March 20, 2008
Mr. Tom Melius, Regional Director
Yukon Flats EIS Project Office
c/o ENSR
1835 S. Bragaw Street, Suite 490
Anchorage, AK 99508-3438
Subject:
Comments on the Proposed Land Exchange, Yukon Flats National Wildlife Refuge, Draft Environmental Impact Statement (DEIS) .doc or .pdf
Deadline for Yukon Flats Land Exchange Environmental Impact Statement (EIS)
comment is March 25, 2008
Overview: A proposed land swap between U.S. Fish and Wildlife Service and
for-profit Doyon Ltd. would remove 110,000 acres of critical and
irreplaceable wildlife subsistence habitat from the Yukon Flats National
Wildlife Refuge in Alaska to allow oil and gas development on the land. It
also threatens Beaver Creek National Wild River and Victoria Creek in White
Mountains National Recreation Area with an oil pipeline and haul road
corridor. The Refuge would obtain scattered parcels of land nearer to
villages which are not currently threatened by development, but now would be
at risk of contamination from operations upstream in the watershed and
eventual industrial sprawl. Yukon Flats communities and communities on the
Yukon River subsistence way of life is under threat by this land trade.
Local communities are seriously concerned with the proposed land exchange
and potential human and ecological impacts, as well as impacts to their
subsistence way of life. Please see the following websites for more
information on local opposition:
* Learn more concerns from Fort Yukon tribal government:
http://www.fortyukon.org/
* Visit the REDOIL website for documents on the issue:
http://www.ienearth.org/redoil
* Detailed information on the alternatives and the overall EIS can be found
at: http://www.yukonflatseis.ensr.com/yukon_flats /
Testify in opposition to the land exchange at one of the following public
meetings:
* Fairbanks: Thursday, February 21st, 5 p.m., Noel Wien Library, 1215
Cowles Street
* Anchorage: Tuesday, March 4th 5 p.m., Public Conference Room,
Loussac Library, 3600 Denali Street
Submit written comments to:
Yukon Flats EIS Project Office
c/o ENSR
1835 South Bragaw, Suite 490
Anchorage, AK 99508
Submit on-line comments at:http://yukonflatseis.ensr.com/Yukon_Flats/Comments.aspx
Points to consider for your comments:
The primary beneficiaries of this proposed land trade are Doyon, Limited, an
Alaska Native Regional Corporation who will acquire what are now refuge
lands to contract with multi-national oil companies for oil and gas
development, and the Fish and Wildlife Service (FWS) who will acquire
Native lands around Gwich'in villages through the trade from wellhead taxes
once multi-national oil companies are invited to lease and contract and
production of oil and gas development begins on what today are refuge lands
within Gwich'in traditional ancestral territory. The FWS will also be able
to purchase native lands in other wildlife refuges within the State with the
proceeds, so this land trade is detrimental to other Native communities in
the State of Alaska as well.
There really would be little or no genuine long-term benefits for the
Gwich'in people within this deal, and the overall direct and cumulative
impacts will be largely detrimental to lands that Gwich'in rely upon to meet
subsistence needs. The Gwich'in people will be impoverished over time as
their land base dwindles and they lose ownership and control within their
ancestral territories, the resources they depend upon are irreparably
damaged, their health and well being is compromised and overall they bear
the brunt of all the negative consequences and suffer disproportionate
harmful impacts from this proposal.
In traditional values, Gwich'in hold their lands in high respect, the land
is there to provide for all time, the western value system of selling and
buying land is a foreign concept that Native peoples in Alaska were forced
into realizing when the Alaska Native Claims Settlement Act (ANCSA) went
into effect. As Gwich'in elders have simply put it: "Our land is forever,
money is short term"
Gwich'in concerns in regard to the proposed Yukon Flats Land Trade to
facilitate oil and gas development within the Yukon Flats Wildlife Refuge
and related oil and gas impacts: Some key concerns have been identified by
Gwich'in people about the proposed Doyon/FWS Land Trade of the Yukon Flats
Wildlife Refuge, some of which are: subsistence resources and rights (loss
of habitat, hunting and fishing), water and air quality, roads and pipelines
(access and competition for resources, loss of local control, introduction
of alcohol and drugs) human and ecological health, socio- effects, land
title, jobs, other issues.
* Subsistence-Gwich'in communities that rely on the Yukon Flats
Wildlife Refuge to provide for their primary subsistence needs are very
concerned for their way of life. The subsistence species that provide for
Gwich'in communities such as moose, sheep, waterfowl, and Yukon River salmon
will be put in detriment from this land exchange.
* Hunting and Trapping-Gwich'in are concerned that the changes in land
status and oil and gas development would affect hunting and trapping and
traditional land use sites. Oil and gas development facilities and
activities could prevent Gwich'in hunters from access to their hunting areas
within the Yukon Flats Wildlife Refuge because hunting is banned or not safe
near and within a certain proximity to the vicinity of oil and gas
development projects. Besides that, who would want to hunt where there are
pipelines, considering how much damage was done by one bullet hole in the
Trans-Alaska pipeline. Many Gwich'in residents have trap lines within the
Yukon Flats Wildlife Refuge as well, including within the area where Doyon
would obtain lands that are currently refuge lands. Access to the traplines
may also become an issue if oil and gas development is allowed in the Yukon
Flats Wildlife Refuge. Finally, negative impacts from oil and gas
exploration and development may alter animals' health, distribution,
populations, or habitats and harm both the availability and access to these
subsistence resources that we have depended on for millennia.
