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[www.audubonalaska.org](http://www.audubonalaska.org/)

STATEMENT OF STANLEY SENNER,

EXECUTIVE DIRECTOR, AUDUBON ALASKA,

ON S. 1680, IZEMBEK AND ALASKA PENINSULA REFUGE AND

WILDERNESS ENHANCEMENT ACT

My name is Stanley Senner, and I am Executive Director and Vice
President of Audubon Alaska, which is the National Audubon Society's
Alaska State Office. Thank you for the invitation to address the Members
of the Senate Committee on Energy and Natural Resources Subcommittee on
Public Lands and Forests today, 15 April 2008, in regard to S. 1680, the
Izembek and Alaska Peninsula Refuge and Wilderness Enhancement Act.

I offer this testimony on behalf of Audubon, an organization with more
than 500,000 members and supporters across the country. Audubon's
mission is the conservation of natural ecosystems, emphasizing birds and
other wildlife, and their habitats, for the benefit of present and
future generations. Audubon established an office in Alaska in 1977, and
we have about 2,100 members in the state.

By way of personal background, I first moved to Alaska in 1974 and have
an M.S. degree in biology from the University of Alaska Fairbanks. I
have studied birds and their habitats throughout the state, and I have
spent much of the last 33 years engaged in wildlife and natural
resources management and policy issues in Alaska. My career includes
more than 7 years of service to the State of Alaska, under three
governors, in the restoration and science programs following the *Exxon
Valdez* oil spill, and three years in Washington, DC, on the Minority
(Republication) Professional Staff) of what used to be the House of
Representatives Committee on Merchant Marine and Fisheries. In the late
1970s I was deeply engaged in developing what became the Alaska National
Interest Lands Conservation Act of 1980.

My home and office are in Anchorage, but I am fortunate to have visited
the communities of Cold Bay and King Cove. I have driven the road from
the King Cove side as far as it is possible to do so, walked in the
Izembek Wilderness, and flown over the proposed exchange lands and road
alignment.

**[Overview]{.smallcaps}**

Audubon is opposed to the land exchange proposed in S. 1680 for the
purpose of building a road between the communities of King Cove and Cold
Bay. Going back a decade, Audubon is on record as recognizing the wishes
of the people of King Cove with respect to transportation, and we have
supported approaches that do not require a road through the Izembek
National Wildlife Refuge and Wilderness. Specifically, Audubon has
supported improving the transportation link between King Cove and Cold
Bay with the combination of a road to Lenard Harbor and a marine link
(preferably a ferry) to Cold Bay. We continue to believe this is the
best option and regret that much time and energy and millions of public
dollars were spent on a longer road and hovercraft, which King Cove and
the Aleutian East Borough have now concluded are insufficient.

Audubon finds that the proposed road is incompatible with the purposes
for which the Izembek refuge was established. This road would fragment
and degrade essential wildlife habitats in the heart of the Izembek
refuge, risking globally significant populations of migratory birds, and
it would violate Congressionally-designated Wilderness, which deserves
great respect. Further, the lands proposed for addition to the Izembek
and Alaska Peninsula refuges are generally not similar in character and
are not equal in value to the important habitats that would be impacted
by the road, the lands are peripheral to the area that would be
traversed by the road, and there are no threats to these lands. Addition
of these lands would not mitigate the long-term impacts of the road.
Hence, there is no net benefit to, nor enhancement of, the Izembek
refuge, notwithstanding the acreage proposed for addition to the Izembek
and Alaska Peninsula refuges.

**[Importance of Izembek Refuge]{.smallcaps}**

In 1980, as part of the Alaska National Interest Lands Conservation Act,
Congress redesignated the existing Izembek National Wildlife Range
(established in 1960) as the Izembek National Wildlife Refuge and
designated about 300,000 of 417,533 acres in the refuge as
Wilderness[^1]. The purposes for which the refuge was established
include conservation of fish and wildlife populations and habitats,
including waterfowl, shorebirds and other migratory birds and brown
bears.

Congress has provided for one of the highest possible levels of
protection for the portion of the Izembek refuge under consideration
today: Wilderness designation within a federally-protected national
wildlife refuge. This level of protection is well deserved, and the
following excerpt from House Report No. 96-97, Part II (p. 136), in 1979
makes clear why:

> The Izembek Wilderness possesses outstanding scenery, key populations
> of brown bear, caribou and other wilderness-related wildlife, and
> critical watersheds to Izembek Lagoon. About 68 percent of the total
> lands in Izembek Lagoon are covered with the largest eelgrass beds in
> the world. These beds are utilized by millions of waterfowl for
> migration and wintering purposes. A wilderness designation will
> protect this critically important habitat by restricting access to the
> Lagoon.

