Alaska Clean Water Advocacy ● Alaska Community Action on Toxics
Alaska Warrier Partnership ● Alaska Wilderness League
Alaska Wildlife Alliance ● Beluga Whale Alliance ● Center for Biological Diversity ● Coalition to Protect America’s National Parks ● Cook Inletkeeper ● Defend the West-Su Earthworks ● Mother Kuskokwim Tribal Coalition National Parks Conservation Association ● Natural Habitat Adventures Northern Alaska Environmental Center ●
Sierra Club1Comments prepared with assistance from Trustees for Alaska.
Via E-mail/Portal
June 24, 2024
Superintendent Susanne Fleek-Green
Lake Clark National Park & Preserve
Johnson Tract Transportation and Port Site Easements
240 West 5th Avenue, Suite 236 Anchorage, AK 99501
Re: Resource Analysis for the Johnson Tract Transportation and Port Site Easements
Dear Superintendent Fleek-Green:
On behalf of the above-listed organizations and our members, we provide the following comments in response to the National Park Service’s (NPS or the Service) request for input on its forthcoming resource analysis evaluating We are concerned about the potential for these easements to have significant impacts across the entire Park and broader region, including the Cook Inlet watershed. NPS is required to fully analyze all potential impacts from this proposed project in a scientifically sound
and publicly transparent manner, and to comply with the broad set of legal mandates that apply to this request.
Lake Clark National Park is one of the wildest national park landscapes in the world.
Lake Clark protects the headwaters of the Kvichak and Nushagak rivers that flow into Bristol Bay, home to the world’s largest wild sockeye salmon run. Wild salmon sustain the traditional lifeways of local people, play an essential role in the ecosystem and support the $2 billion fishing industry that anchors the local economy. Additionally, the world-famous brown bears of the region allow for the most incredible bear-watching opportunities anywhere on the planet, which supports a thriving bear-viewing economy for the region. The Park is also home to many other wildlife, including caribou, moose, a variety of birds, and the endangered beluga whales that inhabit its nearshore waters.
Our organizations are concerned about the significant negative effects that the easements, and the future mining the easements would facilitate, could have on this wild area and its resources. This is a complex and far-reaching proposal that is likely to have significant impacts on the special values and resources of the region and the entire Park. The easements and future mining will cause a large, undeveloped area to become industrialized. Future development will disturb wildlife, destroy wetlands, impact a thriving recreation-based economy, and permanently alter rural lifestyles dependent on traditional food resources. Consistent with its authority and discretion under the 1976 Cook Inlet Land Exchange, NPS must carefully consider how it can address the potentially serious impacts of these easements as part of this process and its upcoming resource analysis.
NPS must also ensure that its process complies with myriad laws intended to protect Lake Clark National Park and its wildlife, environmental, and subsistence values. This includes, but is not limited to, ensuring that this process is consistent with NPS’s mandates under the Alaska National Interest Lands Conservation Act (ANILCA) to protect Lake Clark’s purposes and to address the easements’ impacts on subsistence users. NPS must also fully comply with the Endangered Species Act (ESA) when undertaking this process, given the potentially significant impacts the easements could have on endangered Cook Inlet beluga whales and other species.
Further, the National Historic Preservation Act requires NPS to engage in Section 106 consultation to avoid impacts to historic and cultural resources in the area. These and other legal requirements must be fully complied with as part of NPS’s process.
We are also deeply troubled by the lack of a meaningful opportunity for public participation in this permitting process. Public participation should be a key consideration as NPS undertakes this resource analysis. Instead, the manner in which NPS is proceeding will suppress the public’s ability to review and engage in the evaluation of these easements. A 14-day comment period during the summer for this initial scoping stage — when members of the public, local businesses, and affected communities are busy preparing for and undertaking the very subsistence, commercial, and recreational fishing activities that this proposal threatens — is plainly insufficient to meet any goal to provide robust participation by the interested public and potentially affected communities. Similarly, NPS’s stated plan to only provide a 14-day public review period on the resource analysis this fall is insufficient to ensure the public has time to weigh in on this hugely impactful proposal. That will not provide enough time for the public to review and provide thoughtful comments on the resource analysis. NPS should rethink that approach and provide additional time for public comment to ensure the public has adequate time and the opportunity to engage in each step of this process as it moves forward.
In sum, we are deeply concerned about the impacts from the proposed easements to the resources and values of Lake Clark and the broader region and the limited opportunity for public input. The attached comments represent our best efforts to engage, despite the limited time period for commenting. NPS must do better going forward on engaging the public in this process, given the complexity of the issues and analysis required, and potentially significant adverse impacts these easements could have on Lake Clark’s sensitive resources, the local economy, and subsistence.
If you have any questions or wish to clarify anything in our comments, please do not hesitate to contact Jen Woolworth at (907) 444-1137 or by e-mail at jw********@np**.org.
Thank you for your prompt attention to our comments. [Click here to read the submitted comments.]
Sincerely,
Gershon CohenProject Director
Alaska Clean Water Advocacy
Jasmine Jemewouk
Water Quality and Community Health Protection Coordinator
Alaska Community Action on Toxics
Jessy Lakin
State Lead
Alaska Warrier Partnership
Maddie Halloran
State Director
Alaska Wilderness League
Nicole Schmitt
Executive Director
Alaska Wildlife Alliance
Suzanne Steinert
Director
Beluga Whale Alliance
Cooper Freeman
Alaska Director
Center for Biological Diversity
Phil Francis
Chair
Coalition to Protect America’s National Parks
Loren Barret
Co-Executive Director
Cook Inletkeeper
Luke Brockman
Community Outreach Coordinator
Defend the West-Su
Bonnie Gestring
Northwest Program Director
Earthworks
Sophie Swope
Executive Director
Mother Kuskokwim Tribal CoalitionJen Woolworth
Alaska Program Manager
National Parks Conservation Association
Ben Bressler
Founder and CEO
Natural Habitat Adventures
Court Whelan, Ph.D.
Chief Sustainability Director
Natural Habitat Adventures
Emily Hikes
Mining Impacts Response Coordinator
Northern Alaska Environmental Center
Andrea Feniger
Alaska Chapter Director
Sierra Club