* Water Quality- The potential effects of both acute (oil spills) and
chronic pollution of the watershed with special attention to the downstream
environments where toxic substances may be transported to, and accumulate
over time. This watershed analysis should address the potential degradation
of habitat values over the long term for lands proposed to be transferred to
the Refuge as well as current Refuge lands and other lands downstream that
will remain as native lands. The potential for pollution extending down the
Yukon River beyond the Refuge boundary as a result of the proposed action
should also be addressed. Furthermore, the transboundary impacts to Yukon
River salmon in Canada and the subsistence livelihood of villages located
downriver in Alaska needs to be addressed. Therefore the water quality
impacts must be analyzed in the EIS. Prime waterfowl and salmon habitat
will likely be negatively impacted as toxic spills affect the water table.
Impacts to and mitigation measures regarding water quality and quantity,
including water uses and potential water pollution need to be evaluated and
analyzed within each alternative.
* Air Quality-Potential effects to air quality is another concern for
local people, especially air quality being compromised when toxics
bioaccumalate within the Yukon Flats due to cold spells in the winter when
air can be socked in by air inversions for weeks as the temperature dips to
-40 below. International and National studies have shown that Persistent
Organic Pollutants (POPS) are known to bio-accumulate in cold regions and
return to the environment into the food chain. Local people of the region
are aware of this and have deep concern for the effect of toxins within the
food chain that will have impact to the quality of health of the animals
within the region as well as the human population that relies upon them for
subsistence. Heavy metals created from oil development are known POPS. On
the North Slope the National Academy of Sciences report of 2003 stated that
air quality impacts to human health has lead to higher cases of Asthma and
upper respiratory illnesses in local communities such as Nuiqsut.
* Roads and Pipelines-Gaining access to potential oil and gas
resources by roads and pipeline corridor will have several negative factors
that cause severe impacts to Yukon Flats communities in various ways and
these impacts must be analyzed as well: Loss of local control within
traditional hunting and fishing areas, possible influx of non-natives who
will compete with locals for the subsistence resources, the species that
provide for communities will then decline due to competition, more quotas
will be placed on local people, causing the subsistence way of life to
decline. Alcohol and drugs may be transported from cities to Gwich'in
communities from the roads.
* Human Health-Another consequence that deserves thorough evaluation
in consideration of this land trade are the negative impacts related to
human and ecological health in the face of oil and gas development. The
health and well being of the people is directly related to the health and
well being of the land. Health statistics that will follow any oil and gas
development will be: higher rates of Cancer, Diabetes, Asthma, Upper
Respiratory Illnesses and Obesity due to compromise and loss of subsistence
resources. The social factors that cannot be mitigated and will have long
term negative impact to local communities are high statistics of alcoholism,
drug abuse, suicide, alcohol or drug related fatalities, incarceration,
domestic violence and other forms of abuse etc. There would be the need for
endless meetings related to oil and gas development, and the introduction of
greater sources of conflict among community members. Oil and Gas
development within Indigenous territories usually leaves behind these sort
of devastating social effects as has been cited by the National Academy of
Sciences in Cumulative Environmental Effects of Oil and gas Development on
Alaska's North Slope "Effects on the Human Environment" study of 2003.
* Native Land Acquisition and Loss- This deal sets a bad precedent in
acquisition of Native lands [allotments] including the discussion of ANCSA
village corporation lands and allotments in Phase II which will ultimately
lead to the diminishment of Native Lands within the Yukon Flats Wildlife
Refuge and other refuges across the State. In Phase I, this deal primarily
targets Doyon lands near their villages and this means a loss of Native
lands closest to them and increased competition for subsistence resources in
close proximity to those lands. The loss of Native lands will lead to
eventual loss of control within subsistence use areas and ancestral
homelands. This is highly unacceptable to Gwich'in people; especially
Gwich'in council's who even have council policy in place addressing sales of
lands to non-natives. Gwich'in are the best stewards of the Yukon Flats
Wildlife Refuge lands and native allotments which was the only title granted
under the terms of ANCSA. Maintaining Native land title is the best option
for maintenance of the purposes for the protection of wildlife and habitat
within the Yukon Flats Wildlife Refuge.
* Jobs- Many promises of jobs being provided to Gwich'in are touted
within the land trade discussions, but the reality in most cases of oil and
gas development projects in Alaska is that Native people who may actually
maintain long term jobs are a small minority while the majority of jobs are
usually taken by a primarily non-native workforce.
There is too much at stake with potential long term harm to the environment
that sustains the Gwich'in subsistence lifestyle. The land will provide for
generations to come if left intact. The costs to the Gwich'in people far
outweigh the benefits in the long-term within the Yukon Flats Land Trade
proposal.
Deadline for comment is March 25, 2008
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