valdez Narrows is cited as a reason for eliminating the Valdez Alternative from consideration.180
By all objective measures, the Valdez Alternative’s Marine Terminal site provides a far more
suitable environment for tanker operations than the Nikiski Alternative’s Marine Terminal site.
The Valdez Alternative provides for ice-free conditions year-round and relatively minor tides.
Conversely, the Nikiski Alternative’s site in Cook Inlet has seasonal ice flows and extreme tidal
floods that pose hazards to tanker operations. In fact, Cook Inlet has the largest tidal range in the
United States at over 40 feet.181 FERC has previously recognized that the Valdez Alternative’s
site is more favorable than the Nikiski Alternative’s site because it minimized exposure to extreme
oceanographic conditions, such as those experienced in Cook Inlet, maximized suitability of tanker
maneuvering and anchorage area, and minimized potential hazards to navigation.182
The Project Applicant’sanalysis regarding the Valdez Narrows also ignores the fact that in
1995, when substantially higher oil tanker traffic was occurring in the Valdez Narrows, FERC
found that anticipated oil and LNG tanker traffic in the Valdez Narrows would be “well within the
180 Id. at 10-92.
181 Appendix R (National Ocean and Atmospheric Administration, Ocean Facts, Where is the
highest tide? http://oceanservice.noaa.gov/facts/highesttide.html (last visited Dec. 20, 2016)).
182 Appendix A at 8.
44
limitations of the [Vessel Traffic System],” which is one of only twelve such systems operating in
the United States, and would not exceed the previous peak traffic associated with oil tankers
alone.183 FERC also concluded that “the modest increased tanker traffic in Prince William Sound
would not significantly increase the potential for a collision between an outbound crude oil tanker
and any inbound tanker, either LNG or another crude oil tanker.”184
The marine pilot study,185 Cook Inlet Vessel Traffic Study,186 Cook Inlet Risk
Assessment,187 and other sources described in section III.C of these comments also provide strong
evidence regarding the comparatively high risk of operating tankers in Cook Inlet as opposed to
Prince William Sound near Valdez. In light of the readily available evidence that Cook Inlet poses
far greater challenges to tanker operations than does the Valdez Narrows, reliance on navigational
concerns relating to the Valdez Narrows as justification for deviating from the traditionally
preferred Valdez Alternative is not appropriate. Additional analysis of the difficulties Cook Inlet
presents for tanker operations is included in the comparative advantages section of these comments
supra in section III.C.
C. Proximity of the Valdez Alternative to Wild and Scenic Rivers.
The Valdez Alternative requires construction adjacent to the Delta River and across the
Gulkana River within areas designated for protection under the Wild and Scenic Rivers Act
183 Id. at 15.
184 Id. at 15.
185 Appendix E to City of Valdez Scoping Comments, dated Dec. 4, 2015, Maritime Navigational
Risk Analysis of Shipping North Slope Liquefied Natural Gas (2012).
186 Appendix H.
187 Appendix J.
45
(“WSRA”) and administered by the Bureau of Land Management (“BLM”).188 The WSRA
prohibits FERC from (1) licensing “the construction of any dam, water conduit, reservoir,
powerhouse, transmission line, or other project works under the Federal Power Act . . . on or
directly affecting any [Wild and Scenic River]” and (2) assisting “by loan, grant, license, or
otherwise in the construction of any water resources project that would have a direct and adverse
effect on the values for which such river was established.”189 First, as a natural gas pipeline
licensed under the Natural Gas Act, the WSRA’s prohibition against granting licenses for Federal
Power Act projects does not apply to the AKLNG Project. Second, the elements of the Valdez
Alternative occurring within the Delta and Gulkana Wild and Scenic River corridors do not qualify
as “water resources projects” because they would not impact the free-flowing characteristics of the
respective rivers.190 Accordingly, the assertion in Second Draft Resource Report 10 that the
WSRA “is an exclusion factor with the routing of the delivery option for the Anderson Bay facility
site”191 is erroneous.
Management of Wild and Scenic River systems is intended “to protect and enhance the
values which caused it to be included in said system without . . . limiting other uses that do not
188 Second Draft Resource Report 10 at 10-93 (“Two rivers, one crossed and one paralleled (the
pipeline would need to be within and also cross this river), have since been designated as Wild and
Scenic Rivers by the National Park Service (NPS). The Gulkana River, crossed by a Valdez
delivery option, and the Delta River, paralleled by a Valdez delivery option, would have to be
avoided or require NPS/Congressional/Presidential approval to cross it. For both rivers, there are
no feasible options to avoiding the river (note: even a trenchless or aerial crossing still requires an
easement across the National Park designation, and the NPS is not authorized by Congress to issue
an easement without Congressional and Presidential approval).”
189 16 U.S.C. § 1278(a).
190 Sierra Club N. Star Chapter v. Pena, 1 F. Supp. 2d 971, 978 (D. Minn. 1998) (“a water resource
project can best be defined as any type of construction which would result in any change in the
free-flowing characteristics of a particular river”).
191 Second Draft Resource Report 10 at 10-93.
46
substantially interfere with public use and enjoyment of these values.”192 In recognition of the
importance of balancing development and protection of resources, the WSRA permits pipeline
construction where mitigation measures allow protection of the river’s “esthetic, scenic, historic,
archaeological, and scientific features.”193 In the present case, the River Management Plans for
the Gulkana and Delta Wild and Scenic Rivers provide guidance regarding the special features of
each river and how construction of pipelines may affect those features. The Delta River Wild and
Scenic River Management Plan acknowledges that additional pipelines may be built within the
TAPS utility corridor, stating that “construction of a liquid natural gas pipeline through this utility
corridor has been proposed” and “the purpose of the utility corridor is to serve as a route for
pipelines, power transmission lines and other utility lines.”194 Moreover, both the Gulkana River
Management Plan and the Delta River Management Plan state that new pipelines and electrical
lines may be permitted across the respective Wild and Scenic River corridors if the conditions of
Section 1105 of the Alaska National Interest Lands Conservation Act (“ANILCA”) and Section
13 of the WSRA are met.195
The Valdez Alternative would have minimal impacts on the esthetic, scenic, historic,
archaeological, and scientific features of Wild and Scenic River corridors for the Delta and the
Gulkana Rivers. First, the portions of the Valdez Alternative that traverse the Delta and Gulkana
Wild and Scenic River corridors would be constructed within the existing TAPS utility corridor.
Accordingly, additional impacts associated with construction of a buried gas line therein will be
192 16 U.S.C. § 1281(a).
193 16 U.S.C. § 1281(a).
194 Appendix S at 2 (River Management Plan for the Delta National Wild and Scenic River, U.S.
Department of the Interior, dated Oct. 7, 1983)
195 Id.; Appendix T at 2 (River Management Plan for the Gulkana River, U.S. Department of the
Interior, dated Aug. 2006).
47
marginal compared to the existing TAPS mainline, which is above ground. Second, although the
Valdez Alternative does run adjacent to the Delta River within the Wild and Scenic River corridor,
it does not actually cross the Delta River. Because the Valdez Alternative does not require a
crossing of the Delta River, the impacts to the Wild and Scenic River corridor are limited to those
associated with the buried mainline. Third, the Valdez Alternative only traverses approximately
one mile of the Gulkana Wild and Scenic River corridor and may be designed to cross underneath
the Gulkana utilizing horizontal directional drilling. In comparison to the existing TAPS crossing
of the Gulkana, which is elevated above the river, the Valdez Alternative’s subterranean crossing
would have a minimal impact. Thus, with sufficient mitigation, the Valdez Alternative could
readily satisfy the requirements of the WSRA and ANILCA for the Delta and Gulkana Wild and
Scenic River corridors.
The Valdez Alternative’s additional permitting requirements associated with the WSRA
are not a sufficient reason to eliminate the Valdez Alternative from thorough consideration,
particularly in light of the fact that the portions of the Valdez Alternative traversing Wild and
Scenic River corridors would be constructed within the TAPS utility corridor, which BLM
recognizes as land with a primary purpose of energy transportation.196 Routing decisions for the
AKLNG Project should be based upon analysis of project-wide impacts, not upon the relatively
minor challenges associated with construction in Wild and Scenic River corridors. For example,
while the Valdez Alternative would cross approximately one mile of Wild and Scenic River
corridor not expressly designated for energy transportation, the Nikiski Alternative crosses
approximately 28.4 miles of critical habitat for the endangered Cook Inlet Beluga Whale.
196 Appendix U at 2 (Utility Corridor Resource Management Plan/Environmental Impact
Statement Record of Decision, BLM, dated Jan. 11, 1991) (“the primary management direction
and use of BLM-administered lands in the Utility Corridor is for energy transportation.”).
48
D. Challenges Associated with Thompson Pass and Keystone Canyon.
The Project Applicants also cite challenges associated with laying pipe over Thompson
Pass and Keystone Canyon as a reason why the Valdez Alternative should be eliminated from
detailed comparative analysis in the EIS. However, previously accepted EISs have identified a
suitable route and construction techniques to successfully cross this stretch of terrain.197 Moreover,
a major highway and TAPS have already been built through the pass and provide useful baseline
information regarding construction techniques and conditions in the area.
The Project Applicants should analyze the perceived difficulties associated with Thompson
Pass and Keystone Canyon in the context of the project-wide impacts of each alternative. For
example, while Thompson Pass and Keystone Canyon may pose some difficulty for construction
of the Valdez Alternative, the Nikiski Alternative requires substantially more river crossings and
a 28.4-mile section of subsea pipeline. On a project wide basis the Valdez Alternative has been
repeatedly determined to be viable and less impactful than the Nikiski Alternative. Accordingly,
“the technical/logistical impracticalities of laying a 42-inch pipeline through the steep grade of
Thompson Pass and the narrow work areas of Keystone Canyon” is an insufficient justification for
abandoning the Valdez Alternative in favor of the Nikiski Alternative.
E. Issues Associated With Traversing the Chugach National Forest.
The Project Applicants have asserted that the location of the Valdez Alternative’s site
within the Chugach National Forest is another reason why a thorough analysis of the Valdez
Alternative is not required. Again, absent an objective comparison on project-wide impacts to
state and national park lands, which has yet to be completed, it is impossible to accurately
determine which alternative minimizes such impacts. Anecdotally, it is apparent that the Valdez
197 See Appendix D at 11.
49
Alternative’s impact on Chugach National Forest land is relatively minor, consisting of only a few
miles of pipeline and the LNG Facility. Moreover, the TAPS utility corridor, which the Valdez
Alternative follows, already traverses Chugach National Forest thereby minimizing the impact of
additional pipeline construction within that corridor. The small impact to National Forest lands
adjacent to the existing TAPS marine terminal appears to be outweighed by impacts posed by the
Nikiski Alternative, which requires substantially more Greenfield construction in locations such
as the Minto Flats Game Refuge, Denali State Park, Susitna Flats Game Refuge, and within critical
habitat for the Cook Inlet Beluga Whale.
F. Air Permitting Issues.
Potential air quality permitting issues associated with the Valdez Alternative’s LNG
Facility and Marine Terminal site at Anderson Bay are also cited as a reason for failing to
thoroughly analyze the Valdez Alternative. However, the analysis provided to date does not
contain data from any studies conducted at the actual site despite the fact that such studies have
previously been completed. For example, the FERC-completed EIS for the Yukon Pacific LNG
Project includes ambient air quality studies of the Valdez Alternative’s site at Anderson Bay and
concludes that utilizing “assumptions designed to ensure that errors in the predicted concentrations
would be in the direction of over prediction,” the LNG Facility and Marine Terminal could comply
with all air-quality requirements.198 Rather than providing conclusory statements regarding the
198 Appendix A at 12-14 (“every conservative screening model analysis predicted compliance for
all pollutants with the NAAQS, and compliance for all pollutants with PSD increments except for
N02. Supplemental modeling for N02 using two sets of meteorological data collected near the
proposed Anderson Bay facility depicts a range of potential impacts relative to the screening
assessment. While these results cannot be relied upon to make conclusive determinations on the
ability of the project to comply with applicable NAAQS and PSD increments, the supplemental
modeling shows levels below the respective NAAQS and PSD increments for FEIS purposes.”).
50
“predicted serious compliance problems” purported to exist at the Valdez Alternative’s site,199 the
project applicants should utilize existing on-site studies (or conduct new studies) to provide an
objective comparison of the emission data available for each alternative site.
G. Additional Impacts to Wetlands and Anadromous Fish.
Finally, the Project Applicants have suggested that the Valdez Alternative need not be
thoroughly analyzed because a salmon stream located at the Valdez Alternative’s Liquefaction
Facility and Marine Terminal site must be rerouted and approximately 60 acres of wetlands will
be filled.200 However, FERC previously approved the Valdez Alternative’s site concluding that
“[o]verall, there would be minimal impacts on resident fish resources because of their limited
distribution on the site.”201
The Project Applicants have yet to compare the Valdez Alternative to the Nikiski
Alternative with regard to project-wide impacts on wetlands and anadromous fish. Nevertheless,
the Valdez Alternative appears to better avoid salmon streams and sensitive wetland areas as
measured over the project as a whole. By focusing on minimal impacts on anadromous fish and
wetlands associated with the Valdez Alternative’s site while ignoring the substantially greater
impacts to such resources associated with the Nikiski Alternative, the comparative analysis does
not allow for an objective comparison. Accordingly, the Project Applicants should provide all of
the data necessary to compare the total impacts on anadromous fish species and wetlands. Failure
to provide such data, in light of the Nikiski Alternative’s numerous anadromous salmon stream
crossings in the Susitna Valley and along western Cook Inlet as well as crossing of wetland areas
199 Second Draft Resource Report 10 at 10-95.
200 Id. at 10-92, 10-136.
201 Appendix A at 11.
51
in Minto Flats and the Susitna Delta, reflects the need for the Project Applicant’s to conduct an
objective comparison of the alternatives on a project-wide basis. Unsupported assertions regarding
the Valdez Alternative’s impacts on wetlands and anadromous fish does not justify abandoning
the historically preferred alternative.
V. CONCLUSION
The “heart” of NEPA is to “present the environmental impacts of the proposal and the
alternatives in comparative form, thus sharply defining the issues and providing a clear basis for
choice among options by the decisionmaker and the public.”202 As the United States District Court
for the First Circuit stated:
It is absolutely essential to the NEPA process that the decisionmaker be provided
with a detailed and careful analysis of the relative environmental merits and
demerits of the proposed action and possible alternatives, a requirement that we
have characterized as the linchpin of the entire impact statement.203
The Project Applicants have yet to provide an alternative analysis that satisfies the rigorous
requirements of NEPA or supports deviating from the traditionally preferred Valdez Alternative.
In order to comply with NEPA, FERC will require more information and more objective analysis
of the impacts of the Valdez Alternative as compared to the Nikiski Alternative. Accordingly, the
signatories to these comments encourage FERC to require the Project Applicants to provide data
and analysis with the requisite level of detail and objectivity mandated by NEPA. Absent strong
countervailing evidence provided by the Project Applicants, FERC should not allow the Project
Applicants to deviate from the FERC-approved Valdez Alternative in favor of the previously
disavowed Nikiski Alternative.
202 40 C.F.R. § 1502.14.
203 Dubois v. U.S. Dep’t of Agric., 102 F.3d 1273, 1286-87 (1st Cir. 1996) (quoting Nat’l Res. Def.
Council v. Callaway, 524 F.2d 79, 92 (2d Cir.1975)).

Dated c2-! I j I 7
,,
Dated ——-
Dated ——-
Dated ——-
MAYOR OF THE FAIRBAN KS NORTH STAR
BOROUGH
By ,t-!:::::::t=-

Karl W. Kassel, Mayor
P. O. Box 71267
Fairbanks, AK 99707
Phone: (907) 459-1300
Fax: (907) 459-1102
mayor@fnsb.us
MAYOR OF THE CITY OF NORTH POLE
By ______ _ _____
Bryce Ward, Mayor
125 Snowman Lane
North Pole, AK 99705
Phone: (907) 488-8584
Fax: (907) 488-3002
b ,yce. ward@northpolealaska.org
MAYOR OF THE CITY OF FAIRBANKS
By ______________
Jim Matherly, Mayor
City Hall
800 Cushman Street
Fairbanks, AK 99701
Phone: (907) 459-6715
JMatherly@fairbanks.us
ALASKA GASLINE PORT AUTHORITY
By ______________
Dave Dengel, Chairman of the Board
Alaska Gasline Port Authority
P.O. Box 3144
Valdez, Alaska 99686
Phone: (907) 255-1211
dengel@valdezak.net
53

Dated ——-
Dated ——-
Dated ——-
Dated ,QI Q ! .Q()\’J
MAYOR OF THE FAIRBANKS NORTH STAR
BOROUGH
Karl W. Kassel, Mayor
P. 0. Box 71267
Fairbanks, AK 99707
Phone: (907) 459-1300
Fax: (907) 459-1102
mayor@fnsb.us
MAYOR OF THE CITY OF NORTH POLE
Bryce Ward, Mayor
125 Snowman Lane
North Pole, AK 99705
Phone: (907) 488-8584
Fax: (907) 488-3002
bryce. ward@northpolealaska.org
MAYOR OF THE CITY OF FAIRBANKS
Jim Matherly, Mayor
City Hall
800 Cushman Street
Fairbanks, AK 99701
Phone: (907) 459-6715
JMatherly@fairbanks.us
ALASKA GASLINE PORT AUTHORITY
By _ ),,::\
Dave Dengel, Ch\irman of the Board
Alaska Gasline Port Authority
P.O. Box 3144
Valdez, Alaska 99686
Phone: (907) 255-1211
dengel@valdezak.net
53