At the center of Izembek refuge are two lagoons---Izembek and
Kinzarof---separated by a narrow (\< 3-mile wide) isthmus. In
combination, the lagoons, their immediate watersheds, and the
isthmus---the Izembek-Kinzarof lagoons complex---make up the ecological
heart of the refuge. From the standpoint of migratory birds, especially,
this relatively small area is unquestionably of global significance and
has been repeatedly recognized as such. For example, in 1986, President
Reagan named Izembek as the first Wetland of International Importance in
the United States under the Ramsar Convention on Wetlands. In 1991,
Izembek was named a "sister refuge" with Russia's Kronotskiy State
Biosphere Reserve under the U.S.--Russian Governmental Agreement on
Cooperation in Environmental Protection. And in 2001, BirdLife
International, in cooperation with the National Audubon Society,
recognized Izembek as an Important Bird Area of global significance.

Izembek refuge is best known for its world-class waterfowl and shorebird
populations and habitats. The lagoons complex provides wintering,
breeding, molting, refueling, staging or resting grounds for:

-   the entire Pacific population of Brant (\~138,000), including birds
    from Canada, Russia and Alaska;

-   the world population of Emperor geese (\~70,000);

-   up to 70 percent of the world population of Steller's eiders (\~
    100,000), including birds from Russia and Alaska. The Alaska
    breeding population is listed as threatened under the Endangered
    Species Act;

-   many species of other shorebirds, including Pacific Golden-Plovers,
    Rock Sandpipers, Dunlins; and

-   a resident (mostly nonmigratory) population of Tundra Swans.

Many of the avian species using Izembek---including the Brant and
Pacific Golden-Plover---are recognized on Audubon's Alaska WatchList of
declining and vulnerable bird populations.

Directly or indirectly, the lagoons complex is important for so many
bird species and other fish and wildlife due to the presence of the
world's largest eelgrass beds, which cover about half of each of the
lagoons. Brant, Emperor Geese and other waterfowl graze on the eelgrass,
and shorebirds prey on the invertebrates associated with the eelgrass.
Eelgrass provides food and cover for commercially important fish and
shellfish. The enormous productivity of the eelgrass beds in Izembek
Lagoon and other lagoons on the north side of the Alaska Peninsula is a
key element in driving the productivity of the larger Bering Sea
ecosystem.

The importance of the combination of Izembek and Kinzarof lagoons and
the adjacent watersheds cannot be understated. Migrating and wintering
Brant fly back and forth between the lagoons to forage; migrating and
wintering Emperor Geese use Kinzarof Lagoon, while often foraging in the
adjacent upland tundra for crowberries; and wintering and molting
Steller's Eiders use Kinzarof Lagoon. When Izembek Lagoon freezes,
Kinzarof Lagoon becomes particularly important for the survival of
wintering bird populations. Kinzarof and Izembek lagoons are also used
by marine mammals. Especially noteworthy is the fact that large numbers
of threatened northern sea otters and also harbor seals can be found
near the entrance to Kinzarof Lagoon, while threatened Steller's sea
lions use the barrier islands on the outside of Izembek Lagoon.

The narrow "upland" isthmus between Izembek and Kinzarof lagoons is a
crucial travel corridor---the only path between the west and east sides
of the refuge---for such wide-ranging species as brown bears and
caribou. The Alaska Peninsula Caribou Herd, a population that has
declined from about 10,000 to fewer than 350 animals in the last 10 or
so years, uses the isthmus as its primary migration route (to and from
calving grounds) and wintering area.

Some of the highest densities of brown bears on the lower Alaska
Peninsula are found in the Joshua Green River Valley, an area within
three miles of the isthmus and proposed road corridor. Low levels of
human disturbance have helped maintain the high habitat value of this
area for brown bears. Bears produced in the Joshua Green watershed
frequently roam the isthmus in their search for food.

Numerous small streams along the north shore of Kinzarof Lagoon provide
access routes to upland lakes for spawning sockeye salmon. Resident
Tundra Swans nest in small wetlands and molt on the larger lakes on and
near the isthmus.

