Comments submitted via: https://eplanning.blm.gov/eplanning-ui/project/57323/570/8004057/comment


December 22, 2023

Steven M. Cohn, State Director
Bureau of Land Management
Ambler Road Supplemental EIS Comments
BLM Fairbanks District Office
222 University Ave.
Fairbanks, Alaska 99709

Subject: Comments on the Ambler Road Supplemental Environmental Impact Statement (DSEIS)

Dear Mr. Cohn:

I am writing on behalf of more than 2,500 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 45,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are former National Park Service (NPS) directors, regional directors, superintendents, resource specialists, park rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.

Many of our members worked in Alaska during their NPS careers and are very familiar with the special management requirements of the Alaska National Interest Lands Conservation Act of 1980, Public Law 96-487 (ANILCA). As a non-profit, national parks advocacy group, the Coalition is very concerned about the high potential for adverse impacts of the proposed Ambler Mine Industrial Access Road right-of-way (ROW) construction on the resources and values of the Preserve portion of Gates of the Arctic National Park and Preserve.


Gates of the Arctic National Park and Preserve (GAAR) is a protected area that is full of superlatives. Lying north of the Arctic Circle in Alaska, GAAR is situated in the central Brooks Range, the northernmost extension of the Rocky Mountains. Encompassing 8.4 million acres, including more than 7 million acres of designated wilderness, GAAR is the second largest unit in the National Park System, and second largest wilderness area in the National Park System. Established in 1980 under Section 201(4) of ANILCA, the purposes of GAAR are: 

“To maintain the wild and undeveloped character of the area, including opportunities for visitors to experience solitude, and the natural environmental integrity and scenic beauty of the mountains, forelands, rivers, lakes, and other natural features; to provide continued opportunities, including reasonable access, for mountain climbing, mountaineering, and other wilderness recreational activities; and to protect habitat for and the populations of, fish and wildlife, including, but not limited to, caribou, grizzly bears, Dall sheep, moose, wolves, and raptorial birds. Subsistence uses by local residents shall be permitted in the park, where such uses are traditional, in accordance with the provisions of title VIII [of ANICLA].”

The NPS Organic Act of 1916 had previously established the fundamental purpose of parks (i.e., park system units such as Gates of the Arctic), which is to “conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” 

Furthermore, under NPS Management Policies 2006 Section 1.4.3, “… when there is a conflict between conserving resources and values and providing for enjoyment of them, conservation is to be predominant. This is how courts have consistently interpreted the Organic Act.” 

The proposed mine access road through GAAR epitomizes a conflict between conservation and use. If the proposed road is allowed to be built across the southern “boot” of the Preserve, it would be one of the most destructive construction projects to occur in a unit of the National Park System since the passage of the NPS Organic Act in 1916. One would have to look back to the construction of O’Shaughnessy Dam in Hetch Hetchy Valley at Yosemite National Park to find a project of similar magnitude and lasting adverse impacts. The dam was authorized by the 1913 Raker Act and constructed during the 1920’s to late 1930’s.


In 2019, the Coalition commented extensively on BLM’s draft EIS, which was prepared under the requirements of the National Environmental Policy Act (NEPA). For the current draft SEIS, the Coalition strongly concurs with comments prepared by the Trustees for Alaska and have joined other organizations in signing on to those comments. We offer the following additional comments about the draft SEIS for your consideration.

We have a major concern that the draft SEIS treats consideration of impacts to the GAAR as if it were any other federal public land. It is not. As stated previously, both ANILCA Section 201(4)(a) and the NPS Organic Act mandate that GAAR be managed for conservation purposes. And as described in the park unit’s Foundation Document, “the purpose of Gates of the Arctic National Park and Preserve is to preserve the vast, wild, undeveloped character and environmental integrity of Alaska’s central Brooks Range and to provide opportunities for wilderness recreation and traditional subsistence uses.”