Yukon Pacific .
LNG ·~roje~t
March 1995
– – Final E vironrilentai- pact Statement
Doeke1 o. CP88·195-000
– …. .. .-., –
Feder..al_Energy Regulatory Commissioii’-:-
Office of Pipeline Regulation
Washington, DC 20426 ~ -_::-
.,-. .. .,_.. – ..- – . …. ~– -· ~
Appendix A
Page 1 of 15
TP
7{?1
L
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, D. C. 20426
‘196
) o/C/f
TO THE PARTY ADDRESSED:
In Reply Refer To:
OPR/DEER/ERC I
Yukon Pacific Company L. P.
Docket No. CP88-105-000
The staff of the Federal Energy Regulatory Commission {FERC or
Commission) has made available a final environmental impact
statement {FEIS) on the construction and operation of the liquefied
natural gas {LNG) liquefaction plant, LNG storage and marine
loading facilities, and LNG tanker transport proposed in the abovereferenced
docket.
The staff prepared the FEIS to satisfy the requirements of the
National Environmental Policy Act. The staff concludes that
approval of the proposed action, with appropriate mitigating
measures as recommended, including receipt of necessary permits and
approvals, would have limited adverse environmental impact. The
FEIS evaluates alternatives to various components of the proposal.
Yukon Pacific Company L.P. (Yukon Pacific) is seeking approval
of a specific site at Anderson Bay, Port Valdez, Alaska to export
LNG to destinations in Japan, Korea, and Taiwan. The proposed
action involves construction of:
• a 2.1 billion cubic feet per day LNG liquefaction plant;
four aboveground 800,000-barrel LNG storage tanks;
a marine facility to load two tankers within a 12-hour
period; and
• a cargo/personnel ferry docking facility.
-L In addition, Yukon Pacific proposes to operate a fleet of 15
LNG tankers, each having 125,000 cubic meters of cargo capacity.
The fleet would make 275 trips per year. Construction of the
project would take 8 years with a peak work force of nearly 4,000
workers in the fifth year.
The FEIS will be used in the regulatory decision-making
process at the FERC. While the period for filing interventions in
this case bas expired, motions to intervene out-of-time can be
filed with the FERC in accorda,nc .. .with the Commission’s Rules of
Practice and Procedures, 18 · ..C FR 385. 214 {d). Further, anyone
.r: desiring to file a protest with the FERC should do so in accordance
with 18 CFR 385.211.
ARLIS
Alaska Resources
‘Abfay & Information Services
Anchmagc, Alask”‘
Appendix A
Page 2 of 15
2
The FEIS has been placed in the public files of the FERC and
is available for public inspection in the:
Federal Energy Regulatory Commission
Division of Public Information
Room 3104
941 North capitol Street, N.E.
Washington, DC 20426
Copies of the FEIS have been mailed to Federal, state, and
local agencies, public interest groups, libraries, newspapers,
individuals who have requested the FEIS, and other parties to this
proceeding.
Limited copies of the FEIS are available from:
Mr. Chris Zerby, Project Manager (Room 7312)
Federal Energy Regulatory Commission
825 North Capitol Street, N.E.
Washington, DC 20426
(202) 208-0111
Mr. Jerry Brossia
State Pipeline Coordinator
411 West 4th Avenue, Suite #2
Anchorage, Alaska 99501
(907) 278-8594
Lois D. cashell,
Secretary
Appendix A
Page 3 of 15
EXECUTIVE SUMMARY
The Yukon Pacific LNG Project Final Environmental Impact Statement (FEIS) has been prepared
by the staff of the Federal Energy Regulatory Commission (FERC or Commission) to fulfill the
requirements of the National Environmental Policy Act. Among its other responsibilities, the FERC has
authority under Section 3 of the Natural Gas Act to approve or disapprove the place of export and the
construction and operation of facilities at this place of export. The U.S. Coast Guard, U.S. Department
of TranspoJ;tation, U.S. Army Corps of Engineers, the Alaska State Pipeline Coordinator’s Office, Alaska
Department ofFish and Game, and the City of Valdez are cooperating Federal, state, and local agencies
for this FEIS.
The Draft Environmental Impact Statement (DEIS) for this project was issued in May 1993 and
a 45-day public comment period followed. During that time, we received numerous comments from
regulatory agencies as well as public groups, private individuals, and other concerned parties. Responses
to comments received have either been incorporated into the revised text of this FEIS as new or additional
information, or have been included in separate responses in appendix E. It ·was determined during review
of the comments that there was insufficient data available from Yukon Pacific Company L.P. (Yukon
Pacific) to address a number of comment areas including air quality, wetlands, and spoil disposal issues.
To obtain the information required to address these comments, we requested additional
information from Yukon Pacific in September 1993. A data response was prepared and a technical
conference was held in March 1994 for further clarification of the additional information. The conference
was attended by Region 10 of the U.S. Environmental Protection Agency, the FERC, the Alaska
Department of Environmental Conservation, and Yukon Pacific. Yukon Pacific followed up this meeting
with the preparation and submittal of an Issues Resolution Document summarizing all new information.
A Final Issues Resolution Document, incorporating agency comments, was filed in July 1994 and the
information incorporated into the FEIS.
PROPOSED ACTION
Yukon Pacific is seeking approval of a specific export site at Anderson Bay, Port Valdez, Alaska.
Yukon Pacific proposes to construct and operate facilities to liquefy natural gas delivered to Port Valdez
via pipeline from the North Slope; briefly store the liquefied natural gas (LNG); and transfer the LNG
at a marine terminal in Anderson Bay to LNG tankers for export to various Asian Pacific Rim countries.
The Yukon Pacific LNG facility would receive and liquefy 2.1 billion cubic feet per day of
conditioned natural gas delivered by pipeline from Prudhoe Bay. The entire plant site would occupy a
land area of about 390 acres. Major facilities in the plant would include four LNG process trains
consisting of gas pretreatment and liquefaction, four 800,000-barrel aboveground LNG storage tanks, and
a marine facility to load two tankers of 125,000 cubic meters capacity within a 12-hour period. At
planned capacity, a fleet of 15 double-hulled LNG tankers would transport the LNG through U.S.
territorial waters to receiving terminals in the Pacific Rim, making about 275 loaded voyages per year.
Construction of the proposed facilities would permanently affect approximately 426 acres of
predominantly spruce-hemlock forest, wetland, and non-wetland subtidal marine habitats. The site,
because of its steep topography, would require extensive recontouring, through excavation and filling,
to create bedrock benches on which the facility structures would be constructed. This would result in
about 3.3 million cubic yards of excess excavated materials requiring disposal (2.6 million cubic yards
of overburden and 0. 7 million cubic yards of rock).
S-1 Appendix A
Page 4 of 15
2.1.4.3 Permanent Plant and Marine Site Development
Site development activities would begin as early as possible in the first construction year
and be carried out in three consecutive summer seasons. Site excavation would involve: removal
of overburden soils down to bedrock and placement of these soils in planned fill and disposal areas;
the removal of rock down to design grade elevations; and the placement of compacted rock fill in
low areas up to design grade elevations (figure 2.1-4). Overburden removal would be done using
bulldozers, backhoes, loaders, and haul trucks. Rock excavation would be done using conventional
drilling and blasting techniques. Rock would be moved and placed by bulldozers, loaders, haul
trucks, and compactors. Blasting of rock would commence upon project mobilization and would
be planned initially twice a day-once at lunch period, and sometime between the first and second
shifts, weather permitting.
The amount of underwater blasting would be limited to what is necessary at the
cargo/personnel ferry dock and the LNG tanker berthing docks, and cannot be determined exactly
until detailed bathymetry of the areas is completed. In any event, blasting would be designed to
meet Federal Regulations Part 1926, Safety and Health Regulations for Construction Sub Part “U”.
The proposed schedule restricts underwater blasting to the period October 1 through April 15 or
in accordance with ADFG guidelines to avoid impacts on marine resources. The TAGS Right-ofWay
Lease Stipulation Number 2.11 requires the preparation of a blasting plan and approval by
the Alaska Department of Natural Resources (ADNR) for blasting in streams, rivers, or lakes.
The layout of the site shown on figure 2.1-4 reflects a need to locate all critical facilities
on bedrock while at the same time optimizing cut/fill requirements to minimize spoil quantities.
Site excavation quantities would be approximately 9.7 million cubic yards. Approximately 5.9
million cubic yards of this would be used for onsite fill, including earthwork for the construction
wharf and off-loading area in Anderson Bay. Approximately 3.8 million cubic yards of excavated
material, about 19 percent rock, would not be needed and would require disposal. This is
discussed further in section 2.3.2. The site development concept uses terracing (benching) to
maximize the functional area of a site which is relatively steep.
The highest bench would be occupied by the LNG process trains at an approximate
elevation of 175 feet MLLW. Another major bench would be located to the west where the LNG
storage tanks would be placed at a base elevation of approximately 75 feet MLLW. Secondary
benches would be graded for other facilities such as the:
• power plant and operations support area and utility storage area (100 feet MLLW);
• harbormaster, helipad, and wastewater retention area (50 feet MLL W); and
• construction wharf and off-loading area (31 feet MLL W).
Once site development for the LNG tank area is well underway, the LNG tanks
subcontractor would mobilize to begin construction of the ring foundations for the first LNG tank.
This would be as early as possible in the second construction season; with tank installation the
following year. Using a phased construction strategy it is Yukon Pacific’s intention to complete
one train per year for 4 years with the first train startup occurring in the fifth year. At the end of
the eighth year of construction, all four trains would be.completed and producing.
2-28 Appendix A
Page 5 of 15
LNG plant and terminal. A discharge permit must be obtained by anyone who discharges or
proposes to discharge pollutants into the waters of the United States including, but not limited to:
sanitary wastes; domestic wastes; non-contact cooling water; LNG storage tank cleaner and
hydrotest discharge; oily wastewater; surface runoff (during construction and operation) and bilge
water. The EPA may not issue an NPDES permit until a certification is granted or waived by the
state in which the discharge will occur. There is also a general NPDES permit for stormwater
related to construction activities larger than 5 acres.
The Section 404 permitting process is administered by the COE for all discharge of fill or
dredged material or mechanical land clearing and excavation in waters of the United States,
including wetlands, streams, and navigable waters. Section 10 of the Rivers and Harbors Act is
also administered by the COE; individual Section 10 permits would be required for all construction
activities that occur in navigable waterways, including those that are tidally influenced (COE, 1992,
1995). The COE has responsibility for determining compliance with all regulatory requirements
associated with Section 10 and Section 404 of the CW A.
Ambient air quality is protected by Federal regulations under the CAA. These regulations
include compliance under the New Source Performance Standards (NSPS) and the new
requirements for the Prevention of Significant Deterioration (PSD). The Federal permitting process
for the CAA has been delegated to individual state agencies. Although applications are reviewed
by both the states and the EPA, the State of Alaska would determine the need for NSPS or a PSD
permit.
Some individual state or local permits would be required to construct the proposed project;
however, any such permits must be consistent with the conditions of the authorization for a place
of export and the construction and operation of facilities at this place· of export. The Commission
encourages cooperation between authorization holders and local authorities. However, this does
not mean that state and local agencies, through application of state or local laws, may prohibit or
unreasonably delay the construction of facilities approved by the Commission.!/
At the local level, the proposed location for the LNG plant is currently zoned
“Unclassified” by the City of Valdez. In order for the project to proceed, the property needs to
be rezoned to “Heavy Industrial” and a Conditional Use Permit would have to be obtained from
the Valdez Planning and Zoning Commission, following the submission of a formal project plan.
Under the Valdez Coastal Management Program, Yukon Pacific should file the project plan 6
months before filing the permit application with the Zoning Commission.
2.2 ALTERNATIVE SITE WCATIONS
In Order 350, the DOE concluded that the Valdez export site (Anderson Bay) is preferable
to all other export sites that were considered in the TAGS FEIS issued in June 1988 and
disapproved all sites other than the Anderson Bay site (DOE, 1989). Accordingly, as discussed
in section 1.5, the Commission is not considering any other site. During scoping, however,
several commenters asked that the process leading to selection of the Anderson Bay site be clarified
in the EIS. .
!! See, ~. Schneidewind v. ANR Pipeline Co., 485 U.S. 293 (1988); Natiooal Fuel Gas Supply v. Public Service
Commission, 894 F.2d 571 (2d Cir. 1989); and Iroquois Gas Transmission System, L.P., _!! !)., 52 FERC 1: 61,091 (1990)
and 59 FERC 1: 561,094 (1992).
2-42 Appendix A
Page 6 of 15
The selection of Anderson Bay as the preferred terminal location was the culmination of
a series of studies spanning a period of more than 15 years. In 1976, the FPC issued a FEIS in
FPC Docket CP75-96 on the then-proposed El Paso Alaska System (FPC, 1976). This project was
to carry natural gas from Prudhoe Bay to a site at Gravina Point in Prince William Sound where
it would be converted to LNG and transported from Alaska by ship to Point Conception,
California. As part of studies leading up to issuance of a FEIS in 1976, 11 potential LNG sites
in Prince William Sound, including Anderson Bay, were evaluated against the following 10 criteria:
• topographic conditions • distance to deep water
• foundation suitability • navigational suitability
• seismic considerations • anchorage suitability
• atmospheric conditions • ice formation
• oceanographic conditions • land conflicts
In the El Paso Alaska System FEIS, the Anderson Bay site was then rejected as an
alternative site based on more favorable. topographic, seismic, and anchorage conditions at the
Gravina Point site. Although not specifically discussed in the El Paso FEIS, the Coast Guard was,
at the time, also concerned with the passage of LNG ships (with their relative high “sail” area)
through the Valdez Narrows under high wind conditions.
The Anderson Bay site was re-examined in studies leading to the TAGS FEIS in 1988._2/
The TAGS LNG site selection process involved a variety of steps and considerations. Using
general guidelines, the coastal regions of Alaska were screened for sites that would allow for
development of a pipeline system and LNG and marine facilities capable of transporting natural
gas from Prudhoe Bay for year-round export to Asian Pacific Rim markets. This screening
involved review of alternatives considered in previous studies of a similar nature such as TAPS and
the El Paso Alaska System. Combinations of routes and terminal sites in Norton Sound, Bristol
Bay, Cook Inlet, Prince William Sound, Yakutat Bay, and Lynn Canal/Chatham Strait were
examined. Following initial screening, one major regional pipeline route alternative and six
alternative LNG plant and marine terminal locations were considered in detail along with the now
proposed site at Anderson Bay.
Eleven pipeline criteria, 10 LNG plant site criteria, and 6 criteria related to the marine
terminal were used to determine the degree of favorability for each of the alternative sites. Results
of this analysis are summarized on figure 2.2-1. LNG siting criteria for the Anderson Bay site
were all favorable or moderately favorable. No site was determined to have an overriding
advantage over the Anderson Bay site. Unfavorable characteristics identified in the El Paso Alaska
System FEIS were not found to be significant problems in the TAGS study. Table 2.2-1 compares
the evaluation ratings presented in the 1988 TAGS FEIS with similar criteria unfavorably rated in
the 1976 El Paso Alaska System FEIS.
Between the time of the studies presented in the El Paso Alaska System 1976 FEIS and the
TAGS 1988 FEIS, two major changes occurred which influenced selection of the Anderson Bay
‘1:.1 The criteria and evaluations conducted by the BLM and the COE are described in detail in appendix C of the TAGS FEIS
and incorporated herein by reference.
2-43 Appendix A
Page 7 of 15
FIGURE 2.2-1 Criteria Evaluation Matrix for Proposed TAGS Project and Alternative Locations
Prince William Sound Cook Inlet
Proposed Alternatives Alternatives
Project to:
Anderson Gravina Gold Robe Boulder Cape Harriet
Bay Creek Lake Point Starichkof Point
Pipeline Criteria
– Minimize length of pipeline 0 0 0 0
– Maximize use of existing infrastructure 0 0 0
– Maximize use of proven construction techniques 0 0
– Maximize opportunity for parallel construction techniques 0 0 0
– Avoid areas of potential geohazards
– Minimize potential contlicta with sensitive environmenta 0 0 0
– Maximize compatibility with current and planned land use 0 0 0
– Minimize the number of water crossings 0 0 0 0 0
– Avoid permitting delays 0 0 0
– Minimize potential threat to national security 0 0 0
– Maximize availability of gas to Alaska consumers 0 0 0
LNG Plant Criteria
– Adequacy of available land 0 0 0 0
– Avoid areas with poor foundation characteristics 0 0 0 0
-Avoid areas with faulta
– Avoid sites potentially exposed to seismic sea waves 0 0 0 0 0 0 0
– Minimize length of pipeline to marine terminal 0 0 0
– Maximize use of existing community infrastructure 0 0
– Avoid sensitive environmental habitat
– Public safety considerations 0 0 0
– Maximize value added industrial opportunities 0 0
– Minimize site preparation requirements 0 0 0
Marine Terminal Criteria
– Minimize exposure to extreme oceanographic conditions 0 0 ·0 0
– Minimize distance from shore to 60′ MLLW depth 0 0 0
– Maximize suitability of tanker maneuvering and anchorage area 0 0 0
– Minimize potential hazards to navigation 0 0
– Minimize potential problems related to soils and geohazards 0 0 0 0 0
– Minimize threat to national security
0 – Favorable – Moderately Favorable – Unfavorable – Highly Unfavorable
SOURCE: TAGS FEIS page 1-15. Appendix A
Page 8 of 15
TABLE2.2-l
Comparison of Suitability Criteria Ratings for
Anderson Bay Between :m Paso Alaska System and TAGS Projects
El Paso Alaska System ~/
FEIS Evaluation
Seismic Considerations:
Unfavorable due to possibility of seismic damage resulting
from slide-induced waves.
Topographic Conditions:
Unfavorable due to the rugged topographic conditions at
the site would require extensive site preparation and
disposal of large quantities of spoil material.
Anchorage Suitability:
Unfavorable due to absence of adequate anchorage.
~ El Paso Alaska System FEIS page ll and figure 79, page 505.
:W TAGS FEIS, pages C-30- C34.
TAGSJ!/
FEIS Evaluation
Seismic Sea Waves:
Favorable because the LNG plant would be located at an
elevation higher than the highest recorded tsunami run up
wave and no major impacts on onshore structures would
be anticipated.
Minimize Potential Problems Related to Soils and
Geohazards:
Favorable because there is minimal probability of a major
submarine slide in the area of the marine terminal. The
situation is similar in most respects to the Alyeska Marine
Terminal site.
Minimize Site Preparation:
Moderately favorable because approximately 10 million
yards of excavated quantities (after bulking) would be
utilized and S million yards would require disposal. The
site would require a substantial amount of earthwork
before construction. Soils are of good quality overlying
bedrock, and site preparation would not pose major
difficulties. Excess material could be used to develop the
construction wharf, off-loading area, construction support,
and laydown area.
Maximum Suitability … of Anchoring Areas:
Favorable because a new deep water anchorage has now
been established within Prince William Sound for oil and
LNG tankers.
site. First, during the preparation of the El Paso FEIS and prior to 1980, there were no rigorous
Federal siting requirements similar to Part 193 of the DOT’s LNG Federal Safety Standards (49
CFR Part 193). These DOT standards, established on February 11, 1980, prescribe siting
requirements for thermal radiation protection, flammable vapor-gas dispersion protection, seismic
investigation and design forces, flooding (including tsunamis), wind and other severe weather and
natural conditions, and adjacent site activities. Yukon Pacific contends that it can meet the
requirements of Part 193, as well as meet the industry’s consensus standards embodied in the
NFP A 59 A. Thus, these new standards address and supersede some of the earlier concerns with
a site at Anderson Bay.
2-45 Appendix A
Page 9 of 15
Secondly, since 1977, the construction and operation of the Alyeska oil terminal·and tanker
operations have given us a great deal of knowledge and experience which simply did not exist prior
to and during the preparation of the El Paso FEIS. Design and construction of the Alyeska facility
required extensive site preparation similar to what would be expected at the Anderson Bay site.
The location of Alyeska facilities on cut and fill terraces has demonstrated the feasibility of that
design/ construction concept, although the disposal of the rock and other material remains an issue
(see section 2.3.2). Operation of the oil tankers to and from the Alyeska Marine Terminal, along
with the use of a VTS, has reduced some of the previous navigational concerns. The Coast Guard
does not anticipate VTS problems with the increased LNG tanker traffic (see section 4.15.4).l/
A deep water anchorage is also now available for both oil and LNG tankers in Prince William
Sound; such an anchorage area was not available in 1976.
In addition to the above improvements in terms of site acceptability, a number of
governmental actions have occurred which limit the scope of the FERC’s review of the Anderson
Bay site and issues associated with alternative sites other than Anderson Bay. These actions are
discussed in section 1.1 of this FEIS. Of importance here is the fact that DOE/FE Order 350
granting Yukon Pacific authorization of the export also concluded that “With respect to the place
of exportation for the LNG … , all locations other than Port Valdez, Alaska are rejected.” This
decision was made after evaluation of alternative sites during preparation of the TAGS EIS, taking
into account the Port Valdez site and others evaluated in both the TAGS EIS and the El Paso FEIS.
Accordingly, further consideration of alternatives sites is outside the scope of this FEIS.
2.3 ALTERNATIVE CONSTRUCTION CAMP AND DISPOSAL PLANS
2.3.1 Alternative Construction Camp Sites
As described earlier in section 2.1.4, the construction period for the Yukon Pacific LNG
Project spans 8 years reaching a peak construction workforce of 4,000 people during the fifth and
sixth summers. Yukon Pacific proposes to house the majority of this workforce in a camp adjacent
to the construction site (figure 2.1.4-3). Using land on both banks of Seven Mile Creek at
approximately 100 to 175 feet elevation, 47 acres of forest would be cleared to establish the 30
acres of finished area required to erect the housing modules and ancillary facilities. Contouring
the site would require the excavation of0.175 million cubic yards of material; however, since rock
would be imported to the camp location to supply structural fill requirements, the net impact of
camp construction would be inconsequential regarding overall material disposal. This site is
located far. enough distant from the actual construction to afford undisturbed sleeping for offshift
workers. To supply the 288,000 gpd of potable water required to support the peak workforce, a
40-foot-high dam is proposed to be constructed on Seven Mile Creek just above the waterfall,
creating a 3.5-acre reservoir. With package water treatment and use of a large storage tank, all
of the onsite potable water supply needs could be met from this source. The site could be
developed without interfering with other construction activities, making the camp available for
occupation early in the construction schedule. Our analyses described in section 4.0 determined
that development of the work camp at this site would result in environmental impact.
J’
In an effort to minimize environmental disturbance at the Anderson Bay site, four site and
three access alternatives were screened to identify reasonable alternatives. These included locations
other than Seven Mile Creek but still within the Anderson Bay area (onsite options) as well as one
offsite location in Valdez. Factors considered in the initial screening were: the amount of land
‘J.I Coast Guard Marine Safety Office letter dated May 25, 1990 to Coast Guard Commandant.
2-46 Appendix A
Page 10 of 15
The proposed location of the construction camp is along both banks of Seven Mile Creek.
Yukon Pacific has developed a construction plan that requires considerable grading (figure 2.1.4-3)
which would eliminate riparian vegetation. In addition, working the banks in this steep canyon
area would likely cause rockfall into the streambed and an increased runoff of fines. Grading the
banks and eliminating riparian vegetation may result in increased sedimentation in the stream and
loss of downstream spawning habitat. We recommend that Yukon Pacific prepare a revised site
plan that avoids grading and clearing the riparian zones within 100 feet of the streambank:s
along Seven Mile Creek above the proposed dam. The revised plan should also avoid grading
and clearing to preserve the gorge area surrounding the water falls and the associated
intertidal shoreline area located on either side of the confluence of Seven Mile Creek and
Anderson Bay. The revised plan should be filed with the Secretary for review and approval
by the Director of OPR.
Fuels, lubricants, and other chemicals spilled during plant construction and operation would
negatively impact water quality if allowed to run off into the streams. Leachates from disturbed
soils and decaying vegetation could also negatively impact water quality and affect fish utilizing
the streams. To minimize impacts caused by runoff of spills or leachate, we have recommended
Yukon Pacific develop a SPCC Plan using best management practices (see section 4.3.2.1).
Overall, there would be minimal impacts on resident fish resources because of their limited
distribution on the site. Anadromous fish resources spawning in Nancy Creek would not be
significantly impacted if disturbance to the streambed is avoided or minimized and the runoff of
fine sediments is controlled. The impacts on anadromous fish spawning in Seven Mile Creek are
less clear because the flow patterns are not well understood. Once an in-stream flow study has
been completed, we have recommended that Yukon Pacific coordinate with the ADFG and PERC
staffs to determine a flow regime to minimize impacts on spawning fish (see section 4.3.1).
· Grading and clearing the banks would cause some disturbance of the streambed and increased
runoff of fine sediments. If the disturbance and runoff are minimized by careful construction and
adequate sedimen~, and erosion control, the impacts would not be significant.
4.4 TERRESTRIAL ECOWGY
4.4.1 Wildlife
4.4.1.1 Raptors
The project may adversely affect raptors by disturbance or destruction of existing nest sites.
(These issues as they relate to peregrine falcons are addressed in section 4.6.) Perhaps the greatest
issue concerning raptors is the number of active bald eagle nests which could potentially occur
within and near the project site. The Bald and Golden Eagle Protection Act (16 U.S.C. 668
(1988)) strictly prohibits the disturbance and/or destruction of bald eagle nests. In previous years,
three bald eagle nests have been recorded within the project site and an additional two nests within
1 mile of the facility boundary. A nest site at Nancy Creek is known to have blown down in 1989,
and no nest sites were recorded in the vicinity of Anderson Bay by FWS and ADFG personnel
during surveys in June of 1991 and 1992. Bald eagles could, however, reestablish nesting
territories within the project area at any time and the existence of a bald eagle nest would have an
impact upon project scheduling and/or activities. Consequently, we recommend that Yukon
Pacific conduct surveys for bald eagle nest sites during the year prior to the commencement
of site activities and each year subsequently, to determine nesting activity at the site. If active
4-22 Appendix A
Page 11 of 15
screening methods use very conservative assumptions (i.e., assumptions designed to ensure that
errors in the predicted concentrations would be in the direction of over prediction) to provide rough
estimates of the maximum pollutant concentrations that may result from a proposed source’s
emissions. More detailed information on the screening analysis is presented in appendix F of
Yukon Pacific’s DEIS Issues Resolution Document regarding FERC Docket Nos. CP88-105-000
and CP88-105-001. Copies can be obtained by contacting the FERC Project Manager or Yukon
Pacific directly.
For a project with receptors either above plume height or below stack heights, the EPA
guidelines for screening analyses recommend the use of the SCREEN2 and COMPLEX I models,
respectively. However, SCREEN2 does not allow separate representation of multiple stacks, so
this option was dismissed for the Yukon Pacific screening analysis. Instead, the ISCST2 and
BEESTX models (Versions 93109) were used in screening mode to accomplish the required
analysis for the proposed Anderson Bay facility. BEESTX is a model which uses the simple terrain
algorithms of ISCST2 with the complex terrain algorithms of COMPLEX I. For receptors with
elevations below the lowest stack top elevation, the ISCST2 algorithm is used. For receptors with
elevations above the final plume rise centerline elevation, the COMPLEX I algorithm is used. For
“intermediate terrain” receptors with elevations above the lowest stack top but below the final
plume rise elevation, the highest results from the ISCST2 and the COMPLEX I algorithms are _
selected for each hour of meteorology at each receptor to calculate the maximum concentrations
for each averaging time. Both models were employed because of the variable terrain that
characterizes the project site and its environs and the limited meteorology used with complex
terrain in screening runs.
Theoretically, the BEESTX model could have been used alone in screening mode to
evaluate impacts at all terrain elevations, as it combines the ISCST2 and COMPLEX I dispersion
algorithms with decision tree logic to determine whether the flat terrain or complex terrain
calculations should be used to represent the impact at each receptor, and to select the higher of the
concentrations predicted by the two methods for receptors in “intermediate” terrain. For practical
reasons, however, Yukon Pacific used a combination of ISCST2 and BEESTX runs for efficient
completion of the screening analysis. The use of both models was more convenient, primarily
because different meteorological conditions needed to be addressed for different groups of receptors
and because of the manner in which BEESTX prints out the modeling results. The screening
analysis was therefore conducted according to the following sequence.
1. First, ISCST2 was used with a coarse receptor grid (500-meter spacing) and the
full set of meteorological input parameters incorporated by the EPA SCREEN2
model to compute the maximum concentrations resulting from the algorithm for
flat terrain dispersion.
2. Second, BEESTX was used with the standard EPA screening assumptions for
complex terrain ofF stability with 2.5 rnlsec wind speed to compute the highest
concentrations resulting from the elevated terrain dispersion algorithm. Other wind
speed-stability combinations are not required for the elevated receptors.
3. A second set of runs was made for each pollutant using a fine receptor grid (50-
meter spacing) in the vicinity of the highest values predicted by the first two sets
of runs. Either the ISCST2 or BEESTX model was used for the second round of
simulations, depending on which model yielded the highest coarse grid
concentrations for each pollutant. The highest hourly concentrations for each
pollutant from the second set of runs were used with EPA-approved factors to
4-51 Appendix A
Page 12 of 15
estimate the maximum multiple-hour average values for comparison with applicable
standards and increments. The factors used to convert the model-predicted hourly
maxima to estimates of the peak 3-hour, 8-hour, 24-hour, and annual average
concentrations are listed as follows:
Averaging Time
3-hour
8-hour
24-hour
Annual
Conversion Factor
0.9
0.7
0.4 (ISCST2); 0.25 (BEESTX)
0.08
Based on a methodology described in Use of Ambient Ratios to Estimate Impacts of NO%
Sources to N02 Concentrations by Chu and Meyer (1991), a factor of 0.75 was used to convert
modeled annual average NOx concentrations to N02 concentrations.
Maximum predicted impacts from the screening analysis are shown in table 4. 7 .4-1. More
detailed results are presented in tables D-4, D-5, and D-6 of appendix D. The screening analysis
shows that the proposed Yukon Pacific LNG Project has the potential to cause significant
incremental impacts on air quality in the vicinity of the Anderson Bay site. Based on this finding,
the need for refined modeling analysis is indicated. The screening calculations indicate that such
modeling should be performed for evaluation of compliance with the N02 and S02 PSD
increments. Any increment consuming source identified in the 1992 Petro Star Valdez Refinery
PSD permit application should also be included. Despite extremely conservative assumptions
regarding the project’s operations and emissions, as well as worst-case meteorological inputs, the
results of the screening analysis indicate that compliance with PM increment can be achieved by
the proposed project. Predicted earbon monoxide impacts, both total and increment consuming
emissions, from the screening analysis are sufficiently low to conclude that no significant impacts
on local CO concentrations will occur. In addition, the screening results indicate that all maximum
pollutant concentrations are well below all NAAQS.
TABLE4.7.4-1
ScreeDiDg ModeJiDg Results Compared with App1icable
Natioual Ambient Air Quality Standards and PSD IDcremeots
Predicted
Existing Maximum Total Applicable Applicable Class U
Averaging Ambient Concentration Concentration NAAQS PSD Increment
Pollutant Period (p.g/nr} (p.g/ui) (p.g/m~ (p.g/nr} (p.g/m~
s~ Annual 16 15.1 31.1 80 20
24-hour 81 15.1 156.1 365 91
3-hour 327 170.2 497.2 1,300 512
Annual 27 42.06 69.06 100 25
Annual 33.5 5.04 38.54 so 19
24-hour 100 15.15 115.15 150 37
co 8-hour 4,524 805.1 5,329.1 10,000 N/A
1-hour 7,680 1,150.1 8,830.1 40,000 N/A
4-52
l
Appendix A
Page 13 of 15
Because of the very conservative nature of the screening model analysis discussed above,
it was prudent to make use of available data to support a more reaiistic analysis using supplemental
dispersion modeling with a full year of meteorological data. Two sets of meteorological data were
used, one from a 1 0-meter tower at Anderson Bay and one from the Valdez Air Monitoring System
(V AMS). More detailed information on the supplemental modeling is presented in appendices G
and H of Yukon Pacific’s DEIS Issues Resolution Document regarding FERC Docket Nos. CPSS-
105-000 and CPSS-105-001. Copies can be obtained by contacting the FERC Project Manager or
Yukon Pacific directly.
The first set of meteorological data was improved quality data from the onsite 10-meter
tower at Anderson Bay for the period November 1, 1992 through October 31, 1993. The EPA
acknowledged that more supplemental modeling based on the best year of the Yukon Pacific
meteorological data, although not definitive as refined modeling because the EPA did not consider
the tower’s location to be representative of the LNG trains’ stacks, would provide useful
information regarding the range of air quality impacts that may occur due to operation of the
proposed Anderson Bay facility. The results of that supplemental modeling using the 10-meter
Anderson Bay meteorological data show levels below the respective PSD increments as shown in
table 4.7.4-2 and NAAQS as shown in table 4.7.4-3.
A second set of supplemental dispersion modeling results was generated using 30-meter
meteorological monitoring data for the same period collected by Alyeska at its marine terminal at
Jackson Point, approximately 5 miles east of the proposed LNG process trains at the site of the
Yukon Pacific plant. The EPA has stated that supplemental modeling results obtained with these
data are of interest because the winds 30 meters above ground level may be more representative
of transport and dispersion conditions that would govern the behavior of the Anderson Bay
emission plume than the 10-meter Yukon Pacific data from Anderson Bay. Like the results using
Yukon Pacific’s Anderson Bay meteorological data, the results from supplemental modeling using
the 30-meter Alyeska meteorological data show levels below the respective PSD increments and
NAAQS. The results of this supplemental modeling analyses are presented in table 4. 7.4-4 for the
PSD increment consumption and table 4.7.4-5 for the comparison with NAAQS.
In summary, the very conservative screening model analysis predicted compliance for all
pollutants with the NAAQS, and compliance for all pollutants with PSD increments except for
N02• Supplemental modeling for N02 using two sets ef meteorological data collected near the
proposed Anderson Bay facility depicts a range of potential impacts relative to the screening
assessment. While these results cannot be relied upon to make conclusive determinations on the
ability of the project to comply with applicable NAAQS and PSD increments, the supplemental
modeling shows levels below the respective NAAQS and PSD increments for FEIS purposes. The
meteorological data which Yukon Pacific is capturing from its 40-meter tower at Anderson Bay will
be used for modeling in support of its PSD application which must demonstrate compliance with
all NAAQS and PSD increment standards.
Under the Clean Air Act, the ADEC’s PSD program (which has been delegated to the State
of Alaska by the EPA) is intended to ensure compliance with any operating restrictions necessary
to keep air impacts from Yukon Pacific’s LNG facility from adversely affecting the local
population and environment. The permitting process with the ADEC will ensure that the proposed
project complies with all aspects of the PSD regulations, including BACT for each source of
emissions.
4-53 Appendix A
Page 14 of 15
If unignited, the flammable vapor -cloud would drift downwind until the effects of
dispersion would dilute the vapors below the lower flammable limit for methane. However, if the
flammable vapor cloud would encounter a source of ignition, the cloud would burn back to the spill
site.
The maximum range of potentially flammable vapors-the distance to the lower flammable
limit-is a function of the volume of LNG spilled, the rate of the spill, and the prevailing
meteorological conditions. Yukon Pacific’s study identified that an instantaneous spillage of20,000
cubic meters of LNG with a 10 mph wind and typical atmospheric stability could travel up to 3.3
miles in 25 minutes.
The LNG tanker route through Prince William Sound to the marine terminal is far offshore
for the majority of the voyage. There exist no populated areas within the maximum range of
thermal radiation hazard or flammable vapor cloud hazard for an instantaneous one-tank cargo
spill. As a result, the general public would not be exposed to a hazard from these events.
The instantaneous spillage of one cargo tank is considered to be a “worst case” ·event.
Physical constraints on maximum vessel speeds and maximum depths of penetration required to
rupture one LNG cargo tank render the possibility of an instantaneous release of more than one
cargo tank to be implausible. This is not to imply that the loss of multiple cargo tanks could never
occur, but that the extent of the hazard would not exceed that of the instantaneous spillage of one
tank.
The possibility of a collision between a loaded outbound crude oil tanker and an inbound
LNG tanker in ballast has been suggested as a possible event that could lead to a significant oil
spill. In 1988, the number of crude oil tankers peaked at 990, for an average of 2. 7 tankers per
day. Presently, crude oil tankers make about 700 round trips annually-ali average of 1.9 per
day-through Prince William Sound. At full capacity, the proposed project would add 275 LNG
tanker trips per year, or an average of0.75 per day. This total tanker traffic of2.7 per day is well
within the limitations of the VTS system and is identical to the number of crude tankers in the peak
year of 1988. By the time the TAGS project is operational, the number of crude tankers per year
is expected to be under 500. The modest increase tanker traffic in Prince William Sound would
not significantly increase the potential for a collision between an outbound crude oil tanker and any
inbound tanker, either LNG or another crude oil tanker:
Conclusions on Marine Safety
• LNG tankers have experienced safe operation without cargo tank spillage for more than
30 years. Given the present and planned Coast Guard controls in the Prince William
Sound VTS Area, LNG tankers can safely operate in these waters.
• The thermal radiation and flammable vapor cloud hazards from the maximum credible
LNG tanker spill would not affect the general public.
• Although it is possible for an LNG tanker to spill cargo in a grounding type incident, the
liquid would rapidly vaporize and would not have the long-term environmental
consequences associated with a major oil spill.
• The addition of LNG tankers within the VTS Area would not have a significant increase
on the percent potential of a collision with an outbound crude oil tanker.
4-101
..
Appendix A
Page 15 of 15

FEDERAL ENERGY REGULATORY COMMISSION
Office of Energy Projects
GUIDANCE MANUAL
FOR
ENVIRONMENTAL REPORT
PREPARATION
For Applications Filed Under the
Natural Gas Act
Volume I
DRAFT
December 2015
Appendix B
Page 1 of 11
Appendix B
Page 2 of 11
Appendix B
Page 3 of 11
Appendix B
Page 4 of 11
Appendix B
Page 5 of 11
Appendix B
Page 6 of 11
Appendix B
Page 7 of 11
Appendix B
Page 8 of 11
Appendix B
Page 9 of 11
Appendix B
Page 10 of 11
Appendix B
Page 11 of 11

