Yukon Flats Land Trade EIS public comment Re-opens

Submit written comments by May 19, 2008:

Yukon Flats EIS Project Office

c/o ENSR 1835 South Bragaw, Suite 490

Anchorage, AK 99508

OR use the internet comment form:

http://yukonflatseis.ensr.com/Yukon_Flats/Comments.aspx

Please Support Alternative 3, “No Action.”

The Big Picture -- What’s at Stake:

A proposed land exchange would remove 110,000 acres of wildlife habitat and wilderness from the Yukon Flats National Wildlife Refuge to allow oil and gas development on the land.

Þ This proposed land swap scheme violates the most fundamental purposes of the Yukon Flats Refuge and the Alaska National Interest Lands Conservation Act.

Þ Three conservation areas will be harmed: Yukon Flats Refuge, Beaver Creek National Wild River and White Mountains National Recreation Area.

Þ The Land Trade will destroy the integrity of this vast and important ecosystem

Þ Loss of subsistence and harm to traditional way of life and culture.

Þ The Trade sets a precedent for industrial development within other conservation areas in Alaska through such backdoor deals. If this land exchange proceeds, nothing will be safe.

Þ The proposed land trade will not help curb the effects of global warming, as seen vividly already in the Yukon Flats and across Alaska’s Arctic.

What is Proposed?

Phase I: The U.S. Fish & Wildlife Service (FWS) has proposed to give Doyon a total of 210,000 acres of oil and gas lands (110,000 acres in fee title plus 97,000 acres of subsurface oil and gas rights). In exchange, Doyon has committed to trade 150,000 acres of scattered parcels of land.

Phase II: If Doyon produces oil or gas on the exchange lands, the FWS will receive a production payment of 1.25-1.5% of the resource value at the wellhead and Doyon has agreed to sell up to another 120,000 acres of land, although funds could be used throughout the state.

Yukon Flats Refuge Purposes:

· Conserve fish and wildlife populations and habitats, including migratory birds, sheep, bears, moose, wolves, wolverines, caribou and salmon.

· Fulfill international treaties on fish and wildlife and their habitats.

· Provide for continued subsistence uses by local residents.

· Ensure water quality and quantity.

Bush Administration Fast Track Deal:

Thanks to many requests from tribes, Tanana Chiefs Council, conservation organizations and the public, the U.S. Fish & Wildlife Service is taking public comments for another 30-days on the controversial Yukon Flats Land Trade draft Environmental Impact Statement. If you already commented, please do so again and raise new issues. Explain why you care about the Refuge, the White Mountains and Beaver Creek. Please help stop the Yukon Flats land trade.

Please Support Alternative 3, “No Action.”

For More Information:

www.northern.org; www.fortyukon.org/swap.html.

http://www.wilderness.org/WhereWeWork/Alaska/YukonFlatsSwap.cfm.

Key Issues on Yukon Flats Land Trade

Oil and Gas: Violates Refuge Purposes

According to FWS, “Management policies …prohibit the leasing of any Yukon Flats Refuge lands for oil and gas exploration or development.” (EIS p. 2-24)

The land trade violates the refuge’s fundamental purposes and management plan by taking lands out of the refuge to facilitate for-profit Doyon Ltd.’s plans to drill for oil and gas there.
The refuge was established to protect whole ecosystems and diverse wildlife.
The Refuge would obtain scattered parcels of land near villages not currently threatened by development, but afterwards would be at risk of oil field pollution upstream in the watershed and industrial sprawl.
The EIS underestimates Subsistence impacts, e.g. the EIS did not consider harm to Pacific salmon and fishing if oil spills reach the Yukon River.
FWS plans to remove from the Refuge lands with high value to moose; deep lakes and Midland Lake zone habitats preferred by loons, scoters, some diving ducks, thrushes, and sparrows; and habitats used by mammals such as wolves, grizzly bears, and marten.

Proposed Refuge Wilderness Area is threatened

The proposed action would lead to oil development with roads and pipelines within the only area of the Refuge recommended for proposed wilderness.

White Mountains National Recreation Area threatened by Roads, Pipelines

· The preferred road and pipeline corridor violates the existing White Mountains Management Plan and threatens the current wild and pristine conditions.

· The proposed pipeline and road routes would disturb prime Dall Sheep habitat and mineral licks in the White Mountains NRA and the refuge.

Oil Spills Risk the Beaver Creek National Wild River and Yukon River

A major oil spill (83,580 gallons) into Beaver Creek in summer would travel 148 miles to the Yukon River in 49 hours, contaminating soils and vegetation much of the way.
The DEIS estimates 300 crude oil and other hydrocarbon spills totaling 52,500 gallons.
EIS downplays potential toxic impacts of crude oil to fish by using old biased (Exxon) data on crude oil toxicity to early stages of salmon.
Land trade will harm Beaver Creek Wild River and violates its management plan goals, e.g. to protect water quality, improve fish and wildlife habitats, and preserve the river in its natural condition.

Global Climate Change Impacts

EIS inadequately covers climate change impacts already occurring in Yukon Flats (lakes drying up, increased forest fires, changes to Pacific Salmon, alterations to wildlife habitat and hunting) and fails to assess the cumulative effects of added oil and gas development.
Clean, renewable energy alternatives should be considered for Yukon Flats and the nation.

www.northern.org