**[Harmful Impacts of A Road]{.smallcaps}**

From the time that the King Cove road project was identified in the
Bristol Bay Area Plan in 1985 until this past year, 2007, the U.S. Fish
and Wildlife Service ("Service") has consistently found that a road
across the narrow isthmus between Izembek and Kinzarof lagoons would be
incompatible with the purposes for which the Izembek refuge had been
established and that a road would cause significant, long-term damage to
important fish, wildlife, habitat, and wilderness values of the refuge.
For example, in an August 1997 King Cove Road Briefing Report, the
Service found the "road alternative contrary to the purposes of the
refuge" and anticipated "unacceptable environmental impacts if a road is
constructed on refuge lands through the wilderness area." The Service
supported further study and consideration of other alternatives, such as
a marine link, which would provide increased travel safety, economic
growth and fewer ecological impacts.

The Environmental Impact Statement (EIS) on the King Cove Access
Project, prepared in 2003 by the Army Corps of Engineers, in cooperation
with the Service and funded by the Aleutian East Borough, examined the
potential threats of the proposed road. The EIS found the all-road
alternative to be the most damaging of all the alternatives evaluated.
This conclusion was based in part on the largest footprint (287.0 acres)
among the alternatives. The report documented the potential scope of the
construction, noting the need for 36.7 acres of placement of fill
material in waters of the U.S., including some wetlands below the high
tide line, and 254 stream and drainage crossings requiring 8 bridges and
19 culverts across fish bearing streams. The report cited direct,
indirect and cumulative impacts on the lands and on wildlife.

The EIS also found that if the road between King Cove and Cold Bay was
completed, it would be open for travel by all residents, placing no
restrictions on the numbers or types of vehicles. Estimates of traffic
rates on the road are unavailable, but vehicular traffic is likely to be
variable on a daily and seasonal basis. Increased traffic is expected
beyond that needed for emergency medical access to Cold Bay airport,
including possible commercial use for transporting seafood to the Cold
Bay airport. Increased traffic and transit by large and noisy vehicles
would exacerbate impacts on birds and mammals using these vital
habitats, thereby increasing stress and negative effects. Increased
traffic also means increased dust, erosion and sedimentation, and
pollution.

Many scientific studies have implicated roads as having negative effects
on terrestrial and aquatic ecosystems (e.g., Trombulak and Frissell
1999, US Forest Service 2001). According to the US Forest Service
(2001):

> Undesirable consequences \[of roads\] include adverse effects on
> hydrology and geomorphic features (such as debris slides and
> sedimentation), habitat fragmentation, predation, road kill, invasion
> by exotic species, dispersal of pathogens, degraded water quality and
> chemical contamination, degraded aquatic habitat, use conflicts,
> destructive human actions (for example, trash dumping, illegal
> hunting, fires), lost solitude, depressed local economies, loss of
> soil productivity, and decline in biodiversity.

Because roads have potential for introducing varied impacts to both
terrestrial and aquatic ecosystems, roadless areas provide a significant
foundation for developing comprehensive regional conservation strategies
(Strittholt and Dellasala 2001). []{.mark}

[]{.mark}

Although Section 4(c)(2)(A) of S. 1680 requires a cable barrier on each
side of the road to prevent off-road motorized access, studies have
shown that the mere presence of a road affects the behavior of
wilderness-associated species, particularly brown bears and wolves.

Roads generally result in harmful impacts to large carnivores (Noss et
al. 1996, Trombulak and Frissell 1999). The construction of roads in
what had been roadless brown bear habitat has been demonstrated by many
investigators to have significant adverse impacts on bear populations by
increasing human access, which results in displacement of bears or the
direct mortality of bears through legal hunting,
defense-of-life-or-property (DLP) kills, illegal killing, and road kills
(McLellan and Shackleton 1989, McLellan 1990, Mattson 1990, Schoen et.
al. 1994, Mace et al. 1996). Titus and Beier (1991) demonstrated the
strong relationship of road construction to increased bear mortality on
northeastern Chichagof Island. Suring and Del Frate (2002) demonstrated
an increasing probability of brown bears killed in DLP with increasing
road density on the Kenai Peninsula.

[]{.mark}

At Izembek, this situation is compounded by the fact that the isthmus is
narrow, making it difficult for wildlife to avoid the road. Over time,
use of the road would exacerbate the initial, adverse impacts of the
road. Further, as we have seen elsewhere in Alaska, today's restrictions
may be subsequently lifted. I well remember when the Dalton Highway,
which runs north from the Fairbanks area to the Prudhoe Bay oilfields,
was closed to public access. Today, you can drive a Winnebago to the
Arctic Ocean. In 2006, the Alaska State Legislature considered lifting
the ban on off-road vehicles ("ORV") traffic off the Dalton Highway, and
a picture of sport hunters with their pick-up truck stuck up to its axle
in wet tundra was widely publicized. Problems with off-road access and
increased hunting pressure, both legal and illegal, would be exacerbated
by the Izembek refuge's lack of resources and staff, especially for law
enforcement.