TRANS-ALASKA GAS SYSTEM
FINAL ENVIRONMENTAL IMPACT STATEMENT
•
~w
U.S. ARMY CORPS OF ENGINEERS
ALASKA DISTRICT
o JUNE 1988
BLM-AK-PT-88-003-1792-910
, ,
~’)/
I
I
,/
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,
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HARDING LAWSON ASSOCIATES. 601 EAST 57TH PLACE. ANCHORAGE, ALASKA 99518
Appendix D
Page 1 of 13
Bureau of Land Management
Department of the Interior
U.S. Army Corps of Engineers
Department of the Army
FINAL
ENVIRONMENTAL IMPACT STATEMENT
FOR THE PROPOSED
TRANS-ALASKA GAS SYSTEM
Prepared by
Bureau of Land Management
and
U.S. Army Corps of Engineers
Cooperating Agencies
o
……
oo
o..q
o
oo
l!’)
l!’)
r–.
M
M
Department of Agriculture
Forest Service
Department of Commerce
National Marine Fisheries Service
Department of Energy
Economic Regulatory Administration
Department of the Interior
Bureau of Indian Affairs
Bureau of Mines
Fish and Wildlife Service
Geological Survey
Minerals Management Service
National Park Service
Department of Transportation
Coast Guard
Federal Highway Administration
Office of Pipeline Safety
Environmental Protec·tion Agency
Federal Energy Regulatory Commission
State of Alaska
Division of Governmental Coordination
Department of Fish and Game
Department of Natural Resources
Department of Transportation and Public
Facilities
Department of Environmental Conservation
Michael J. Penf
JUNE 1988
BLM-AK-PT-88-003-1792-910
Director, Bureau of Land Management
., District Engineer, Ala ska District,
Corps of Engineers
Appendix D
Page 2 of 13
Figure 1.9.4-3 Criteria Evaluation Matrix for Proposed TAGS Project and Alternative Locations
Prince William Sound Cook Inlet
Proposed Project·to: Alternatives Alternatives
Anderson Gravina Gold Robe Boulder Cape Harriet
Bay Creek Lake Point Starichkof Point
Pipeline Criteria
– Minimize length of pipeline 0 0 0 0 0 0 0 – Maximize use of existing infrastructure 0 @ 0 0 0 ~ @ — MMaaxxiimmiizzee uospepoorftupnriotvyenfocr opnasrtraulcletiloncotnescthrnuicqtuioens techniques 0 0 0 0 @ 0 @ 0 @ 0 0 @ 0 ~ — Avoid areas of potential geohazards ~ 0 ~ @ @ 0 & Minimize potential conflicts with sensitive environments 0 @ 0 0 @ 0 e — Maximize compatibility with current and planned land use 0 0 0 0 0 0 0 – Minimize the number of water crossings 0 0 0 0 0 0 0 – Avoid permitting delays 0 ~ 0 0 • • • Minimize potential threat to national security 0 @ 0 0 @ 0 ~ – Maximize availability of gas to Alaska consumers @ @ @ ~ 0 0 0
LNG Plant Criteria
– Adequacy of available land 0 0 0 • 0 ell) 0 – Avoid areas with poor foundation characteristics 0 0 0 0 @ @ @ — Avoid areas with faults ® ~ ® 0 0 ® 0 – Avoid sites potentially exposed to seismic sea waves 0 0 0 0 0 0 0 – Minimize length of pipeline to marine terminal 0 0 0 • ® 0 0 Maximize use of existing community infrastructure ® • 0 0 0 0 @ – Avoid sensitive environmental habitat @ e ® @ 0 0 ~ – Public safety considerations 0 0 ® ! – ~ 0 0 Maximize value added industrial opportunities f2l • ® 0 0 @ – Minimize site· preparation requirements f2l @ e f2l 0 0 0
Marine Terminal Critieria
– Minimize exposure to extreme oceanographic conditions 0 0 0 0 0 e ~ – Minimize distance from shore to 60′ MLLW depth 0 0 0 0 @ f2l f2l – Maximize suitabll ity of tanker maneuvering and anchorage area 0 0 0 0 ® 0 ® – Minimize potential hazards to navigation 0 @ 0 @ ~ @ @ – Minimize potential problems re.1ated to soils and geohazards 0 0 e e 0 0 0
– Minimize threat to national security @ @ f2l @ ® 0 @
o Favorable
@ Moderately Favorable
® Unfavorable
• lIighly Unfavorable Appendix D
Page 3 of 13
SECTION 2.0 DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES
These actions would take place from six
camps north of the Yukon-River and from
existing facilities in communities
elsewhere. Material yards would be made
ready to hold construction supplies,
equipment, and pipe.
Right-of-way acquisition and surveying
would entail major field operations prior to
construction. The location of the pipeline
would be described by a surveyed centerline
description of the route through Alaska.
A total of 26 construction camps would
be required for the construction of the
proposed TAGS project, as shown in
Table 2.3.1-1. All of the proposed
pipeline construction camps except Prudhoe
Bay and Sourdough Creek would utilize former
TAPS construction campsites. There would be
a construction camp at each of the 10
compressor stations, as well as the LNG
·plant/terminal camp. Total bed space for
construction camps would be 11,600.
Access roads would be built to provide
necessary access from existing public or
private roads to construction areas such as
pipeline right-of-way, material/disposal
sites, compressor stations, and material
storage sites. Selection of access road
locations would be based largely on the
location of existing pUblic and TAPS access
roads, terrain roughness, and haulage
distances. Approximately 100 miles of
existing access roads, permanent or
abandoned, would be repaired for reuse, and
approximately 34 miles of new access roads
would be constructed to a specification of
3D-feet wide at the crown with thickness
determined by soil and thermal conditions.
Appendix E includes a list of all major
access roads required for the project by
milepost and length. As an option to
structural fill access roads, TAGS would
consider the use of snow/ice access roads in
areas where all construction activities are
scheduled for winter snow/ice roads, on a
site-specific basis where conditions are
determined to be advantageous, and where
an adequa.te winter supply of surface wa.ter
is available for project use.
Construction of the pipeline and
ancillary facilities work pad would require
natural soil or rock borrow material. This
would be needed for right-of-way
preparation, access roads, temporary and
permanent facility foundations, and
specialized ditch backfill. Borrow pit and
2-19
Table 2.3.1-1
TAGS Temporary Construction Camps
Bed Soaces
Construct10n Mlle- p~pellne Compressor
Spread mL Location -lLL- Station
0 Prudhoe 8ay 200
43- Frankl in 81uffs 400
66 Compressor Stat i on 11 100 300
84 Happy Vall ey 500
125 Compressor Station #2 100 300
140- Galbraith Lake 500
1′;1’0′[ mr
170 Chandalar 500
201 Oietrich 600
213 Compressor Station 13 100 300
236- Coldfoot 900
2,1’ll’cr 1M’
281 Compressor Station t4 100 300
299 01 dman 700
345- Five Mlle 700
358 Compressor Station IS 100 300
394- Li ven900d 700
422 Compressor Station 16 100 300
2,’400 goo
451 Fairbanks 1,000
487 Compressor Station 17 100 300
526 Oelta 800
563 Compressor Stat i on 18 100 300 r.oocr 0il0
600 Isabel Pass 600
639 Compressor Station il9
Sourdou9h Creek 600 300
682 Glennallen 700
t,900 30e
721 Compressor Station ilIa
Tonsina 700 300
770 Sheep Creek 500
797 LNG/Marine Terminal 200 l.seo
1,400 :•sao
TOTALS 11,600 4~5CO
*’ Preeonstruction camps plus one at Prospect Airport. Ml1epost 275w
quarry development would probably be
accomplished in the first year of pipe Une
development. Reconnaissance investigations
would be conducted during the detailed
design phase to identify natural deposits
suitable for use as borrow sources for the
project. Initially, an inventory of
existing sites within the corridor would be
assessed. Then, a search for new, suitable
borrow sources would be initiated.
Through the use of exploratory borings
and geophysical evaluation, potential sites,
new or existing, that best meet project
needs, would be examined in greater detail
to establish site quality and quantity.
Detailed development and-mining plans would
be prepared for required borrow sites.
Plans would be in conformance with state and
federal requirements and would contain
sufficient data to permit development,
Appendix D
Page 4 of 13
SECTION 2.0 DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES
Figure 2.3.3-1 presents three typical
configurations for three types of buried
river and stream crossings. The unweighted
crossing would be used where crossings of
minor streams and drainages require only
minimum cover depths and where pipe buoyancy
would not be a problem. Weighted river
crossing designs would be utilized to allow
pipeline construction in wet ditch areas.or
for long-term pipe buoyancy control.
Selection of bolt-on weights or continuous
concrete coating would be based on
site-specific conditions. As previously
mentioned, site-specific design would be
incorporated to mitigate chilled pipe
effects to rivers and streams.
Construction schedules would be
developed to minimize impacts at critical
water crossings to protect anadromous fish
stocks and prevent downstream impacts.
Temporary stream diversions could be
required for pipeline installation: such
diversions would require state approval. To
avoid possible conflict with resident and
anadromous fish, timing constraints could be
required.
Following pipe-laying, trenches would be
backfilled with materials equal to or better
than the materials excavated. This would
minimize changes in channel characteristics
with respect to scour and erosive forces.
Use of riprap or other bank protection
techniques would be required in some
locations.
2.3.3.2 Aerial River Crossing
The proposed TAGS conceptual design
identified four major river crossings that
would require independent aerial suspension
bridges due to known environmental and
difficult construction conditions. Aerial
rather than buried crossings would be used
for the Yukon, Tanana, GUlkana, and Tazlina
rivers.
Figure 2.3.3-2 is a conceptual sketch of
the single-span bridge proposed for the
crossing of the Tanana, Gulkana, and Tazlina
rivers. Span lengths for the three
crossings are estimated to be 1,200 feet,
380 feet, and 700 feet, respectively. The
Yukon River crossing would be an
independent, twin-span suspension bridge.
2-26
2.3.3.3 Road Crossings
The proposed TAGS pipeline road
crossings would be designed and installed
with or without casings in accordance with
49 CFR 192. Access roads into material
sites, camps, foreign pipelines, service
facilities, and private property would be
traversed uncased, as shown in
Figure 2.3.3-3. The 67 major highway and
road crossings would be evaluated on a
site-specific basis to determine if an
uncased crossing can be used. Where
excessive wheel loads are. anticipated or
concerns for pipeline integrity are
identified at road crossings, the advantages
and disadvantages of cased crossing would be
evaluated during the design phase.
Design and construction would be
coordinated with the Alaska Department of
Transportation and Public Facilities
(DOT/PF) for highway crossings, proper
authorizing agents for other public roads,
telephone cables, and private owners for
access roads as appropriate. Activities
would be coordinated with Alyeska Pipeline
Service Company where highway crossings are
proximate to its fuel gas line or where its
access roads are crossed by TAGS.
2.3.3.4 Crossing of Existing Pipelines
The design and construction of crossings
of existing pipelines would require
consideration of site-specific conditions
and operational characteristics at each
crossing. The proposed TAGS route crosses
TAPS (above-ground and below-ground
sections), the TAPS fuel gas line, the
Kuparuk oil line (above-ground section),
producer gathering lines, the Haines
products pipeline, and the right-of-way for
the proposed ANGTS.
Crossings of an existing above-ground
pipeline would be designed for minimal
impact to the existing pipeline or
respective right-of-way. Although precise
angles of crossing would vary based upon
site-specific conditions at each crossing
location, the angle between the two
pipelines at the crossing point would tend
toward a right angle (80 0 to 1000
). The
TAGS pipeline would be buried a minimum of
2.5 feet below the original ground surface.
A crossing point at the midpoint between
Appendix D
Page 5 of 13
SECTION 2.0 DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES
Due to the extreme tidal fluctuations
and currents found in Cook Inlet, a
multipoint anchoring system would be
required to hold the lay barge in position.
The presence of the lay barge and its
multipoint anchor system would result in the
need for a traffic control system for
vessels bound to and from the Port of
Anchorage during the construction phase.
Additionally, pipe burial depth for both
pipelines should be sufficiently deep to
provide adequate protection from anchor
dragging or protection from scour.
From the Point Possession area the
pipeline would parallel an existing gasoline
pipeline right-of-way southwesterly for
about 50 miles along the coast, terminating
at Boulder Point just north of Nikiski, one
of the Cook Inlet sites previously
considered for location of the LNG plant and
marine terminal as shown in Figure 2.9.2-2.
This route avoids the Kenai National Moose
Range but traverses the Susitna Flats State
Wildlife Refuge and the Captain Cook State
Recreation Area for about 1.5 miles.
The Boulder Point site is located on the
east side of Cook Inlet on the Kenai
Peninsula approximately 17 road miles north
of the city of Kenai and 6 miles north of an
existing petroleum, petrochemical, refining,
and LNG industrial complex at Nikiski.
Boulder Point is located northeast of East
Forelands, a designated reserve for
navigational purposes.
Commercial and residential development
is not common, particularly near the site.
Good infrastructure is in place for
supporting construction and operations, but
land availability could be a problem.
Possible conflicts with nearby shipping and
docking operations at Nikiski might exist
(BLH 1976).
The north Kenai Road passes within 1~5
miles of the Boulder Point site, ending at
Captain Cook State Recreation Area. The
Nikiski airstrip is approximately 1.5 miles
inland from Boulder Point; a regional
airport at Kenai approximately 14 miles
south.
The Boulder Point site has fair
proximity to deep water, coastal bluffs of
moderate height, and stable shoreline. It
is the northernmost feasible industrial site
with deepwater marine acccess on the east
side of Cook Inlet and the closest site to
Anchorage (ESL 1980b).
2-61
Soils are suitable for development
(loess over glacial outwash), and terrain
above the cliffs is gently sloping to hilly
(SCS 1962). Bedrock foundation may be
lacking. Faults, volcanoes, and glacial
floods should not be a problem. The water
table is low, and liquefaction potential is
low (OIW 1975; SCS 1962).
Site terrain and’ topography would allow
construction of the LNG plant a safe
distance from the marine terminal. Distance
from the 60-foot isobath to shore is
approximately 4,000 feet. Earlier studies
(OIW 1975) indicated acceptable anchoring at
depths less than 200 feet and an adequate
maneuvering area (2,000 feet minimum).
Navigation aids are present and the state
requires a licensed coastal pilot for
vessels moving up Cook Inlet above Kachemak
Bay.
A number of prominent rock outcrops
occur along the shoreline of Boulder Point,
particularly on the north side. The
National OCeanic and Atmospheric
Administration’s (NOAA) National Ocean
Survey charts warn of numerous uncharted and
dangerous submerged boulders in the eastern
portion of Cook Inlet, and some shoaling
also exists along the east side of the
inlet. Projected dangers from tsunamis are
minimal due primarily to low predicted wave
height, historical resistance of central
Cook Inlet to earthquake-caused tsunamis,
and existence of the Alaska Regional Tsunami
Warning System (OIW 1975).
Floating ice and icing conditions can be
severe problems in this area, and extreme
tidal exchanges are generally strong in this
area (BLM 1976; OIW 1975). Ice in Cook
Inlet would be an inherent winter hazard,
requiring ice strengthening of LNG tankers,
advance scheduling, and two berths. Six out
of 13 accidents recorded in Cook Inlet
during a four-year study period (1971-1974)
were due to ice. The ice problem is most
severe in the upper inlet, particularly
north of the forelands, a constriction shown
in Figure 2.9.2-2. LNG shipments to/from
the existing Nikiski facility have been
delayed due to ice or strong winds, though
only for short periods of time (OIW 1975).
Increased LNG tanker traffic due to the TAGS
project might, however, increase the
incidence of such delays.
Appendix D
Page 6 of 13
SECTION 2.0 DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES
The Cook Inlet-Boulder Point alternative
would require construction of approximately
791 miles of pipeline and 10 compressor
stations.
The basic project components for the
Cook Inlet-Boulder Point alternative would
be similar to the proposed TAGS project.
The pipeline route from Prudhoe Bay to near
Livengood for the proposed project and the
Cook Inlet-Boulder Point alternative would
be the same. Likewise, the proposed
project’s approach to road crossings,
elevated and below-ground river and stream
crossings, fault crossings, and other basic
construction techniques would be the same
for the remainder of the route.
The major differences in construction
would be for those conditions specific to
the Cook Inlet alternative route that would
require different construction techniques,
such as the subsea pipeline under Cook
Inlet, the approach to the pinch point near
Denali National Park and Preserve, and the
major access roads required for access to
the compressor stations located in Minto and
Susitna flats.
Table 2.9.3-1 summarizes the major
facility components that would be required
for the Cook Inlet alternatives compared to
those for the proposed project.
In addition to the 15 construction camps
which would be required from Prudhoe Bay to
Livengood (see Subsection 2.3.1), 13
additional new construction campsites would
be required from Livengood to Boulder
Point. The locations of these sites are
shown in Alignment Map 3 and the sizes
identified in Table 2.9.3-2. Unlike the
proposed route, which would use existing
camp pads, except at Anderson Bay, all sites
would require the construction of a gravel
pad. Total bed space would be similar to
that proposed for the proposed project.
It is assumed that the amount of mineral
materials needed for the construction
spreads for the Cook Inlet-Boulder Point
alternative from Livengood to Boulder Point
would be similar to that shown in Table
2.3.2-1 for the proposed TAGS project except
that increased amounts of material would be
required for permanent access roads to the
Minto and Susitna Compressor Station and the
new construction camp pads.
2.9.3 System Components for the Cook
Inlet-Boulder Point Alternative
2-63
Table 2.9.3-1
Summary of Major Facility Components
for the Proposed Project and Alternatives
Proposed Cook Inlet-
Project- Boulder
Anderson Point
Bay AlternatiVE
Pipeline to LNG 797 791
Site (miles)
Compressor Stations 10 10
Elevated River 4 6
Crossings
Subsea Pipeline None 15
(miles)
Length of Loading less greater
Line (miles) than 1 than 1
Ferry Loading Yes No
Construction Camp Yes Yes
at LNG Plant/
Terminal Site
Construction Camps 1 13
at New Sites
Table 2.9.3-2
Temporary Construction Camps and Storage Pads
Livengood to Boulder Point
Bed Staces Pipeline
pipe hne ompressor Storage
.Location –f.L!:..- Station ~
Compressor Station 6A 200 300 Yes
Ounbar 800 Yes
Compressor Station 7A 300 No
Rex 600 Yes
Healy/Compressor Station 8A 500 300 Yes
Cantwell 600 Yes
Chul itna/Compressor Stat ion 9A 500 300 Yes
Talkeetna 600 Yes
Kashwitna 600 Yes
Compressor Station lOA 100 300 Yes
Beaver Lake 600 Yes
Otter Creek 400 Yes
Boulder Point 100 1500* No
TOTALS 5600 3000
* LNG Plant/Marine Terminal
Appendix D
Page 7 of 13
SECTION 2.0 DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVES
Proposed Cook Inlet-
Project Boulder
Anderson Point
Bay Alternative
Pipeline Criteria
— MMainxiimmiizzee ul~sengtohf eoxf-ipstiipneglininefrastructure 0 0 0 ~ – Maximize use of proven construction techniques 0 0 – Maximize opportunity for parallel construction techniques 0 ~ – Avoid areas of potential geohazards 0 0 – Minimize potential conflicts with sensitive environments 0 ~ – Maximize compatibility with current and planned land use 0 ~ – Minimize the number of water crossings 0 0 — Avoid permitting conflicts 0 • Minimize potential threat to national security 0 ~ – Maximize availability of gas to Alaska consumers 0 0
LNG Plant Criteria
– Adequacy of available land 0 0 – Avoid areas with poor foundation characteristics 0 ~ – Avoid areas with faults @ @ — MAvinoiidmizseitelesngptohteonftipailplyelienxepotsoedmtaorinseeistmerimc inseaal waves 00 0~ – Maximize use of existing community infrastructure @ 0 – Avoid sensitive environmental habitat ~ ~ – Public safety considerations 0 ~ – Maximize value added industrial opportunities @ ~ – Minimize site preparation requirements @ 0
Marine Terminal Criteria
– Minimize exposure to extreme oceanographic conditions 0 0 – Minimize distance from shore to 60′ MLLW depth 0 ~ – Maximize suitability of tanker maneuvering and anchorage area 0 @ – Minimize potential hazards to navigation 0 0 — Minimize potential problems related to soils and geohazards 0 0 Minimize threat to national security @ ~
NOTE: Individual criteria cannot be weighted on an equal basis.
Figure 2.9.5-1
Criteria Evaluation Matrix for Proposed TAGS Project
and Cook Inlet-Boulder Point Alternative
2-68
o Favorable
® Moderately Favorable
@ Unfavorable
• Highly Unfavorable
Appendix D
Page 8 of 13
SECTION 3.0 AFFECTED ENVIRONMENT OF THE PROPOSED ACTION AND ALTERNATIVES
The
identified
the North
In 1985 the total employment in Valdez
was 1,850–15 federal government workers,
399 state employees, 311 local government
workers, and 1,125 employees of private
companies. About 200 people are employed by
Alyeska.
Table 3.2.2-4 summarizes the enormous
increase in the Valdez tax base which
occurred due to construction of ,TAPS. In
1970 Valdez had an assessed valuation of
only $35 millio~. In 1978 the assessed
valuation was $1.7 billion and has remained
fairly constant at that level. The oil and
gas property within the city limits accounts
for more than 90 percent of the community’s
assessed valuation. Depreciation in the
value of TAPS is expected to seriously erode
the community’s tax base over the next two
decades.
3.2.3 Land Use and Ownership
3.2.3.1 Introduction
The proposed pipeline with its
associated compressor stations and LNG plant
and terminal have the potential to alter the
present land use of the existing pipeline
route to a certain extent. The
following subsection discusses the existing
land use of the route and the nearby
area in order to establish a framework for
the discussion of potential TAGS project
impacts to land use.
3.2.3.2 General Land Use Patterns
The proposed TAGS project would be built
primarily on federal and state land within
an existing utility corridor that contains a
public/private road, a major oil pipeline,
and Federal lands that have been authorized
to contain chilled gas ANGTS pipeline.
Therefore, the corridor area and its
vicinity is already partially
industrialized, even though it may be
surrounded in many areas by undeveloped,
essentially inaccessible country.
Throughout the corridor area, there
are numerous existing land use plans and
programs, and the TAGS project must be
consistent with them or prior to
construction, secure a variance.
following plans and programs are
for the proposed TAGS corridor:
3-12
Slope Borough comprehensive Land Use Plan,
the North Slope Borough Coastal Management
Program, Utili ty Corridor Draft Resource
Management Plan (Federal–BLM), Fairbanks
North Star Borough Comprehensive Land Use
Plan, Tanana Basin Area Plan (State–DNR),
Tanana Valley State Forest Management Plan,
Delta-Salcha Area Plan, Copper River Basin
Area Plan (Si:ate–DNR), Delta and Gulkana
Wild and Scenic Rivers Plans (Federal–BLM),
Draft Prince William Sound Area Plan
(State–DNR), City of Valdez Comprehensive
Land Use Plan, and Valdez Coastal Management
Program. Other approved plans or studies
include: Corridor Management Framework Land
Use Plan, and Denali Scenic Highway Study
(Federal–Alaska Land Use Council).
Since the utility corridor was
established by the federal government in
1971, portions have been transferred to
state and Native ownerships. This is
especially true between the Yukon River and
Fairbanks and in the Copper River drainage
where in three instances federal lands
within the Utili ty Corridor, wi thdrawn by
PLO 5150, as amended, transferred to the
State of Alaska the segment Yukon River to
Washington Creek; to ATHNA Region and/or
several villages scattered acreage between
sourdough and Pippin Lake areas; and to
Chugach Natives small acreage in the
vicinity of Tonsina south of Pippin Lake
area. Appendix -F shows the generalized
land-ownership along the route TAGS
proposes. Presently land ownership along
this route is approximately 45 percent state
(either patented, tentatively approved, or
pending), 50 percent federal (under BLM,
military, or USFS jurisdiction), 5 percent
Alaska Native or in other private ownership.
In the Prudhoe Bay area the land is
primarily state-owned industrial (oilfield
development and production), with some sporl
and subsistence hunting occurring outside
the lease area and pipeline corridor and
fishing along the coast and the
Sagavanirktok River. Subsistence and
commercial fisheries for whitefish exist in
the colville River Delta.
Federal lands located north of the
68-degree parallel close to TAGS have been
initially screened for wilderness
opportunities. Lands determined to possess
wilderness characteristics are not available
for any use until such time as Congress
Appendix D
Page 9 of 13
SECTION 4.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION AND ALTERNATIVES
and airstrips would result in substantial
direct losses of vegetation. In this regard
it is noteworthy that the area disturbed in
developing material sites during the TAPS
project construction (including the Dalton
Highway) was significantly greater than was
initially estimated (12,200 acres versus
5,760 acres) (Pamplin 1979). Approximately
29 percent of the surface area directly
disturbed by TAPS material sites involved
wetlands. This proportion would be lower
during TAGS construction because of lower
demand for gravel and greater attention
to site selection to minimize destruction of
wildlife habitat and wetlands in the arctic
drainage area.
Construction of the TAPS material sites,
Dalton Highway, and work pad accounted for
the majority of damage to terrestrial
habitats by that project (Pamplin 1979).
The extensive use to be made of existing
gravel pads for the proposed TAGS facilities
would mitigate a substantial portion of the
adverse impacts expected from material
extraction and placement. Adherence to
recommended guidelines for gravel mining
(Burger and Swenson 1977; Noodward-elyde
Consultants· 1980) would further mitigate
adverse impacts. Nevertheless, the
additional losses of vegetated habitats
through these activities would constitute a
major component of the expected impacts.
Any loss of riparian willow habitat in
arctic floodplains would potentially be
disruptive in view of its high value as
wildlife habitat and its limited occurrence
(Hernandez 1974; Pamplin 1979). Impacts are
expected to be moderate.
The impoundment of water caused by the
disruption and alteration of surface
drainage patterns due soil compression;
permafrost degradation; trenching;
erosion-control measures; grading; and
gravel pad, access road, and pipeline mound
construction would constitute major, though
generally localized, impacts on vegetation
and wetlands (FPC 1976b). Inhibition of
cross-drainage would cause ponding and
thermal.erosion on the upslope side of
linear gravel structures and gradual drying
of habitats on the downslope side.
Both types of impact would result in
changes in species composition over the long
term and in direct mortality of some plants
in the short term (Hernandez 1974). Gully
4-63
erosion downslope, induced by the
concentration of flow through culverts onto
ice-rich soils not previously subjected to
such flow, would also occur in some areas
(Brown and Berg 1980). Ponding problems
would be exacerbated by clogging of culverts
through icing and road-maintenance
activities. Careful attention to terrain
and drainage features in” the placement of
culverts and low-water crossings, coupled
with proper maintenance, would mitigate some
of these impacts. However, alteration of
drainage patterns would constitute a
principal construction-related impact on the
vegetation communities and wetlands along
the proposed route, particularly on the
coastal plain. The overall impact is
expected to be minor to moderate, depending
on topography.
Dust fallout from vehicular traffic on
gravel roads would occur throughout the life
of the proposed project but would
undoubtedly peak during the construction
phase. This impact would be most noticeable
along the Dalton Highway. Studies along the
Dalton Highway have demonstrated that some
plant species, especially certain mosses and
lichens, are sensitive to road dust, and a.
few’ species appear to respond positively to
it (E~erett 1980; Alexander and Van Cleve
1983). Thus, some changes in species
composition near gravel roads would be
anticipated. In addition, the accumulation
of dust on the snow within 100 to 300 feet
of heavily traveled roads causes early snow
melt (Everett 1980), which accelerates the
chronology of growth of plants near the road
by perhaps as much as two to three weeks.
On the other hand, the chronology of plant
growth would be delayed in areas where
snowdrifts persist in spring as a result of
snow accumulation along access roads and
near project structures.
Accidental spills and leaks of toxic
fluids such as fuels and antifreezes would
occur throughout the life of the project but
would be most like~y during construction.
The direct impact on vegetation would be
considerable in localized areas and would
vary according to the amount spilled, the
terrain, and the season of the year (EEl
1977). Such spills would be especially
serious in riparian zones and wetlands.
Careful construction practices would reduce
the frequency and size of spills, and
Appendix D
Page 10 of 13
SECTION 4.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION AND ALTERNATIVES
The proposed TAGS route traverses
Keystone Canyon for approximately 4 miles
along the Richardson Highway. Both are
routed near the Lowe River which is incised
in a steep-walled canyon. Except where TAGS
proposes to route the pipeline through the
Old Richardson Highway tunnel,
pipeline/highway co-use is proposed. The
Keystone Canyon Railroad Tunnel has been
proposed as a National Historical Landmark,
see Subsection 4.2.16.2.1 ..
For the sections north and east of the
tunnel, a temporary bypass would be
constructed in the Lowe River floodplain to
allow traffic to pass without significant
delay during normal construction
operations. The TAGS pipeline would be
routed through the tunnel. Construction
would be coordinated with DOT/PF to keep
summer highway traffic delays to a minimum.
The Blueberry Lake SRS is a 192-acre
scenic area established on state lands in
1972 by the State of Alaska as a day-use
area in a scenic alpine high country
setting, located on the south side of
Thompson Pass adjacent to the Richardson
Highway. Use is primarily during the summer
tourist season.
The proposed TAGS pipeline crosses the
Blueberry Lake SRS along the western part of
the property. Route options to the east of
the SRS boundary are precluded by a
rugged terrain immediately adjacent to the
east SRS boundary that leads to Heiden
Canyon. An optional route along the
abandoned state highway was rejected because
it involved more impact directly to the
SRS property and use areas. During
summer construction the typical impacts
related to the construction of a pipeline
would occur, which would exclude use of part
or all of the area during the single .
construction season with moderate impacts.
Once construction is completed, the
right-of-way would be revegetated to a
manner similar to the nearby TAPS. Overall
impacts are considered minor.
4.2.19.20
4.2.19.21
Blueberry Lake State
Recreation Site (SRS)
(Milepost 765)
Keystone Canyon (Milepost
770.8 to 774.5)
Traffic would be carefully controlled on a
24-hour-per-day basis by means of
radio-equipped flagmen and a pilot car to
reduce traffic impacts. Construction
through the canyon should not impact
Ruddleston Falls or the Goat Trail located
on the rock cliffs above the highway.
DOT/PF is concerned about the potential
impact during construction or operations
should a landslide occur, closing this pinch
point. This is the only land route from
Valdez to other areas of the state.
Completion of the new state highway through
Keystone Canyon and Thompson Pass and the
construction of TAPS have provided a
baseline of data and experience for the
proposed TAGS project. No evidence of rock
failure was observed in Keystone Canyon
during the 1964 earthquake, and there has
been an excellent record of highway
performance. There is a concern about the
potential for creating localized unstable
rock slopes by the undercutting or
day-lighting of discontinuities in the
bedrock during construction of the
pipeline. The failure of a locally undercut
or day-lighted bedrock section would create
additional traffic delays and increased
requirements for rock reinforcement. Since
construction through the canyon would be
limited to short 200- to 400-foot sections,
the extent of a potential problem area and
its potential impact would be limited to
relatively short and manageable durations.
YPC would conduct detailed field
investigations to accomplish geologic
mapping, core and soil borings and testing,
ground-water investigations, surface water
hydrology, and rock slope stability
evaluations. The detailed design and
construction plan for TAGS would be based on
the results of the field investigation and
evaluation and would be coordinated with the
DOT/PF during the final design phase.
Coordination of blasting and excavation
procedures, rock reinforcement requirements,
traffic control, and safety are considered
to be a necessary part of a successful
design by YPC.
4.2.19.22 Canyon Slough Area (Milepost 780)
Canyon Slough is located within a
portion of a highly productive salmon
habi tat .area along the south side of the
4-104
Appendix D
Page 11 of 13
SECTION 4.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION AND ALTERNATIVES
4.3.9.2 Nenana River to Summit
Through this area the primary challenge
would be to coordinate the drainage design
with that existing for the railroad and the
General types of hydrologic impacts that
may arise along the Cook Inlet-Boulder Point
alternative route are the same as those for
the primary route described in Subsection
4.2.9. The following paragraphs identify
specific impacts most applicable to various
segments of this alternative route.
4.3.9.1 Livengood to the Nenana River
Permanent effects would accrue from the
need to provide permanent access along the
50-mile portion of this route that is not
connected to the existing road or railroad
system. To ensure year-round access, the
TAGS access road would have permanent
bridges and culverts. The route would also
require development of material sites to
supply gravel for both the work pad and
access road. This would possibly cause
major and long-lasting disturbances to an
undisturbed area. Hydrologic impacts would
result from the introduction of sediment and
pollutants into Minto Flats. Erosion
control would be particularly difficult due
to the instability of the ice-rich silts on
the’ hill slopes and because of the tendency
of the streams to ice. A compensating
effect would be improved access for TAGS oil
spill control and cleanup activities should
,they be necessary. Overall, impacts would
be expected to be moderate for this area.
The Tanana and Nenana river crossings
are in a very unstable area. As a result of
pipeline construction, or due to natural
activities which constrict the river, ice
jams could divert the Nenana River through
anyone of the existing distributaries
forming its junction with the Tanana. This
could breach the alternative route between
the crossings, endanger the pipeline, and
alter the existing geometry of both the
Tanana and Nenana rivers. These changes in
geometry could affect navigation on the
Tanana and conceivably increase risks of
flooding. Impacts would be expected to be
moderate.
highway so as to not accelerate erosion for
either of the existing systems. Impacts
would be major should such acceleration
occur.
Impacts are primarily from
construction-related erosion and would most
likely be minor.
4.3.9.3 Summit to Cook Inlet
Through both the Chulitna and Susitna
portions of section, the prime hydrologic
impacts of the pipeline would be the
potential for affecting the water quality of
the existing streams or altering hydraulics
of the adjoining highway or railroad
drainage structures.
Primary hydrologic impacts in the Willow
to Cook Inlet section would be constructionrelated
pollution and erosion. Additional
long-term impacts to water quality might
arise because of improved access to an
otherwise inaccessible area. Impacts would
probably be minor in this section.
4.3.10 Marine Environment
The marine environment could affect or
be affected by project construction or
operation in ways similar to those described
for the proposed project (Subsection
4.2.10.1). The Cook Inlet-Boulder Point
alternative is notably different from the
proposed project in its additional
requirement for a 15-mile subsea pipeline.
This introduces a major construction
activity into the marine environment and
subjects the project to an additional
potential impact from’accidents and pipeline
maintenance or repair. There are several
major differences in the characteristics of
the marine environment for the Cook
Inlet-Boulder Point alternative that
influence potential environmental impacts.
The presence of tidal extremes in excess of
30 feet vertical height and accompanying
currents reaching as high as 6 to 7 knots
present major problems to marine
construction, facility design, and routine
operations and would also increase the
potential for accidents. Extreme winter
icing conditions would increase the
4.3.9.4 Cook Inlet to Boulder Point
4.3.9 ,Surface and Ground Water
4-110
Appendix D
Page 12 of 13
SECTION 4.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION AND ALTERNATIVES
probability that operations would have to be
curtailed at times and would also increase
the potential for accidents. Extensive
shoaling areas off the East Forelands just
south of Boulder Point would require some
dredging and pose potential navigational
hazards, while sedimentation, scour, and the
presence of mobile submarine bedforms would
affect engineering design suitability for
marine terminal facility offshore components.
Burial of the pipe crossing Cook Inlet
deeply enough to ensure it would not be
exposed by scour or endangered by ships
anchors would”be difficult. Winter
construction or repair would be practically
impossible because of floating ice and the
extreme tidal current. To ensure dependable
service, two crossings might be necessary.
The crossings would need to be widely
separated so that in the event one fails,
flow could be maintained by diverting gas to
the other crossing. Impacts in this area
would likely be minor related mainly to
potential to increased silt loading and
interference with ship traffic. All these
factors make construction of the pipeline
crossing and construction and maintenance of
the marine terminal more difficult and
possibly make the entire systems more
susceptible to accidents during operations.
There is less deepwater turning room for
tanker maneuvering and anchoring in Cook
Inlet, which has a narrow channel and major
potential problems with ice in the winter
season. There is the additional possibility
that a vessel could anchor in the vicinity
of the pipeline crossing and perhaps drag
its anchor across the pipe. The subsea
transmission line from the west side of Cook
Inlet has been broken in this manner,
causing electrical outages in Anchorage.
Even though the pipeline would be jetted
into the bottom, much of the jetted silt
would not settle back over the line due to
the currents. Eventually, the pipeline
trench would be filled in with silt.
The marine terminal pilings could cause
sediment to accumulate or erode due to
changes in current patterns, resulting in
sills being created or producing a deeper
channel which could impact marine operation.
The potential effect of the facility or
resultant tanker traffic on marine birds,
fish, or mammals would be negligible. There
is an increased possibility of an oil spill
due to increased ship traffic in the area;
and such a spill could cause damage to the
local clam beds or affect bald eagle
populations which gather each summer at the
mouths of most Cook Inlet rivers. Spills
would be difficult to control or clean up in
the area during high winds and/or broken ice
conditions.
The possibility also exists for
collision of a beluga whale with a ship.
Once out of Cook Inlet and on the high
seas, LNG tanker traffic would follow the
general route of LNG tankers that have been
successfully delivering Cook Inlet LNG to
Tokoyo for the past 17 years. No new
impacts are expected to the high seas marine
environment.
4.3.11 Fish Impacts
Since construction techniques,
mitigation procedures, and types of streams
involved are similar, impacts to fish along
the Cook Inlet-Boulder Point-alternative
route would be similar to those described
for the proposed route in Subsection
4.2.11. Those areas where impacts would be
different are discussed below. .
More fishing pressure, resulting from
fishing by construction workers, and,
possibly, from improved access for
recreational fishermen would result in
increased stress to fish populations during
TAGS construction and possibly operation
along the Cook Inlet-Boulder Point
alternative route. There is also a chance
that some existing, heavily.used areas would
have restricted access after construction
due to creation of an exclusion or security
zone around some TAGS-related facilities,
resulting in a shift of existing fishing
pressure to other Cook Inlet fish
resources. Much of this can be regulated.
A number of access roads, work pads, and
culverts crossing many streams could result
in temporary blockage or erosion with
resultant turbidity of small streams and
cross drainages along the Cook Inlet-Boulder
Point alternative route. Excavation of a
greater number of new materials sites would
have the potential for similar impacts.
Impacts would probably be moderate during
construction and minor during operation.
There would be minor impacts from the
compressor stations, LNG plant, or marine
4-111
Appendix D
Page 13 of 13

