May 9, 2012
Ms. Stephanie Brady, Project Team Leader
U.S. Fish and Wildlife Service
1011 E. Tudor Road, MS-231
Anchorage, AK 99503
Re: Izembek National Wildlife Refuge Draft Environmental Impact Statement
Dear Ms. Brady:
The Resource Development Council (RDC) is writing to support the exchange of land between the federal government, the State of Alaska, and King Cove Corporation for the purpose of constructing and operating a single-lane gravel road between communities of King Cove and Cold Bay.
RDC is a statewide business association comprised of individuals and companies from Alaska's oil and gas, mining, forest products, tourism, and fisheries industries. RDC's membership includes Alaska Native corporations, local communities, organized labor, and industry support firms. RDC's purpose is to encourage a strong, diversified private sector in Alaska and expand the state's economic base through the responsible development of our natural resources.
Although there is no industry interest that will benefit from the land exchange, RDC supports the proposed action because it is the right thing to do. For over a decade, RDC has consistently advocated for a road link between King Cove and Cold Bay. RDC strongly believes that a road corridor from King Cove to the all-weather airport at Cold Bay is in the public interest. In our view, this is a public safety and human rights issue, which should be given the highest priority.
Specifically, RDC supports Alternative 2 and encourages the Corps of Engineers and the Fish and Wildlife Service to adopt this option as the Preferred Alternative. This alternative would provide safe, reliable, and affordable transportation for King Cove residents and require only 236 acres for the one-lane, 19-mile gravel road.
The proposed land exchange would involve the removal of only 131 acres within the Izembek Wilderness for the road corridor and 1,600 acres of federal land within the Alaska Maritime National Wildlife Refuge. In exchange, the federal government would receive more than 43,000 acres of land owned by the State and approximately 13,000 acres of land owned by the King Cove Corporation near Cold Bay and adjacent to the Alaska Peninsula National Wildlife Refuge. Overall, the exchange would add more than 56,000 acres to the Izembek and Alaska Peninsula National Wildlife Refuges and designate 43,000 acres as Wilderness.
Clearly, the land exchanges outlined in the Draft Environmental Impact Statement (DEIS) would provide a big net gain for the national wildlife refuge system while providing a vital public health and safety corridor for King Cove residents to Cold Bay and its all-weather airport. The road would be narrow and unobtrusive. The road would be used primarily for health and safety purposes and would be closed to commercial traffic. Mitigation strategies will allow the road, the environment, and wildlife to coexist. Mitigation measures will include provisions to avoid wildlife and fish impacts and to mitigate wetlands loss. Both of the proposed road corridors evaluated in the EIS were designed to minimize adverse impacts to refuge resources, require the transfer of the minimum acreage of federal land, and to incorporate existing roads into the corridor.
There is adequate existing information to allow for the Final EIS to proceed, a Record of Decision issued, and for the Secretary of the Interior to make a public interest finding that meets the intent of Congress and affords equitable treatment of the Aleut people.
The road would solve the community’s perennial problem with access to the outside world, especially in poor weather conditions. The proposed land exchange would provide for a long term, safe, and reliable year-round transportation system between King Cove and Cold Bay. As proposed, the project would balance the needs of the communities, the national wildlife refuges, and ecosystem functions in the area.
Meanwhile, the marine link between the two communities has not solved King Cove’s transportation challenges in reaching Cold Bay and its airport. The community has not found the hovercraft to be an effective solution to their problems, which is why King Cove and tribal leaders are united in their support of a road link, which they have pursued for many years.
Affordable, reliable, and practical transportation is not available for the residents of King Cove to access the Cold Bay airport. Air transportation is limited by weather, availability of aircraft, and the topographic constraints of the King Cove airport. Flights are often delayed or cancelled due to weather.
Costs for air travel is also an issue for many residents. The hovercraft has proven more expensive and more difficult to keep in service than originally expected. Ridership and associated revenues have been lower and operations and maintenance costs higher than projected. Keeping the minimum number of trained crew required for operations has been difficult and has resulted in the cancellation of scheduled service. In addition, weather conditions have inhibited hovercraft service. The hovercraft option was attempted in good faith, but it has now been shut down.
The hovercraft option has failed. The road has always been the community’s first choice because it provides residents with the greatest amount of security and peace of mind. The proposed road link is the safest and most reliable transportation option for the life, safety, and health of local residents. It is the only workable long-term solution. For these reasons and others, the State of Alaska, City of King Cove, Agdaagux Tribe, King Cove Corporation, and Aleutians Borough strongly support a cost-efficient, reliable surface transportation system between King Cove and the Cold Bay Airport.
However, the transportation system must be affordable for local families, and be constructed, operated, and maintained at a cost that can be borne by local or state government. The road should be operated and maintained without undue requirements and provide for safe, reliable, affordable transportation with the least amount of interruption by weather conditions.
The spirit of the proposed land exchange would recognize and honor with equal regard the human side of conservation, alongside wildlife and wilderness. The DEIS acknowledges local needs and the fact that current transportation infrastructure does not meet these needs. The DEIS appropriately recognizes that the proposed road options, with appropriate mitigation strategies to limit impacts, would best meet human health and safety needs.
The King Cove Corporation is giving up 20 percent of its land for a single-lane gravel road. That demonstrates how much of a priority emergency access to the airport in Cold Bay is to local residents. Residents of King Cove have been waiting over 20 years to build a surface transportation link to Cold Bay and the proposed action is a big step in the right direction.
Thank you for the opportunity to provide comment on the proposed action, which is so critical to the future health and welfare of local residents.
Resource Development Council for Alaska, Inc.