The EIS also noted that the all-road alternative has the greatest
potential of any alternative to adversely affect subsistence harvest due
to its potential to create competition between residents of Cold Bay and
King Cove. This impact on subsistence use due to enhanced access would
be negative and potentially significant, and the local caribou herd, in
particular, cannot withstand additional pressure.

Concern about impacts on subsistence harvests extends beyond the Izembek
area to the Yukon-Kuskokwim (Y-K) Delta, where many Alaska Native
residents are dependent on Brant as a key subsistence resource. It is
for this reason that the Association of Village Council Presidents
(AVCP), the recognized tribal organization and non-profit Alaska Native
Regional Corporation for 56 member Native villages in western Alaska,
has consistently opposed the King Cove Road. In 1998, the AVCP passed a
resolution opposing the road, and this opposition was reaffirmed in 2007
and again in 2008. It may be relevant to note that many residents of the
Y-K Delta live in communities with fewer and less reliable
transportation and medical-care options than are found in King Cove.

**[Congress Previously Addressed This Issue]{.smallcaps}**

Congress determined that a road through the Izembek Wilderness is not in
the public's best interest when, in 1997, it passed the King Cove Health
and Safety Act. With this legislation, Congress addressed King Cove
residents' health and safety concerns by providing \$37.5 million from
the American taxpayer to upgrade King Cove's medical facilities, improve
the airstrip in King Cove, and provide for a transportation link between
King Cove and the Cold Bay Airport, including a single lane, unpaved
road from King Cove to a marine facility.

Congress reiterated its intention not to permit a road through Izembek's
designated Wilderness in the King Cove Health and Safety Act, Section
353(d):

> In no instance may any part of such road, dock, marine facilities or
> equipment enter or pass over any land within
> congressionally-designated wilderness in the Izembek Wildlife
> refuge...

In addition, Congress required that all actions undertaken pursuant to
this section must be in accordance with all other applicable laws.

After passage of the King Cove Health and Safety Act, and prior to the
Corps of Engineers issuance of a Record of Decision for the EIS,
Congress adopted an appropriations bill with a rider that directed
construction of a 17.6-mile road from the King Cove air strip to a
hovercraft terminal. Construction for this road began in March 2004.
More than \$35 million dollars have been spent for this road, which
remains unfinished. Construction costs continued to escalate as crews
confronted numerous obstacles, including unstable volcanic soils in the
area. Avoiding the unstable soils has meant rerouting the road onto the
shores of Cold Bay, where winter ice scouring and spray will increase
maintenance costs and safety problems. All of that effort and additional
cost remain puzzling to observers since it would require moving the
existing hovercraft terminus in Lenard Harbor, which is only seven miles
from King Cove, to a point 10 miles farther away and require longer
transits across steep, windy mountainous terrain where winter travel
conditions would be made even more treacherous.

Although any marine vessel is costly to maintain and operate, and won't
be safe to operate under all conditions, the same may be said of a road,
especially in the harsh environment surrounding Cold Bay. In fact, in
the community of Cold Bay, it is not unusual for roads---including the
main road to the airport---to be closed because of an inability to keep
the road plowed during snow/wind storms. Audubon has yet to see a
current, rigorous analysis of the construction and
operation-and-maintenance costs of the road. Nor have we seen an
analysis of what can be expected in terms of road closures due to
weather or what can be expected in the way of the inevitable accidents,
injuries, and fatalities that will occur on the road. These issues
should be considered fully prior to any further action on transportation
alternatives.

**[Lands Offered for Exchange]{.smallcaps}**

Audubon appreciates that the State of Alaska and King Cove Corporation
are proposing to exchange lands that have value as wilderness and
wildlife habitat. Especially in the case of the Corporation, which has
been a good steward of its lands, I know this was a very difficult
decision.

The exchange lands proposed in S. 1680, however, would not provide
habitat comparable to or compensate for the loss or degradation of the
Izembek-Kinzarof lagoons complex. Fundamentally, this is not an issue
that can resolved on the basis of acreage: no amount of exchange lands
can compensate for the unacceptable and irreversible impacts of a road
on globally significant and unique wildlife habitats, which are the very
heart of Izembek refuge.