Appendix E
Page 1 of 7
2 LUNG.org AMERICAN LUNG ASSOCIATION STATE OF THE AIR 2016
Acknowledgments The American Lung Association “State of the Air® 2016” is the result of the hard work of
many people:
In the American Lung Association National Office: Paul G. Billings, who supervised the
work; Janice E. Nolen, MA, who directed the project, analyzed data, wrote the text, and
coordinated print and web presentations; Thu Anh Vu Tran, who assisted with the data
analysis and report preparation; Lyndsay Moseley Alexander and Laura Kate Bender, who
integrated the Healthy Air Campaign with this report; Zach Jump, MA, who converted the
raw data into meaningful tables and comparisons and calculated all the population data;
Susan Rappaport, MPH, who supervised the data analysis; Norman Edelman, MD, and Al
Rizzo, MD, who reviewed the science and health discussions; Neil Ballentine, who directed
the online presentation; Todd Nimirowski, who designed and created the user experiences
online; Lauren Innocenzi and MacKenzie Olsberg, who managed content production
online; Laura Lavelle, who developed social sharing and digital engagement strategy;
Kim Lacina, Allison MacMunn, and Gregg Tubbs, who coordinated internal and external
communications and media outreach; Michael Albiero, who designed the logo and report
cover; and Craig Finstad, who coordinated sharing the data with direct mail donors.
In the nationwide American Lung Association: All Lung Association charters reviewed
and commented on the data for their states. Hard-working staff across the nation went
out of their way to ensure that their state and local air directors were informed and had
a chance to review the draft data.
Outside the American Lung Association: Allen S. Lefohn of A.S.L. and Associates, who
compiled the data; Deborah Shprentz, who assisted with the research and review of the
science; Beaconfire RedEngine Consulting, who uploaded the data to the website; and
Our Designs, Inc., who designed the print version.
Great appreciation goes to the National Association of Clean Air Agencies, who along
with their Executive Director Bill Becker, strove to make this report better through their
comments, review and concerns. Many of their members reviewed and commented
on the individual state data presented and the methodology to make this report more
accurate. We appreciate them as our partners in the fight against air pollution. This
report should in no way be construed as a comment on the work they do.
The American Lung Association assumes sole responsibility for the content of the
American Lung Association “State of the Air® 2016”.
American Lung Association
National Headquarters
55 W. Wacker Drive, Suite 1150
Chicago, IL 60601
Advocacy Office
1301 Pennsylvania Avenue, NW, Suite 800
Washington, DC 20004
Phone: 1 (800) 586-4872
Fax: (202) 452-1805
www.stateoftheair.org
www.Lung.org
Copyright © 2016 by the American Lung Association
American Lung Association, State of the Air, and Fighting for Air are registered
trademarks of the American Lung Association.
Fighting for Air
Designed by Our Designs, Inc., Nashville, TN
Appendix E
Page 2 of 7
RANKINGS
14 LUNG.org AMERICAN LUNG ASSOCIATION STATE OF THE AIR 2016
People at Risk In 25 U.S. Cities Most Polluted by Short-Term Particle Pollution (24-hour PM2.5)
2016 Total 65 and Pediatric Adult CV
Rank1 Metropolitan Statistical Areas Population2 Under 183 Over3 Asthma.4,6 Asthma5,6 COPD7 Disease8 Diabetes9 Poverty10
1 Bakersfield, CA 874,589 257,512 86,198 22,811 47,274 27,545 39,611 58,509 206,604
2 Fresno–Madera, CA 1,120,522 321,538 127,627 28,482 61,434 37,066 54,190 78,465 293,929
3 Visalia–Porterville–Hanford, CA 608,467 186,159 61,302 16,490 32,302 18,893 27,286 39,992 160,479
4 Modesto–Merced, CA 798,350 225,241 92,260 19,952 44,214 26,914 39,399 57,132 160,041
5 Fairbanks, AK 99,357 23,924 7,913 2,205 5,999 2,938 3,875 4,764 9,011
6 Salt Lake City–Provo-Orem, UT 2,423,912 749,941 222,480 50,564 145,851 59,401 93,542 115,627 267,966
7 Logan, UT—ID 131,364 41,232 11,968 2,889 7,834 3,153 4,831 5,817 17,696
8 San Jose–San Francisco–Oakland, CA 8,607,423 1,876,296 1,168,168 166,204 523,893 330,069 488,003 703,447 968,270
9 Los Angeles–Long Beach, CA 18,550,288 4,419,138 2,287,192 391,452 1,093,121 670,009 981,745 1,425,473 3,174,300
10 Missoula, MT 112,684 21,839 15,363 1,555 8,935 5,475 5,801 6,945 17,216
11 Reno–Carson City–Fernley, NV 597,837 130,592 97,747 8,848 38,360 34,676 45,621 47,522 89,277
11 Lancaster, PA 533,320 128,671 87,385 13,929 39,794 27,486 39,175 44,979 54,499
13 El Centro, CA 179,091 51,111 21,523 4,527 9,863 6,046 8,897 12,791 40,162
14 Pittsburgh–New Castle–Weirton, PA—OH—WV 2,653,781 512,313 489,155 55,262 210,546 154,349 218,588 249,655 331,578
15 Yakima, WA 247,687 73,891 31,719 4,826 16,075 10,398 12,998 14,992 50,044
16 Anchorage, AK 398,892 101,730 36,091 9,374 23,752 12,587 16,994 20,760 39,450
1 7 Sacramento-Roseville, CA 2,513,103 592,935 358,196 52,523 149,894 96,523 144,007 205,390 397,024
18 Philadelphia–Reading–Camden,
PA—NJ—DE—MD 7,164,790 1,601,349 1,058,447 164,662 520,226 350,165 491,940 577,817 950,284
18 Harrisburg–York–Lebanon, PA 1,239,677 271,569 204,056 29,398 95,249 66,506 94,211 108,812 129,647
20 El Paso–Las Cruces, TX—NM 1,050,374 290,708 124,863 20,269 55,486 39,945 58,111 81,066 250,142
21 Eugene, OR 358,337 68,413 62,334 4,963 29,455 16,575 24,260 26,412 64,722
21 South Bend–Elkhart-Mishawaka, IN—MI 723,537 178,540 110,538 15,281 58,635 48,571 53,112 58,902 111,135
21 Phoenix–Mesa-Scottsdale, AZ 4,489,109 1,121,933 638,383 122,364 325,041 226,682 264,470 327,660 753,716
24 New York–Newark, NY—NJ—CT—PA 23,632,722 5,198,379 3,383,979 473,026 1,812,756 1,039,620 1,392,285 1,785,585 3,281,939
25 Medford–Grants Pass, OR 293,886 60,420 63,154 4,383 23,312 14,641 22,447 24,063 54,487
Notes:
1. Cities are ranked using the highest weighted average for any county within that Combined or Metropolitan Statistical Area.
2. Total Population represents the at-risk populations for all counties within the respective Combined or Metropolitan Statistical Area.
3. Those under 18 and 65 and over are vulnerable to PM2.5 and are, therefore, included. They should not be used as population denominators for disease estimates.
4. Pediatric asthma estimates are for those under 18 years of age and represent the estimated number of people who had asthma in 2014 based on state rates (BRFSS) applied to population estimates (U.S. Census).
5. Adult asthma estimates are for those 18 years and older and represent the estimated number of people who had asthma in 2014 based on state rates (BRFSS) applied to population estimates (U.S. Census).
6. Adding across rows does not produce valid estimates. Adding the disease categories (asthma, COPD, etc.) will double-count people who have been diagnosed with more than one disease.
7. COPD estimates are for adults 18 and over who have been diagnosed within their lifetime, based on state rates (BRFSS) applied to population estimates (U.S. Census).
8. CV disease is cardiovascular disease and estimates are for adults 18 and over who have been diagnosed within their lifetime, based on state rates (BRFSS) applied to population estimates (U.S. Census).
9. Diabetes estimates are for adults 18 and over who have been diagnosed within their lifetime, based on state rates (BRFSS) applied to population estimates (U.S. Census).
10. Poverty estimates come from the U.S. Census Bureau and are for all ages.
Appendix E
Page 3 of 7
RANKINGS
15 LUNG.org AMERICAN LUNG ASSOCIATION STATE OF THE AIR 2016
People at Risk In 25 U.S. Cities Most Polluted by Year-Round Particle Pollution (Annual PM2.5)
2016 Total 65 and Pediatric Adult CV
Rank1 Metropolitan Statistical Areas Population2 Under 183 Over3 Asthma.4,6 Asthma5,6 COPD7 Disease8 Diabetes9 Poverty10
1 Bakersfield, CA 874,589 257,512 86,198 22,811 47,274 27,545 39,611 58,509 206,604
2 Visalia–Porterville–Hanford, CA 608,467 186,159 61,302 16,490 32,302 18,893 27,286 39,992 160,479
3 Fresno–Madera, CA 1,120,522 321,538 127,627 28,482 61,434 37,066 54,190 78,465 293,929
4 Los Angeles–Long Beach, CA 18,550,288 4,419,138 2,287,192 391,452 1,093,121 670,009 981,745 1,425,473 3,174,300
5 El Centro, CA 179,091 51,111 21,523 4,527 9,863 6,046 8,897 12,791 40,162
6 Modesto-Merced, CA 798,350 225,241 92,260 19,952 44,214 26,914 39,399 57,132 160,041
6 San Jose–San Francisco–Oakland, CA 8,607,423 1,876,296 1,168,168 166,204 523,893 330,069 488,003 703,447 968,270
8 Pittsburgh–New Castle–Weirton, PA—OH—WV 2,653,781 512,313 489,155 55,262 210,546 154,349 218,588 249,655 331,578
9 Harrisburg–York–Lebanon, PA 1,239,677 271,569 204,056 29,398 95,249 66,506 94,211 108,812 129,647
10 Louisville/Jefferson County–Elizabethtown–
Madison, KY—IN 1,498,593 348,103 213,057 35,700 134,900 132,472 132,990 138,376 213,396
11 Cleveland–Akron–Canton, OH 3,497,851 763,909 583,516 79,634 296,253 229,278 285,478 327,871 527,700
12 Philadelphia–Reading–Camden,
PA—NJ—DE—MD 7,164,790 1,601,349 1,058,447 164,662 520,226 350,165 491,940 577,817 950,284
13 Indianapolis–Carmel-Muncie, IN 2,353,935 581,717 304,412 46,418 190,921 152,034 157,184 183,577 342,625
14 Cincinnati–Wilmington–Maysville, OH—KY—IN 2,208,450 532,957 302,529 55,681 186,179 148,558 168,576 191,278 304,362
14 Altoona, PA 125,955 25,897 24,360 2,803 9,732 7,144 10,387 11,828 18,367
16 Houston–The Woodlands, TX 6,686,318 1,793,010 668,355 126,257 322,667 251,119 362,663 515,515 1,014,700
16 San Luis Obispo–Paso Robles–
Arroyo Grande, CA 279,083 50,639 48,977 4,486 17,852 11,905 18,081 25,139 38,048
16 Lancaster, PA 533,320 128,671 87,385 13,929 39,794 27,486 39,175 44,979 54,499
16 Johnstown–Somerset, PA 213,950 40,609 43,588 4,396 16,796 12,637 18,455 20,999 29,818
20 Detroit–Warren–Ann Arbor, MI 5,315,251 1,206,783 779,744 123,521 448,280 362,499 401,894 414,592 854,741
21 Erie–Meadville, PA 365,618 79,430 59,913 8,598 28,186 19,491 27,596 31,850 55,897
22 Birmingham–Hoover–Talladega, AL 1,317,269 305,150 195,649 40,271 96,700 102,850 119,939 129,794 227,444
23 Little Rock–North Little Rock, AR 902,443 215,116 126,381 19,823 60,518 60,538 83,498 83,957 138,677
23 Fairbanks, AK 99,357 23,924 7,913 2,205 5,999 2,938 3,875 4,764 9,011
23 Wheeling, WV—OH 145,205 28,098 27,933 2,779 12,814 13,249 15,016 15,880 22,863
Notes:
1. Cities are ranked using the highest Design Value for any county within that Combined or Metropolitan Statistical Area.
2. Total Population represents the at-risk populations for all counties within the respective Combined or Metropolitan Statistical Area.
3. Those under 18 and 65 and over are vulnerable to PM2.5 and are, therefore, included. They should not be used as population denominators for disease estimates.
4. Pediatric asthma estimates are for those under 18 years of age and represent the estimated number of people who had asthma in 2014 based on state rates (BRFSS) applied to population estimates (U.S. Census).
5. Adult asthma estimates are for those 18 years and older and represent the estimated number of people who had asthma in 2014 based on state rates (BRFSS) applied to population estimates (U.S. Census).
6. Adding across rows does not produce valid estimates. Adding the disease categories (asthma, COPD, etc.) will double-count people who have been diagnosed with more than one disease.
7. COPD estimates are for adults 18 and over who have been diagnosed within their lifetime, based on state rates (BRFSS) applied to population estimates (U.S. Census).
8. CV disease is cardiovascular disease and estimates are for adults 18 and over who have been diagnosed within their lifetime, based on state rates (BRFSS) applied to population estimates (U.S. Census).
9. Diabetes estimates are for adults 18 and over who have been diagnosed within their lifetime, based on state rates (BRFSS) applied to population estimates (U.S. Census).
10. Poverty estimates come from the U.S. Census Bureau and are for all ages.
Appendix E
Page 4 of 7
31 LUNG.org AMERICAN LUNG ASSOCIATION STATE OF THE AIR 2016
HEALTH EFFECTS
EPA Concludes Ozone Pollution Poses Serious Health Threats
■■ Causes respiratory harm (e.g., worsened asthma, worsened COPD, inflammation)
■■ Likely to cause early death (both short-term and long-term exposure)
■■ Likely to cause cardiovascular harm (e.g., heart attacks, strokes, heart disease,
congestive heart failure)
■■ May cause harm to the central nervous system
■■ May cause reproductive and developmental harm
—U.S. Environmental Protection Agency, Integrated Science Assessment for Ozone and Related Photochemical
Oxidants, 2013. EPA/600/R-10/076F.
Based on that review, the EPA set more protective limits, called national ambient air
quality standards, on ozone pollution in October 2015. These official limits drive the
cleanup of ozone pollution nationwide. The Clean Air Act requires EPA to review the
standards every five years to make sure that they protect the health of the public.
Particle Pollution Ever look at dirty truck exhaust?
The dirty, smoky part of that stream of exhaust is made of particle pollution.
Overwhelming evidence shows that particle pollution—like that coming from that
exhaust smoke—can kill. Particle pollution can increase the risk of heart disease, lung
cancer and asthma attacks and can interfere with the growth and work of the lungs.
Particle pollution refers
to a mix of very tiny
solid and liquid particles
that are in the air we
breathe. But nothing
about particle pollution
is simple. And it is so
dangerous, it can shorten
your life.
What Is Particle Pollution?
Particle pollution refers to a mix of very tiny solid and liquid particles that are in the air
we breathe. But nothing about particle pollution is simple. And it is so dangerous, it can
shorten your life.
Size matters. Particles themselves are different sizes. Some are one-tenth the diameter
of a strand of hair. Many are even tinier; some are so small they can only be seen with
an electron microscope. Because of their size, you can’t see the individual particles. You
can only see the haze that forms when millions of particles blur the spread of sunlight.
HUMAN HAIR
50-70m
(microns) in diameter
PM2.5
Combustion particles, organic
compounds, metals, etc.
< 2.5m (microns) in diameter
PM10
Dust, pollen, mold, etc.
< 10m (microns) in diameter
90m (microns) in diameter
FINE BEACH SAND
Image courtesy of the U.S. EPA
The differences in size make a big difference in how they affect us. Our natural defenses
help us to cough or sneeze larger particles out of our bodies. But those defenses don’t
keep out smaller particles, those that are smaller than 10 microns (or micrometers) in
diameter, or about one-seventh the diameter of a single human hair. These particles get
trapped in the lungs, while the smallest are so minute that they can pass through the
Appendix E
Page 5 of 7
32 LUNG.org AMERICAN LUNG ASSOCIATION STATE OF THE AIR 2016
HEALTH EFFECTS
lungs into the bloodstream, just like the essential oxygen molecules we need to survive.
Researchers categorize particles according to size, grouping them as coarse, fine and
ultrafine. Coarse particles fall between 2.5 microns and 10 microns in diameter and are
called PM10-2.5. Fine particles are 2.5 microns in diameter or smaller and are called PM2.5.
Ultrafine particles are smaller than 0.1 micron in diameter22 and are small enough to
pass through the lung tissue into the blood stream, circulating like the oxygen molecules
themselves. No matter what the size, particles can harm your health.
“A mixture of mixtures.” Because particles are formed in so many different ways, they
can be composed of many different compounds. Although we often think of particles as
solids, not all are. Some are completely liquid; others are solids suspended in liquids. As
the EPA puts it, particles are really “a mixture of mixtures.”23
The mixtures differ between the eastern and western United States and in different
times of the year. For example, the Midwest, Southeast and Northeast states have
more sulfate particles than the West on average, largely due to the high levels of sulfur
dioxide emitted by large, coal-fired power plants. By contrast, nitrate particles from
motor vehicle exhaust form a larger proportion of the unhealthful mix in the winter in
the Northeast, Southern California, the Northwest, and North Central U.S.24
Who Is at Risk?
Anyone who lives where particle pollution levels are high is at risk. Some people face
higher risk, however. People at the greatest risk from particle pollution exposure include:
■■ Infants, children and teens;25
■■ People over 65 years of age;26
■■ People with lung disease such as asthma and chronic obstructive pulmonary disease
(COPD), which includes chronic bronchitis and emphysema;
■■ People with heart disease27 or diabetes;28
■■ People with low incomes;29 and
■■ People who work or are active outdoors.30
Diabetics face increased risk at least in part because of their higher risk for
cardiovascular disease.31
Breathing particle
pollution may trigger
illness, hospitalization
and premature death.
What Can Particles Do to Your Health?
Particle pollution can be very dangerous to breathe. Breathing particle pollution may
trigger illness, hospitalization and premature death, risks that are showing up in new
studies that validate earlier research.
Thanks to steps taken to reduce particle pollution, good news is growing from
researchers who study the drop in year-round levels of particle pollution.
Looking at air quality in 545 counties in the U.S. between 2000 and 2007, researchers
found that people had approximately four months added to their life expectancy
on average due to cleaner air. Women and people who lived in urban and densely
populated counties benefited the most.32
Another long-term study of six U.S. cities tracked from 1974 to 2009 added more
evidence of the benefits. Their findings suggest that cleaning up particle pollution
had almost immediate health benefits. They estimated that the U.S. could prevent
approximately 34,000 premature deaths a year if the nation could lower annual levels of
particle pollution by 1 μg/m3.33
Other researchers estimated that reductions in air pollution can be expected to produce
rapid improvements in public health, with fewer deaths occurring within the first two
years after reductions.34
These studies add to the growing research that cleaning up air pollution improves life
and health.
Appendix E
Page 6 of 7
33 LUNG.org AMERICAN LUNG ASSOCIATION STATE OF THE AIR 2016
HEALTH EFFECTS
Short-Term Exposure Can Be Deadly
First and foremost, short-term exposure to particle pollution can kill. Peaks or spikes
in particle pollution can last for hours to days. Deaths can occur on the very day that
particle levels are high, or within one to two months afterward. Particle pollution does
not just make people die a few days earlier than they might otherwise—these are deaths
that would not have occurred if the air were cleaner.35
Even low levels of particles can be deadly. A 2016 study found that people age 65 and
older in New England faced a higher risk of premature death from particle pollution,
even in places that met current standards for short-term particle pollution.36
Particle pollution also diminishes lung function, causes greater use of asthma
medications and increased rates of school absenteeism, emergency room visits and
hospital admissions. Other adverse effects include coughing, wheezing, cardiac
arrhythmias and heart attacks. According to extensive research, short-term increases in
particle pollution have been linked to:
■■ death from respiratory and cardiovascular causes, including strokes;37,38,39,40
■■ increased mortality in infants and young children;41
■■ increased numbers of heart attacks, especially among the elderly and in people with
heart conditions;42
■■ inflammation of lung tissue in young, healthy adults;43
■■ increased hospitalization for cardiovascular disease, including strokes and congestive
heart failure;44,45,46
■■ increased emergency room visits for patients suffering from acute respiratory
ailments;47
■■ increased hospitalization for asthma among children;48,49,50 and
■■ increased severity of asthma attacks in children.51
Again, the impact of even short-term exposure to particle pollution on healthy adults
was demonstrated in the Galveston lifeguard study. In addition to the harmful effects
of ozone pollution, lifeguards had reduced lung volume at the end of the day when fine
particle levels were high.52
In late 2013, the World
Health Organization
concluded that particle
pollution could cause
lung cancer.
Year-Round Exposure
Breathing high levels of particle pollution day in and day out also can be deadly, as
landmark studies in the 1990s conclusively showed53 and as other studies confirmed.54
Chronic exposure to particle pollution can shorten life by one to three years.55 Recent
research has confirmed that long-term exposure to particle pollution still kills, even with
the declining levels in the U.S. since 200056 and even in areas, such as New England,
that currently meet the official limit, or standard, for year-round particle pollution.57
In late 2013, the International Agency for Research on Cancer, part of the World Health
Organization concluded that particle pollution could cause lung cancer. The IARC
reviewed the most recent research and reported that the risk of lung cancer increases
as the particle levels rise.58
Year-round exposure to particle pollution has also been linked to:
■■ increased hospitalization for asthma attacks for children living near roads with heavy
truck or trailer traffic;59,60
■■ slowed lung function growth in children and teenagers;61,62
■■ development of asthma in children up to age 14;63
■■ significant damage to the small airways of the lungs;64
■■ increased risk of death from cardiovascular disease;65 and
■■ increased risk of lower birth weight and infant mortality.66
Research into the health risks of 65,000 women over age 50 found that those who
Appendix E
Page 7 of 7