While in Section 201(4)(b) of ANILCA Congress finds there is a need for access for surface transportation across the Preserve, it is only to access the Ambler Mining District. It must be clearly demonstrated that mining in the Ambler District is so economically viable and critically important to the nation that a permit is issued. It must also be demonstrated that both the short term and long term adverse impacts to GAAR and the surrounding communities be fully mitigated. However, the draft SEIS fails to make the case for mitigating the substantial impacts. And while this section of ANILCA authorizes a mine access road through GAAR, subject to terms and conditions intended to minimize adverse impacts of a road, it does NOT authorize the construction of gravel mines, maintenance stations, airstrips, or other facilities associated with construction or future maintenance of the road. It also does NOT authorize use of the industrial access road to facilitate public access to or through the Preserve. As a result, any proposals to construct gravel mines or other infrastructure within GAAR or to eventually use the road to facilitate public access need to be removed from consideration in the draft SEIS, as it is contrary to ANILCA.

The alternatives presented in the draft SEIS include No Action and three different action alternatives, A-C. Of these, the only options that would allow the NPS to fully accomplish its conservation mandate for GAAR are the No Action Alternative (i.e., no road) and Alternative C, which would allow a road that avoids GAAR entirely. Of the remaining action alternatives, both A and B would cause significant impairment to GAAR’s resources and values through immediate and long term impacts. Alternative A’s impacts would be significantly higher due to its proximity to Walker Lake and designated wilderness. Alternative B would have less direct immediate impacts on GAAR, being a significantly shorter crossing of the Preserve (18 miles compared to 26 miles in Alternative A). In addition, Alternative B is much farther away from the Walker Lake area of GAAR, causing less sound, dust, and other disturbance to designated wilderness in proximity the lake. Despite these relative differences between Alternatives A and B,  both would cause significant long term impacts to fish and wildlife populations that utilize both the Park and Preserve and the surrounding area. Road construction and future industrial use of the road would dramatically disturb and curtail subsistence opportunities of local communities in the area including in the Park and Preserve.  


In contrast to BLM’s preparation of an EIS in accordance with NEPA procedures, ANILCA section 201(4)(d) requires the Secretaries of the Interior and Transportation to jointly prepare an “environmental and economic analysis” (“EEA”) solely for the purpose of determining the most desirable route for the right-of-way through the Preserve and terms and conditions which may be required for the issuance of that right-of-way. 

In its 2022 motion for remand, NPS acknowledged that there were problems with the subsistence analysis in its 2020 Final EEA and Record of Decision and suspended its own right-of-way authorization. As a result, in conjunction with preparation of the draft SEIS under the remand process, one would also expect the NPS to review the 2020 EEA, which previously authorized the project. The prior process problems relate not only to the 2020 EEA, but also to the overall information and analysis of the project. As a result, NPS should reopen its EEA process, update its analysis to address problems with the prior decision, and ensure it is acting on current and complete information about this project.

We commented extensively on NPS’s draft EEA in 2019 and are now very concerned that NPS has not undertaken a review of its 2020 final EEA as part of this remand process. Many of our 2019 comments on the EEA remain relevant to the current draft SEIS and are attached for your reference and further consideration. 


The proposed construction of the Ambler Mine Industrial Access Road through Gates of the Arctic National Preserve would irreparably harm the environmental integrity, scenic beauty, and visitor experience opportunities that Congress directed the Department of the Interior to protect under ANILCA 201(4). Given the likely impairment to GAAR’s resources and values that would result from the development of this industrial access road, the No Action Alternative should be chosen.   

In closing, we appreciate the opportunity to comment on this important issue.


Michael Murray signature



Michael B. Murray
Chair of the Executive Council
Coalition to Protect America’s National Parks
Email: Ed****@pr********.org
Mail:   2 Massachusetts Ave NE, Unit 77436, Washington, DC 20013




Deb Haaland, Secretary, U.S. Department of the Interior
Laura Daniel-Davis, Acting Deputy Secretary, USDOI
Shannon Estenoz, Assistant Secretary for Fish and Wildlife and Parks, USDOI
Tracy Stone-Manning, Director, Bureau of Land Management
Charles F. Sams, III, Director, National Park Service
Sarah Creachbaum, Alaska Regional Director, National Park Service
Lisa Murkowski, U.S. Senator for Alaska
Dan Sullivan, U.S. Senator for Alaska
Mary Peltola, U.S. Representative for Alaska