[State Townships.]{.underline} The two townships offered by the State
(approximately 43,000 acres) do not include comparable wetlands habitat.
The southernmost State township is primarily uplands, and is adjacent to
some bear denning habitat, but has virtually no value for waterfowl. The
more northern township has some wetlands and some caribou and brown bear
habitat, but, except for Tundra Swans, is of low or very low value for
the waterfowl species of concern in the lagoons complex. Although the
State townships have wilderness qualities, as a practical matter, there
is little or no development threat and little in the way of compensatory
value. Neither of the State townships is located in the Izembek or
Kinzarof lagoon watersheds.

[King Cove Corporation lands.]{.underline} Corporation-owned lands
offered along the eastern shore of Cold Bay (relinquished ANILCA
selections, approximately 5,430 acres) are primarily uplands with low
value for caribou or key waterfowl species.

Lands offered in the Mortensen's Lagoon parcel, approximately 10,800
acres, include upland and freshwater wetland habitats of medium to high
value for caribou, brown bears, salmon, Tundra Swans, Emperor Geese, and
several other waterfowl species, not including Brant and Steller's
Eiders. Although Mortensen's Lagoon has some tidelands, it does not have
the major eelgrass beds present in Izembek and Kinzarof lagoons, and it
is these eelgrass beds that drive the productivity of the Izembek
ecosystem. The Mortensen's Lagoon tract is bisected by a road, which
would remain in use.

The "bookend" parcels at the mouth of Kinzarof Lagoon, about 2,500
acres, contain high-value habitats for waterfowl, northern sea otters
and harbor seals, but have no foreseeable development threat. Further,
these parcels are located within the "zone of influence" of road
construction, operation and maintenance and, therefore, may sustain
diminished usage and reduction in value over time.

[State Refuges.]{.underline} The exchange proposal includes an offer to
make Kinzarof Lagoon a State game refuge refuge. Although Kinzarof
Lagoon is very valuable from a conservation perspective, historically
Alaska has not made protection and management of State game refuges a
priority. For example, Izembek State Game Refuge was established in 1972
and there still is no management plan and little in the way of an
on-site State presence. In State ownership, the future of Kinzarof
Lagoon would remain in question and may sustain unavoidable negative
impacts from road construction, operation and maintenance, thereby
limiting its benefit to Izembek refuge.

**[Literature Cited]{.smallcaps}**

Mace, R., J. Waller, T. Manley, L. Lyon, and H. Zuuring. 1996.
Relationships among grizzly bears, roads and habitat in the Swan
Mountains, Montana. Journal of Applied Ecology 33:1395--1405.

Mattson, D. 1990. Human impacts on bear habitat use. International
Conference on Bear Research and Management 8:33--56.

McLellan, B. 1990. Relationships between human industrial activity and
grizzly bears. International Conference on Bear Research and Management
8:57--64.

\_\_\_\_\_ and D. Shackleton. 1989. Immediate reactions of grizzly bears
to human activities. Wildlife Society Bulletin 17:269-275.

Noss, R, H. Quigley, M. Hornocker, T. Merrill, and P. Paquet. 1996.
Conservation biology and carnivore conservation in the Rocky Mountains.
Conservation Biology 10:949--963.

Schoen, J., R. Flynn, L. Suring, K. Titus, and L. Beier. 1994.
Habitat-capability model for brown bear in Southeast Alaska.
International Conference on Bear Research and Management 9:327--337.

Strittholt, J. and D. Dellasala. 2001. Importance of roadless areas in
biodiveristy conservation in forested ecosystems: case study of the
Klamath-Siskiyou ecoregion of the United States. Conservation Biology
15(6)1742-1754.

Suring, L., and G. Del Frate. 2002. Spatial analysis of locations of
brown bears killed in defense of life or property on the Kenai
Peninsula, Alaska, USA. Ursus 13:237--245.

Titus, K., and L. Beier. 1991. Population and habitat ecology of brown
bears on Admiralty and Chichagof islands. Federal Aid in Wildlife
Restoration. Research Progress Report W-23-4. Alaska Department of Fish
and Game, Juneau, AK.

Trombulak, S., and C. Frissell. 1999. Review of ecological effects of
roads on terrestrial and aquatic communities. Conservation Biology
14:18--30.

U.S. Army Corps of Engineers. 2003. King Cove Access Project. Final and
draft environmental impact statements. Alaska District.

U.S. Fish and Wildlife Service. 1997. King Cove road briefing report.
Izembek National Wildlife Refuge.

U.S. Forest Service. 2001. Forest roads: a synthesis of scientific
information. General Technical Report PNW-GTR-509. Pacific Northwest
Research Station.

[^1]: Not incidentally, proposed Wilderness at what was then the Izembek
    National Wildlife Range was endorsed by Alaska Governor Keith Miller
    as early as 1970.