Fairbanks North Star Borough
Air Pollution Control Commission
Air Quality Comprehensive Plan
Framework for Healthy Air, People, and Economy
Appendix F
Page 1 of 16
Appendix F
Page 2 of 16
5
FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
Recommendations to the Mayor of the Fairbanks North Star Borough
The purpose of this Air Quality Comprehensive Plan, Framework for Healthy Air,
People, and Economy (AQ Framework) is to provide a list of actionable items to the
Fairbanks North Star Borough (FNSB) Mayor, staff, and policy makers to achieve
compliance with the Clean Air Act as expediently and economically as possible.
Executive Summary The combustion of solid and liquid fuels creates very fine
particulate matter, known as PM2.5. These particles are two and a half millionths of a
meter and smaller and cannot be seen with the naked eye. High levels of PM2.5 in the air
can lead to mild to severe human health problems and even premature death. Federal
law provides for the protection of human health and safety, and PM2.5 levels in the air
are regulated under the federal Clean Air Act.
Due to geography, climate, types of emission sources, and population density within the
FNSB, the concentrations of PM2.5 often exceed the maximum levels set by the Clean
Air Act. If PM2.5 levels exceed the maximum allowable levels on a regular basis, federal
law mandates the development and implementation of a plan to reduce and maintain
PM2.5 below the regulatory maximums. In the event that a plan is not developed that
meets EPA approval and PM2.5 levels are not reduced, the federal government can and
will impose economic sanctions, including withholding federal funds for highway
construction, reducing or eliminating federal expenditures on military bases in the area,
and creating additional challenges for the local power plants and refinery to install
emission controls or obtain permits.
Balancing an individual’s right to economic self-determination against others’ life,
liberty, and pursuit of happiness may create conflict. The AQ Framework was
developed as a tool for the FNSB, recommending methods to reduce PM2.5 in the most
effective way that protects both the individual’s freedom of choice and economic rights
and the community’s right to a healthy environment. This AQ Framework presents 1)
the health needs to reduce PM2.5; 2) the policy, economic, social, and technological
challenges faced in doing so; 3) consequences of failure in addressing the problem; 4) a
desired future scenario; and 5) limiting factors which includes lack of awareness,
affordable clean energy, high emitting equipment, and building energy efficiency. This
AQ Framework does not provide a specific plan, and instead provides a suite of ideas,
from abstract to specific, focused on moving our community toward solving these
challenges. The recommendations include changes to policy, subsidies to reduce
emissions, increased communications, and the use of technologies to protect people
Appendix F
Page 3 of 16
6
FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
from air pollution.1 The Air Pollution Control Commission (APCC) intends to revisit
and revise this AQ Framework every 3 years.
Introduction If we are to protect our health and our economy, it is vitally important
that we reduce air pollution in our community. The APCC was established “to develop
comprehensive plans for the prevention, abatement, and control of air pollution in the
borough.”2 Members of the APCC, Alaska Department of Environmental
Conservation (ADEC), FNSB residents, and state and locally-elected officials
supported the development of this AQ Framework.
Background According to the Environmental Protection Agency (EPA),
Congress designed the Clean Air Act to protect public health and welfare from
different types of air pollution caused by a diverse array of pollution sources.
The Act contains key provisions to control common pollutants, with the
intention to protect public health and welfare nationwide. The law requires the
EPA to establish national ambient air quality standards (NAAQS) based on the
latest science. The EPA also requires states to adopt enforceable plans to
achieve these standards.3
The EPA must identify and issue “air quality criteria” for pollutants that “cause or
contribute to air pollution which may reasonably be anticipated to endanger public
health or welfare” and “the presence of which in the ambient air results from numerous
or diverse mobile or stationary sources.”4 After issuing air quality criteria for a pollutant
the EPA must establish primary and secondary NAAQS for the pollutant.5 Primary
NAAQS are standards “requisite to protect the public health” and secondary NAAQS
are standards “requisite to protect the public welfare.”6
Under the Clean Air Act, states are divided into air quality control regions.7 If the EPA
issues NAAQS for a pollutant then states must, within three years, adopt and submit
1 The APCC would like to acknowledge the efforts of the Fairbanks economic Development
Corporation, through the Interior Issues Council, who hosted during the months of May and June
2015 nine meetings of interested parties known as the Air Quality Task Force (AQTF). The initial
draft of this document is a result of the efforts of these participants.
2 Fairbanks North Star Borough Code Chapter 2.48.120
3 Information accessed on June 11, 2015 at http://www.epa.gov/air/caa/pdfs/CAA_Nutshell.pdf.
4 42 U.S.C. § 7408(a)(1) (2012).
5 Id. § 7409(a)(1)(A).
6 Id. § 7409(b)(1)-(2).
7 Id. § 7407.
Appendix F
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FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
state implementation plans (SIPs), specifying the manner in which the state will achieve
and maintain the NAAQS for each of the state’s air quality control regions.8
If the air quality in a control region falls short of NAAQS for a criteria pollutant then
the region is designated in nonattainment for that pollutant. 9 States with nonattainment
areas are required to devise and carry out additional SIP measures in order to improve
air quality. 10 Generally, SIPs must provide for attainment of the NAAQS within five
years of a nonattainment designation. 11 But the EPA may, after taking into account
the severity of the nonattainment and the availability of pollution control measures, conclude
that additional time is warranted and extend the period for attainment up to an additional five
years. 12
The Clean Air Act includes provisions to ensure states and local communities submit and
implement adequate SIPs. Sanctions are applied if the agency finds a state has failed to
submit or carry out an adequate SIP, or if the EPA disapproves a submitted plan.13 If
the state has not cured the deficiency within 18 months of the EPA’s finding or
disapproval then the EPA may restrict the state’s use of federal highway funds in the
nonattainment area or require offsetting emissions reductions, at a two-to-one ratio,
for new or modified major stationary sources in the nonattainment area.14
If the deficiency is not remedied within two years of the EPA’s finding or disapproval
then the EPA must impose both sanctions.15 And if the EPA finds a state has not
submitted an approvable SIP demonstrating attainment within two years, or if the EPA
disapproves a SIP after two-years nonattainment, then the EPA is required to develop a
federal implementation plan to ensure air quality improvement.16
State of Alaska Mandate Article 7, Section 4 of the Alaska Constitution states,:
“The legislature shall provide for the promotion and protection of public health.” The
legislature has declared that “[i]t is the policy of the state to conserve, improve, and
protect its natural resources and environment and control water, land, and air
pollution, in order to enhance the health, safety, and welfare of the people of the state
and their overall economic and social well-being.” Pursuant to this policy the
legislature established the Alaska Department of Environmental Conservation
8 Id. § 7407, 7410.
9 Id. § 7407(d).
10 Id. § 7502.
11 Id. § 7502(a)(2)(A).
12 Id.
13 Id. § 7509.
14 Id. §§ 7503, 7509.
15 Id. § 7509(a)-(b).
16 Id. § 7410.
Appendix F
Page 5 of 16
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FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
(ADEC). Within the ADEC is the Division of Air Quality, which “prevents, abates and
controls air pollution in a cost-effective, accountable manner.” The Division oversees
three programs:
• The Air Non-point and Mobile Sources Program is responsible for managing
mobile and area air pollution sources. Its mission is to protect public health and the
environment by working to achieve ambient clean air standards throughout Alaska.
• The Air Permit Program controls significant, stationary sources of air pollution to
protect and enhance air quality, abate air pollution impacts, and ensure protection
of public health and the environment.
• The Air Quality Monitoring Program undertakes air quality assessments to provide
measurement of air quality conditions to support decision making related to
improving or preserving clean air.
FNSB Setting The FNSB is a second-class, general law Borough. “The Borough
has the following general powers, subject to other provisions of law . . . To establish
and prescribe the functions of a borough department, office, or agency . . . To
enforce an ordinance and to prescribe a penalty for violation of an ordinance.”17
The FNSB is located in the interior region of Alaska and covers 7,444 square miles.
The population is approximately 100,000 people living predominantly in and around
the cities of Fairbanks and North Pole. There are approximately 41,607 housing
units,18 153,333 total vehicles,19 and eight stationary sources which includes power plants
or refineries. 20 The physiographic setting and climate are described as “sub-arctic
interior river valley.” The FNSB is located at the edge of an area where air masses
remain in place for long periods of time due to low wind speed and cold temperatures.
This stagnating air, combined with wintertime radiative cooling leads to strong lower
atmospheric inversions. This is exacerbated in and around the cities of Fairbanks and
North Pole because they are surrounded by hills on three sides.
EPA adopted a NAAQS for particulate matter (PM) pollution 2.5 microns or less in
diameter (PM2.5). The following table provides the current PM2.5 NAAQS.
17 Information accessed on June 11, 2015 at
http://www.codepublishing.com/AK/FairbanksNorthStarBorough/?FairbanksNSB15/FairbanksNSB
1504.html.
18 Information accessed on June 9, 2015 at http://quickfacts.census.gov/qfd/states/02/02090.html.
19 Information accessed on June 9, 2015 at http://doa.alaska.gov/dmv/research/curreg14.htm.
20 ADEC SIP Appendix III.D.5.6-6.
Appendix F
Page 6 of 16
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FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
National Ambient Air Quality Standards
Particulate Matter PM2.5
Averaging
Time Level Form
24-hr 35 μg/m3 Not to exceed more than once per year on average over 3 years
3 years 35 μg/m3 98 percentile, average over 3 years
Annual 12 μg/m3 Annual mean, averaged over 3 years
In 1997, the EPA established the first annual and 24-hour NAAQS for PM2.5. In 2006,
the EPA strengthened the 24-hour ambient PM2.5 standard from 65 micrograms per
cubic meter (μg/m3) to 35 μg/m3. States were required to examine monitoring data
collected within their communities and to make designation recommendations based on
the new standard by December 2007. Compliance with ambient air quality standards is
based on the calculation of a “design value” for individual monitors consistent with the
calculation of the applicable standard. For the 24-hour ambient PM2.5 standard, the
design value is calculated from the 3-year average of annual 98th percentile values.
In 2009, the EPA designated Fairbanks as nonattainment for the 24-hour PM2.5 standard
using measurements collected at the State Office Building over the previous 3-year
period, 2006 – 2008. The 98th percentile value for each of those years was 42.2 μg/m3,
33.1 μg/m3 and 46.7 μg/m3; collectively they produced a PM2.5 design value of 41
μg/m3 for the 3-year period ending in 2008. Design values are updated each year, based
on the previous 3-years of data.21
Source of FNSB PM2.5 Emissions PM2.5 within the nonattainment area consists
mainly of organic carbon, sulfate, nitrate, and ammonia. And in the summer, wildfires
can contribute to PM2.5 exceedance days. To determine the exact local PM2.5 sources,
the FNSB examined air pollution from three permanent air quality monitoring stations
in downtown Fairbanks: a multi-pollutant station at the FNSB Administrative Center; a
micro-scale station at the Old Post Office building; and a neighborhood-scale station at
the State Office Building. In 2012 the North Pole Fire Station on Hurst Road (also
known as North Star Fire Station), a micro-scale station, also began collecting air
pollution measurements.
According to Ward et al22
21 State of Alaska Fairbanks PM2.5 Moderate State Implementation Plan December 24, 2014
22 Source Apportionment of PM2.5 in a Subarctic Airshed – Fairbanks, Alaska, Aerosol and Air Quality
Research, 12: 536–543, 2012 .
Appendix F
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FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
In an effort to understand the sources of PM2.5 in the Fairbanks airshed,
source apportionment using Chemical Mass Balance (CMB) modeling
was conducted at four locations in Fairbanks over a three-winter period
(2008/2009, 2009/2010, and 2010/2011). At each of the four sites,
PM2.5 concentrations averaged between 22.5 ± 12.0 μg/m3 and 26.5 ±
18.9 μg/m3, with frequent exceedances of the 24-hour NAAQS on the
scheduled sample days. The results of the CMB modeling revealed that
wood smoke (likely residential wood combustion) was the major source
of PM2.5 throughout the winter months in Fairbanks, contributing
between 60% and nearly 80% of the measured PM2.5 at the four sites.
The other sources of PM2.5 identified by the CMB model were secondary
sulfate (8–20%), ammonium nitrate (3–11%), diesel exhaust (not
detected-10%), and automobiles (not detected-7%). Approximately 1%
of the PM2.5 was unexplained by the CMB model. Additional research is
needed to confirm the wood smoke results of the CMB model, as well as
determine which sources (fuel oil residential heating, coal combustion,
etc.) contribute to the measured secondary sulfate.
In 2009, the Cold Climate Housing Research Center (CCHRC) completed a study which
calculated the contribution of PM2.5 emissions from various wood burning devices.
CCHRC referenced a 2005/2006 Sierra Research survey 23 which inventoried FNSB wood
burning devices and how they were used (such as all day, only night/weekends, not at all)
and then used that data along with PM2.5 emission rates (grams/hour) from wood burning
devices to calculate the resulting PM2.5 emissions. The survey estimated there were 10,420
wood stoves in the nonattainment area, and they emitted approximately 214 tons of
PM2.5 per year. The study also indicated there were approximately 1,500 wood fired
hydronic heaters in the nonattainment area and they emitted approximately 350 tons
of PM2.5 per year, more than any other residential source. Thus solid fuel hydronic
heaters representing 13% of the Solid Fuel Burning Appliances (SFBA)
(1500/11,920) in the non-attainment area contributed approximately 62% of the total
tons of PM2.5 per year resulting from SFBAs (350 tons/564 tons).24
23 Dulla, Bob, Frank Di Genova. March 18th, 2008. Subject: Fairbanks Home Heating Survey, Winter
2007-2008
24 Cold Climate Housing Research Center, Reducing PM
2.5 Emissions from Residential Heating
Sources in the Fairbanks North Star Borough, February 23, 2009 (p. 14) as cited in ADEC’s Final 2014
SIP.
Appendix F
Page 8 of 16
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FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
FNSB PM2.5 Monitoring Data Because FNSB is one nonattainment area with
potentially multiple airsheds, meeting the Clean Air Act standard is difficult but
achievable. The city of Fairbanks three-year air quality average has recently decreased
and is close to meeting the Clean Air Act 24-hour standard of 35 micrograms of PM2.5
per cubic meter known as an exceedance day. The number of exceedance days at the
North Pole monitoring site is well above the Clean Air Act Standard.25
According to the ADEC in its draft monitoring plan for 2014/2015, the Alaska
Monitoring NAAQS Summary for PM2.5 for 2011, 2012, and 2013 at the NCore site
located at 809 Pioneer Road (installed in December 2010) and at the North Pole Fire
Station on Hurst Road (installed in March 2012) were as follows:
TARGET: NAAQS 35 μg/m3 (24-Hr, 98th percentile)
Site 2011 2012 2013 2014 2015
NCore Site 33.1 50.0 36.2 31.6 36.7*
North Pole Fire #3 NA NA NA 139 111.6*
* Preliminary data
24-Hr, 98th percentile, average over 6 month winter sampling season
Site 2011 2012 2013 2014
North Pole Fire #3 No Data 158.4 121.6 139
TARGET: NAAQS 12 μg/m3 (Annual mean)
25 ADEC Annual Air Quality Monitoring Network Plan 2014-2015 (Public Notice Draft)
Appendix F
Page 9 of 16
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FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
Site 2011 2012 2013 2014 2015
NCore Site 10.4 11.3 10.5 10.4 10.0*
North Pole Fire #3** No Data 16.8 29.1 No Data No Data
* Preliminary Data
* *Not an actual annual mean, data collected over 6 month period during winter
season
In summary, significant investment in monitoring and research has been expended to
define the nature and magnitude of air quality issues in the Fairbanks area. This
information has provided a basis upon which mitigation measures have been discussed
and continue to be debated. What is clear is that action needs to be taken by all
stakeholders in the FNSB to improve air quality, protect public health, and reduce the
direct and indirect costs associated with poor air quality. Ultimately, these actions need
to work toward achieving Clean Air Act standards.
Health Effects of PM2.5 Wood smoke is especially harmful to children, pregnant
women, the elderly, and people with lung and heart disease.26 Wood smoke is a
mixture of solids, gases, and liquids. Much like cigarette smoke, wood smoke
contains hundreds of air pollutants that can cause cancer and other health
problems. The particles in smoke are tiny bits of solids and liquids produced by
incomplete combustion. Breathing air with wood smoke in it causes inhalation of fine
particles deeply into the lungs. The particles contain toxic substances that can remain
in the lungs for months, causing changes that lead to diseases and structural damage.
These 2.5 micron diameter particles are so small they get past the respiratory tract’s
defenses and reach the deepest areas of the lungs (the alveoli, tiny air sacs where
oxygen enters the blood stream).
Many other harmful substances, such as toxic organic chemicals, can be carried into
the lungs by fine particles. An organic chemical is any chemical containing carbon
and hydrogen. Many organic chemicals in wood smoke contribute to health
problems in the respiratory tract. Examples of harmful organic chemicals of concern
in wood smoke include: benzene, formaldehyde, acetaldehyde, acrolein, and polycyclic
aromatic hydrocarbons (PAHs).27
26 Affidavit of Dr. Ali Hamade in Case No. 4FA-13-01205CI, State of Alaska v. Straughn, January 22,
2013.
27 Naeher, Luke P. et al. Woodsmoke Health Effects: A Review. Inhalation Toxicology, 19:67-106,
2007.
Appendix F
Page 10 of 16
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FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
Breathing wood smoke can have short- and long-term effects. Some of the shortterm
effects include: irritated eyes, throat, sinuses, and lungs; headaches; reduced
lung function, especially in children; lung inflammation or swelling; increased risk of
lower respiratory diseases; more severe or frequent symptoms from existing lung
diseases (such as asthma, emphysema, pneumonia, and bronchitis), and risk of heart
attack and stroke. Other long-term effects include: chronic lung disease including
chronic bronchitis and emphysema (COPD), chemical and structural changes in
lungs, and cancer.28
Adults with normal health generally have better resistance to most effects of wood
smoke. However, they may feel shortness of breath and notice it is more difficult to
exercise. They may also notice irritated eyes, sore throats, phlegm, chest tightness,
headaches, and allergy symptoms. Although anyone can have health effects from
wood smoke, those most likely to be affected even at low levels are: infants and
children, the elderly, pregnant women, and adults with existing heart or lung
conditions.29
PM2.5 is a particle small enough to enter the bloodstream and cause immediate or
consequential human health impacts. Sources that emit PM2.5 can also emit even
smaller particles that can enter a human cell causing other health impacts.
For the period 2003-2008, the State of Alaska Department of Health and Social
Services (ADHSS) reviewed Fairbanks Memorial Hospital data and FNSB PM2.5 air
monitoring data to determine if increases in PM2.5 concentrations were associated
with increases in hospital visits for selected cardiac and respiratory conditions.30 A
total of 5,718 hospital visits consisting of 1,596 emergency room visits and 4,122
hospitalizations were analyzed; the mean 24-hr PM2.5 level was 20.1 μg/m3.
According to the report, hospitalizations for the following health conditions were
statistically significantly associated with increased mean 24-hr PM2.5 levels:
28 Affidavit of Dr. Ali Hamade in Case No. 4FA-13-01205CI, State of Alaska v. Straughn, January 22,
2013.
29 Ibid.
30 ADHSS Association between Air Quality and Hospital Visits — Fairbanks, 2003–2008, Bulletin 26,
August 2010.
Appendix F
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FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
In summary, these results indicate that increased concentrations of ambient PM2.5
levels in FNSB were associated with increased risk of hospitalizations due to
cerebrovascular disease in all persons and respiratory tract infections all persons aged
>65 years during the study period.
According to the American Lung Association31, lung disease diagnoses amongst the
FNSB population have increased between 2011 to 2014 at representative rates of
pediatric asthma by 22.8% (n= 1,775 to 2,180), adult asthma by 9.3% (n=6482 to 7,074),
and COPD by 7.2% (n=2900 to 3810). Cardiovascular disease diagnoses have been made for
5.8% of the population.
On January 29, 2015, a representative of the Fairbanks Memorial Hospital testified
to the FNSB Assembly that, between 2009 and 2014, there was a positive
correlation between elevated PM2.5 concentrations and hospital admittance for
respiratory complaints such as wheezing, shortness of breath, and a cough.32
While research links air pollution with increased illnesses in children, including
documented increased rates of school absenteeism,33 a similar correlation cannot be
31 American Lung Association, State of the Air Report 2012 and 2015, accessed on June 1, 2015 at
http:/www.stateoftheair.org/2015/states/Alaska/
32 Testimony of Shawn X. Zhan to FNSB Assembly, January 29, 2015.
33 Noonan CW, Ward TJ, Navidi W, Sheppard L, Bergauff M, Palmer C. 2011. Assessing the Impact of
a Wood Stove Replacement Program on Air Quality and Children’s Health. Research Report 162.
Health Effects Institute, Boston, MA.
0
2
4
6
8
10
Cerebrovascular disease
persons <65 yrs
Cerebrovascular disease
persons >65 yrs
Respiratory Tract
Infections persons > 65
yrs
Percent Increase
2003 to 2008
Increase in Next Day Hospital Visits
After a 10 μg/m3 increase in the mean 24-hr PM2.5
Appendix F
Page 12 of 16
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FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
made with an FNSB school district reference because the FNSB school district does not
report data in this manner.
State of Alaska’s Response to the Problem Based upon historical
measurements of FNSB PM2.5 levels , in 2006 the EPA notified the State of Alaska
and the FNSB that average daily amounts of air-borne particulate matter in parts of
the FNSB exceed the level deemed healthy by the Clean Air Act. The EPA
designated FNSB as noncompliant on December 18, 2009. Noncompliance triggered
a requirement to provide a SIP that demonstrated a path to attainment by December
2012. Due to lawsuits the EPA pushed that date back to December 31, 2014.
Pursuant to section 107(d) of the Clean Air Act, EPA must designate as
“nonattainment” those areas that violate the NAAQS and those areas that contribute
to violations. The Clean Air Act prescribes the methodology to consider “pollutant
emissions, air quality data, population density and degree of urbanization, traffic and
commuting patterns, growth, meteorology, geography and topography, jurisdictional
boundaries, and level of control of emissions sources.” In 2007, ADEC worked
with the FNSB and the EPA to describe and designate the area not meeting the
established standards.
Initial evaluation of possible control measures and model development with those
various measures began and continued from 2011 through 2013. In September 2013
ADEC released proposed regulation changes for the non-attainment area pertaining
to open burning, wood-fired heating device visible emission standards, solid fuel-fired
heating device fuels, wood-fired heating device standards, and PM2.5 air episode and
advisories. ADEC announced a plan to take comments through the Fall of 2013,
incorporate comments into a draft Moderate SIP in early 2014, conduct a final 30-day
public comment period, and submit the SIP to EPA by May 2014. However, after the
closure of the public comment period the draft SIP was not released for public
comment until November 17, 2014. The final SIP was submitted to the EPA on
December 31, 2014 and the proposed regulations became effective on February 28,
2015.
Access to affordable and abundant natural gas is paramount to substantially reducing
PM2.5 emissions in the FNSB. In a borough with over 100,000 residents, currently only
about 1,100 commercial and residential properties have access to natural gas. To
deliver natural gas to the most people possible and minimize air pollution as soon as
possible, the State of Alaska, along with the FNSB community, has taken several steps
in the past few years through the creation of the Interior Energy Project (IEP).
The IEP has three main goals:
1) Boost the economy of the Interior by lowering heating costs.
Appendix F
Page 13 of 16
16
FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
2) Improve public health concerns by significantly reducing air quality PM 2.5
levels.
3) Help avoid federal funding sanctions if the air quality does not improve.
Interior utilities, Interior Gas Utility (IGU) and Fairbanks Natural Gas (FNG) are
both project entities within the IEP.
Funding for the IEP was provided in sponsored legislation – namely SB 23 in 2013
totaling over $332.5 million for the delivery, transportation and distribution of LNG
to Interior Alaska communities.
The IEP funding package includes a collaboration of legislation including SB 23 and
others equaling $150 million in bonding authority, $125 million in low-interest loan
availability, $30 million in tax credits for construction of natural gas storage facilities
and $57.5 million in zero percent interest grants to assist the community in achieving
its goals of providing $15/mcf gas (roughly $2.00/gal fuel oil) to as many FNSB
residents as businesses possible, as quickly as possible.
To date, IGU has received about $38 million and FNG has received about $15 million
through low cost, tax-free loans and grants from the State of Alaska, administered by
the Alaska Industrial Development and Exploration Authority (AIDEA). Additionally,
the FNSB has authorized a $7.5 million line of credit for the IGU, as well as a $3
million capital grant from the State administered by the FNSB. The IGU distribution
system is estimated to cost about $300 million. This price does not include storage or
transportation costs.34
In 2015, the Interior Gas Utility installed about 72 miles of pipe in the City of North
Pole and the surrounding area south to Dyke Road and north to Hurst Road. The 2
inch to 8 inch high density polyethylene (HDPE) pipe runs in front of 2,200 homes
available to hook up to the system, with project costs equaling $20 million. Phase 1
included partnerships with over a dozen contracting, permitting and construction
agencies, crossing the Alaska Railroad in five areas and the Trans-Alaska Pipeline
(TAPS) for the first time in their history by a pipeline not owned or controlled by
Alyeska Pipeline Service Company.
Fairbanks Natural Gas (FNG), the current supplier to 1,100 residents and businesses
in the FNSB community, expanded their distribution system by an additional 60 miles
from 2014 to 2015. The FNG system is currently capable of serving an additional
3,500 residents with a natural gas supply if there were additional LNG storage.
34“FAQ” Interior Gas Utility. 2013. Web. Accessed April 14, 2016.
Appendix F
Page 14 of 16
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FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
AIDEA purchased Fairbanks Natural Gas in 2015, with plans to combine the two
utilities for better efficiency and lower costs in serving the community with an
affordable natural gas option. Initially, this acquisition has reduced rates to current
FNG customers while negotiations are underway for transitional ownership and the
planned sale to IGU, expected in 2016.
Due to the various efforts and delays of the IEP since its inception in 2013 and a
significant drop in oil prices, GVEA, who was considered a possible tenant anchor,
secured a 12-year contract to buy a new naphtha fuel blend instead of waiting for a
natural gas project to come to fruition.35 GVEA, however, has expressed interest in
taking 2.5 million gallons of LNG should the price be competitive. GVEA has
committed to take 0.6 bcf of gas to help the project by taking gas in the summer when
other users would not need gas for heating. Storage capacities for residents are
mandated to have a 5-day reserve and LNG processing plants are anticipated to begin
construction in fall of 2016.
In March 2016, AIDEA announced that Salix, a subsidiary of Avista Corporation, was
chosen as a finalist to produce LNG from southcentral Alaska (Cook Inlet) for
Interior use with an anticipated delivery date of 2018. Delivery to the burner tip is
targeted at a price of $14-17 per thousand cubic feet or the equivalent of $2 per gallon
of home heating oil.36 The reduction in energy costs and air pollution are considered
large motivators for conversions from heating oil to natural gas at these prices.
ADEC Response to the Problem In response to the failure to meet the Clean Air
Act standards, ADEC has implemented a suite of control measures and made
information available to the public. Enforcement of ADEC regulations can only be
accomplished through cease and desist orders and ultimately court procedures. The
most well-known instance in Fairbanks, Alaska v. Straughn, was focused on outdoor
wood boiler emissions and led to multiple court events and dozens of dockets over a
seven-month period.37
35 Buxton, Matt. “New GVEA Fuel Contract Worries Backers of Natural Gas for
Fairbanks.” Fairbanks News Miner. N.p., 15 Dec. 2015. Web. 14 Apr. 2016.
36 IEP Natural Gas Conversion Analysis. 2014. Prepared for AIDEA by Cardno Entrix. Ch. 39 SLA
2015.
37 Case number 4FA-13-01205CI, information accessed on July 8, 2015 at
http://www.courtrecords.alaska.gov/eservices/?x=EH*tNFLDzxby5R7WlCJWSz6qgx5MITn6Cw74
Z6ydUT31fTGNP0C4fZau5wzqCHdEYT*MtdZfePDi5h*3f19n8A.
Appendix F
Page 15 of 16
18
FNSB APCC AIR QUALITY COMPREHENSIVE PLAN – APRIL 2016
ADEC submitted a Moderate SIP to EPA in December 2014 and EPA found the
Moderate SIP officially “complete” on February 18, 2015. Now EPA has up to
June 2016 to review the SIP and make a finding of adequacy. They can approve,
partially approve, or disapprove all or parts of the SIP. If any part of the SIP is
disapproved, ADEC will be required to address the deficiencies with a SIP
amendment.
ADEC anticipates the EPA will designate Fairbanks as a Serious Area for nonattainment
in June 2016 triggering a requirement to submit a Serious SIP by December
2017. Thus, ADEC began Serious SIP development in January 2015 in order to meet
the December 2017 deadline for submission to EPA.
Anticipating mandatory Best Available Control Technology (BACT) for stationary
sources upon Serious non-attainment designation by EPA in 2019, ADEC has
requested that owners and operators of eight stationary sources voluntarily conduct and
submit a preliminary BACT analysis by December 2015 and a final by March 2016.
ADEC begins Serious SIP modeling in March 2016. ADEC anticipates having a draft
Serious SIP for public review by December 2016, public notice and hearings in
February 2017, and submission to EPA by December 2017.
City of Fairbanks Response to the Problem Responding to the problem of nonattainment
and pending federal sanctions, on May 18, 2009 the Fairbanks City Council
adopted Ordinance No. 5775 whereby “no hydronic heater may be installed inside the
City of Fairbanks after June 8, 2009 without a permit issued by the City of Fairbanks
Building Department. No permit shall be issued until standards are adopted by the
Fairbanks City Council.” On October 22, 2012 Ordinance No 5903 amended Fairbanks
General Code Chapter 34, Article VI Section 34-201 to include the stipulation that
permits for the upgrade or replacement of existing hydronic heaters may be issued if the
upgraded or replacement heater is qualified by the EPA.
During the period from 2009 through 2014, Aurora Energy expanded the system
distributing steam building heat in the Fairbanks city core. It is estimated that the
equivalent displacement of heating oil is 326,400 gal/yr.38
FNSB Response to the Problem Since 2009 there have been several Borough
Assembly and Voter Initiatives to resolve the PM2.5 issue. Key actions are represented
in Figure 1, FNSB Assembly Activity & Voter Initiative Timeline. Actions moving the
Borough forward to resolve this problem is designated by green boxes. Actions creating
barriors to resolve this problem is designated by red boxes.
38 Per David Fish, Aurora Energy, August 16, 2015 email correspondence
Appendix F
Page 16 of 16

Fairbanks North Star Borough
Gas Distribution System
Analysis
June 29, 2012
Prepared by
Northern
Economic s
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ArKhurdg~. Alo9cd 99501
Phone: (907) 274· 5600
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8dir>9hom, WA 98215
PhOne: (360) 71 S 1808
f.u_ (36017 15-3588
In association with
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Michael Baker, Jr. Inc.
SLR
SLR Internat iona l
Alaska Energy Board
Appendix G
Page 1 of 8
PROFESSIONAl CONSULTING SERVICES IN APPLIED ECONOMIC ANAlYSIS
Principals:
Patrick Burden, M.S.- President
Marcus L. Hartley, M.S. – Vice President
Jonathan King, M.S.
Consultants:
Joel Ainsworth, B.A.
Alexus Bond, M.A.
leah Cuyno, Ph.D.
Michael Fisher, MBA
Cal Kerr, MBA
Alejandra Palma, M.A.
Bill Schenken, MBA
Don Schug, Ph.D.
Katharine Wellman, Ph.D,
Administrative Staff:
Diane Steele – Office Manager
Terri McCoy, B.A.
Michelle Humphrey, B.S.
Pre parers
Team Member
Patrick Burden
Project Role
Project Manager
Northern
Economics
880 ~I Street. Suite 210
Anchorage. Alaska 99501
Phone: (907) 274·5600
Fax: (907) 274·5601
tm~Jil: n1d1l ill\or~m 1 .c nm
Fi rm
119 N Commercial Street, Suite 190
Bellingham, WA 98225
Phone: (360) 71 5·1808
F;tx:(360) 715·3S88
Northern Economics, Inc.
Cal Kerr Assistant Project Manager Northern Economics, Inc.
Leah Cuyno Economist Northern Economics, Inc.
Mike Fisher Analyst Northern Economics, Inc.
Alejandra Palma-Riedel Economist Northern Economics, Inc.
Joel Ainsworth Analyst Northern Economics, Inc.
Derek Christianson Baker Project Manager Michael Baker, Jr. Inc.
Charles Barnwell GIS Lead Michael Baker, Jr. Inc.
Vin Robinson Cost Estimator ENSTAR Natural Gas
Carolyn Dunmire Strategic Planning Alaska Energy Board
Jeff Staser Funding Strategies Alaska Energy Board
Tonylzzo Gas Utility Operations Alaska Energy Board
AI Trbovich Task Lead, Air Quality SLR International
Courtney Kimball Task Support, Air Quality SLR International
Terri McCoy Technical Editor Northern Economics Inc.
Please cite as: No1thern Economics, Inc. Fairbanks North Star Borough Gas Distribution System
Analysis: . Prepared for the Fairbanks North Star Borough. June 29,2012. FNSB Project number: 11 –
PWDPRJ-02.
Appendix G
Page 2 of 8
price differentiaJ between propane and heating fuel is less than the price difference between natural
gas and heating fuel.
The present value of costs of an alternative using natural gas and propane to meet the heating and
industrial demand is estimated at approximately $5.25 billion i11 2012 dollars. This amount i •~cludes
the cost of the fuels, conversion costs tor replacing the existing furnaces or boilers, and the capital
and operating costs for the piped distribution system. This estimate also inc ludes the cost of new
propane trucks and tanks to serve the low-density area of the borough; similar to the status quo,
estimated costs for the high, medium, and low-density areas of the borough are presented in the table.
The $5.25 billion also assumes that the distribution system is operated by a private company, which
results in a more conservative comparison since government or cooperatives would be expected to
have lower costs, as discussed later in the report (see Sections 4.1 and 7).
The net present value expressed in 2012 dollars of the potential cost savings from converting to lower
cost natural gas and propaiJe is estimated at approximately $5.36 bill ion over the 50-year study
perjod.
Air Quality
Project air quality engineers prepared an analysis of the potential effects on air emissions from
conversion to natural gas-tired space heating systems in the residential and commercial sectors of the
three zones noted earlier. This ana lysis estimates the annual amount of criteria pollutant emissions in
each demand zone for each year of the conversion eff01t.
Criteria pollutants are regulated pollutants under the Clean Air Act, and include:
• Oxides of nitrogen (NOx),
• Carbon monoxide (CO),
• Particles with an aerodynamic diameter less than or equal to I 0 micrometers (PM10),
• Particles with an aerodynamic diameter less than or equal to 2.5 micrometers (PM25),
• Sulfur dioxide (S02), and
• Volatile organic compounds (VOC).
Emissions of each criteria pollutant are expected to decrease substa11tially based on the conversion
scenarios presented in t his report.
Of particular concern to the FNSB is the criteria pollutant PM2.5, also known as fine particulate
matter. The United States Environmental Protection Agency (EPA) has designated portions of the
Fairbanks and North Pole areas as a nonattainment at·ea for PM2.5, as shown in Figure ES-1. The EPA
regulates PM2.s because it can cause or aggravate serious health problems, including asthma,
bronchitis, and heart attacks. Further, the nonattainmenl designation negatively affects economic
growth due to air quality permitting constra ints that apply in nonattainment areas.
The analysis demonstrates that converting to natural gas use for heating will reduce the overall
emissions of PM2~5 in the Fairbanks area. Figure ES-3 illustrates the estimated change in PM25
emissions from residential and commercial sources in the high and meditu11-demand zones. Total
PM2.5 emissions dectease from approx imately 2,200 tons per year to less than 200 tons per year. The
analysis makes clear that conversion of residential heating systems fTom wood-tired and coal-fired to
natural gas-fired is essential to achieving reductions in PM2 .5 emissions.
E$-10 NorthetnEconomics
Appendix G
Page 3 of 8
Figure ES-3. PM 2.s Emissions Estimates, High and Medium Demand Areas, 2015 to
2020, in Tons of Pollutant per year.
1,400
1 ,200
1,000
f t:.
800
“1
N
2 600 a…
400
wo
0
2015 2016 2017 2018 2019 2020
Year
– High Conversion Zone – Medium Conversion Zone
Source: SLR International
The conversion to natural gas will also reduce NOx and S02 emissions, whi ch are precursors to the
formation of secondary PM 2.s in the atmosphere. These e mission reductions will help bring the
Fairbanks area into attai nment with the ambient PM 2.5 air quality standard.
The em issions reductions presented here reflect the changes associated with the piped natural gas
systems in the high and medium-demand areas or propane systems in t he low-demand area.
Emissions from fac ilitie s in the industrial sector, as described in Section 2, are not included in t his
analysis.
If the Fairbanks area converts many of the existing space heating emiss ion units to natural gas
combustion, water vapor emissions wi ll likely increase. These additional water vapor emissions do
not necessarily mean that ice fog events will become more common because the frequency of the
meteorological conditi o ns that trigger ice fog events will not increa se. However , the ice fog events
that do occur may have s li ghtly longer duration and may cover a sli ghtly larger geograph ic area.
Decision Points
The purpose of thi s report section is to identify if there were zones or areas where the costs of
converting to natural gas and propane were greater than the costs of using di stillates and wood. As
noted in the BCA di s c u ssion (Section 8), th e benefit-cost ratio for each of the three density areas
( hi gh, medium, and low) is very positive, so there is no need to phase the project or to not undertake
development of the distribution system in any area.
Northet n Economics ES-11
Appendix G
Page 4 of 8
10 Air Quality
Conversion of heating system fue ls such as wood, oi l, and coal to natural gas will reduce the
emissions of criteria air poll utants in the Fairbanks area. Criteria pollutants are regulated pollutants
under the Clean Air Act, and include oxides of nitrogen (NOx), carbon monoxide (CO), particulate
matter with an aerodynamic diameter less than or equal to lO micrometers (PM 10), particulate matter
with an aerodynamic diameter less than or equal to 2.5 micrometers (PM2.5) , sulfur dioxide (S02), and
volatile organic compounds (VOC).
An analysis has been prepared to estimate the annual amount of criteria po llutants emitted ti·om the
heating systems for existing residential and commercial bu ildings in the FNSB. Emissions from
facili ties in the industrial sector, as described in Section 2, are not inc luded in this ana lysis. Table 21
provides a summary of the estimated cun·ent emissions from these sources, distributed between the
high, medium, and low-demand areas as described in Section 2.4. Note that the high and mediumdemand
zones together approximate the area designated as the PM25 nonattainment area.
Table 21. Summary of Existing Emission Estimates in the FNSB, by Zone
Zone Category NOx (tpy) co (tpy) PM1o (tpy) PM2.s (tpy) so2 (tpy) voc (tpy)
Residential 399 12,672 1,505 1,294 452 9,592
High Commercial 347 203 59 54 534 10
Total 746 12,875 1,564 1,348 986 9,602
Residential 278 8,815 1,047 900 315 6,672
Medium Commercial 61 36 10 10 94 2
Total 339 8,851 1,057 909 409 6,674
Residential 83 2,679 318 274 96 2,028
Low Commercial 24 114 6 5 36 4
Total 108 2,793 324 279 131 2,033
Residential 760 24,166 2,871 2,467 863 18,292
Overall Commercial 433 353 75 68 664 16
Total 1 ‘193 24,519 2,946 2,536 1,526 18,308
Source: SLR International Corp 2012
Note: All emissions are in terms of tons of pollutant emitted per year (tpy).
The residential emissions estimates wei·e calculated using data from the 20 I 0 Fairbanks Home
Heating Survey report, prepared by Sierra Research for the Alaska Departinent of Environmental
Conservation. This survey estimated the number of residential heating devices, types of fuel used, and
amount of fuel used in the PM2.5 nonattainment area. Four categories of fuel are used for space
heating in residential buildings: wood, oi l, coal, and natural gas. The oil category inc ludes fuel oi l,
diesel, and kerosene. The same fuels are used for space heating in commercial buildings. Fuel
combustion efficiency varies depending on the type of heating device used and the fuel being
combusted. Existing emissions were calculated by applying the fuel use ratios to the demand
estimates discussed in Section 6.2.1 (in terms of Btu of natural gas input), add·ing the existing natural
gas consumpt ion to the fuel use tally, adjusting the demand for each fuel based on the average
combustion efficiency of that fuel compared to natural gas, and convett ing the heat input demand into
fuel consumption for each of the fu el categories. Demand in the low zone is discussed in Section
6.2.1 in terms of propane. The heat demand in this zone was originally calculated in terms of Btu of
64 Northern Economics
Appendix G
Page 5 of 8
natural gas input ; therefore, the low zone demand numb ers did not req uire add iti onal adjustment prior
to the emiss ion calculations.
Annual em iss ion estimates were calculated usin g an EPA reference document, AP-42, Com pil atio n of
Ai r Pollutant Em iss ion Factors, Section 1 (EPA 20 I 0). Emission estimat es for PM 10 a nd PM2.s may
differ from the PM em iss ions in the analyses being prepared as part of the PM 2.5 State Im ple mentation
Plan (S JP) . Th e FNSB and !he contractor preparing the SIP analyses, Sierra Research, are currently in
the final stages of development of Alaska-spec ifi c PM emiss ion factors. These em ission factors arc
based on so urce te sting of com monly used heating devices and locally available fue ls in the FNSB.
Preliminary discussio ns indicate that the Alaska-specific PM emission factor s may be s ub stantially
lower than the PM e mi ss ion facto rs provided in AP-42.
The same met hod described above was used to calcu late the emiss ion estim ates for the commercial
sources, except the fue l type use data were provided by Sierra Resea rch (S ierra Research 20 I 0).
Wood wa s not includ ed in the fuel type use data for commercial sources. The calculation method
assumes that the fue l use rat io is the same in the hi gh, med ium , and low-demand zones.
10.1 Non-attainment Area
Particulate matter is a pollutant of special co ncern in the Fairbanks area. Excecdances of the ambient
air quality sta nd ard for PM25 have been measured in Fairbanks. As a result, EPA has designated
portions of the Fairbanks and North Po le areas as a nonattainment area for PM25 . This nonattainment
area is p01trayed in Figure 2. Because of the very small size of the particle, PM 2 5 can reach deeply
into hum an resp ira tory sys tems and ca use or aggravate serious heaJt h prob lems, including asthma,
bronchitis, an d hea 11 attacks. PM25 can be e mit te d directly f rom sources of combustion and ca n also
form when gases emitted by combust ion react in the air (EPA 2012).
The nonatta in ment des ignatio n for the Fa irbanks area is a cause for concern for several reasons. First ,
the local population is at increased risk for re spiratory and c irculatory health problems. Secondly, th e
des ignation negatively affects economic growth in the area. Air quality pe rmits for any commercial or
industrial activity cannot be obtained if the activity will increase the amoun t of PM 2.5 emissions over
current amounts. Because of this restriction, growth of existing commercial and industrial activity
wi ll likely not occur, and new commercial and industrial activities will lik ely not take root in the
Fairbanks area, unti l EPA is satisfied that compliance with the ambient PM2.5 standard is attained and
a p lan is in place to maintain comp li ance with the ambient standard.
Natural gas conversion in Fairbanks will reduce t he emiss ions of PM 2.s from residential and
commercial facilitie s. The conversion to natural gas wi ll also reduce NOx. and SO:! emissions, which
are precursors to the formation of secondary PM 2 s in the atm osphere. The reduction will help brin g
the Fairbanks area into attainment with the ambient PM2.5 air quality standard. The reduction in
emissions is disc us se d further in Section 1 0.2.
10.2 Potential Impacts, Conversion to Natural Gas
SLR ln terDational Corp’s analysis estimates the cha nge jn emiss ion s resulting from conversion of tht:
th ree demand zones to natural gas over a period of six years. The em issions ca lculations assume thai’
the rate of conve rsion for each original fuel type is the sa me except in the low-demand zone, where
demand modeling indicates that residential wood burners will likely not begin converting to propane
prior to 2021. In the low-demand zone, the emissions calcul ations assume that residential conversions
from coal and oil occu r at the same rate, whil e residential conversion from wood combustion does not
occur during the six years of the scenario. The emission calculati ons also assume that the existing us e
No rthe rnEconomics 65
Appendix G
Page 6 of 8
of natural gas supplied by FNG remains constant during the years of the analysis. Results of the
analysis are shown in Table 22 through Table 24.
Table 22. Estimated Annual Emissions (tpy) After Conversion in the High-Demand
Zone, 6-Year Conversion
Pollutant Category Existing Year1 Year2 Year3 Year4 YearS Year6
Residential 399 391 355 279 216 172 160
NOx Commercial 347 330 281 227 199 198 199
Total 746 721 636 506 415 369 360
Residential 12,672 12,166 10,268 6,389 3,093 795 152
co Commercial 203 199 187 172 165 166 168
Total 12,875 12,366 10,454 6,562 3,258 961 319
Residential 1,505 1,445 1,221 761 371 99 23
PM1o Commercial 59 54 40 24 16 15 15
Total 1,564 1,499 1,260 785 387 114 38
Residential 1,294 1,242 1,049 655 320 86 21
PM2.s Commercial 54 49 37 23 15 14 15
Total 1,348 1,292 1,086 678 335 101 36
Residential 452 434 366 227 109 27 4
so2 Commercial 534 471 301 112 14 1 1
Total 986 905 668 340 123 28 5
Residential 9,592 9,207 7,763 4,816 2,309 563 73
voc Commercial 10 10 10 11 11 11 11
Total 9,602 9,217 7,774 4,826 2,320 574 84
Source: SLR InternatiOnal Corp 2012
Note: All emissions are in terms of tons of pollutant emitted per year (tpy).
66 NorthernEconomics
Appendix G
Page 7 of 8
Table 23. Estimated Annual Emissions (tpy) After Conversion in the Medium-Demand
Zone, 6-Year Conversion
Pollutant Category Existing Year1 Year2 Year3 Year4 YearS YearS
Residential 278 280 249 200 158 129 122
NOx Commercial 61 62 50 40 35 35 35
Total 339 343 299 240 193 164 157
Residential 8,815 8,904 7,250 4,714 2,560 1,060 644
co Commercial 36 36 33 30 29 29 30
Total 8,851 8,940 7,283 4,745 2,589 1,089 673
Residential 1,047 1,058 862 562 306 129 80
PM1o Commercial 10 11 7 4 3 3 3
Total 1,057 1,068 869 566 309 132 82
Residential 900 909 741 483 264 112 69
PM2.s Commercial 10 10 6 4 3 3 3
Total 909 919 747 487 267 114 72
Residential 315 318 259 168 91 37 22
so2 Commercial 94 95 53 20 2 0 0
Total 409 413 312 188 93 37 22
Residentia l 6,672 6,740 5.482 3,555 1,917 777 460
voc Commercial 1.8 1.8 1.8 1.9 1.9 1.9 1.9
Total 6,674 6,741 5,484 3,557 1,9 19 779 462
Source: SLR International Corp 2012
Note: All emissions are In terms of tons of pollutant emitted per year (tpy).
Northern Economics 67
Appendix G
Page 8 of 8

Appendix H
Page 1 of 7
December 2006
Cook Inlet Vessel Traffic Study
states, “During colder winters the cold may extend into the lower Inlet as far
south as Anchor Point on the east side and Cape Douglas on the west side.
The thickness of the ice varies between 0.5 and 2.0 meters.”
As we conducted the research for this traffic study, reviewed the casualty
records, and talked to marine pilots, agents and operators, a succinct
description of the water body became quite clear:
“Cook Inlet is a wide, long inlet with moderate to low levels of vessel
traffic when compared to other large North America ports, but is a water
body vexed by:
• Sudden, severe weather,
• Strong tides, and
• Large ice pans aggressively moved by strong tides in the winter.”
Vessels Trading in Cook Inlet
Cook Inlet supports a wide variety of vessel traffic ranging from the smallest
fishing vessel to crude oil tankers. Refined products and crude oil are
routinely shipped in and out of the Inlet. In addition, Liquefied Natural Gas
(LNG) and ammonia carriers call at the Nikiski Industrial complex. Many
crude oil development and production platforms operate in the area. Crude
oil and natural gas pipeline crossings exist in Cook Inlet and Turnagain Arm
in several locations.
There is only moderate fuel barge traffic through out the inlet since much of
the refined oil needed for regional consumption is provided to Anchorage via
a pipeline from the Tesoro refinery in Nikiski.
The Port of Anchorage (POA) is a ‘classic’ port in that it imports and exports
a variety of goods and raw material in bulk and containers.
Overview of Coastwise and International Traffic
Based on US Coast Guard advance notice of arrival records and other
local sources of information , 704 large vessels , other than fuel barges on
domestic trade, called at Cook Inlet ports from January 1, 2005 through
July 15, 2006. As can be seen in Figure 1, almost two-thirds (65%) of the
calls were made by container vessels operated by Horizon Lines, roll-on,
Required by 33 CFR 160, Subpart C for all vessels carrying certain dangerous cargoes and all vessels at 3 00 gross tons or
greater traveling not carrying certain dangerous cargoes.
Horizon Lines, TOTE, and Alaska Marine Highway System sailing schedules: www.horizonlines.com, www.totemocean.com,
and http://www.dot.state.ak.us/amhs/
300 gross tons or more in size. This is the Coast Guard’s break point for advance notice of arrival.
Gross Tonnage refers to the volume of all ship’s enclosed spaces measured to the outside of the hull framing.
It was a measurement of the enclosed spaces within a ship expressed in “tons” – a unit which was actually
equivalent to 100 cubic feet. The calculation of gross tonnage is complex but important given that fees,
registration requirements and, as seen here, regulatory standards are based on gross tonnage.
Appendix H
Page 2 of 7
December 2006 25
Cook Inlet Vessel Traffic Study
two other radars are still functional. In other words, there are degrees of
‘loss of maneuverability’ that are not obvious within the summary of Coast
Guard records displayed in Table 7. These notes also apply to the full list of
casualties in Appendix E.
Table 7: Cook Inlet Summary of Vessel Casualties Reported to US Coast Guard
June 22, 1990 through August 1, 2006.
Accident or Event Total Comments
Allision 27
Includes one allision with oil production platform
and one barge damaged by ice.
Capsize 2
Collision 20 Includes two barge/tug collisions.
Explosion 2
One explosion resulted in subsequent fire, sinking
and pollution.
Fire 18
Included cargo hold fire on container ship moored
at Port of Anchorage.
Flooding, sinking 40 Includes four abandonments
Grounding 26
Material Failure 17
Set Adrift/Breakaway 4
Includes breakaway of Seabulk Pride in February
2006.
Loss of Vessel
Maneuverability
69 Includes loss of electric power.
Total 225
Total, Alaska waters 5,922
During the period of study, there were 59 casualties resulting in damage to
a vessel in excess of $20,000. In eleven of the incidences, vessel damage
exceeded $250,000. The most significant casualties were M/V Glacier Bay
spill in 1987 (which is earlier than the records studied in this report), the
capsizing of the barge Oregon in 1997, the Container Ship Greatland cargo
hold fire in 2003, and the breakaway of the tankship Seabulk Pride in 2006.
Casualties of Interest16
1. Explosion and subsequent fire (on board the 113-ft supply vessel Alaska
Constructor on November 2, 1988). The explosion ignited a tank truck
containing 3,000 gallons of gasoline, thus multiplying the consequences
of the casualty. Three lives were lost and the vessel was destroyed.
Water pollution was minor.
2. Potential for ammonia release (M/V EEKLO at Agrium Wharf on
February 11, 2005): During loading ammonia, an able bodied seaman
(AB) inadvertently slacked instead of tightened one of the bow mooring
16 Sources: (1) Conversation and follow-up e-mail with Lt Ken Phillips, Marine Safety Detachment supervisor
Kenai. 1 Nov 2006, (2) Whitney, John. 2002. Cook Inlet, Alaska Oceanographic and Ice Conditions and
NOAA’s 18-Year Oil Spill Response History 1984-2001, and (3) ADEC records.
Appendix H
Page 3 of 7
26 December 2006
Cook Inlet Vessel Traffic Study
wires in heavy (5.7 kt) current and ice coverage. This caused the gas
ship M/V EEKLO to move 3-12 feet aft, shifting the loading arm, and
subsequently shutting down the loading process. The Coast Guard
issued a requirement to secure loading when currents exceed 4kt on the
flood.
3. Tow-Tug collision (SCT Barge 282 and tugboat Pacific Challenger near
Homer March 22, 2006): The SCT Barge 282 was departing from
Pioneer Dock in Homer under the Tugboat PACIFIC CHALLENGER.
The tug and barge were about to round the spit in Kachemak Bay
when the PACIFIC CHALLENGER rolled in a swell pushing the PACIFIC
CHALLENGER into the starboard bow of the SCT Barge 282. At that
time no damages were identified. The barge continued onto Port
Graham where they discovered damage to the bow. This collision
resulted in a fracture in the #1 starboard cargo tank in way of the deck
edge. No spill observed. The product in tank #1 was offloaded at Port
Graham.
4. Tow-Tug collision (towing vessel Paragon and Barge 344, underway in
Cook Inlet, January 21, 2006): The Paragon was struck by the barge
it was towing when an ice pan slowed the progress of the Paragon and
allowed the barge to overtake it. Barge 344 struck the Paragon’s stern
causing a 4” wide by 18” long hole in the port forward void space of
Barge 344.
5. Ship allision with dock (M/V PEONY at Agrium dock, October 18, 2005):
Unexpected heavy weather set the ship into the pier causing structural
damage to the pier initially estimated at less than $100,000. A pilot
was requested and arrived on board but was unable to move the ship
due to low tide levels. Damage to the vessel is minimal on the port bow
and does not affect seaworthiness. Allision was caused by unexpected
extreme weather conditions and was ruled unavoidable by Coast Guard
investigators.
6. Dragging anchor and near miss in Kachemak Bay (Informal report by
the Coast Guard). Two Coast Guard marine safety personnel were on
board the M/V STEWART ISLAND conducting an ice rules boarding
when it began to drag anchor. The wind was ‘blowing pretty hard’.
The STEWART ISLAND came within 30-40 yards of colliding with the
SEABULK PRIDE, which was anchored as well. Anchoring guidelines for
Kachemak Bay were written as a result. See Appendix D.
7. Container ship fire (M/V Greatland at the Port of Anchorage, May 19,
2002): Shortly after mooring at the Port of Anchorage, personnel on
the container ship M/V Greatland discovered a fire in one of the cargo
holds. Trained marine firefighters from the Anchorage Fire Department
entered the compartment and found several school buses smoldering.
Appendix H
Page 4 of 7
December 2006 27
Cook Inlet Vessel Traffic Study
They extinguished the fire and there was no serious damage to the
vessel. The fire was believed to have originated from a small fuel oil leak
on one of the buses. This was the first serious marine fire at Port of
Anchorage since the 1960’s.
8. Freight Barge capsize (Crowley Barge OREGON, south Cook Inlet,
January 25, 1997) . This barge suffered a breach (hole) amidships, took
on water, and overturned. The entire load of 12,500 tons solid urea was
lost.
9. Vessel collision with a moorage (M/V Chesapeake Trader and Christy
Lee Dock, January 1, 1998). While coming along side, the Chesapeake
Trader hit and damaged the catwalk of the moorage. Damage to the
vessel was superficial, but the moorage catwalk needed to be replaced,
costing $425,000.
10. Freight ship breakaway (M/V OCEAN LAUREL, Nikiski, January 31,
1999). While moored at the pier during periods of heavy icing the vessel
was struck by a large pan of ice, estimated to be ¾ mile in length. The
vessel was sheared off the pier, parting 19 mooring lines, and struck the
pier face, resulting in approximately $40,000 in damage to the mooring
structure and $20,000 in damage to the vessel. The hull was indented
in two locations above the waterline along the portside.
11. Tank barge breakaway (T/B ENERGIZER, Nikiski, January 19, 2000).
The barge was moored to the Kenai Pipeline (KPL) dock when it was
struck by a large pan of ice, parting mooring lines and the cargo transfer
hose. Approximately 60 gallons of isomerate (an oil distillate used in
blending gasoline) spilled into the water. The barge cargo pipe header
and deck crane were damaged.
12. Freight ship breakaway (M/V TORM PACIFIC, Nikiski, January 20,
2000). The ship was moored portside to the Alaska Nitrogen Products
Terminal (Agrium) when it was struck by a large pan of ice moving at
approximately 5.3 knots. The vessel was sheared from the pier, parting
24 mooring lines, and struck the terminal’s northern catwalk. The
catwalk was destroyed and the ship sustained some damage above the
waterline.
13. Tank ship breakaway (Seabulk Pride, Nikiski, February 2, 2006). This
601-foot double-hull oil cargo tanker, broke free of its moorings at Kenai
Pipeline Dock, Nikiski. It drifted north until grounding about a half mile
away along the bluff at the East Forelands. Initial investigations indicate
that heavy ice and strong tidal currents were main factors in causing
the breakaway. The vessel was re-floated without significant oil spillage.
However, catastrophe was narrowly averted, given the numerous rocks
and reefs in the vicinity.
Appendix H
Page 5 of 7
28 December 2006
Cook Inlet Vessel Traffic Study
Pollution from Vessels
Between January 1, 1992 and August 30, 2006 there were 295 oil spills
reported to the Coast Guard from vessels operating in Cook Inlet. Of
that total, 286 were spills not connected to a vessel casualty (grounding,
collision, fire, or sinking). One hundred and twenty eight (128) spills (43%
of the total) were small diesel or gasoline spills from fishing vessels and
pleasure craft. All the spills were reported as “not serious”. This means that
the Coast Guard classified the spills as minor.17
During the same period there were 333 spills reported from the 15 Cook
Inlet oil production platforms.
Between 1996 and 2002 ADEC reported 126 spills in Cook Inlet from
vessels.18 All were minor. All spills combined only contributed 7415 gallons
of the 500,359 gallons of oil spilled in the Cook Inlet sub-area during that
period.
Most significant spills of the past 20 years have come from oil platforms or
on-shore facilities. Vessel spills19 of interest include:
• On July 2, 1987 at 0334, the tank ship Glacier Bay grounded south of
the mouth of the Kenai River while enroute Nikiski to offload North Slope
crude oil. Hull damage resulted in a 130,000 gallon spill. The vessel
reportedly ran aground on an uncharted rock. (Note: This incident is a
pre-spills database era report.)
• Spill response vessel M/V Sun Tide collision with the jack-up drilling rig,
Gilbert Rowe, on August 23, 1993. The collision ruptured a fuel oil tank
on the Sun Tide, releasing 6000 gallons of diesel fuel.
• Five hundred gallon light oil spill during loading operations on the tank
barge Annahootz at the Port of Anchorage on September 1, 1994.
As can be seen, significant oil spills from vessels are rare. Furthermore,
ADEC and Coast Guard records of the minor spills over the last 14 years
do not provide any particular insights that would assist prevention and
response planning for major or high consequence vessel spills.
17 The US Coast Guard categorizes oil spills into these sizes: minor – less than 10,000 gallons; medium –
10,000 to 99,999 gallons; and major – 100,000 gallons or more.
18 ADEC. Statewide Summary of Oil and Hazardous Material Spill Data July 1, 1995 – June 30, 2002
(provisional report) See http://www.dec.state.ak.us/spar/perp/data.htm
19 Sources: (1) Whitney, John. 2002. Cook Inlet, Alaska Oceanographic and Ice Conditions and NOAA’s 18-
year Oil Spill Response History 1984-2001, and (2) ADEC spills database. See http://www.dec.state.ak.us/
spar/perp/data.htm.
Appendix H
Page 6 of 7
December 2006 29
Cook Inlet Vessel Traffic Study
Summary and Recommendations
1. Risk is traditionally defined as:
Risk = Probability X Consequence
Twelve vessels make 80% of the large vessel port calls in Cook Inlet.
These vessels have the greatest potential (probability) for a Cook Inlet
marine casualty due simply to their time in the inlet. Of the twelve,
five are gas or oil carriers where the consequence of environmental
damage from a casualty is high. On the non-tank vessels, six vessels
carry a 0.5 to 1.2 million gallons of persistent fuel oil. The remaining
common carrier – AMHS ferry Tustumena – carries a much smaller
quantity of diesel fuel oil but it’s cargo (passengers) is of the highest
value. Thus, continued or enhanced partnerships with and monitoring
of the operators of these vessels will address the majority of the risk of
significant or major vessel casualties and oil spills in Cook Inlet.
2. Risk analysis could be improved by requiring that near-miss incidents
be reported.
3. Severe environmental conditions (high winds, ice, strong tide currents)
coupled with human error in negotiating these conditions during vessel
operations pose the most likely root cause of the next major vessel
casualty and oil spill.
4. Cook Inlet is unique in that potentially the most serious casualties can
occur while a vessel is moored. Ice and strong tides broke the tankship
Seabulk Pride from its moorings in 2006. A serious ammonia spill was
narrowly averted when a gas ship shifted at the Agrium dock while
loading in 2005. A study of best mooring practices and monitoring of
their effectiveness will be an important contribution to vessel traffic risk
management in Cook Inlet.
Appendix H
Page 7 of 7

Coast Guard Report of Investigation:
Grounding of the Tank Vessel SEABULK PRIDE in Cook Inlet
February 2nd, 2006
Investigations Division
Sector Anchorage, Alaska
Appendix I
Page 1 of 2
Summary
On February 2, 2006 at approximately 0523 (all times are Alaska Standard
Time) the tank vessel SEABULK PRIDE’s mooring lines parted at the Kenai Pipe
Line (KPL) Dock in Nikiski, Alaska. The ship went adrift and grounded
approximately one-half mile north of the pier near the East Forelands.
The vessel was pushed parallel to the dock by a sudden force generated by
ice and current, this was the initiating event. At 0523 the two after spring wires
parted within seconds of each other and the order was given to shutdown the
loading operation. The mooring lines continued to part, come free from hooks,
and spool off their winch reels setting the ship adrift in the flood tide. The cargo
hoses parted as the ship drifted away from the pier, discharging as much as 5
BBLS of product into Cook Inlet. At 0530 the port anchor was let go, with four
shots of chain, to check the motion of the vessel.
The vessel grounded near the East Forelands and remained relatively static
until it was re-floated following the initial damage surveys. The vessel transited to
Homer and anchored in Kachemak Bay pending a more thorough inspection of
the damage and completion of the Coast Guard on scene investigation.
At the time of the incident the vessel was not in full compliance with the
ice guidelines issued by the Captain of the Port, Western Alaska. The vessel did
not meet the recommendation to be in immediate standby, was not moored in
preparation for a worst case scenario, and the bridge was not manned with an
underway watch. A combination of tidal conditions, poor line handling, and ice
flows all contributed to the break away and subsequent grounding. The ice flows
and current were the clear initiating factor in this casualty.
The on scene risk assessment conducted was inadequate for the situation
faced. The only sure course of action that would have prevented this casualty was
to require the ship to depart the terminal during the icing conditions experienced.
The forces generated at max flood combined with ice present a substantial risk to a
vessel moored at the KPL dock.
Jurisdiction & Authority
The SEABULK PRIDE is a U.S. Flagged vessel, and the casualty occurred on a
navigable waterway of the U.S.
33 USC 1227 authorizes the investigation of any incident, accident, or act
involving damage to a waterfront facility, or which affects or may affect the safety
or environmental quality of the ports, harbors, or navigable waters of the United
States.
Appendix I 3
Page 2 of 2

Coo k I n l e t Ri s k As s e s sme n t F i n a l Re p o r t i
January
27,
2015
Revision
1
Appendix J
Page 1 of 3
Coo k I n l e t Ri s k As s e s sme n t F i n a l Re p o r t i i
Cook Inlet Risk Assessment
Final Report
January 27, 2015 (Revision 1)
Developed by:
Nuka Research and Planning Group, LLC
and
Pearson Consul t ing, LLC
Appendix J
Page 2 of 3
Coo k I n l e t Ri s k As s e s sme n t F i n a l Re p o r t 1 1
4 . 1 Cons t ruct Subsea Pi p e l i ne Across Cook I n l e t
Currently, oil produced on the west side of Cook Inlet, either on land or from platforms in the Inlet,
is transported via pipeline to the Drift River Terminal where it is loaded on to tank vessels and
shipped across the Inlet to the Tesoro Refinery in Nikiski. There is a pending proposal submitted to
state and federal regulators by Cook Inlet Energy to replace this tanker traffic with a subsea
pipeline that would move oil produced from both onshore and offshore drilling sites on the
western side of the Inlet to the Nikiski Industrial Facilities. This change would result in the removal
of tank vessels from the system, thereby reducing the risk of vessel spill.
4 . 1 . 1 O v e r v i ew o f P r o p o s e d P r o j e c t
In 2012, Cook Inlet Energy proposed the Trans-Foreland Pipeline Project that would consist of a 29-
mile, subsea pipeline built to transport up to 90,000 barrels of crude oil per day along the bottom of
Cook Inlet from Kustatan to Nikiski. At the federal level, the project qualifies for a nationwide
permit from the U.S. Army Corps of Engineers, pending a review by other agencies. Permitting by
the Alaska Department of Natural Resources is also required for the right-of-way. Figure 4 shows
the proposed pipeline route, which was modified in 2012 after consultation with the Southwest
Alaska Pilots Association to avoid the strong currents and deep areas in the immediate vicinity of
the Forelands (Baker, 2013). The project is estimated to cost $50 million (Loy, 2012).
4 . 1 . 2 Po t e n t i a l f o r S u b s e a Pi p e l i n e t o Re d u c e Ov e r a l l S p i l l Ri s k s
The construction of a subsea pipeline across Cook Inlet would reduce the number of tanker transits,
and therefore would also reduce the potential for a tanker spill because the exposure, or total
volume of oil transported by tanker, would be reduced. However, oil would still be transported
across the Inlet by pipeline, so spill risk is not entirely eliminated. The probability of a spill and
potential spill volume were compared for tankers and subsea pipelines.
The Glosten Associates estimated the extent to which the potential number and size of tanker spills
would be reduced if tankers were no longer transporting oil across Cook Inlet (The Glosten
Associates, 2013a). This estimate was developed based on the Cook Inlet Vessel Traffic Study (Cape
International, 2012) and Spill Baseline and Accident Causality Study (The Glosten Associates and ERC,
2012). Assuming the pipeline displaced all cross-Inlet tanker traffic, 38 one-way crude tanker
transits would be eliminated each year.7 This translates to removing 35.1 traffic-days per year from
the system, and would reduce spills by an estimated 0.105 per year (The Glosten Associates,
2013a).8 The potential size of these spills does not change from the sizes estimated in the Spill
7 The vessel traffic study was conducted using 2010 data. At that time, activity at the Drift River Terminal had changed
significantly due to the 2009 eruption of Mt. Redoubt. Because the Drift River oil storage tanks were not in service in
2010, actual numbers of tank vessels transits from the West to the East side of Cook Inlet are now lower though not
quantified for the study. (Information provided by Jack Jensen, Tesoro Alaska and Advisory Panel member.)
8 In addition to displacing tanker traffic, the pipeline would presumably eliminate the need to store oil at the Drift River
Terminal prior to vessel loading. This would reduce the potential for spills from the storage terminal which is currently at
a capacity of 1,080,000 bbl capacity per the operating company’s state-approved oil spill contingency plan (CIPL, 2013).
This risk reduction was not quantified as the terminal and associated storage are outside the scope of the CIRA.
Appendix J
Page 3 of 3

Recovery Plan
for the
Cook Inlet Beluga Whale
(Delphinapterus leucas)
National Marine Fisheries Service
National Oceanic and Atmospheric Administration
December 2016
Appendix K
Page 1 of 9
Cover photo is a composite of two photographs and was created specifically for this document.
Use by permission only:
Anchorage photo: Michael Benson
Beluga photo: T. McGuire, LGL Alaska Research Associates, Inc., under MMPA/ESA
Research permit # 14210
Appendix K
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Appendix K
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contaminant toxicity may change as the climate changes. There is no evidence to suggest that
this pesticide, with low toxicity for mammals, short half-life in water (2–18 days), and low level
of use in Alaska, is a threat to CI belugas.
b. Relative Concern
Predicting cumulative effects is extraordinarily difficult, as it requires knowledge of a myriad
of contextual factors for each exposure (e.g., acoustic exposure; contaminant exposure; predatory
exposure), and synergistic effects can be very unpredictable (Wright et al. 2007). Because
susceptibility varies among individuals in a population and because mortalities may be dispersed
over time, factors contributing to cumulative effects are difficult to detect, making mitigation of
these effects challenging. Stressors related to the current small population size of CI belugas,
when combined with anticipated trends of increased anthropogenic impacts, can increase the
likelihood of co-occurring and interacting multiple stressors that may combine effects to the
detriment of the CI belugas’ recovery.
Moreover, stress resulting from anthropogenic noise, a threat of high relative concern, needs
to be evaluated in combination with other stressors because noise has been demonstrated as a
component of harmful synergistic effects in several animals and humans (Steyger 2009).
Given the increase of human activities in Cook Inlet and the presence of contaminants in
Cook Inlet and CI belugas, the trend for and likelihood of cumulative effects is increasing over
time. Cumulative effects are categorized as a threat of high relative concern for CI belugas due to
the following: 1) multiple stressors occur year-round and throughout range of CI belugas; 2)
uncertainty regarding the magnitude of future cumulative effects; 3) uncertainty over the
mechanisms of existing and future cumulative effects (including synergistic effects, if any); 4)
difficulty in detecting impacts attributable to cumulative mechanisms; and 5) difficulty in
effectively mitigating cumulative effects due to the occurrence of multiple stressors.
3. Threat Type: Noise
Anthropogenic noise effects to CI beluga prey are discussed in the “Threat Type: Reduction
in Prey” section (III.A.6); and cumulative effects involving noise are considered in the “Threat
Type: Cumulative Effects of Multiple Stressors” section (III.A.2).
a. Sources of Noise in Cook Inlet
The acoustic environment of Cook Inlet is naturally noisy, complex, and dynamic. Natural
sources of noise are particularly abundant in the CI beluga hearing range and include: bottom
substrate being transported by high currents; sand and mud bars generating breaking waves
during low tide/high current periods; river mouths becoming rapids at low tide periods; and fast
and pancake ice being formed during winter months and under continuous mechanical stress by
high tide oscillations and currents. Furthermore, the inflow of cold freshwater of glacial origin
can vary considerably near major river mouths and arms in the upper Inlet, creating a complex
sound propagation environment due to changes in both salinity and temperature as a result of
sharp water mass fronts. These differences in water density and temperature act as sound
barriers, reflecting and refracting sound energy. In addition, the large volume of fresh water from
glacial areas surrounding Cook Inlet introduces suspended glacial silt and sediments into beluga
habitat. Silt and other fine sediments suspended in the water column create acoustic clutter (a
volume of scattered sound reflection) that can further impede echolocation performance. The
Appendix K
Page 4 of 9
presence of all of these natural sources of noise varies over time and space, as does their
contribution to the overall ambient noise of Cook Inlet. Their contribution is important as a wide
range of frequencies overlap with beluga signals, including both lower frequency ranges used for
social communication and higher frequency ranges used for echolocation. The effects of these
natural conditions, while difficult to quantify, may compromise CI beluga acoustic
communication and echolocation, particularly as the sound transmission distance increases.
Consequently, the natural acoustic space for CI belugas may be more limited than for belugas
found elsewhere. This particular condition enhances the potential for negative effects when
anthropogenic sources of noise are introduced into CI beluga habitat.
Due to the co-occurrence of Alaska’s urban center and the current range of CI belugas, a
wide variety of anthropogenic noises that could affect recovery exists, especially in the upper
Inlet. Most sources of anthropogenic noise in Cook Inlet are seasonal and occur during the icefree
months, although some sources are present year-round. Sources of anthropogenic noise in
Cook Inlet include: propeller cavitation, engines, and depth sounders associated with vessels;
dredging activities; pile driving activities; military detonations; aircraft; airguns used for seismic
surveys; drilling associated with oil and gas exploration; hydraulic/mechanical noise; and sounds
associated with other noise-producing activities. Although there are several technical reports
documenting specific Cook Inlet noise sources and their signal characteristics,19 a
comprehensive survey of anthropogenic noise sources in Cook Inlet and beluga exposure to these
sources has not been conducted. Most of the identified sources in the Inlet are not well
documented, and many are not controlled, monitored, or regulated.
Due to industrial activity and development in the current range of CI beluga, a wide variety
of anthropogenic noise sources that could potentially interfere with recovery are present in CI
beluga habitat. Sources are listed below by order of importance, based on signal characteristics
and the spatio-temporal (space and time) acoustic footprint. The order was determined by
considering the following factors: intensity (loudness), frequency (range of tones), and duration
of acoustic signal; area affected by the sound source; and duration of sounds in both seasonal
terms (e.g., happening all summer) and frequency of occurrence (e.g., happening once per week
throughout the summer; M. Castellote, NMFS, unpub. data).
• Tug boat noise: propeller cavitation (the formation of bubbles in a liquid) and engine
noise including azimuth/bow thruster noise;
• Cargo/tanker noise: propeller cavitation and engine noise including bow thruster noise;
• Small vessel noise: outboard and inboard engine noise and propeller cavitation;
• Dredging: suction and/or grabbing operations;
• Pile driving noise: hammering or vibratory noise (rotatory or oscillatory to a lesser
extent);
19 See a sample listing of acoustic reports pertaining to Cook Inlet and Cook Inlet belugas available on the NMFS AKR Research
on Cook Inlet Belugas webpage: http://alaskafisheries.noaa.gov/pr/beluga-research-cook-inlet.
Appendix K
Page 5 of 9
• Military detonations of high explosives:20 demolition and projectile explosions in military
firing ranges;
• Oil/gas exploration: airgun sources for seismic survey and high power active transducers
(multibeam echosounders, sub-bottom profilers, etc.);
• Shore construction noise: other than pile driving;
• Oil/gas exploitation: platform noise (in-air noise radiated into the water), drilling noise
(in water and/or bottom substrate), air/water vessels during operations;
• Commercial jet aircraft: overflights, take offs, and landing approaches;
• Military jet aircraft: overflights, take offs, and landing approaches;
• Propeller aircraft: overflights, take offs, and landing approaches;
• Depth sounders: from vessels;
• Fishing related noise (other than engine noise): hydraulic/mechanical operations;
• Research related noise: sonars such as acoustic Doppler current profilers and dualfrequency
imaging sonars; scientific echo sounders and other active transducers, boat
transit for photo-identification surveys, and instrument deployment/retrievals, etc.; and
• Pipe and cable laying operations.
Climate change is having an indirect effect on ocean noise pollution (Reeder and Chiu 2010).
As levels of carbon dioxide rise in the atmosphere, ocean waters are becoming more acidic.
Ocean acidification reduces concentrations of seawater salts that absorb sound, particularly lowfrequency
sound. This ocean pH change is predicted to be greatest in higher latitudes, allowing
lower frequency sound to carry farther and to be stronger at a given distance. Shallow sound
channeling exists in Cook Inlet, which allows potential noise impacts to be concentrated in
shallow waters and become more spatially extensive (i.e., sound channels can trap noise and
allow it to travel farther). At the same time, climate change may directly result in either an
increase or decrease of in-water noise. For example, warming temperatures may reduce the
prevalence of ice cover, and thus reduce ice-associated noise, but warmer temperatures may also
result in higher wind speeds resulting in higher noise levels at the waters’ surface.
b. Potential Effects of Noise on CI Belugas
There is an extensive body of literature regarding the effect of anthropogenic noise on marine
mammal behavior. Most of the studies addressing this problem have used behavioral attributes
such as changes in site fidelity, dive patterns, swimming speed, orientation of travel, herd
cohesiveness, and dive synchrony to indicate possible disturbance or stress caused by noise
(Richardson et al. 1995). A review and summary of available information regarding effects from
anthropogenic noise to beluga hearing and behavior is presented in Appendix IX.E – CI Beluga
Hearing, Vocalization, and Noise Supplement.
20 Demolition activities and mortar/artillery firing on military ranges.
Appendix K
Page 6 of 9
Factors, whether anthropogenic or natural, that affect the available prey species may have a
greater impact on one prey species or species subcomponent (e.g., age or size-related). Resultant
changes in relative abundance of prey will affect the prey composition available (Pyke et al.
1977).
a. Competition for Prey Resources
CI belugas compete with humans and other animals for prey resources, particularly salmon
and eulachon. Quantitative data on the spatial and temporal distribution of beluga prey in upper
Cook Inlet are limited (see Appendix IX.F – CI Beluga Prey Supplement). Although
management of fisheries targeting anadromous species in Alaska attempts to constrain harvests
to be no greater than the level of surplus production, it is unlikely that escapement goals will be
met in all tributaries across all years. Effects of fishing by humans on beluga foraging success
are not well known, yet may include spatial and temporal components for any specific prey
resource. Effects on belugas will depend on the extent to which a reduction occurs to the
abundance, quality, or availability of prey (localized or Inlet-wide), and if the belugas can
compensate for losses of preferred prey by shifting to other feeding sites or less-preferred prey. If
a non-preferred prey species is reduced, the relative or absolute abundance of preferred prey may
increase over time, depending on the ecological linkages and response times. The temporal
distribution of these prey resources may be as important as their magnitude, particularly for
growing juveniles and pregnant and/or lactating female belugas. Changes in seasonality of prey
may occur due to seasonality and species preference of fisheries, changes in seasonal fish habitat,
or seasonal environmental changes affecting Cook Inlet. The extent to which shifts in the
seasonality of prey species or temporal gaps in prey availability impact reproductive success and
survival of belugas, particularly during critical life stages, is unknown. However, these impacts
are likely to be most important if affecting temporal availability of energy-rich high-lipid prey.
Alternatively, events that result in decreases of specific runs or changes in the availability of prey
(e.g., by changing schooling patterns or altering nearshore terrain) may leave temporal gaps in
the availability of prey at sufficient densities resulting in the reduction in total days when beluga
blubber fat storage can occur. For more information see Appendix IX.F – CI Beluga Prey
Supplement.
CI belugas may also compete against other predators (harbor porpoise, harbor seals, killer
whales, sea lions, large whales, sea otters, sea birds, etc.) for available prey resources,
particularly in upper Cook Inlet where the available prey resources may be more limited in
abundance or diversity. Although there may be some foraging specialization upon available prey
species, there is also likely to be a high degree of dietary overlap due to the limited prey diversity
available. In upper Cook Inlet, belugas are most likely to compete for prey resources with harbor
seals and harbor porpoises, which have been documented also to be present in Cook Inlet year
round and co-occur in the same general locations as CI belugas (Small et al. 2011; AEA 2013; T.
McGuire, LGL, unpub. data).
b. Disturbance or Modification of Prey Habitat
The amount or types of prey available to CI belugas may also be reduced as a result of
disturbances or modifications to prey habitat. Anthropogenic activities that may detrimentally
affect prey habitat and possibly reduce the availability of prey to belugas are present both
seasonally and continuously in Cook Inlet. Anthropogenic activities in Cook Inlet that may
Appendix K
Page 7 of 9
disturb or modify the habitat of beluga prey include dredging; oil or gas activities; hard rock
quarrying; laying of electrical, communication, or fluid lines; construction of docks, bridges,
breakwaters or other structures; and other activities. These activities may cause avoidance or
destruction of an area used by beluga prey as a result of anthropogenic disturbance. Permanent
structures, such as docks, platforms, or bridges, alter the Cook Inlet habitat by altering local tidal
flow, among other potential effects. However, the net effect of anthropogenic structures on
beluga prey remains unknown.
In addition to loss of habitat available to beluga prey species by displacement or avoidance,
anthropogenic activities may reduce the quality of the prey as a result of contamination of the
habitat. For example, mechanical disturbance of the seafloor (e.g., dredging) re-suspends silt, and
potentially buried chemicals, into the water column. A sewer outfall plume alters both the abiotic
and biotic environment, releasing various hormones, pharmaceuticals, and other chemicals into
Cook Inlet. Catastrophic events such as oil or chemical spills are infrequent, but may have
significant effects on beluga prey, whether through changes to spawning or migration patterns,
direct mortality, or potential long-term sub-lethal impacts (Moles et al. 1994; Marty et al. 1997;
Murphy et al. 1999). While some of these contaminants are known to bioaccumulate and be
passed up the food chain, they also may impact the survival, quality, and reproduction of the
prey species itself. For example, elevated copper concentrations can harm salmon and other CI
beluga prey.
The habitat upon which beluga prey depend may also be affected by natural events,
including: Pacific decadal oscillation, an El Niño-like pattern of Pacific climate variability
(potentially affecting rainfall, freshwater runoff, water temperature, and water column stability);
climate change (potentially affecting glacial output and siltation and salinity in downstream
estuarine environments); volcanic ash outfall (affecting siltation and water chemistry); and
earthquakes and associated landslides, elevation changes, and tsunami waves. Some of these
natural threats are infrequent, but may have instantaneous and substantial impacts upon
abundance, quality, or seasonality of CI beluga prey. However, other threats, such as Pacific
decadal oscillations, may occur more regularly, may or may not be readily detectable, may
develop over an extended time period, and may have long-lasting ecological effects.
Ecological regime shifts, in which species composition is restructured in association with
abrupt changes in climate, have been identified in the North Pacific (Hollowed and Wooster
1992; Anderson and Piatt 1999; Hare and Mantua 2000; Spies 2007) and are believed to have
affected prey species availability in Cook Inlet. For example, in the 1970s, dominance in the
Gulf of Alaska ecosystem transitioned from crustaceans to groundfish, particularly gadid (e.g.,
cods) species. In another analysis, Hare and Mantua (2000) reaffirmed the 1976 to 1977
ecosystem change in the Gulf of Alaska and identified a less dramatic shift in 1989. Analyses of
multi-decadal data from small-mesh trawl surveys conducted by NMFS and ADF&G showed
ecosystem reorganization in the 1970s at Kachemak Bay in southern Cook Inlet and around
Kodiak Island and in Shelikof Strait located in the northern Gulf of Alaska south and west of
Cook Inlet Gulf waters (Bechtol 1997; Anderson and Piatt 1999). Of particular note was a
decline in forage species, particularly pandalid shrimp and capelin, and increases in cod, pollock,
and flatfish.
Changes to the marine, coastal, and freshwater ecosystems are known to be occurring as a
result of global climate change and the associated occurrence of shifts in temperature, oxygen
content, ocean acidification, and other physical and chemical changes (Doney et al. 2012), and
Appendix K
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Surveys, Cook Inletkeeper, the Alaska Ocean Observing System, and the CI beluga photoidentification
project’s “Seen Belugas?” sighting program). The monitoring program could be
organized and supported by the NMFS Cook Inlet Beluga Recovery Coordinator (see Action 2).
39. Evaluate impacts on CI belugas from anthropogenic activities with potential to result in
degradation or loss of CI beluga habitat, with emphasis in known and historic feeding areas.
Construction and operation of new physical structures (e.g., bridges, docks, dams, etc.) and
increased numbers of vessels in CI beluga habitat can potentially affect the distribution,
migration, or behavior of CI belugas and their prey. However, a lack of understanding of
distribution, migration, and behavior patterns of prey inhibits potential mitigation measures and
argues for a more precautionary approach to maximize opportunity for CI beluga recovery.
Additional information is needed on the impacts to CI belugas from construction and operation
of physical structures, including structures located both within Cook Inlet proper and upstream of
CI beluga habitat (which could affect beluga prey). Particular emphasis should be given to areas
of known and historic feeding importance (e.g., Susitna River and Delta; Kenai River; Knik
Arm).
40. Assess the biological benefits, costs, and implementation feasibility of potential protection or
restoration measures for particular habitats important to CI beluga recovery and implement
such measures if determined warranted.
Considering the ecological value, stability, and resiliency of habitats important for CI beluga
recovery, including habitats that support foraging or reproduction, an analysis will be needed to
determine if protection or restoration measures are warranted and whether previous mitigation
measures may no longer be needed. Throughout the long term, a variety of potential mitigation
measures may be applied, representing a range of likely outcomes for CI beluga habitat and
future CI beluga recovery. An analysis must first be conducted to evaluate the costs, biological
benefits, and implementation feasibility, of potential protection or restoration measures. For
some potential measures, realistic benefits may be achieved at little cost, whereas other measures
may be expensive to implement and are likely to offer questionable or limited positive results.
Implementation of any protection or restoration measures must be accompanied by long-term
monitoring to determine the effects on CI beluga recovery. Because CI beluga recovery is likely
to be an ongoing process, the array of potential protection or restoration measures should be
periodically examined and the implemented measures revised as needed.
41. Work with local, state, and federal agencies and stakeholders to develop a comprehensive
Cook Inlet habitat database, and methods and plans for reducing or mitigating the levels of
habitat loss or degradation in areas of known importance to CI belugas for foraging and
reproduction, including restoration of habitats if necessary.
Ongoing and future coastal development projects that are deemed likely to degrade CI beluga
habitat should be mitigated. Potential effects of individual development projects should be
evaluated on the basis of the aggregate and comprehensive impacts on beluga habitat, taking into
account existing projects and disturbance, and not simply as the incremental impact of an
additional individual project. Such mitigation efforts will be most effective if they are developed
collaboratively between government and non-government entities. For instance, collaborative
work with municipalities or other entities could be undertaken to help minimize runoff and
stormwater pollution and to reduce the incidence of toxic spills into Cook Inlet.
Appendix K
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Appendix L
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Appendix L
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Appendix L
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Appendix L
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Appendix L
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Appendix L
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12/19/2016 Minto Flats State Game Refuge Fish and Wildlife, Alaska Department of Fish and Game
http://www.adfg.alaska.gov/index.cfm?adfg=mintoflats.species 1/1
Alaska Department of Fish and Game
ADF&G Home » Lands and Waters » Conservation Areas » Minto Flats
Switch to area:
Minto Flats Go
Minto Flats — State Game Refuge
Fish and Wildlife
Overview Fish and Wildlife Visitor Information Permits Contacts
Birds
Minto Flats is one of the highest quality waterfowl habitats in
Alaska. It supports high density duck nesting, producing
150,000 or more ducks annually, with breeding populations
averaging 213 ducks per square mile. The refuge sustains
one of the largest trumpeter swan breeding populations in
North America. Minto Flats is also an important spring and
fall waterfowl staging area, particularly for geese and
swans. Sandhill cranes and loons nest in the area in
relatively large numbers. Bald eagles are known to nest in
the flats, and peregrine falcons have historically nested
adjacent to the refuge. During winter, grouse and ptarmigan are present in large numbers, and
overwintering passerines and small owls are common.
Mammals
Minto Flats has historically supported large numbers of moose and provides excellent habitat for black
bear. Healthy populations of furbearers inhabit the flats, including beaver, muskrat, river otter, lynx,
wolverine, red fox and mink. Marten, normally a dry land dweller, is uncommonly abundant on the flats.
Fish
The rivers and shallow lakes on the flats combine to make an excellent home for northern pike, burbot
and grayling. Several species of whitefish (including sheefish) reside there also. Chinook, chum and
coho salmon migrate through the area. Many of the lakes that are not connected to rivers support
blackfish.
Appendix M
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Appendix N
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Appendix N
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Appendix N
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Appendix N
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Denali State Park
Management Plan
2006
Division of Parks and Outdoor Recreation
Alaska Department of Natural Resources
Appendix O
Page 1 of 8
Denali State Park
Management Plan
Adopted 2006
Division of Parks and Outdoor Recreation
Alaska Department of Natural Resources
Appendix O
Page 2 of 8
Appendix O
Page 3 of 8
FRANK H. MURKOWSKI, GOVERNOR
400 WILLOUGHBY AVENUE
JUNEAU, ALASKA 99801-1796
PHONE: (907) 465-2400
FAX: (907) 465-3886
DEPARTMENT OF NATURAL RESOURCES 550 WEST 7TH AVENUE, SUITE 1400
ANCHORAGE, ALASKA 99501-3650
DIVISION OF PARKS AND OUTDOOR RECREATION PHONE: (907) 269-8431
FAX: (907) 269-8918
“Develop, Conserve, and Enhance Natural Resources for Present and Future Alaskans.”
June 30, 2006
Dear Alaskan,
The creation of Denali State Park in 1970 and expansion in 1976 was the realization of decades of
local, state, and national interest and involvement. Renowned for its wealth of natural resources
and recreational opportunities, Denali State Park is one of the jewels of the Alaska State Park
System. Sharing a common boundary with Denali National Park and Preserve to the north and the
Matanuska-Susitna Borough and state lands to the south, the state park and its surrounding public
lands offer limitless outdoor opportunities, spectacular mountain scenery, and an abundance of fish
and wildlife.
For the last several years, it has been widely recognized that the northern Susitna Valley is
experiencing increasing pressures from private and commercial development as well as by
increasing recreational use and tourism. To address these concerns, the State of Alaska along with
its partners, the Matanuska Susitna Borough and the National Park Service, embarked on a planning
effort to ensure that the increasing development and uses in this area occur in an orderly manner. It
was important to the partners to provide for a diversity of uses while being sensitive to the concerns
of local residents. Over the course of the planning process, planners made every effort to address
and accommodate concerns and desires while fulfilling the mandate of the park’s enabling
legislation. This plan represents these efforts and we are proud of the results.
This plan is designed to be used over the next twenty years. As resources become available to State
Parks, the recommendations in the plan will be implemented in phases. In addition, State Parks will
continue to participate in planning efforts for lands along the park’s boundaries. We look forward
to working together with the public, the State Parks Advisory Board, and the South Denali Steering
Committee to address the pressing issues in the region, to help achieve the plan’s goals, and to
better serve the public.
Sincerely,
Jerry Lewanski
Director
Appendix O
Page 4 of 8
Chapter 1 – Introduction
Chapter 1
INTRODUCTION
Plan Purpose
This plan provides guidance for management of park lands and development of recreational
facilities, consistent with the park’s Mission Statement. In addition, the plan discusses
trends in recreation and tourism, and provides natural resource information that will simplify the
task of maintaining a current resource database as new information becomes available.
Establishment of the Park
The Alaska State Legislature created Denali State Park (AS 41.21.150-152) in 1970, and in
1976 amended the boundary to add the upper reaches of the Tokositna basin, west of the old
park boundary (see Figure 1). In both actions, the legislature had a strong interest in tourism
related development, as well as providing recreational opportunities for Alaskans and preserving
the area’s natural resources. In 1994 the Blair Lake and Tokositna State Recreation Areas were
established. The Indian River State Recreation area was added in 2002. All three were created
through management agreements within DNR.
Overview of the Park
Denali State Park is approximately 324,240 acres in size. The State Recreation Areas include an
additional 1,470 acres. Although much smaller than Denali National Park and Preserve to the
north (6,028,203 acres), Denali State Park and its associated State Recreation Areas are very
diverse area. They afford tremendous views of Denali; contains three major rivers, the Susitna,
Chulitna, and Tokositna; and have three glaciers adjacent to or within its boundaries, the Ruth,
Eldridge and Tokositna. Vegetation ranges from lowland spruce and hardwood forests to alpine
tundra. The George Parks Highway transects the park and opens its scenery, wildlife and other
natural resources to the public.
Primary uses of the park are camping, hiking, fishing, viewing Denali, canoeing, rafting, river
boating, hunting and trapping.
Historical Background
The Mount McKinley National Park was created in 1917, when the federal government
“reserved” a 2 million acre tract around Mt. McKinley as a national park. The national park
quickly became one of Alaska’s primary tourist attractions.
Denali State Park Management Plan 1
Appendix O
Page 5 of 8
Chapter 2 – Goals & Objectives
Chapter 2
GOALS & OBJECTIVES
Park Mission Statement
The park’s enabling legislation does not include a formal statement of purpose for Denali State
Park. The Division of Parks and Outdoor Recreation, as part of the planning process and
in conjunction with the Susitna Valley State Park Citizen’s Advisory Board, developed the
following “Mission Statement” to serve in the absence of an explicit legislative statement of
purpose.
Denali State Park shall be managed and developed in a manner compatible with the following
goals:
I. Protect the natural and cultural resources of the park and ensure that the park’s resources
are maintained to allow for the public’s experience and understanding of the unique
natural features that are found in this part of Alaska.
II. In a manner that is compatible with Goal I, provide for a variety of opportunities for
visitors to the park to experience and understand the park’s natural and cultural
resources, including viewing Denali.
Park facilities shall be designed and developed to support the public use and
understanding of the park and its resources and not serve as attractions in and of
themselves.
III. In a manner that is compatible with Goals I and II, recognize and accommodate, in so far
as reasonable, the diverse needs of different types of visitors to the park. Avoid conflicts
between different groups of visitors or between visitors and park resources.
Denali State Park Goals and Objectives
There are a number of goals and objectives to be achieved in the management and development
of Denali State Park. This section presents a list of goals, organized into four groups:
environmental, cultural, recreational, and tourism. Each goal statement is followed by
specific objectives. The objectives are not ranked in terms of priority.
1. Protect Natural Resources within the Park. The park’s natural resource base consists of two
parts: 1) the natural ecosystem with its processes and wildlife, and 2) the visible landscape
composed of natural and man-made features.
• Protect naturally significant areas, such as:
o specific habitat areas (such as bear denning and swan nesting areas),
Denali State Park Management Plan 7
Appendix O
Page 6 of 8
Chapter 2 – Goals & Objectives
o sensitive wetlands,
o sensitive alpine and sub-alpine tundra,
o wildlife concentration areas, such as along rivers and creeks during salmon spawning
season.
• Minimize impact to the park landscape, in general, by:
o locating non-recreational activities outside the park,
o locating facilities and activities where carrying capacity is adequate,
o concentrating development in nodes to minimize the area disturbed,
o locating recreation facilities relatively close to the highway to reduce impact to the
backcountry,
o rehabilitating disturbed areas, such as existing gravel borrow sites, to natural
conditions or using them to meet recreation facility objectives,
o designing and locating recreation facilities to minimize the need for management
controls, and
o limiting opportunities for misuse of the park.
• Minimize conflict with natural processes by:
o locating facilities and activities on soils that are well-drained, permafrost-free, and
not subject to erosion,
o locating intensive development on sites that have gentle slopes that will not be
subject to erosion,
o locating facilities and activities outside floodplains (including glacier outburst
floods),
o locating recreation facilities where there is adequate water for proposed uses, and
o locating facilities where the soil is suitable for waste disposal (Note: a package
treatment plant is recommended for intense development sites, such as a lodge).
• Protect the natural character of the landscape by:
o protecting the view from the road and the railroad, and keeping major development
out of sight,
o designing facilities to blend, rather than contrast with, the natural landscape, and
o keeping the scale of facilities (including roads, parking, buildings, and other
structures) relatively small.
2. Protect Historic Sites and Current Land Uses, and contribute to a new sense of community
in the Denali Region.
• Protect historic and cultural sites, such as:
o the Curry Lookout, and
o any archaeological sites discovered (none are known to exist in the park).
8 Denali State Park Management Plan
Appendix O
Page 7 of 8
Chapter 7 – Management Recommendations
Activity/Facility Natural Wilderness Cultural
Recreation
Development
Guiding and Outfitting. Licensed big game
hunting, fishing, mountaineering, and
backcountry guiding, outfitting, and all other
commercial operations providing services to park
users for compensation.
Compatible only by
permit or concession
contract issued by
DPOR.
Same Same Same
Grazing. Grazing or loose herding of domestic
or wild animals for personal or commercial
purposes.23
Not compatible Same Same Same
Resource Extraction. Extraction for commercial
or personal use. Removal of timber, gravel,
rock, sand, minerals, plants, or other park
resources.
Not compatible Same Same Same
Resource Extraction by State Parks. Removal of
timber, gravel, rock, sand, plants, or other park
resources for use by State Parks in the park.
Compatible Not Compatible Compatible Compatible
Utilities, Transmission Lines, Pipelines.
Includes telephone and electrical power lines, oil
and gas pipelines, communication and wind
generation towers and other associated facilities.
Allowed by permit only
when no viable
alternative exists.
Tower heights limited to
85 feet. Use best
practices to minimize
impacts to viewshed,
especially areas within
viewsheds of areas with
high public use.
Not compatible Not compatible Same as Natural
23 From 11 AAC 20.430.
Denali State Park Management Plan 65
Appendix O
Page 8 of 8

FISHERY MANAGEMENT PLAN
For The
SALMON FISHERIES
In The EEZ Off Alaska
North Pacific Fishery Management Council
National Marine Fisheries Service, Alaska Region
State of Alaska Department of Fish and Game
June 2012
North Pacific Fishery Management Council
605 W. 4th Avenue, #306
Anchorage, AK 99501-2252
Appendix P
Page 1 of 4
Figure 19 EFH Distribution for Sockeye Salmon – South-Central Region
Figure 20 EFH Distribution for Sockeye Salmon – Southwestern Region
Appendix P
Page 2 of 4
Figure 25 EFH Distribution for Chinook Salmon – Southeastern Region
Figure 26 EFH Distribution for Chinook Salmon – South-Central Region
Appendix P
Page 3 of 4
Figure 33 EFH Distribution for Coho Salmon – South-Central Region
Figure 34 EFH Distribution for Coho Salmon – Southwestern Region
Appendix P
Page 4 of 4

Overview of TAPS
Pipeline Facts
Glossary
Pipeline History/Design
/Construction
Permafrost
Pipeline Bridges
Earthquake
Protection
Pipeline Operations
Declining Throughput
Low Flow Impact
Study
Crude Oil
Pump Stations
Throughput
Valdez Marine Terminal
& Tankers
Tankers
SERVS
Assets & Capabilities
Oil Spill Exercise
Program
Vessel of
Opportunity
Electrification &
Automation
The Valdez Marine Terminal
The Valdez Marine Terminal marks the end of the Trans Alaskan Pipeline System. Located in the northeast corner of Prince William
Sound, the Terminal lies on more than 1,000 acres of land. The facility was designed for loading crude oil onto tankers and holding
crude oil so that North Slope production can continue without impact from the marine transportation system. There are 14 storage
tanks in service, facilities to measure the incoming oil, two functional loading berths, and a power plant.
At the Terminal, crude oil is measured and stored, then loaded onto tankers and sent to market. Tankers tie into a berth, where they
hook into loading arms to take on crude oil. Before loading begins, crews protect the surrounding waters by placing an oil spill
containment boom around the berth and tanker.
The Valdez Marine Terminal also has a facility to purify storm water, other Terminal drainage water, and primarily ballast water — the
water that fills tankers’ hulls to stabilize them before they take on crude cargo. The Ballast Water Treatment system sends oily water
through multiple processes to strip it of any hydrocarbons.
Basic information
Located in Port Valdez, the northern most ice-free port in the U.S
Total area — 1,000 acres
Cost to build — $1.4 billion
Elevation — sea level to 660 ft. All facilities except berths 15 ft. or higher
18 storage tanks constructed, 14 in service as of January 1, 2012
Current holding capacity in crude oil with 14 tanks — 7.13 million bbl.
Two functional loading berths with vapor recovery capacity
Back to top
©2011 Alyeska Pipeline Service Company. All Rights Reserved
Site Map | Contact
About Us TAPS Safety & Environment News Center Employment Connect
Alyeska Pipeline – TAPS – Valdez Marine Terminals & Tankers http://www.alyeska-pipe.com/TAPS/ValdezTerminalAndTankers
1 of 1 12/19/2016 5:14 PM
Appendix Q
Page 1 of 1

MENU
H O M E ( / ) O C E A N F A C T S ( / F A C T S / ) W H E R E I S T H E H I G H E S T T I D E ?
Where is the highest tide?
The highest tide in the world is in Canada.
The highest tides in the world can be found in Canada’s Bay of Fundy. Shown here: Hopewell Rocks, New Brunswick, located in the Bay. Image credit: New Brunswick
Department of Tourism and Parks (Canada).
The highest tides in the world can be found in Canada at the Bay of Fundy, which separates New Brunswick from Nova Scotia. At some times of the year the diꃢ�erence between high and
low tide in this Bay is 16.3 meters (53.5 feet), taller than a three-story building.
The highest tides in the United States can be found near Anchorage, Alaska, with tidal ranges up to 12.2 meters (40 feet).
Tidal highs and lows depend on a lot of diꃢ�erent factors. The shape and geometry of a coastline play a major role, as do the locations of the Sun and Moon. Storm systems at sea and on
land also shi脔� large quantities of water around and aꃢ�ect the tides. Detailed forecasts are available for high and low tides in all sea ports, but are specific to local conditions.
That many of the areas of the world with high ranges of tides are in the areas of Alaska, Canada, and northern Europe has created a misconception that the range of tide increases with
increasing latitude (as one moves farther from the equator and closer to the poles). This is incorrect.
Increased tidal ranges in these areas are created by the positions and configurations of the continents in the northern hemisphere. In the higher latitudes of the northern hemisphere,
the continents of North America, Europe, and Asia are pressed closer together. This “constriction” of the oceans creates the eꃢ�ect of a higher range of tides.
In the higher latitudes of the southern hemisphere, in the southern tips of South America, southern Africa, Australia, and Antarctica, tidal ranges are not increased. In these areas the
continents are not pressed closely together, there is not a “constriction” of the oceans, and the tidal ranges are not increased.
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Appendix R
Page 1 of 2
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Appendix R
Page 2 of 2

RIVER MANAGEMENT PLAN
FOR THE
DELTA NATIONAL WILD AND SCENIC RIVER
U.S. DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
ANCHORAGE DISTRICT, ALASKA
Appendix S
Page 1 of 3
Delta River Management Plan
20
• WSRA requires that each component of the national wild and scenic rivers
system be administered to protect and enhance the values which caused it to be
included in the system.
• The Delta River Habitat Management Plan outlines actions for protecting and
enhancing fish and wildlife habitat.
ITEM 13 – SCENIC QUALITY
Issue
How will the existing natural scenic qualities within the river corridor be protected?
Situation
Most of the scenery around Tangle Lakes and the wild stretch of the Delta River is
outstanding and is in a natural primitive condition. The area east of the recreational
stretch has been modified by highway and pipeline construction.
Considerations
• The outstanding quality of the existing scenery was a major reason for including
the Tangle.Lakes and Delta River in the wild and scenic rivers system.
• The WSRA (Section 10) allows for changes in the existing landscape if those
changes do not substantially interfere with public enjoyment of the scenery.
ITEM 14 – PIPELINES AND ELECTRICAL TRANSMISSIONS
Issue
Will additional pipelines and other utility lines be allowed within the river corridor?
Situation
A portion of the wild stretch of river and all of the recreational stretch is within the utility
corridor originally established as a route for the Trans-Alaska Pipeline System.
Construction of a liquid natural gas pipeline through this utility corridor has been
proposed.
Considerations
• The purpose of the utility corridor is to serve as a route for pipelines, power
transmission lines and other utility lines.
• ANILCA allows for transportation and utility corridors across wild and scenic
rivers (Section 1105).
• WSRA allows for easements and rights-of-way upon, over, under, across, or
through any component of the national wild and scenic rivers system (Section
13).
• The scenery and other values along a wild and scenic river must be protected.
Appendix S
Page 2 of 3
Delta River Management Plan
21
ITEM 15 – OIL AND GAS DEVELOPMENT
Issue
How will oil and gas exploration and development be affected by the river corridor?
Situation
The Denali/Tiekel amendment to BLM’s Southcentral Management Framework Plan
resulted in a Public Land Order (PLO 6329) which opened most of the land adjacent to
but not within the river corridor for mineral location and oil and gas exploration under the
United States mining and mineral leasing laws. However, the potential for commercial
deposits of oil and gas in the area around the river corridor is considered to be low.
Considerations
• Utility corridor.
• ANILCA (Section 606) amended WSRA (Section 9) to withdraw minerals in
Federal lands within one-half mile of a wild river in Alaska from all forms of
appropriation under the mining laws and mineral leasing laws.
• The WSRA does not prohibit mining and mineral leasing within the boundaries of
scenic or recreational rivers but does provide for regulating activities associated
with this industry (Section 9).
ITEM 16 – NAVIGABILITY
Issue
How will a navigability determination for the Delta River and Tangle Lakes affect this
management plan?
Situation
Preliminary findings of the BLM are that the Delta River is non-navigable. The
navigability situation has been discussed under BLM policy for boundary determination.
Considerations
• The State owns the bed of navigable waters up to the ordinary high water mark.
• The wild and scenic river boundaries will not include land owned by the State.
• The WSRA (Section 10) provides for a cooperative agreement with the Governor
of a State to participate in the administration of a wild and scenic river.
ITEM 17 – CLASSIFICATION OF THE TANGLE LAKES AND TANGLE
RIVER
Issue
What WSRA classification (wild, scenic, or recreational) will be applied to the 24-mile
Tangle Lakes and Tangle River segment of the river corridor?
Appendix S
Page 3 of 3

RIVER MANAGEMENT PLAN REVISION
for the
GULKANA RIVER
A Component of the National Wild and Scenic Rivers System
U.S. Department of the Interior
Bureau of Land Management
Glennallen Field Office
August, 2006
Appe ndix T
Page 1 of 2
River Management Plan Revision
access via the road mentioned under Item 1, helicopter, and occasionally powerbo
and airboat. Alyeska, the company responsible for pipeline maintenance, periodically
conducts spill response drills, staging activity out of Sourdough campground and boat
launch.
at
Considerations:
with the provisions of the Wild and Scenic Rivers Act (WSRA) and
l
• mitive and scenic qualities of
ction 14.1: New pipelines and electrical transmission lines will not be permitted within
iscussion:
• In accordance
Title XI of ANILCA, new utility systems may be permitted within NWSR corridors.
This includes items such as electric transmission lines and other systems of genera
transportation and utility transmission. ANILCA sections 1104 and 1105 provide
applicable standards for granting such authorizations
New pipeline/utility corridors would detract from the pri
the river corridor.
A
or across the wild river corridor unless conditions of ANILCA Section 1105 and the
WSRA are met.
D Before any such utility line will be authorized, a determination must first be
ITEM 15: NAVIGABILITY
Situation:
made that it would be compatible with the purposes for which the national wild river was
established, and that there is no economically feasible and prudent alternate route or
location (ANILCA 1105, WSRA).
Navigability has been determined on the Gulkana. Consequently, this issue
ITEM 16: HEADWATERS OF THE SOUTH BRANCH OF THE WEST FORK
Issue: How should the 15 miles of floatable water upstream of the designated
ituation:
has been addressed in Item 11, State and Private lands, under Action Item 11.1 which
provides for cooperative management with the State.
portion of the south branch of the West Fork Gulkana River be managed?
S It has been established through field investigation that the start of the
ot the
na
designated river corridor on the south branch of the West Fork Gulkana River is n
actual start of the floatable section of this river. The south branch of the West Fork can
actually be floated from two separate lakes 15 miles upstream from the lake identified
as the start of the river corridor. This 15-mile segment upstream of the start of the
designated wild river corridor contains the wildest stretch of river on the entire Gulka
River system. There are no roads, trails, or privately owned lands along this stretch of
the river. This segment shares the same outstandingly remarkable values as identified
for the designated corridor.
Part IV: Management Considerations 57 Gulkana NWSR Appendix T
Page 2 of 2

UTILITY CORRIDOR
Resource Management Plan/
Environmental Impact Statement
RECORD OF DECISION
prepared by
United States Department of the Interior
Bureau of Land Management
Arctic District Office
January 11, 1991
/
Appendix U
Page 1 of 2
Utility Corridor Record of Decision
Introduction
This document is the Bureau of Land
Management’s (BLM) Record of Decision
prepared for the Utility Corridor Resource
Management Plan/Environmental Impact Statement
(RMP/EIS). The Utility Corridor RMP is a longterm
comprehensive land use plan developed to
direct the BLM’s management of a portion of the
lands and minerals it administers in northern
Alaska. The lands are shown on map 1.1, of the
Proposed RMP (reproduced in this document for
your convenience) and amount to approximately
6.1 million acres of BLM-administered surface, of
which 5.8 million acres is BLM-adrninistered
mineral estate. The Utility Corridor RMP
supersedes all previous land use planning
decisions for this area, many of which are
contained in a Management Framework Plan
completed in 1979.
The Utility Corridor, established by Public Land
Order (PLO) 5150, as amended, on December 30,
1971, is an essential component of the national
domestic oil and gas transportation system. It
provides a route to transport a significant portion
of the nation’s petroleum; the present and future
importance of access to these resources cannot be
overstated. In recognition of this fact, the
Proposed RMP provides that the primary
management direction and use of BLM- .
administered lands in the Utility Corridor is’ for
energy transportation. Therefore, both the “Inner”
and “Outer” Corridor, as shown on map 1.1 of the
Proposed RMP, are designated as a Federal Land
Policy and Management Act of 1976 (FLPMA)
section 503 right-of-way corridor under 43 C.F.R.
2806.2.
The signing of this Record of Decision completes
the initial phases of our land use planning process.
However, the signing of this Record of Decision
does not represent the end of the planning process.
Planning is an on-going process of data collection,
analysis and evaluation related to the prescribed
uses of public lands that continues during plan
implementation, and may eventually lead to
amendment or revision of the plan.
The planning process began with the determination
of the scope of the issues to be addressed in the
1
RMP in 1986. The Draft RMP/EIS was
distributed for public review on August 28, 1987,
for a 90-day review period, which ended on
November 30, 1987. The Proposed RMP/Final
EIS was signed on September 27, 1989, and made
available to the public on November 24, 1989, for
a 30-day protest period. The BLM Director
received 14 timely protests, of which 12 were
accepted for administrative review.
The Proposed RMP was prepared in accordance
with the FLPMA, the Alaska National Interest
Lands Conservation Act of 1980 (ANILCA), and
the Department of the Interior, BLM planning
regulations (43 C.F.R. 1600). The draft and final
EISs were prepared in accordance with the Council
on Environmental Quality’s (CEQ) regulations for
implementing the National Environmental Policy
Act of 1969 (NEPA) (40 C.F.R. 1500.) These
regulations require the consideration of cumulative
impacts–the total level of impacts that would arise
from the implementation of management actions
described in the Utility Corridor RMP.
An important cross-reference to our analysis is
contained in the final EIS prepared for the
Proposed RMP. The reader is directed to the Final
Environmental Impact Statement for the Proposed
Trans-Alaska Gas System, published in June,
1988, document number BLM-AK-PT-88-003-
1792-910, chapter 4.7 for a detailed cumulative
impact analysis, which was utilized in the analysis
performed for the Proposed RMP.
Specific attention was given to analysis of and
impacts to existing subsistence uses and resources.
In the ”Affected Environment” chapter, pages 3-28
throug,h 3-31 describe the use occurring both
inside· and outside the planning area (for example,
Anaktuvuk Pass, Nuiqsut, and Kaktovik, all areas
that are outside of the planning area.) While not
specifically stated in the text, based on the body of
data on pages 3-28 through 3-31, the impact
analysis that is contained in the “Environmental
Consequences” chapter, extended outside the
planning area and the reader of the RMP should
bear this fact in mind.
Appendix U
Page 2 of 2